[{"data":1,"prerenderedAt":441},["ShallowReactive",2],{"blog:\u002Fblog\u002Fcbam-mark-up-do-not-recompute":3},{"id":4,"title":5,"body":6,"date":426,"description":427,"extension":428,"hero":429,"heroAlt":429,"keywords":430,"meta":431,"navigation":432,"path":433,"readingMinutes":434,"seo":435,"stem":436,"tags":437,"__hash__":440},"blog\u002Fblog\u002Fcbam-mark-up-do-not-recompute.md","Never recompute the CBAM mark-up. 2026 will not tell you why.",{"type":7,"value":8,"toc":416},"minimark",[9,18,21,28,33,36,196,199,202,206,222,225,328,331,337,341,344,351,354,358,361,364,371,375,381,392,395,399,405,408,411],[10,11,12,13,17],"p",{},"The EU default values come with a penalty built in. If you use them instead of verified supplier\ndata, the published figure is your emissions plus a statutory mark-up — and the mark-up rises with\nthe year, not with the material: ",[14,15,16],"strong",{},"+10 % in 2026, +20 % in 2027, +30 % from 2028"," (Annex I of\nImplementing Regulation (EU) 2025\u002F2621). Fertiliser is the one exception, flat at +1 % in all three\nyears.",[10,19,20],{},"So the annex publishes two numbers per row: the raw value, and the marked-up value for each of the\nthree year columns. Which invites an obvious shortcut. You have the raw figure, you know the year,\nyou multiply.",[10,22,23,24,27],{},"Do not. And the reason it is worth a whole article is that ",[14,25,26],{},"in 2026 the shortcut works perfectly"," —\nso it will not warn you.",[29,30,32],"h2",{"id":31},"what-is-actually-in-the-table","What is actually in the table",[10,34,35],{},"We load the whole annex into our own store: 32,790 rows, 10,930 per year, across five sectors. Taking\nthe ratio of published to raw on every row gives this:",[37,38,39,58],"table",{},[40,41,42],"thead",{},[43,44,45,49,52,55],"tr",{},[46,47,48],"th",{},"Year",[46,50,51],{},"Ratio",[46,53,54],{},"Rows",[46,56,57],{},"Sector",[59,60,61,76,89,102,113,125,137,156,167,179],"tbody",{},[43,62,63,67,70,73],{},[64,65,66],"td",{},"2026",[64,68,69],{},"×1.0100",[64,71,72],{},"2,416",[64,74,75],{},"fertiliser",[43,77,78,80,83,86],{},[64,79,66],{},[64,81,82],{},"×1.1000",[64,84,85],{},"8,512",[64,87,88],{},"aluminium, cement, hydrogen, iron & steel",[43,90,91,93,96,99],{},[64,92,66],{},[64,94,95],{},"×1.0999",[64,97,98],{},"1",[64,100,101],{},"iron & steel",[43,103,104,107,109,111],{},[64,105,106],{},"2027",[64,108,69],{},[64,110,72],{},[64,112,75],{},[43,114,115,117,120,123],{},[64,116,106],{},[64,118,119],{},"×1.2000",[64,121,122],{},"8,502",[64,124,88],{},[43,126,127,129,132,135],{},[64,128,106],{},[64,130,131],{},"×1.2001",[64,133,134],{},"7",[64,136,101],{},[43,138,139,141,146,151],{},[64,140,106],{},[64,142,143],{},[14,144,145],{},"×1.2100",[64,147,148],{},[14,149,150],{},"5",[64,152,153],{},[14,154,155],{},"cement",[43,157,158,161,163,165],{},[64,159,160],{},"2028",[64,162,69],{},[64,164,72],{},[64,166,75],{},[43,168,169,171,174,177],{},[64,170,160],{},[64,172,173],{},"×1.3000",[64,175,176],{},"8,509",[64,178,88],{},[43,180,181,183,188,192],{},[64,182,160],{},[64,184,185],{},[14,186,187],{},"×1.3310",[64,189,190],{},[14,191,150],{},[64,193,194],{},[14,195,155],{},[10,197,198],{},"Look at 2026 on its own and the rule holds everywhere. One row is off by a ten-thousandth, which is\nrounding. Nothing suggests the shortcut is unsafe.",[10,200,201],{},"Now look at 2027 and 2028.",[29,203,205],{"id":204},"five-rows-where-the-act-compounds-instead","Five rows where the act compounds