default value

What does default value mean?

Default values keep CBAM reporting operational when primary data is missing. They should create pressure to improve supplier evidence, because relying on defaults can increase uncertainty and financial exposure.

Source context

CBAM default values are part of the method for handling missing actual emissions data. They are not equivalent to verified supplier data and should not be treated as a comfortable long-term substitute for installation-level evidence; they are not a preferred evidence standard.

Official definitions by source

Definition status

Reviewed public draft page. Aligns with CBAM high-priority policy: source-bound method boundaries, concrete implementation records, and evidence/cost-focused commentary. Commission Implementing Regulation (EU) 2023/1773 adds transitional reporting and calculation context rather than a second formal definition.

Relationship to product carbon footprint

CBAM and product carbon footprint (under ESPR or the Battery Regulation) both quantify emissions associated with goods, but use different methodologies, scope boundaries, and regulatory purposes. CBAM focuses on production-process emissions at installation level; product carbon footprinting uses lifecycle thinking from raw material to end-of-life. A company may need to run both calculations for the same goods, and the numbers will differ — this is expected and not a compliance error.

Regulatory context

Commission Implementing Regulation (EU) 2023/1773 Article 4(3) allowed, until 31 July 2024, other methods for determining the emissions, including Commission default values or other Annex III default values, where the reporting declarant did not have all Article 3(2) and 3(3) information. The declarant still had to indicate and reference the methodology followed for establishing such values.

Practical application

Implementation records should capture fallback reason, default-value source, goods scope, CN code, country/origin context where relevant, application period, replacement path, responsible actor, and the open evidence request needed to replace the default with actual emissions.

Minespider commentary

Default value is a data-quality and cost-risk signal. The record should stay linked to the missing evidence request and replacement path so teams can see where conservative assumptions are creating financial exposure. Missing upstream evidence gets converted into a conservative compliance assumption until better supplier data replaces it.

Common confusions

• Treating a default value as equally strong evidence as actual emissions data.
• Assuming default values are commercially neutral when they can operate as conservative proxies.
• Confusing a CBAM default value with a voluntary estimate used in product carbon footprinting or corporate reporting.

Related regulations

• CBAM

External references

Related terms

• actual emissions
• embedded emissions
• CBAM certificate
• carbon price