[{"data":1,"prerenderedAt":247},["ShallowReactive",2],{"blog:\u002Fblog\u002Fcbam-cscf-100-percent-published":3},{"id":4,"title":5,"body":6,"date":232,"description":233,"extension":234,"hero":235,"heroAlt":235,"keywords":236,"meta":237,"navigation":238,"path":239,"readingMinutes":240,"seo":241,"stem":242,"tags":243,"__hash__":246},"blog\u002Fblog\u002Fcbam-cscf-100-percent-published.md","The CBAM factor nobody could look up is now 100 %",{"type":7,"value":8,"toc":223},"minimark",[9,18,25,28,33,36,47,62,69,73,76,85,96,103,107,114,117,123,138,142,145,148,155,158,169,173,180,183,187,215,218],[10,11,12,13,17],"p",{},"For most of this year, one of the inputs to the CBAM calculation could not be looked up anywhere. Not\nbecause it was hard to find — because it did not exist yet. The ",[14,15,16],"strong",{},"cross-sectoral correction factor",",\nthe CSCF, sits in the formula that decides how much of your embedded emissions is treated as free of\ncharge, and for the allocation period beginning 1 January 2026 it was simply unset.",[10,19,20,21,24],{},"It is set now. ",[14,22,23],{},"100 %, for every year from 2026 to 2030"," (Article 1 of Implementing Decision (EU)\n2026\u002F1862 of 23 July 2026, published in the Official Journal on 24 July 2026).",[10,26,27],{},"That is the short version, and for most declarants it is good news of the dullest kind: the number\npeople assumed turned out to be the number that was adopted. The part worth six minutes is what it\ndoes — and does not do — to figures that were already calculated.",[29,30,32],"h2",{"id":31},"where-the-factor-sits","Where the factor sits",[10,34,35],{},"Under the definitive regime, the free-allocation adjustment for a good is:",[37,38,43],"pre",{"className":39,"code":41,"language":42},[40],"language-text","SEFA = CBAM factor × CSCF × benchmark\n","text",[44,45,41],"code",{"__ignoreMap":46},"",[10,48,49,50,53,54,57,58,61],{},"Three terms, and only the middle one was missing. The ",[14,51,52],{},"CBAM factor"," is the share still allocated\nfree in a given year and steps down on a schedule written into the law — 97.5 % in 2026, 95 % in\n2027, 90 % in 2028, 77.5 % in 2029, 51.5 % in 2030 (Article 10a(1a) of Directive 2003\u002F87\u002FEC). The\n",[14,55,56],{},"benchmark"," is the goods-specific figure published in the annex to Implementing Regulation (EU)\n2025\u002F2620. The ",[14,59,60],{},"CSCF"," is a uniform factor that exists to keep\nthe total of all free allocation inside the emissions-trading cap: if the sum of what installations\nare entitled to exceeds the ceiling, everyone's allocation is scaled down by the same percentage\n(Article 10a(5) and (5a) of Directive 2003\u002F87\u002FEC).",[10,63,64,65,68],{},"That is the whole mechanism, and it explains why the factor is so easy to miss. ",[14,66,67],{},"It is not a CBAM\ninstrument."," It is adopted under Article 14(6) of Delegated Regulation (EU) 2019\u002F331, in the\nemissions-trading file, on the schedule of the free-allocation cycle — and it lands in the CBAM\nformula from the side. A declarant watching the CBAM acts for the numbers they need would not have\nseen it coming, and would not see it change.",[29,70,72],{"id":71},"what-was-decided-and-why","What was decided, and why",[10,74,75],{},"The decision is short. Article 1 sets the factor for the whole allocation period at once:",[77,78,79],"blockquote",{},[10,80,81],{},[82,83,84],"em",{},"\"For each year in the allocation period 2026 to 2030, the uniform cross-sectoral correction factor\nfor the adjustment of free allocations of emission allowances in accordance with Article 10a(5) and\n(5a) of Directive 2003\u002F87\u002FEC shall be 100 %.