instead",[10,207,208,209,212,213,216,217,221],{},"1.10, ",[14,210,211],{},"1.21",", ",[14,214,215],{},"1.331",". Those are not arbitrary. They are 1.1¹, 1.1², 1.1³ — the mark-up applied\n",[218,219,220],"em",{},"again each year"," rather than stepped 10 \u002F 20 \u002F 30.",[10,223,224],{},"It affects five (origin, CN) pairs, all cement, all from two countries:",[37,226,227,246],{},[40,228,229],{},[43,230,231,234,237,240,243],{},[46,232,233],{},"Origin",[46,235,236],{},"CN",[46,238,239],{},"Raw",[46,241,242],{},"2027 published",[46,244,245],{},"2028 published",[59,247,248,265,281,297,313],{},[43,249,250,253,256,259,262],{},[64,251,252],{},"Angola",[64,254,255],{},"2523 10 00",[64,257,258],{},"1.2600",[64,260,261],{},"1.5246",[64,263,264],{},"1.6771",[43,266,267,269,272,275,278],{},[64,268,252],{},[64,270,271],{},"2523 29 00",[64,273,274],{},"1.2700",[64,276,277],{},"1.5367",[64,279,280],{},"1.6904",[43,282,283,285,288,291,294],{},[64,284,252],{},[64,286,287],{},"2523 90 00",[64,289,290],{},"1.2200",[64,292,293],{},"1.4762",[64,295,296],{},"1.6238",[43,298,299,302,304,307,310],{},[64,300,301],{},"Argentina",[64,303,255],{},[64,305,306],{},"0.9000",[64,308,309],{},"1.0890",[64,311,312],{},"1.1979",[43,314,315,317,319,322,325],{},[64,316,301],{},[64,318,271],{},[64,320,321],{},"0.9200",[64,323,324],{},"1.1132",[64,326,327],{},"1.2245",[10,329,330],{},"Check the first line yourself: 1.26 × 1.21 = 1.5246, and 1.26 × 1.331 = 1.6771. The linear rule would\nhave given 1.512 and 1.638.",[10,332,333,336],{},[14,334,335],{},"And in 2026 these same five rows sit at exactly ×1.1000"," — indistinguishable from every other row\nin the table. The divergence does not exist yet. Whatever you build this year to check your figures\nwill pass, and then quietly stop being right on 1 January 2027.",[29,338,340],{"id":339},"what-it-costs","What it costs",[10,342,343],{},"The gap on Angolan clinker is 0.0126 tCO₂\u002Ft in 2027 and 0.0391 in 2028 — 0.8 % and 2.3 % of the\npublished value.",[10,345,346,347,350],{},"The free-allocation subtraction does not move when SEE does, so a shortfall in SEE carries straight\nthrough to the certificate count. On a 1,000 t consignment of CN 2523 10 00 from Angola in 2028, the\nlinear shortcut understates the obligation by about ",[14,348,349],{},"39 certificates"," — roughly €2,900 at the Q2\n2026 certificate price of €75.28. Article 26 penalises under-surrender at three to five times the\ncertificate price, so the exposure is a multiple of that, not the figure itself.",[10,352,353],{},"That is one origin and one commodity. Small. The point is not the size of this particular gap — it is\nthat a method which reproduces the published table exactly, on ten thousand rows, in the year you are\nimporting, is still the wrong method.",[29,355,357],{"id":356},"eight-rows-that-never-land-on-the-factor-at-all","Eight rows that never land on the factor at all",[10,359,360],{},"There is a second, smaller finding in that ratio table, and it matters for a different reason.",[10,362,363],{},"One 2026 row (Angola, CN 2601 12 00) comes out at ×1.0999: raw 0.6166, published 0.6782, where the\nexact product is 0.67826. And seven 2027 rows — all Thailand, all iron and steel, all sharing the raw\nvalue 1.4396 — come out at ×1.2001: published 1.7276 against an exact 1.72752.",[10,365,366,367,370],{},"Those are four-decimal rounding in the published table, nothing more. But they are worth noticing,\nbecause they tell you something about the column: ",[14,368,369],{},"it was