EU CBAM Moves to Actual Data Verification: Penalties for Default Value Reliance
3 Min Read • Strategic Briefing
As the EU CBAM transitional period concludes, a critical legal shift is occurring: Article 4 regarding the calculation of embedded emissions is being fully implemented. Many EU sourcing managers have relied on "default values" during the initial phase.
However, reliance on these defaults will soon cease to be a valid compliance method when actual data can be reasonably obtained.
EU Customs authorities are now demanding actual, third-party verified data from Chinese manufacturing sites. Sourcing teams relying on defaults will face not only steep CBAM certificate surcharges (calculated at the EUA price) but also audits for potential non-compliance under EU antitrust and anti-greenwashing directives.
"It is imperative that sourcing departments pivot immediately to demanding accurate, uncalculated carbon data directly from their manufacturers."