[{"data":1,"prerenderedAt":268},["ShallowReactive",2],{"blog:\u002Fblog\u002Fcbam-actual-vs-default-values":3},{"id":4,"title":5,"body":6,"date":252,"description":253,"extension":254,"hero":255,"heroAlt":256,"keywords":257,"meta":258,"navigation":259,"path":260,"readingMinutes":261,"seo":262,"stem":263,"tags":264,"__hash__":267},"blog\u002Fblog\u002Fcbam-actual-vs-default-values.md","Actual values or default values — and what the choice really costs",{"type":7,"value":8,"toc":242},"minimark",[9,22,29,34,41,52,55,75,79,82,97,123,134,140,144,147,170,173,177,184,187,191,197,203,213,219,223,234,237],[10,11,12,13,17,18,21],"p",{},"There are two ways to put an emissions number on an imported good. You can use the EU ",[14,15,16],"strong",{},"default value","\nfor that good and origin — a figure you look up in a table — or you can use your supplier's ",[14,19,20],{},"actual","\nmeasured emissions. Since the Omnibus amendment (Regulation (EU) 2025\u002F2083) the choice is genuinely\nfree: Art. 7(2) lets the declarant elect either, with no condition attached.",[10,23,24,25,28],{},"The instinct is that actual values are the better deal. They are more precise, and a clean supplier's\nreal emissions are usually ",[14,26,27],{},"below"," the conservative default — so the actual path looks like a lower\nbill. For most importers that instinct is wrong, and it is wrong before any emissions are compared,\nbecause of what the actual path drags in behind it.",[30,31,33],"h2",{"id":32},"what-the-actual-path-actually-requires","What the actual path actually requires",[10,35,36,37,40],{},"Choosing actual values is not \"write a smaller number in the same box.\" Art. 7(2)(a) pulls Art. 8 in\nwith it, and Art. 8 requires the emissions to be ",[14,38,39],{},"verified by an accredited verifier."," A default\nvalue needs no verifier at all — that is the entire point of a default.",[10,42,43,44,47,48,51],{},"Accredited verification is not a form. It is an audited assessment of a ",[14,45,46],{},"production installation's","\nemissions, against the CBAM methodology, by a body accredited for it. Industry pricing for a single\ninstallation runs in the region of ",[14,49,50],{},"EUR 12,000 to 25,000",", and it recurs — a verification covers a\nperiod, not forever.",[10,53,54],{},"Two more things travel with the actual path, and both are load-bearing:",[56,57,58,65],"ul",{},[59,60,61,64],"li",{},[14,62,63],{},"The data has to exist and be shared with you."," You cannot verify your supplier's installation\nyourself; the operator has it verified, publishes it to the third-country installations register,\nand passes the figure to you in a CBAM communication. A supplier who has not done this cannot give\nyou an actual value, however clean their plant.",[59,66,67,70,71,74],{},[14,68,69],{},"There is no accredited verifier to use yet."," The accreditation of CBAM verifiers does not open\nuntil around ",[14,72,73],{},"1 September 2026."," For imports before that, the actual path is not merely expensive —\nit is unavailable, and the default path is the only lawful basis.",[30,76,78],{"id":77},"the-break-even-and-why-it-usually-isnt-close","The break-even, and why it usually isn't close",[10,80,81],{},"Here is the arithmetic that settles it for most importers, and it does not depend on knowing your\nsupplier's real number.",[10,83,84,85,88,89,92,93,96],{},"The ",[14,86,87],{},"most"," an actual value can ever save you is your ",[14,90,91],{},"entire default obligation."," The figure can\nonly go down, and the floor is zero certificates. So the verifier can only pay for itself when your\nannual default levy — on the goods from that one installation — is already larger than the verifier's\nfee. Below roughly ",[14,94,95],{},"EUR 12,000 of annual levy",", verification is a guaranteed loss, no matter how low\nthe real emissions turn out to be.",[10,98,99,100,105,106,109,110,113,114,118,119,122],{},"Put that against a concrete figure. In ",[101,102,104],"a",{"href":103},"\u002Fblog\u002Fcbam-two-numbers-most-calculations-get-wrong","an earlier worked example","\nthe default obligation on steel came to about ",[14,107,108],{},"EUR 114 per tonne of goods"," (CN 7208 51 20, origin\nArgentina, 2026). At that rate the break-even sits near ",[14,111,112],{},"105 tonnes a year, from a single\ninstallation"," — and that is the point at which the actual path ",[115,116,117],"em",{},"could"," start to pay only if the real\nvalue were near zero. To save anything ",[14,120,121],{},"net",", you need materially more.",[10,124,125,126,129,130,133],{},"Now the small-importer case the threshold rules out entirely. Take ",[14,127,128],{},"60 tonnes of the same steel."," The\nwhole default obligation is around ",[14,131,132],{},"EUR 6,800."," Even if verification drove the number to zero — the\nbest case that can exist — the saving is EUR 6,800 against a verifier that starts at EUR 12,000. The\narithmetic forecloses it. A 60-tonne importer cannot save 12,000 euros out of an obligation of 6,800,\nand no amount of supplier cleanliness changes that.",[10,135,136,137],{},"This is the uncomfortable part for anyone selling \"we'll get you your accurate, lower number\": for a\nlarge share of importers the accurate number is real, lower, and ",[14,138,139],{},"not worth having.",[30,141,143],{"id":142},"when-actual-values-do-pay","When actual values do pay",[10,145,146],{},"They are not a trap — they are a volume play. The actual path earns its verifier