authored, not derived."," The act publishes\na figure. It does not publish a recipe you are meant to run. Recompute it and you will sometimes get\na number the act does not contain — usually in the fourth decimal, occasionally, as above, in the\nfirst.",[29,372,374],{"id":373},"two-numbers-and-you-need-both","Two numbers, and you need both",[10,376,377,378],{},"The practical rule is short: ",[14,379,380],{},"read the published column for the year, verbatim.",[10,382,383,384,387,388,391],{},"But do not throw the raw value away either, and this is the part that catches people who tidy up\ntheir data model. Article 22(2) of Regulation (EU) 2023\u002F956 computes the ",[14,385,386],{},"quarterly holding\nobligation"," — the 50 % of your year-to-date liability you must hold in certificates at each\nquarter-end — on the value ",[218,389,390],{},"without"," the mark-up.",[10,393,394],{},"So the two figures serve two different purposes, in two different places, and neither can be derived\nfrom the other with confidence. Store both. We do, in the same row, precisely because storing one and\ncomputing the other guarantees a wrong number somewhere.",[29,396,398],{"id":397},"what-to-check-this-week","What to check this week",[10,400,401,402],{},"If you or a provider computes CBAM figures from the default values, ask one question: ",[14,403,404],{},"is the\nyear-column value read from the act, or multiplied out?",[10,406,407],{},"If the answer is \"multiplied out\", it is producing correct numbers today and will produce wrong ones\nfor cement from Angola and Argentina in fifteen months — with nothing in this year's output to\nsuggest it. And ask the same question about the quarterly holding figure, from the other direction:\nif it uses the marked-up value, it is overstating what you must hold.",[409,410],"hr",{},[10,412,413],{},[218,414,415],{},"This article explains the rules as we read them; it is not legal advice. The default values, their\nyear columns and the mark-up are set out in Annex I of Implementing Regulation (EU) 2025\u002F2621; the\nquarterly holding obligation in Article 22(2) of Regulation (EU) 2023\u002F956 as amended by Regulation\n(EU) 2025\u002F2083; the penalty regime in Article 26 of the same. The row counts and ratios above are\nfrom our own load of the published annex and are reproducible from it. Verify your own position with\nyour customs agent or the competent authority in your member state — in Germany, the DEHSt.",{"title":417,"searchDepth":418,"depth":418,"links":419},"",2,[420,421,422,423,424,425],{"id":31,"depth":418,"text":32},{"id":204,"depth":418,"text":205},{"id":339,"depth":418,"text":340},{"id":356,"depth":418,"text":357},{"id":373,"depth":418,"text":374},{"id":397,"depth":418,"text":398},"2026-09-10","The default values carry a statutory mark-up that rises with the year, and it is tempting to apply it yourself. In 2026 that gives the right answer on every row. From 2027 it stops — five cement rows compound instead, and eight steel rows never land on the factor at all. Read the published column.","md",null,"CBAM default values mark-up, CBAM Aufschlag Standardwerte, IR 2025\u002F2621 Annex I, CBAM 2027 mark-up 20%, CBAM cement Angola Argentina, Art 22(2) CBAM quarterly holding, CBAM SEE calculation",{},true,"\u002Fblog\u002Fcbam-mark-up-do-not-recompute",6,{"title":5,"description":427},"blog\u002Fcbam-mark-up-do-not-recompute",[438,439],"calculation","compliance","TzmkDwADHKpGaDuU5sIHMb0aiynY3NSBwDXyVZzaLRE",1790002810922]