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  • calculation
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Actual values or default values — and what the choice really costs

7 min read

There are two ways to put an emissions number on an imported good. You can use the EU default value for that good and origin — a figure you look up in a table — or you can use your supplier's actual measured emissions. Since the Omnibus amendment (Regulation (EU) 2025/2083) the choice is genuinely free: Art. 7(2) lets the declarant elect either, with no condition attached.

The instinct is that actual values are the better deal. They are more precise, and a clean supplier's real emissions are usually below the conservative default — so the actual path looks like a lower bill. For most importers that instinct is wrong, and it is wrong before any emissions are compared, because of what the actual path drags in behind it.

What the actual path actually requires

Choosing actual values is not "write a smaller number in the same box." Art. 7(2)(a) pulls Art. 8 in with it, and Art. 8 requires the emissions to be verified by an accredited verifier. A default value needs no verifier at all — that is the entire point of a default.

Accredited verification is not a form. It is an audited assessment of a production installation's emissions, against the CBAM methodology, by a body accredited for it. Industry pricing for a single installation runs in the region of EUR 12,000 to 25,000, and it recurs — a verification covers a period, not forever.

Two more things travel with the actual path, and both are load-bearing:

  • The data has to exist and be shared with you. You cannot verify your supplier's installation yourself; the operator has it verified, publishes it to the third-country installations register, and passes the figure to you in a CBAM communication. A supplier who has not done this cannot give you an actual value, however clean their plant.
  • There is no accredited verifier to use yet. The accreditation of CBAM verifiers does not open until around 1 September 2026. For imports before that, the actual path is not merely expensive — it is unavailable, and the default path is the only lawful basis.

The break-even, and why it usually isn't close

Here is the arithmetic that settles it for most importers, and it does not depend on knowing your supplier's real number.

The most an actual value can ever save you is your entire default obligation. The figure can only go down, and the floor is zero certificates. So the verifier can only pay for itself when your annual default levy — on the goods from that one installation — is already larger than the verifier's fee. Below roughly EUR 12,000 of annual levy, verification is a guaranteed loss, no matter how low the real emissions turn out to be.

Put that against a concrete figure. In an earlier worked example the default obligation on steel came to about EUR 114 per tonne of goods (CN 7208 51 20, origin Argentina, 2026). At that rate the break-even sits near 105 tonnes a year, from a single installation — and that is the point at which the actual path could start to pay only if the real value were near zero. To save anything net, you need materially more.

Now the small-importer case the threshold rules out entirely. Take 60 tonnes of the same steel. The whole default obligation is around EUR 6,800. Even if verification drove the number to zero — the best case that can exist — the saving is EUR 6,800 against a verifier that starts at EUR 12,000. The arithmetic forecloses it. A 60-tonne importer cannot save 12,000 euros out of an obligation of 6,800, and no amount of supplier cleanliness changes that.

This is the uncomfortable part for anyone selling "we'll get you your accurate, lower number": for a large share of importers the accurate number is real, lower, and not worth having.

When actual values do pay

They are not a trap — they are a volume play. The actual path earns its verifier fee when:

  • your annual tonnage from one installation is high enough that the default levy comfortably clears the fee (steel in the hundreds of tonnes, more for lower-value goods);
  • the supplier's verified emissions are materially below the default, not marginally;
  • and the verification cost is shared across every shipment from that installation for the period — which is why it favours importers with a stable, concentrated supply chain over ones who buy a container here and there from whoever is cheapest.

If you import a lot, from few installations, from producers who have already verified for the EU market, actual values can be the right call. That is a specific shape of importer, and it is worth knowing whether you are one before you pay for verification.

The part you cannot do halfway

One more reason the choice is bigger than a single field: you cannot keep the default's free allocation while swapping in an actual emissions number. The free-allocation basis follows the emissions basis. On the default path you deduct a Column B (cradle-to-good) benchmark; the actual path is calculated on a different footing (Implementing Regulation (EU) 2025/2620, Art. 2 and 3). Taking a low actual value and still subtracting the default-path benchmark mixes two yardsticks in one subtraction and produces a figure with no legal basis — and it is the kind of figure that looks fine until someone reconciles it.

So "actual values" is not a discount you toggle on. It is a different calculation, a different evidence requirement, and a recurring cost — chosen as a whole or not at all.

What to check this week

1. Total your annual tonnage per installation, not per shipment. The break-even lives at the installation level. Fragmented buying from many small suppliers almost never reaches it.

2. Ask whether your supplier already has verified emissions for the EU. If they do, and you buy in volume, the actual path may pay — get the CBAM communication and the verifier's report. If they don't, your only near-term basis is the default value, and that is fine.

3. Compare the whole default levy to the verifier fee before anything else. If the entire obligation from that installation is smaller than about EUR 12,000, stop — the actual path cannot win, and the time is better spent making the default calculation correct.

4. Remember the timing. For imports before verifier accreditation opens (~September 2026), default values are not a fallback — they are the only lawful basis.

The short version

Actual values are more accurate, often lower, and for a large share of importers not worth the verifier they require. The decision is not "which number is smaller" — it is "does the smaller number save more than EUR 12,000-plus a year, from this installation, net." For anyone importing modest volumes, the default value is not a compromise. It is the correct and cheaper answer, and the effort belongs in getting that calculation right.

This article explains the rules as we read them; it is not legal advice. The free choice of basis is in Regulation (EU) 2023/956 Art. 7(2) as amended by Regulation (EU) 2025/2083; the verification requirement in Art. 8; the free-allocation basis in Implementing Regulation (EU) 2025/2620. Verifier pricing is indicative market research, not a quote. Verify your own position with your customs agent or the competent authority in your member state — in Germany, the DEHSt.