fee when:",[56,148,149,156,163],{},[59,150,151,152,155],{},"your annual tonnage from ",[14,153,154],{},"one"," installation is high enough that the default levy comfortably clears\nthe fee (steel in the hundreds of tonnes, more for lower-value goods);",[59,157,158,159,162],{},"the supplier's verified emissions are ",[14,160,161],{},"materially"," below the default, not marginally;",[59,164,165,166,169],{},"and the verification cost is ",[14,167,168],{},"shared"," across every shipment from that installation for the period —\nwhich is why it favours importers with a stable, concentrated supply chain over ones who buy a\ncontainer here and there from whoever is cheapest.",[10,171,172],{},"If you import a lot, from few installations, from producers who have already verified for the EU market,\nactual values can be the right call. That is a specific shape of importer, and it is worth knowing\nwhether you are one before you pay for verification.",[30,174,176],{"id":175},"the-part-you-cannot-do-halfway","The part you cannot do halfway",[10,178,179,180,183],{},"One more reason the choice is bigger than a single field: ",[14,181,182],{},"you cannot keep the default's free\nallocation while swapping in an actual emissions number."," The free-allocation basis follows the\nemissions basis. On the default path you deduct a Column B (cradle-to-good) benchmark; the actual path\nis calculated on a different footing (Implementing Regulation (EU) 2025\u002F2620, Art. 2 and 3). Taking a\nlow actual value and still subtracting the default-path benchmark mixes two yardsticks in one\nsubtraction and produces a figure with no legal basis — and it is the kind of figure that looks fine\nuntil someone reconciles it.",[10,185,186],{},"So \"actual values\" is not a discount you toggle on. It is a different calculation, a different evidence\nrequirement, and a recurring cost — chosen as a whole or not at all.",[30,188,190],{"id":189},"what-to-check-this-week","What to check this week",[10,192,193,196],{},[14,194,195],{},"1. Total your annual tonnage per installation, not per shipment."," The break-even lives at the\ninstallation level. Fragmented buying from many small suppliers almost never reaches it.",[10,198,199,202],{},[14,200,201],{},"2. Ask whether your supplier already has verified emissions for the EU."," If they do, and you buy in\nvolume, the actual path may pay — get the CBAM communication and the verifier's report. If they don't,\nyour only near-term basis is the default value, and that is fine.",[10,204,205,212],{},[14,206,207,208,211],{},"3. Compare the ",[115,209,210],{},"whole default levy"," to the verifier fee before anything else."," If the entire\nobligation from that installation is smaller than about EUR 12,000, stop — the actual path cannot win,\nand the time is better spent making the default calculation correct.",[10,214,215,218],{},[14,216,217],{},"4. Remember the timing."," For imports before verifier accreditation opens (~September 2026), default\nvalues are not a fallback — they are the only lawful basis.",[30,220,222],{"id":221},"the-short-version","The short version",[10,224,225,226,229,230,233],{},"Actual values are more accurate, often lower, and for a large share of importers ",[14,227,228],{},"not worth the\nverifier they require."," The decision is not \"which number is smaller\" — it is \"does the smaller number\nsave more than EUR 12,000-plus a year, from this installation, net.\" For anyone importing modest\nvolumes, the default value is not a compromise. It is the correct and cheaper answer, and the effort\nbelongs in getting ",[115,231,232],{},"that"," calculation right.",[235,236],"hr",{},[10,238,239],{},[115,240,241],{},"This article explains the rules as we read them; it is not legal advice. The free choice of basis is\nin Regulation (EU) 2023\u002F956 Art. 7(2) as amended by Regulation (EU) 2025\u002F2083; the verification\nrequirement in Art. 8; the free-allocation basis in Implementing Regulation (EU) 2025\u002F2620. Verifier\npricing is indicative market research, not a quote. Verify your own position with your customs agent or\nthe competent authority in your member state — in Germany, the DEHSt.",{"title":243,"searchDepth":244,"depth":244,"links":245},"",2,[246,247,248,249,250,251],{"id":32,"depth":244,"text":33},{"id":77,"depth":244,"text":78},{"id":142,"depth":244,"text":143},{"id":175,"depth":244,"text":176},{"id":189,"depth":244,"text":190},{"id":221,"depth":244,"text":222},"2026-08-27","Since the Omnibus you may declare your supplier's actual emissions instead of the EU defaults. It sounds like the cheaper, more accurate path. For most importers the arithmetic forecloses it before it begins — the verifier costs more than the whole obligation could ever save.","md","https:\u002F\u002Fy7cuzzvjaoml1mzf.public.blob.vercel-storage.com\u002Fblog-5.webp","An old brass balance scale on a dark steel workbench: one pan holds a thick wax-sealed verification report, the other a single thin printed table card, the sealed report weighing the heavier","CBAM actual values, CBAM default values, CBAM Art 7(2), CBAM accredited verifier, CBAM Art 8, CBAM verification cost, CBAM Ist-Werte Standardwerte, CBAM Prüfer, embedded emissions verification",{},true,"\u002Fblog\u002Fcbam-actual-vs-default-values",7,{"title":5,"description":253},"blog\u002Fcbam-actual-vs-default-values",[265,266],"calculation","compliance","CM-nZY6Qce1tMVd1UnebaOw1PMhYkT4ZPVeotYhuElo",1790002811473]