What are the default values? How does this work?
For imports until 30 June 2024 (i.e. CBAM reports due until 31 July 2024), for each import of goods for which the reporting declarant does not have all the information, the reporting declarant could use other methods for determining the emissions, including default values made available and published by the Commission (see the TAXUD CBAM website). The use of default values for the purpose of reporting during the transitional period was thus possible for the first three reporting periods, without quantitative limits.
In addition, estimated values (including default values) can be used when determining direct emissions during the whole transitional period for input materials or subprocesses with a relatively minor contribution (i.e. <20%) to the total embedded emissions of complex goods (see Article 5 of the CBAM Implementing Regulation). For determining these 20%, indirect emissions are only relevant to calculate what the 100% total embedded emissions entails.
In other words, this means that for imports until 30 June 2024, 100% of the total embedded emissions could be determined using default values. For the remaining transitional period (i.e. for imports from 1 July 2024 to 31 December 2025), estimated values may be used when determining direct emissions but a quantitative limit is applied: for complex goods, up to 20% of the total embedded emissions, considering the entire production chain, may be then determined using estimations (using default values provided by the Commission would qualify as ‘estimation’). When reporting declarants make use of this flexibility to use estimated values (including default values) within the 20% limit, they should follow these steps in the Transitional Registry:
(1) In the field “Type of determination” for Direct embedded emissions, select “Actual data”.
(2) In the field “Type of applicable reporting methodology”, select “Commission rules”
(3) In the field “Additional Information”, provide details on the applicable reporting
methodology and the use of estimated values within the 20% limit.
By the end of the transitional period in 2025, the Commission will assess the default values based on the data collected.
During the transitional period, there will be only global default values (for each CN code under the CBAM scope). During the definitive period then, default values by country or even by region will be made available.
During the definitive period, authorised CBAM declarants will be able to use default values, without quantitative limits, in cases where actual emissions data is not available. However, it will likely be more favourable for importers to provide the calculation of embedded emissions.
Source: EC’s Questions and Answers on CBAM
CBAM Regulation
CBAM Regulation 2023_1773