CBAM Default Values Are Getting More Expensive Every Year — Here Is the Schedule

EU default CBAM values are designed to be expensive. They are calculated from the worst-performing 10% of EU installations in each sector — the highest-emitting producers — and they carry an additional mark-up penalty on top of that already high baseline. That mark-up increases over time.

If your EU buyer is using default values now, their cost exposure is growing automatically — even if EUA prices stay completely flat.

What EU default values are

Under Implementing Regulation (EU) 2025/2621, EU default values represent the specific embedded emissions of the least efficient producers in each sector and country combination. They are deliberately set high to create a financial incentive for exporters to provide verified actual data.

For context: the EU default value for iron and steel from Egypt is approximately 4.395 tCO₂e/t. A verified actual SEE of 1.615 tCO₂e/t — as achieved by exporters who have completed the measurement and verification process — reduces the embedded emissions basis for certificate calculation by 63%. At commercial export volumes this difference is worth hundreds of thousands of euros per year.

The mark-up penalty schedule

On top of the already high default values, EU law applies a percentage mark-up as an additional penalty for not providing verified data:

| Year | Mark-up on EU Default | Impact | | --- | --- | --- | | 2026 | +10% | Applies now — buyers using defaults pay 10% more than the default baseline | | 2028 onwards | +30% | Permanent escalation — buyers using defaults pay 30% above an already high baseline |

(Note: Intermediate years should be confirmed with latest available EU implementing regulations.)

This means a buyer who continues to use EU default values beyond 2027 faces a compounding cost increase: the default baseline is already the worst-performing 10% of EU producers, and the 30% mark-up adds a further premium on top.

A worked example for iron and steel

• Base EU default SEE for Egyptian iron and steel: 4.395 tCO₂e/t
• With 2026 mark-up (+10%): 4.834 tCO₂e/t
• With 2028 mark-up (+30%): 5.714 tCO₂e/t

For a buyer importing 25,000 tonnes per year at the 2026 CBAM phase-in factor of 2.5%:

• Using 2026 default (with mark-up): approximately €227,000 annual cost
• Using verified actual SEE of 1.615 tCO₂e/t: approximately €12,000 annual cost
• Annual saving: approximately €215,000

By 2028, the same comparison at 22.5% phase-in factor and 30% default mark-up produces a difference of over €1.8 million per year.

The compounding effect

The mark-up is not the only cost escalation. The CBAM phase-in factor also increases every year — from 2.5% in 2026 to 100% in 2034. This means both the default mark-up and the phase-in factor work against buyers who delay obtaining verified data. The financial case for getting verified now grows stronger every year.

What to tell your EU buyer

Every year your buyer uses EU default values costs them more than it would have cost the previous year — not because EUA prices necessarily increased, but because both the mark-up and the phase-in factor are higher. The conversation to have with your buyer is not "will you need CBAM data?" but "how much is it costing you every month that you do not have it?"

Use the DeCarbonPro Gap Analysis tool to calculate the exact saving your buyer achieves by switching from EU default to your verified actual SEE — and show them the year-by-year cost trajectory.