European importers of steel, aluminium, cement and other carbon-intensive materials must review their emissions calculations following changes to the EU Carbon Border Adjustment Mechanism (CBAM) default-value framework. The corrections affect production classifications, product codes, measurement units and the assumptions used to calculate embedded emissions and related carbon liabilities.
Commission Implementing Regulation (EU) 2026/1740, published on 31 July 2026, amended the default-value tables established under Regulation (EU) 2025/2621. The corrections apply from 1 January 2026, bringing transactions completed since the start of the definitive CBAM period within their scope.
The amendments address missing or incorrect indicators for production routes, clarify measurement units and refine product classifications. These changes are relevant to importers that depend on default emissions values when calculating their obligations under the EU carbon border regime.
Production routes and product classifications affect calculations
The corrected framework distinguishes between production methods with different emissions profiles and implications for CBAM calculations. Conventional blast-furnace steelmaking, for example, has a different emissions profile from steel produced using direct reduced iron or recycled scrap in electric arc furnaces.
Aluminium classifications also need to reflect the distinction between primary and secondary production, which involve different processes and emissions characteristics. For cement-related products, the regulation clarifies classifications covering white and grey clinker and hydraulic cement, helping distinguish materials subject to different emissions reference values.
These distinctions have implications beyond the accuracy of emissions reporting. Production-route classifications can affect the calculation of free-allocation adjustments, making the correct identification of the manufacturing process important to determining an importer’s carbon liability.
Default-value mark-ups increase through 2028
Where verified actual emissions data are unavailable, importers must use the applicable default values and prescribed mark-ups. The schedule provides for progressively higher adjustments for several CBAM-covered product categories.
For steel, aluminium, cement and hydrogen, the mark-up increases from 10% in 2026 to 20% in 2027 and 30% from 2028. For fertilisers, the applicable default-value mark-up remains 1%.
These percentages adjust emissions default values; they are not direct increases in product prices or universal CBAM surcharges. Their financial implications depend on the applicable emissions assumptions and the other elements used to calculate the importer’s obligations.
Outdated emissions data create financial and contractual risks
Importers using superseded datasets could miscalculate their expected carbon liabilities, affecting supplier comparisons, purchasing contracts and financial forecasts. The risk is particularly relevant to companies sourcing multiple product categories from different countries, where classifications and emissions assumptions can vary across products and production routes.
To maintain consistency, customs classifications, production-route information and emissions assumptions need to align across supplier declarations, internal databases and annual CBAM reporting. Incorrect or inconsistent records can undermine the reliability of calculations based on the corrected framework.
For industrial traders, the amendments reinforce the need for centralised emissions data management and systematic checks against the latest legally binding default-value tables. Importers must ensure that the information used in procurement and financial planning reflects the applicable regulatory requirements.
CBAM compliance becomes an ongoing data-management task
The corrections also have implications for banks financing large inventory positions or manufacturers dependent on imported carbon-intensive materials. Assessments of financing exposure may need to account for whether expected CBAM liabilities have been calculated using current regulatory tables and appropriate product classifications.
As the definitive regime progresses, companies must maintain processes for monitoring regulatory changes and updating emissions calculations. The corrections to the default-value framework demonstrate that CBAM compliance requires continuing coordination between customs classification, production data, emissions verification and financial reporting rather than a single reporting exercise.