\"",[10,86,87,88,91,92,95],{},"The reasoning is in the recitals, and it is arithmetic rather than policy. Of the maximum amount\navailable for free allocation in 2021–2025, ",[14,89,90],{},"125,586,948 allowances went unused",", alongside the\nentire 3 % reserve for that period (recital 8). Against that headroom, the Commission puts the total\ndraw needed across 2021–2030 at ",[14,93,94],{},"289,226,630"," allowances from the reserve (recital 9). The\nentitlement fits inside the ceiling, so nothing has to be scaled down — the factor is 100 % and the\nterm is neutral.",[10,97,98,99,102],{},"Two things are worth noting beside it. The same factor was ",[14,100,101],{},"100 % for 2021–2025"," (Implementing\nDecision (EU) 2021\u002F927), so the adopted value continues an unbroken line rather than breaking one.\nAnd it is not to be confused with Decision (EU) 2026\u002F1312 of 15 June 2026, which approved the\nnational implementation measures — the installation lists — five weeks earlier and sets no factor at\nall. If you went looking in June and came back empty-handed, that is probably what you found.",[29,104,106],{"id":105},"what-100-means-in-the-arithmetic","What 100 % means in the arithmetic",[10,108,109,110,113],{},"It means the middle term drops out. ",[44,111,112],{},"SEFA = CBAM factor × benchmark",", and the figure you get is the\nfigure you would have got by assuming 1.0.",[10,115,116],{},"A worked line, using a cement consignment of the kind that shows up in every second CBAM file — grey\nclinker under CN 2523 10 00, benchmark 0.6660 tCO₂\u002Ft, imported in 2026:",[37,118,121],{"className":119,"code":120,"language":42},[40],"SEFA = 0.975 × 1.000 × 0.6660 = 0.64935 tCO₂\u002Ft\n",[44,122,120],{"__ignoreMap":46},[10,124,125,126,129,130,133,134,137],{},"Now the counterfactual, because it shows how much was riding on an unpublished number. Had the factor\ncome in at 90 %, the same line would read ",[44,127,128],{},"0.975 × 0.900 × 0.6660 = 0.584415"," — a free allocation\nlower by 0.064935 tCO₂ per tonne. On a 512-tonne consignment that is ",[14,131,132],{},"33 certificates",", about\n",[14,135,136],{},"€2,500"," at the Q2 2026 certificate price of €75.28. One consignment, one commodity, one\npercentage point set in a decision most CBAM declarants never read.",[29,139,141],{"id":140},"the-number-is-right-the-status-is-not","The number is right. The status is not.",[10,143,144],{},"Here is the part that catches tidy operations.",[10,146,147],{},"If you computed a 2026 obligation before 24 July 2026, you used an assumption. The decision does not\nretroactively turn that into a calculation — it produces the same digits, which is a different thing.\nEvery figure computed under the assumption is now confirmable, and until somebody confirms it, it is\na figure whose basis is a guess that happened to be correct.",[10,149,150,151,154],{},"That distinction has a practical edge, because the failure mode is invisible. A recomputed figure and\nan assumed figure are ",[14,152,153],{},"identical to the last decimal",". Nothing in the output flags which is which.\nIf your process marks provisional figures — and it should — then those marks are the only thing\nstanding between \"we checked\" and \"we were lucky\", and they do not clear themselves when the act is\npublished. Somebody has to recompute against the adopted value and re-date the result.",[10,156,157],{},"In our own system that is deliberate: an assessment carries the provisional flag it was stored with,\nthe declaration export stays locked while any figure on it is provisional, and publishing the\ndecision does not silently unlock anything. The figures do not change. Their standing does, and only\nonce they have been run again.",[10,159,160,161,164,165,168],{},"Anyone who assumed something ",[82,162,163],{},"other"," than 1.0 has the opposite problem and a bigger one. A factor\nwhose entire purpose is to scale allocations down invites a cautious guess below 100 %, and a\ncautious guess is the wrong kind here: it understates the free allocation and