Where do I get CBAM default values for a system?
From Annex I of Commission Implementing Regulation (EU) 2026/1740, which corrected the values first issued in 2025/2621: 1,533 country × CN-code base values across five sectors. Since the correction the published figures exclude the mark-up.
The CBAM definitive period began on 1 January 2026, so the numbers you are using now are the ones you will declare. Default values are what you fall back on when a supplier will not give you verified emissions data — and the Commission publishes them as annexes to a regulation, not as anything a developer can use. This page explains what is actually in that dataset, the mark-up change that caught people out in July, and the one annex nobody can legally hand you.
Where you are in the timeline
CBAM ran a transitional period from 1 October 2023 to 31 December 2025, during which importers reported embedded emissions and owed nothing. That is over. Since 1 January 2026 the definitive period applies: importers must surrender CBAM certificates against the embedded emissions of the goods they bring in.
The reporting rhythm changed with it. Transitional reporting was quarterly, due within a month of each quarter end. Definitive reporting is a single annual CBAM declaration, due 31 May for the preceding calendar year — so the imports you are recording now are declared in May 2027, and the numbers you attach to them are the ones you will have to defend.
Two consequences follow, and they pull in opposite directions. The exposure ramps: CBAM mirrors the EU ETS free-allocation phase-down for covered sectors, with 97.5% of free allowances remaining in 2026, 95% in 2027, 90% in 2028, and steeply down thereafter — 51.5% by 2030 and 14% by 2033. But the data is easiest to fix early, while you are still setting up supplier requests rather than reconstructing a year of them.
When you may use a default at all
This is the part most explanations skip, and it decides whether the rest of the page is even relevant to you.
Default values are a fallback, not a choice. Under Article 7 of Regulation (EU) 2023/956, they apply where the importer cannot determine actual embedded emissions using verified primary data from the operator of the installation that produced the goods. If your supplier gives you verified installation-level data, you use that. Defaults exist for the case where they will not, or cannot.
The practical reading: defaults are the price of not having the supplier relationship sorted out. They are deliberately conservative, and using them is a commercial decision as much as a compliance one — which is why the mark-up in the next section matters.
What Annex I actually contains
Annex I is the per-country, per-product matrix — direct emissions, indirect emissions and total, for each combination of country and CN code. In the current edition it covers 1,533 country × CN-code combinations, built from 260 distinct CN codes across six country groups.
| Sector | Country × CN-code rows | Share |
|---|---|---|
| Iron and steel | 1,190 | 78% |
| Fertilisers | 161 | 11% |
| Aluminium | 144 | 9% |
| Cement | 32 | 2% |
| Hydrogen | 6 | <1% |
The country groups are China, India, South Korea, Russia and Türkiye, plus a residual “Other Countries and Territories” group carrying 260 rows. If you import from anywhere not named, the residual group is your row — and because it has to cover everything from a modern EU-adjacent mill to a plant with no data at all, it is the least flattering set of numbers in the annex.
Note the skew. Iron and steel is 78% of the matrix, which reflects how many distinct CN codes that sector spans rather than how much trade sits behind each one. A cement importer has 32 rows to search; a steel importer has 1,190, and picking the wrong CN code is the commonest way to attach a wrong number to a real declaration.
The mark-up trap
Reg (EU) 2025/2621 printed Annex I values with the sector mark-up already applied, in per-year columns. Reg (EU) 2026/1740 no longer prints those marked-up figures. The values it publishes are base defaults, and the mark-up is applied downstream by the declarant or the CBAM Registry. If you copied numbers from the original regulation and have not re-read the correction, you may be carrying figures that are marked up twice, or comparing a marked-up 2025 number against a base 2026 one and concluding the default moved when it did not.
The mark-ups themselves are sectoral and escalate: for cement the original schedule ran 10% in 2026, 20% in 2027 and 30% in 2028, while fertilisers carried 1% a year. That escalation is deliberate — it makes defaults progressively worse than real data, so that chasing your supplier for verified figures becomes the cheaper option over time.
The practical instruction is simple: work from Reg (EU) 2026/1740, treat its values as base defaults, and be explicit in your own records about whether a stored number is base or marked up. A column named value with no note of which it is will cost somebody a day in 2027.
The annex nobody can hand you
Annex I gives you direct emissions. For indirect emissions — the electricity consumed making the goods — the regulation points to Annex II, a per-country table used when an importer cannot determine actual indirect emissions from verified primary data.
