CBAM: waiting is no longer a neutral strategy

In many organisations, CBAM is still approached with a familiar mindset among compliance managers: waiting. Waiting for final rules, waiting for more clarity, waiting to see what 2026 will bring. During the transitional phase, this was understandable. Today, that stance is increasingly becoming a risk.

Over the past months, a growing amount of concrete CBAM information has become available. This includes default values, CBAM benchmarks and the methodology for the free allocation adjustment. As a result, CBAM is no longer an abstract compliance obligation, but a quantifiable cost and risk issue.

The challenge is clear: organisations that wait will ultimately depend on default values. These defaults are explicitly designed as a fallback mechanism, not as a favourable option. At the same time, obtaining verified actual values towards 2026 is proving to be complex. Emissions data is deeply embedded in supply chains, suppliers are often unprepared, and verification capacity is limited.

This makes the current moment critical. Preparation does not mean having all answers today, but it does mean making risks explicit, understanding what default values and benchmarks mean for cost exposure, and investing in the right software and expertise in time. The goal is not perfection tomorrow, but avoiding surprises later.

In the context of CBAM, waiting is no longer a safe option.

What has concretely emerged so far?

1. CBAM default values have been structured and published

Extensive tables of default values per CN code have been released (leaked), specified per country or under the category “other countries”. These default values are broken down into:

  • direct emissions

  • indirect emissions

  • total embedded emissions

From 2026 onwards, these defaults will be increased through progressive mark-ups (10%, 20% and 30% in subsequent years). This explicitly confirms that reliance on default values will become increasingly costly over time.

2. CBAM benchmarks (standard values) have been defined

CBAM benchmarks have been derived from EU ETS benchmarks and defined per product category. Where relevant, benchmarks are:

  • production-route specific (for example, steel based on BF/BOF, DRI/EAF or scrap/EAF routes)

  • differentiated between primary and secondary production (for example, aluminium)

For 2026, these benchmarks will be based on estimated ETS benchmark values, with a revision foreseen once the final ETS benchmarks are formally published.

3. The methodology for the free allocation adjustment is fixed

A defined calculation methodology now exists for:

  • simple goods

  • complex goods, including the treatment of precursors

The use of actual data is permitted, provided it is verified. Where verified actual data is not available, a mandatory fallback to default values and standard benchmarks applies.

4. A clear signal: data must be traceable and defensible

The framework introduces explicit presumptions:

  • goods are assumed to be produced in the year of import unless proven otherwise

  • the same presumption applies to precursors

In practice, this means that without proper documentation and verification, an organisation will automatically lose the discussion. Would you like to get more insight? Contact your Dubrink specialist to help you out.