If your company imported CBAM-liable goods in 2026 and used default emission values for the calculation, it is worth revisiting your figures. The European Commission has corrected part of the previously published values. What is more, the change does not apply from August, but retroactively, from January 1, 2026.
What happened, and why does it matter to an importer?
On July 31, 2026, the Commission Implementing Regulation (EU) 2026/1740 was published, correcting two annexes of the earlier Implementing Regulation (EU) 2025/2621, which contains the CBAM default emission values.
At first glance this may look like a technical legislative amendment. The practical consequence, however, is simpler: if a company carried out a CBAM calculation this year based on default emission values, the data used in that calculation may have changed in the meantime.
The corrective regulation entered into force on August 3, 2026, but its provisions must be applied from January 1. The rules therefore treat the situation as if the correct data had already been in the annexes of the earlier regulation since the start of the year.
It is important to note, however, that no new CBAM system has come into effect. Nor has the underlying logic of the calculation fundamentally changed. The Commission corrected errors, gaps and technical inaccuracies in the earlier tables.
Why did the earlier data need to be corrected?
According to the professional summary from the CBAM Section of VJASZSZ (the Association of Customs, Excise and Tax Service Providers), several types of problems occurred in the previously published annexes.
There were specific numerical errors, and values for certain countries were missing even though the data was available. The correction therefore also fills in values linked to certain products for Albania, Gabon, Guatemala, Liberia, New Caledonia, Zambia and Zimbabwe, among others.
This is not necessarily just an administrative detail. If a separate value was not available for a given country, in certain cases the default value under the "Other countries and territories" category would have had to be used instead. A newly added country-specific figure can therefore also affect the outcome of a specific CBAM calculation.
The Commission also refined production routes, corrected certain CN and TARIC codes and country names, and clarified the units of measurement for the default values.
What is a default emission value?
This is worth pausing on for a moment from the perspective of corporate decision-makers.
The essence of CBAM is that the embedded carbon dioxide emissions linked to specific products imported into the European Union must be taken into account. Within the system, alongside actual emissions data, default values set out in legislation can in certain cases be used instead.
In other words, these are not simply informational figures in a spreadsheet. If a company calculates using them, they feed directly into the process of determining CBAM liability.
That is why the correction matters now.
The annual mark-up has not disappeared
One easily misunderstood element of the change is that the separate columns containing pre-calculated, mark-up-increased default values for 2026, 2027 and 2028 have disappeared from the corrected annexes.
This does not, however, mean that the annual mark-up has been abolished.
According to the VJASZSZ professional summary, in the earlier tables the mark-up values were already calculated from rounded base figures, which could cause discrepancies in certain cases. For this reason, the pre-calculated values were removed from the tables. The mark-up itself, and the rule for applying it, remains in place.
According to the summary, the final, mark-up-increased default values will in future need to be determined from the base value within the CBAM registry itself. The corrective regulation, however, does not fully detail the technical operation of this, so further official guidance may become important in this area.
What should companies check now?
If a business imported CBAM-liable goods in 2026, the publication of the regulation alone does not necessarily mean that an earlier calculation was definitely wrong.
The question is what data the company used.
It is worth checking the internal calculations, spreadsheets or IT solutions that are based on default emission values. Reconciling the country of origin, the CN or TARIC classification of the product, the applicable production route and, where relevant, the precursor value against the corrected annexes can be particularly important.
This is especially relevant for companies that carry out CBAM calculations in their own spreadsheets or with a previously built internal calculator. A system can, after all, still function flawlessly even though the data behind it is no longer current.
A spreadsheet is not the same as legislation
The Commission had previously also published a searchable, filterable spreadsheet database of the default emission values. This undoubtedly makes the work of companies and professionals easier.
There is, however, an important distinction: the spreadsheet is a supporting tool, not a legal source.
The legally authoritative values are contained in the annexes of the implementing regulation. In a corporate CBAM process, it is therefore not advisable to rely solely on a previously downloaded spreadsheet without checking its currency and consistency with the applicable legislation.
This is perhaps one of the most important practical lessons of the current correction.
CBAM is becoming less and less an "annual administrative task"
The current change also highlights that handling CBAM is becoming increasingly difficult to treat as a one-off administrative task.
A company needs to know the tariff classification, origin and background of the emissions data of its imported products, while also tracking regulatory changes and ensuring its internal systems always work with up-to-date data.
This is no longer solely the job of the customs administrator.
CBAM can be a financial, procurement, customs, compliance and even supplier-selection issue. If, for example, two products with the same purchase price differ significantly in their emissions profile or applicable default value, this can have business consequences in the longer term.
Summary – what should a company leader take away?
The current amendment does not rewrite the CBAM system, but businesses that used default emission values in 2026 should check their calculations so far.
The most important reason is retroactive application: the corrected data must be taken into account from January 1, 2026.
It is not necessarily the case that everything needs to be redone from scratch. It is, however, worth examining whether the country, product, CN/TARIC classification, production route and other relevant data used match the values currently in force in the annexes.
Executive takeaway
If your company brings CBAM-liable goods into the EU and calculates using default emission values, now is a good time to ask the responsible colleague or expert: have we already checked our 2026 calculations against the new, corrected values?
Frequently asked questions
Has a new CBAM system come into effect? No. The Commission corrected the earlier default emission values and related technical data.
From when must the new values be applied? From January 1, 2026, even though the corrective regulation entered into force on August 3, 2026.
Does every importer need to recalculate everything? Not necessarily. It is primarily those who applied default emission values who should check their earlier calculations.
Has the annual mark-up been abolished? No. The separate tabular columns containing the mark-up-increased values were removed from the annexes; application of the mark-up itself has not been abolished.
What is a precursor value? Under CBAM, a precursor is an intermediate material or raw material used in producing the final product, whose own embedded emissions must also be taken into account when determining the emissions of the final product.
