Default values vs actual emissions

Every good in a CBAM declaration carries an embedded-emissions figure, and that figure arrives by one of two routes. Actual values come from the producing installation's own monitored data. Default values are published by the Commission for each good and country of origin, and apply where actual values are not used.

The choice is made per installation and per good, not per company and not per declaration. One producer may report actual values for a good it monitors closely and fall back to defaults for another, and both can sit in the same declaration.

Actual values are not simply a number the producer states. They rest on a monitoring methodology applied at the installation, records showing how the figure was arrived at, and documentation that survives scrutiny after the declaration is filed. The calculation methods are set by the Commission's implementing act on embedded-emissions calculation.

The practical test is whether the figure can be substantiated on request. A number that cannot be traced back to monitored data and a documented method is not an actual value, and the exposure lands on the declarant rather than on the producer.

Default values are the fallback. They apply where actual data is absent, incomplete, or cannot be substantiated. They are published per good and per country of origin, with electricity treated separately from the rest.

Defaults are conservative by design. They are set so as not to understate emissions, which means a producer with a genuinely low-carbon route will usually be worse off reporting on defaults than on its own documented figures.

The comparison is arithmetic. Certificates are surrendered against the embedded emissions declared, so a lower figure means fewer certificates for the same volume. The question is whether the gap between the default value and the producer's own figure is wide enough to repay the cost of monitoring, documenting and verifying that figure.

Where the producer's route sits close to or above the default, defaults are cheaper and simpler, and choosing them is a legitimate answer. Where it sits materially below, actual data repays the effort, and the wider the gap and the larger the volume, the faster it does so.

Whichever route is used, the declaration records which one it was. The determination method sits alongside the emissions figure for each good and tells the Registry which evidence standard applies to that figure.

A declaration that mixes methods across goods is normal and expected; what is not acceptable is a method flag that disagrees with the evidence behind the number. Guide 05 sets out the direct and indirect emissions concepts in full.