What is the EU default value costing you?

How far above actual performance can a default value sit?

Turkish cement gives the clearest published answer. According to Volkan Bozay, Chairman of TÜRKÇİMENTO, members’ actual data for clinker stands at 0.88 tCO₂ per tonne, while the default value the EU applies to Türkiye is 1.551 tCO₂ per tonne — roughly 1.76 times actual performance.

This gap pushes the carbon cost to 80 euros per tonne, which exceeds even the unit price of the product itself.

For an importer, that last clause is the whole story: a carbon cost larger than the goods’ own unit price does not stay in a compliance file — it lands in the landed cost, in the margin and eventually in the sourcing decision. The figure belongs to cement and the ratio differs by sector, but the mechanism does not: no data means a default, a default means a gap, and a gap means an invoice.

If the importer buys the certificates, whose problem is the gap?

The party that surrenders certificates is the authorised CBAM declarant in the EU — the importer. The cost, however, does not stop at customs; it travels back up the supply chain. A shipment declared on a default value is simply more expensive than the same goods declared on verified data, and an importer closes that difference in one of three ways: asking for a price concession, splitting the volume, or changing supplier.

Competition is therefore no longer only about unit price. Between two suppliers of equal quality at an equal price, the one that can produce verified data delivers a lower total landed cost. A producer can have the lower manufacturing cost and still arrive at the table as the expensive option, purely because its declaration is weak.

There is also the nature of an average. A default value is a country-level average, and averages penalise the best-performing installations in a sector. A plant that has upgraded its kiln, switched to alternative fuels and cut its clinker ratio is described by the same number as a plant that has done none of it — until it supplies data. Efficiency investments only reach the price once they are measured and declared.

What is the gap costing you?

The calculator places the two scenarios side by side — the annual certificate cost of a shipment declared with a default value, and the same shipment declared with verified installation data. Selecting a sector also shows the range of published indicative values for that sector.

How large is the mark-up on a default value?

Default values are applied with a margin on top of the country-specific average. Implementing Regulation (EU) 2025/2621 sets that margin on a rising scale: +10% for 2026, +20% for 2027, and +30% from 2028 onwards. For fertilisers the margin is limited to 1%.

The intent is straightforward — a default must never be cheaper than measuring, so that not measuring is never the commercially rational choice. The practical consequence is that the same default value costs roughly a fifth more in 2028 than in 2026, even if nothing else changes. Postponing the monitoring system has a price, and the price rises.

Why does the 2026 invoice look so small?

Because only a share of the obligation is surrendered. The CBAM factor in Regulation (EU) 2023/956 tracks the phase-out of free allocation:

In 2026, certificates cover just 2.5% of calculated emissions, which is why the first invoice reads as manageable. The break comes between 2029 and 2030, when the rate moves from 22.5% to 48.5% — more than doubling in a single year — before reaching 100% in 2034.

The planning implication is simple: a 2030 invoice cannot be reduced by a decision taken in 2030. Verifiable installation data cannot be produced retroactively; it accumulates from the moment monitoring starts.

Where does the certificate price stand today?

Through 2026 the CBAM certificate price is published quarterly: €75.36/tCO₂e for the first quarter, published on 7 April 2026, and €75.28/tCO₂e for the second quarter, published on 6 July 2026. The calculator uses the latter by default, and the field is editable so you can run your own price sensitivity.

Certificate purchasing opens on 1 February 2027, and from 2027 the price is set weekly. In other words, the 2026 obligation is settled with certificates bought in 2027, after which price risk shifts from a quarterly figure to a weekly one. Your emissions intensity is the single variable that determines how much of that volatility you are exposed to.

What does moving to actual data actually require?

The only way out of a default value is a declaration the importer can rely on and a verifier can check. That takes more than filling in a template:

• Installation-level monitoring: fuel, raw material and production data collected systematically and traceably.
• Definition of production processes: drawing the boundary of which process produces which good, in CBAM terms.
• Mass balance and allocation rules: inputs and outputs that reconcile.
• Allocation in multi-product installations: splitting emissions across goods made on the same site.
• Embedded emissions of precursor materials: carrying supplier emissions through to the final good.
• Electricity data for indirect emissions: consumption, source and the applicable grid factor.
• Evidence documents: measurement records, invoices, laboratory analyses and the calculation trail.
• The declaration handed to your EU importer: right format, right period, on time.

Where does the CarbonTrex CBAM module fit?

The module takes on the calculation and tracking side of that list. What it does:

• Multi-product installation calculation
• Mass allocation
• Deduction of renewable electricity generated on site
• Separation of direct and indirect emissions
• Certificate price tracking
• CN code mapping
• Phase-out schedule tracking

None of this measures anything on your behalf; it makes the data you do measure declarable. That is where the difference is won — not accepting 1.551 on a form when the installation is running at 0.88.

Could this calculation change?

It could. The EU ETS revision proposal COM(2026) 616, dated 17 July 2026, would slow the phase-in and move full obligation to 2038. It is a proposal, not law in force. If adopted, cost projections for 2028–2037 change.

Rather than guess at that outcome, the calculator applies the law as it stands today: the rates in Regulation (EU) 2023/956 and the mark-up in Implementing Regulation (EU) 2025/2621. Whatever happens to the proposal, one thing does not move — the gap between the default value and actual performance. Only the year in which it hits the invoice does.

Where should you start?

In order: confirm whether the goods are in scope, see what becomes binding on which date, then put installation data into a structure a verifier can sign off.