When a steel product’s origin has no published country default value and no verified data, CBAM applies a deliberately high fallback default, 3.48 tonnes of CO2e per tonne for pig iron before the annual mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028. The value is set high on purpose, so verified installation data or a valid country default usually lowers the declared figure.
CBAM has no single default value for steel. Where a consignment carries neither verified installation data nor a published default for its country of origin, a fallback default applies, and it is pitched deliberately high so that supplying real data almost always brings the declared figure down. Because the fallback is product-specific, it differs across pig iron, direct reduced iron, flat-rolled products and the rest of the iron and steel group.
How CBAM selects the value
Under Article 7(2) of Regulation (EU) 2023/956, the declarant uses either actual emissions data or default values:
- Actual installation data verified by an accredited verifier can be used in place of default values.
- Where actual data is not used, the default value published for the country of origin applies, carrying its annual mark-up.
- Where reliable data for the exporting country cannot be applied, Annex IV point 4.1 sets the high fallback default.
Pig iron across origins
For pig iron, the country figures sit well below the fallback:
| Origin basis | Pig iron (tCO2e per tonne) |
|---|---|
| India country value | 2.53 |
| Türkiye country value | 1.85 |
| China country figure | about 1.66 |
Iron and steel count direct embedded emissions only, so the production route rather than electricity explains most of the spread between origins. Each country value undercuts the fallback, which is why a correct country default or verified plant data reduces the charge.
Goods bought through traders are the most likely to be declared on default values, because installation data does not always reach the declarant in time. A precursor whose country of production cannot be identified takes the highest default value, 7.92 tonnes of CO2e per tonne for pig iron before mark-up. CBAM compliance support covers guidance on declarant status, embedded-emissions calculation and certificate exposure, including which value applies to a given product and origin. A CBAM guide sets out how to keep verified data with the consignment.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM