Corrected CBAM Default Values Apply from 1 January 2026

The CBAM default values that importers have used since January have been corrected. Commission Implementing Regulation (EU) 2026/1740 replaces Annex I and Annex IV of Regulation (EU) 2025/2621 in full, and it applies retroactively from 1 January 2026. Every embedded emissions figure calculated with the original tables this year needs to be rechecked.

This is a technical correction rather than a policy change, which is exactly why it is easy to miss. There was no press release and no consultation. The legal effect is nonetheless immediate and backdated to the start of the first compliance year.

What Regulation (EU) 2026/1740 changed

The original default values for the definitive regime were set out in Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025. Within weeks of the definitive regime starting, importers and consultants began reporting entries that did not add up: values that were simply absent, CN codes attached to the wrong product, units that were inconsistent between tables, and rounding that differed between the direct and indirect emissions annexes.

The Commission adopted the correction on 20 July 2026. It was published in the Official Journal on 31 July 2026 and entered into force on 3 August 2026. Rather than issue a list of amendments, the Commission replaced Annex I (default values for embedded emissions) and Annex IV in their entirety.

The corrected annexes repair four categories of problem:

Missing values. Country and product combinations that had no entry, forcing declarants onto a fallback value that was often far higher than the correct figure.
Erroneous entries. Transcription errors, values attached to the wrong country, and inconsistent rounding between tables.
Production routes. Route indicators that were absent or wrong, which matters because the applicable value depends on how the good was made, not only on what it is.
Customs distinctions. Cement and clinker now distinguish white from grey product at ten digit TARIC level instead of eight digit CN level, so two goods that shared a value before may no longer do so.

Why a technical correction matters financially

Default values are not a formality. They are the figure that applies whenever actual verified emissions data is not available, which for most importers still describes the majority of their supplier base in 2026. Our explainer on CBAM default values and how they are set covers the mechanics in more detail.

Multiply a corrected value by annual import tonnage and by the certificate price, and the effect is real money. The Q2 2026 benchmark was €75.28 per tonne of CO₂, so a shift of one tonne of embedded CO₂ per tonne of product across ten thousand tonnes of imports moves roughly three quarters of a million euros of certificate liability.

The timing is a small mercy. Certificates covering 2026 imports are not purchased until sales open in February 2027, and the annual declaration for 2026 is due by 30 September 2027. Nothing has been irreversibly paid on the old figures. What has happened is that the accruals, budgets and supplier conversations built on those figures are now based on superseded data.

Base values and mark ups now sit apart

One structural change deserves separate attention. The corrected annexes publish base values, without the mark up already folded in. Previously the published figures included the uplift.

The mark up itself is unchanged in policy terms: most default values carry an uplift of 10 percent in 2026, rising to 20 percent in 2027 and 30 percent from 2028, designed to make reliance on defaults progressively less attractive than obtaining actual data. Fertilisers are treated separately, with a 1 percent annual increase reflecting inflation and the sensitivity of the agricultural sector.

The calculation of the uplift now sits with the declarant and the CBAM Registry rather than being pre baked into the table. Anyone who exported the earlier tables into a pricing model is at risk of the same error in two directions: applying the uplift twice, or dropping it entirely.

Where the movements are largest

All five CBAM sectors are affected: cement, iron and steel, aluminium, fertilisers and hydrogen. The size of the change depends entirely on the specific country and product combination, and generalisations are unhelpful. A few illustrative movements reported in the trade press give a sense of the range:

Stainless steel from Taiwan fell by roughly 40 percent.
Several Tunisian aluminium products fell by between 63 and 74 percent.
Precursor values for certain aluminium articles rose by around 50 percent.

The practical point is that the direction of travel is not uniform. An importer cannot assume the correction is good news, and equally cannot assume it is bad. Only a line by line comparison of the actual product and origin combinations in your import book will tell you.

What importers should do this month

The work is finite and mostly mechanical:

List the affected calculations. Every 2026 embedded emissions figure derived from a default value rather than verified supplier data is in scope.
Compare on five fields. Country of origin, CN or TARIC code, production route, unit, and product description. A match on the code alone is not enough now that TARIC level distinctions apply.
Check the mark up treatment. Confirm your model applies the uplift once, to a base value, at the correct percentage for the year.
Restate the accrual. Recalculate the 2026 certificate liability and update the provision and the liquidity plan behind it.
Reopen the supplier business case. Where a corrected value has fallen sharply, the payback on obtaining verified actual data may have shrunk. Where it has risen, the case for verified data just got stronger. Our overview of accredited CBAM verifiers arriving in 2026 sets out what that route involves.
Tell the people downstream. Customs brokers, tax advisers and software providers all need to be running the corrected reference data, not a cached copy.
Keep the evidence. Record which version of the annexes each figure was derived from. A verifier and a competent authority will both want to see that the restatement was deliberate.

CBAM Desk maintains the default value tables centrally, so a correction of this kind propagates to every affected line rather than leaving you to find them by hand. If you are currently reconciling this in spreadsheets, the pricing page shows what the alternative costs.

FAQ

What did Commission Implementing Regulation (EU) 2026/1740 change?

It replaces Annex I and Annex IV of Implementing Regulation (EU) 2025/2621 in full. The correction repairs missing and erroneous CBAM default values, production route indicators, units, country entries and customs code distinctions. It was adopted on 20 July 2026, published on 31 July 2026 and entered into force on 3 August 2026.

From when do the corrected CBAM default values apply?

From 1 January 2026. The correction applies retroactively to the whole of the first compliance year, so any calculation made earlier in 2026 with the original annexes needs to be rechecked against the replacement tables.

Do the corrected default values change my CBAM certificate costs?

They can, in both directions. Some values fall because a missing country specific value was added or a wrong entry was removed. Others rise, and in some cases a production route or a ten digit TARIC distinction now applies where an eight digit CN code was used before. Certificates for 2026 imports are only bought from February 2027, so there is time to correct the figures before money moves.

Are the mark ups still included in the published default values?

No. The corrected annexes publish base values, and the mark up is applied on top. That makes the tables cleaner to read but shifts the arithmetic to the declarant and the CBAM Registry, so anyone who copied the earlier figures into a spreadsheet should check whether they are now double counting or omitting the mark up.

Which sectors are affected by the correction?

All CBAM sectors are touched: cement, iron and steel, aluminium, fertilisers and hydrogen. Cement and clinker gain a sharper split between white and grey product at TARIC level, and several country and product combinations in steel and aluminium moved by tens of percent.

Key takeaway

A correction that arrived without fanfare has rewritten the reference tables underneath every default based CBAM calculation made in 2026. The importers who handle it well will treat it as a scheduled restatement in August rather than a discovery in September 2027, when the first annual declaration is due and there is no room left to absorb a surprise. Talk to our team if you want a second pair of eyes on the restatement, or browse the rest of our CBAM news coverage.