Under CBAM the declaration is made by the EU importer; a non-EU exporter does not declare, it supplies data. If the importer cannot obtain actual emissions data from the producer, it must use the default value published by the EU.
The mark-up on the default value
Under Implementing Regulation (EU) 2025/2621, a mark-up of 10% for 2026, 20% for 2027 and 30% from 2028 applies to default values for steel, aluminium, cement and hydrogen. For fertilisers the rate is 1%.
A worked example
For CN 7208 51 20, origin Türkiye, 1,000 tonnes, with a certificate price of €75.28, the cost of the gap between the default value and actual data is roughly €18,278 in 2026, €36,556 in 2027 and €54,834 in 2028. This is an example; your product's figure is calculated from your own data. The certificate price follows the EU ETS and changes.
Who carries the difference?
The importer pays, but the cost usually comes back to the exporter in price negotiations, or the buyer switches supplier.
How Nechh Eco-Report handles it
In Eco-Report, entering the origin country, CN code, year and tonnage shows the official default value and the value including the mark-up side by side. Calculations with actual data follow the EU method, and every figure shows its source.