Documented steps

Identify the applicable calculation methodology for the goods' sector under Commission Implementing Regulation (EU) 2025/2547 on methods for calculating embedded emissions in the definitive regime.
Request actual embedded emissions data (direct and, where relevant, indirect) from the non-EU installation operator, using the Commission's guidance document on CBAM implementation for installation operators outside the EU.
Where actual data is unavailable or incomplete, use the Commission's published default values, subject to the sector-specific rules.
Download the current Default Values and Benchmarks spreadsheets for the definitive period, published 13 February 2026 under Implementing Regulation (EU) 2025/2621, from the CBAM legislation and guidance page.
Apply the mark-up required when default values are used: 10% in 2026, 20% in 2027, 30% from 2028, reflecting the shrinking permitted role of defaults.
For electricity, resolve the applicable basis before relying on a number: obtain country-level CO2 emission factors or actual producer-specific factors as the rules require for the specific import situation.
Have embedded emissions data independently verified by a verifier accredited specifically for CBAM under EN ISO 14065 and EN ISO 17029, per Implementing Regulation (EU) 2025/2546 on verification principles.
Retain all supporting documentation (installation data, verification reports, emission factor sources); the authorised CBAM declarant carries the record-keeping burden for the figures used in the annual declaration.
Where a carbon price was effectively paid abroad, gather evidence that it was not rebated, exempted, or offset by free allocation, for the Article 9 deduction claim.
Refresh values annually. Default values and benchmarks are republished periodically and the mark-up steps up each year, so a 2026 value is not automatically valid for 2027.
Official sources verified 2026-08-03: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en | https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en | https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202502083

Known gotchas

Official Commission material is not fully consistent on electricity: the CBAM Q&A states default values cannot be used for electricity and actual data is required, while the Commission's electricity factsheet describes country-level emission factors as the standard basis. Re-check Implementing Regulation (EU) 2025/2547 and the Q&A on CBAM and Electricity before relying on either.
The default-value mark-up schedule (10/20/30%) is a definitive-regime feature. Transitional-period default values used a different methodology and no mark-up; do not reuse them.
Definitive-period default values and benchmarks were only published 13 February 2026. Anything downloaded earlier is transitional-period data and wrong for 2026 declarations.
A generic ISO 14065 auditor is not sufficient. The verifier must hold CBAM-specific accreditation and the goods category must fall within its accredited scope.
The implementing act setting detailed evidence rules for the third-country carbon-price deduction was still pending per the Commission's own Q&A during 2026. Treat those documentation requirements as provisional.
Free-allocation adjustment is governed by a separate act, Implementing Regulation (EU) 2025/2620. Do not conflate it with the Article 9 third-country carbon-price deduction.

Determine and document embedded emissions for 2026 CBAM imports, choosing between actual verified installation data and Commission default values with the annual mark-up

Documented steps

Known gotchas

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