CBAM default values or supplier data in 2026: what the documents must show

What the 2026 rules say

The base text is Regulation (EU) 2023/956, and Regulation (EU) 2025/2083 changed it. The transitional period ran from 2023 to 2025, and the definitive period started on 1 January 2026.

• An importer whose imports stay under a cumulative 50 tonnes of net mass per calendar year is exempt (Article 2a). Above it, all obligations apply to all goods imported that year.
• An authorised CBAM declarant submits the annual declaration by 30 September of the following year. The first one is due in 2027 for 2026 (Article 6(1)).
• Member States sell CBAM certificates from 1 February 2027 (Article 20(1)).
• The declaration states the quantity of each type of goods and the embedded emissions per tonne, with copies of verification reports where they apply (Article 6(2)). The declarant keeps the records used to calculate them (Article 7(5)).

Default values or actual supplier data

Article 7(2) gives two routes. Embedded emissions are either the actual emissions of the installation that made the goods, worked out by the methods in Annex IV, or default values from point 4.1 of Annex IV. The Commission calculates the default values and makes them available. Implementing Regulation (EU) 2025/2621 sets them, and Implementing Regulation (EU) 2026/1740 corrected its annexes in July 2026.

Defaults are listed by country of origin and good. A country that is not listed falls back to the table for other countries and territories. The values for total emissions then carry a mark-up. For cement, iron and steel, aluminium and hydrogen it is 10 percent in 2026. In 2027 it is 20 percent, and from 2028 it is 30 percent. For fertilisers it is 1 percent from 2026. The final value with the mark-up is calculated in the CBAM registry.

Only actual values need verification, and an accredited verifier does it (Article 8). With default values, a deduction for a carbon price paid in the origin country can only use yearly default carbon prices, where they exist (recital 21 of Regulation 2025/2083). Whether supplier data beats the default depends on the supplier. You only find out by reading what they send.

A supplier figure is only as good as the document behind it.

What supplier emissions data must show

There is no single format. Suppliers send a PDF report, a spreadsheet, a table in an email or a scan of a signed statement. For the actual route, these fields matter in all of them.

• The installation: name, country and an identifier.
• The product: CN code and description, as the goods are classified for customs.
• The production route, for example electric arc furnace or blast furnace for steel.
• Direct and indirect emissions in tonnes of CO2e per tonne of product.
• The reporting period the figures cover.
• Whether the figures are verified, and by whom.
• Any carbon price paid in the origin country.

Annex IV sets which emissions count for a given product, direct only or direct and indirect. Look it up by CN code before you treat a missing indirect value as a gap.

Checks before a figure is used

1. The CN code matches the invoice. A supplier report for CN 7208 does not cover goods you import under another code.
2. The period fits the import. The reporting period must be one the goods belong to. A report from two years ago needs a reason.
3. The unit is per tonne. A yearly total in tCO2e is not an intensity in tCO2e per tonne. Mixed-up units are a common slip in spreadsheets.
4. The parts add up. If direct, indirect and a total are all given, the sum should match, allowing for rounding.
5. The route fits the number. A figure far from the usual range for that route is worth a question to the supplier.
6. The verification exists. If the supplier calls the figures actual and verified, ask for the verification statement. Without it, talk to your adviser about the default route.
7. Nothing is blank. A blank carbon price field and a stated zero mean different things. Mark blanks as missing.

Collect the gaps for each supplier and ask once. Six emails about six separate fields is where the days go.

What Corteal does with it

The Read page shows an illustrative table for three invented suppliers with installation, CN code, production route and direct and indirect emissions. One invented supplier is missing its indirect value and its verifier statement, and the table flags both. The values and scores in that table are typed in, not measured.

In a free pilot, our team extracts your suppliers' documents into these fields and checks every value by hand before you see it. Each value comes with its page, and anything uncertain carries a flag. You get a CSV or a file in the format of the system you already use. Read does not file declarations and does not judge whether a figure is acceptable. It prepares the data so a person can decide between the default and the supplier figure with the source in front of them.

Have a folder of supplier emissions reports? Start a pilot with the most awkward ones.