therefore\n",[14,166,167],{},"overstates"," the certificate obligation. That is the error that costs money rather than the one\nthat costs a penalty, and nobody is going to write to you about it.",[29,170,172],{"id":171},"one-more-thing-and-it-is-genuinely-useful","One more thing, and it is genuinely useful",[10,174,175,176,179],{},"The decision covers ",[14,177,178],{},"2026 to 2030 in a single article",". That is five reporting years in which this\nparticular input does not move, does not need an annual lookup, and does not belong in the list of\nthings to re-check each January. The next time it is open is the allocation period starting in 2031.",[10,181,182],{},"For a regime where almost everything else is annual — the CBAM factor steps every year, the benchmark\nannex is revised, the certificate price moves quarterly in 2026 and weekly from 2027 — one input that\nis fixed for five years is worth writing down as fixed.",[29,184,186],{"id":185},"what-to-check-this-week","What to check this week",[188,189,190,197,203,209],"ol",{},[191,192,193,196],"li",{},[14,194,195],{},"Find out which CSCF your figures used."," Not which one your provider intended — which one is in\nthe stored calculation. If the answer is \"1.0 by assumption\", you are fine numerically and owe\nyourself a recomputation for the record.",[191,198,199,202],{},[14,200,201],{},"Recompute anything calculated before 24 July 2026"," and re-date it, rather than reasoning that\nthe result would be unchanged. It would be. That is not the point of the exercise.",[191,204,205,208],{},[14,206,207],{},"If any figure came in with a factor below 100 %, redo it."," It overstates your obligation, and\nnobody will send you a correction for paying too much.",[191,210,211,214],{},[14,212,213],{},"Take this one off your annual list"," until 2031, and put the source on it: the Official Journal\nentry, not a summary. One practical note for anyone automating that check — EUR-Lex answers\nscripted requests for this document with an empty response, so the text has to be read by hand.",[216,217],"hr",{},[10,219,220],{},[82,221,222],{},"This article explains the rules as we read them; it is not legal advice. The factor is set by\nArticle 1 of Implementing Decision (EU) 2026\u002F1862 of 23 July 2026 (OJ L, 24 July 2026), adopted under\nArticle 14(6) of Delegated Regulation (EU) 2019\u002F331; the free-allocation mechanism in Article 10a(5)\nand (5a) of Directive 2003\u002F87\u002FEC; the CBAM free-allocation adjustment and its benchmarks in\nImplementing Regulation (EU) 2025\u002F2620; the preceding period's factor in Implementing Decision (EU)\n2021\u002F927. The recital figures are quoted from the decision itself. Verify your own position with your\ncustoms agent or the competent authority in your member state — in Germany, the DEHSt.",{"title":46,"searchDepth":224,"depth":224,"links":225},2,[226,227,228,229,230,231],{"id":31,"depth":224,"text":32},{"id":71,"depth":224,"text":72},{"id":105,"depth":224,"text":106},{"id":140,"depth":224,"text":141},{"id":171,"depth":224,"text":172},{"id":185,"depth":224,"text":186},"2026-09-20","One input in the CBAM free-allocation formula could not be looked up for most of 2026: the cross-sectoral correction factor. It was set on 23 July 2026 at 100 % for every year to 2030 — and it arrived as an emissions-trading decision, not a CBAM one. If you assumed 1.0, your number is right. Its status still is not.","md",null,"CBAM cross-sectoral correction factor, CSCF 2026, Implementing Decision (EU) 2026\u002F1862, CBAM free allocation SEFA, CBAM factor 97.5% 2026, CBAM Durchführungsbeschluss 2026\u002F1862, CSCF 100 percent 2026 2030",{},true,"\u002Fblog\u002Fcbam-cscf-100-percent-published",6,{"title":5,"description":233},"blog\u002Fcbam-cscf-100-percent-published",[244,245],"calculation","compliance","Z5zB0sFhCpqbUDWXAqmpB32SgyZEh97D85AcRArVp5M",1790002810921]