Annex II is where this dataset stops being redistributable, and the Commission says so itself. Its own disclaimer records that the per-country indirect factors are sourced from the International Energy Agency dataset under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 licence, and that using them for commercial purposes requires a separate licence from the IEA.
A legal instrument that importers are obliged to comply with contains a table that a commercial product may not reproduce. That is not a gap in anyone’s coverage — it is the licence of the data underneath the law. We hold the Annex II framework rows and deliberately withhold the values from our factor pages, our downloads and our API, and any vendor telling you otherwise has either bought an IEA licence or has not read the disclaimer.
What to do instead: read Annex II directly from the Official Journal for your country and apply it yourself, or obtain actual indirect emissions from your supplier, which the regulation prefers anyway. If you are building a commercial tool and want those values inside it, the route is a licence from the IEA — not a dataset vendor.
This is the clearest live example of a pattern we documented across the wider landscape: licences attach per source, not per publisher, and an aggregator’s badge does not launder the terms underneath. The database landscape guide sets out how often this happens and how to check for it.
Annex IV, the catch-all
There is a third layer worth knowing about. Annex IV carries the highest default emission factors per CBAM-covered sector — cement clinker, Portland and aluminous cement; nitric acid, anhydrous ammonia and urea; pig iron, direct reduced iron, crude steel ingot and hot-rolled products, and so on.
These are the values that apply when even the country-and-CN-code route fails you. They are punitive by design, and their existence is the strongest argument in the regulation for getting real data: the further you fall down the hierarchy from verified primary data, to country default, to sector catch-all, the worse the number gets, and every step is one you chose by not having the information.
Getting the values
The Commission publishes these as annexes to a regulation, which is authoritative and close to unusable for software. We keep the Annex I values in a searchable, machine-readable form with each row carrying the exact regulation, annex, country and CN code it came from:
- The full CBAM default-value dataset — every Annex I row, searchable by CN code, with per-row provenance and a download. Annex II values are excluded, for the reason above.
- The EU CBAM calculator — if you want a liability figure rather than the underlying factors.
- The API — the corpus is browsable with no key, so you can check a CN code before deciding whether any of this is worth an integration:
curl "https://api.greencalculus.com/v1/factors?key_prefix=cbam.country.chn&limit=3"One commitment, because this dataset moves by legal instrument rather than on a schedule: the Commission may revise these values under Article 7(7) of Regulation (EU) 2023/956, and it has already done so once, in July 2026. When it revises them again we will re-ingest, note what moved, and date the change — and if you want telling rather than checking, the factor page carries a change-alert route.
Frequently asked questions
Commission Implementing Regulation (EU) 2026/1740 of 20 July 2026, which corrected Reg (EU) 2025/2621. The older regulation is still the one most search results and consultancy notes point at, and its Annex I figures were presented differently — with the sector mark-up already applied. Working from the superseded edition is the single commonest error we see in this dataset.
Because the Annex II per-country indirect factors are IEA data under a CC BY-NC-SA licence, and the Commission’s own disclaimer states that commercial use requires a separate IEA licence. You can read them in the Official Journal and apply them yourself; a commercial product cannot redistribute them to you without licensing them from the IEA. It is an unusual situation — a compliance obligation whose supporting table is not freely reusable — and it is the Commission’s to resolve, not a vendor’s.
No. They are a fallback for where actual embedded emissions cannot be determined from verified primary data supplied by the producing installation. If you have verified supplier data, that is what you use. Defaults are deliberately conservative and carry escalating mark-ups precisely so that they are worse than doing the work, and that gap widens each year.
The residual “Other Countries and Territories” group, which carries 260 rows — one for each CN code. Because it has to cover every origin not named individually, it is calibrated conservatively, so importers from unlisted countries generally have more to gain from obtaining verified supplier data than importers from the five named ones.
By legal instrument, not on a schedule. The Commission may revise them under Article 7(7) of Reg (EU) 2023/956, and did so in July 2026 — a correction that also changed how the figures are presented. There is no announced cadence, which means a stored copy is only as current as the last time somebody checked the Official Journal.
No. It describes what the regulation and its annexes contain, with the citations to check each statement against, so that you and your advisers are arguing about the right document. Your own obligations depend on what you import, from where, and in what volume — and on the CBAM Registry’s treatment of your declaration, which is outside anything a dataset can tell you.
Annex I of Commission Implementing Regulation (EU) 2026/1740 holds the 1,533 country × CN-code base values; the Commission publishes them as a regulation annex, not a data file, so they must be extracted and marked up. The Annex II indirect factors are IEA data under a non-commercial licence and cannot be redistributed by anyone.