Verified emissions data replaces a CBAM default value once an accredited verifier has checked the steel plant’s actual embedded emissions. The declarant then uses those figures instead of the country default. That default carries a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028 (fertilisers carry a flat 1 percent). For steel, verified data also moves the free allocation deduction onto the plant’s own production route.
How verified data replaces a default value
Article 7(2) of Regulation (EU) 2023/956 allows embedded emissions to be based on actual emissions or on default values, and Article 8(1) requires verification only for actual emissions. The plant works out its embedded emissions under Annex IV of that Regulation and Implementing Regulation (EU) 2025/2547. It uses either the calculation-based approach, built on activity data and emission factors, or the measurement-based approach, built on continuous measurement of emission sources. GreenSutra prepares the installation data and the records that an accredited verifier checks. It does not verify. The plant’s operator can register in the CBAM registry and share the verified figures with authorised declarants, who use them in place of the default for those goods.
Which route the deduction follows
On default values the plant’s own route does not count. Point 5.1 of the Annex to Implementing Regulation (EU) 2025/2620 uses the route assigned to the country of origin. An Indian electric arc furnace mill on defaults therefore carries the blast furnace default of 4.280 and the 1.370 benchmark. The three routes and their benchmarks are set out in how the production route changes a steel CBAM bill.
Verified data changes both numbers. Answer 3.8 of the Commission’s CBAM Q&A of 15 October 2026 says that when actual emissions are declared, the deduction reflects the actual production process. The deduction is then built from the plant’s own processes and precursors. An electric arc furnace mill can verify emissions far below the blast furnace default, but it also gives up a large part of the 1.370 deduction. On India’s defaults, a tonne of CN 7208 needs 3.372 certificates for 2026. Verified data lowers the bill only if verified emissions minus the plant’s own deduction come in below that figure.
What the switch is worth by 2034
Verified data removes the mark-up, and an efficient plant declares below the default itself. Certificates are due for the embedded emissions minus the free allocation adjustment and any carbon price deduction. The adjustment shrinks each year: the CBAM factor is 97.5 percent in 2026, and from 2034 nothing is deducted for free allocation, whatever the route. In 2026, 2.5 percent of the benchmark is no longer deducted. That figure is not 2.5 percent of the embedded emissions.
Example: a line of 500 tonnes a year of hot-rolled flat steel (CN 7208) from India, in 2034. On default values with the 30 percent mark-up, it needs 500 x 4.280 x 1.30, or 2,782 certificates, about EUR 229,014. With verified data at an example intensity of 2.2 tonnes of CO2e a tonne, roughly half the India default, it needs 1,100 certificates, about EUR 90,552. That is about 60 percent lower.
Both bills assume today’s India default and the third-quarter 2026 price of EUR 82.32 still apply in 2034. The Commission must review the default values by December 2027. The example is set in 2034 because nothing is deducted that year, so the comparison rests on emissions alone. The full India default schedule is in CBAM default values for Indian steel exports.
Four steps from installation to registry
A steel exporter moves from estimates to verified declarations in four steps:
- Quantify embedded emissions from installation data: production volumes, source streams, precursor inputs and the direct emissions of each production route.
- Prepare the monitoring methodology documentation that fixes system boundaries and the chosen calculation-based or measurement-based approach.
- Have the dataset verified by an accredited verifier; verification is always a third-party act.
- Share the verified figures with the importer or authorised declarant, preferably through the CBAM registry, since operator registration is optional in 2027, so the declaration can use actual data.
The same steps apply to every CBAM good, as set out in how an exporter switches from default values to actual data. For steel, the work starts with the CBAM discovery intake, which maps products, routes and installations in one pass. GreenSutra’s CBAM solutions service then covers quantification and report preparation, up to independent verification.
Sources: Regulation (EU) 2023/956, consolidated, Implementing Regulation (EU) 2025/2547, Implementing Regulation (EU) 2025/2620, Implementing Regulation (EU) 2025/2621, Implementing Regulation (EU) 2026/1740, CBAM Questions and Answers, 15 October 2026