These measures lay down the rules for the practical application of the CBAM regulation as of January 2026.
It’s important to note that, as of December 10, the CBAM steel benchmark values and default values have not yet been published in the EU Official Journal.
Market sources circulated draft annexes and technical implementing acts earlier this week, outlining these benchmarks and default values.
The European Commission CBAM Committee has voted today to accept the final revisions to these documents, sources said.
Sources familiar with the matter told Fastmarkets that these benchmarks and default values are considered technically final and will become legally binding as of January 1, 2026.
“Vote was positive on benchmarks and defaults. So all data confirmed,” a source familiar with the matter said.
The Commission is expected to publish the final, legally binding benchmarks before December 25, Fastmarkets heard.
Benchmarks
The Commission used the same approach as in leaked drafts seen by Fastmarkets in November.
Benchmarks for different steel products vary depending on production route — blast furnace-basic oxygen furnace (BF/BOF), direct reduced iron/electric-arc furnace (DRI/EAF), and scrap-based EAF. Importantly, benchmarks also vary depending on whether actual emissions data or default emissions values are used.
Therefore, for each product, the benchmark is expressed in tonnes of CO2 equivalent (tCO2e) per tonne of steel produced, with separate values for different production routes. For example, flat-rolled products and semi-finished products have distinct benchmarks for BF/BOF, DRI/EAF and scrap-EAF routes, reflecting the differing carbon footprint of each process. Where actual emissions data is available and verified, it can be used to determine the specific embedded emissions for a given import. If not, default values — often set at the higher end of the range — apply.
It’s important to note that the finalized benchmarks are lower than those seen by Fastmarkets in November. For example, in the November leaked drafts, steel hot-rolled coil carried benchmark values of 1.530 tCO2e per tonne of steel for BF/BOF production, 1.033 tCO2e per tonne of steel for DRI/EAF and 0.288 tCO2e per tonne of steel for scrap-based EAF routes. These have been revised to 1.370 tCO2e per tonne of steel for BF/BOF, 0.481 tCO2e per tonne of steel for DRI/EAF, and 0.072tCO2e per tonne of steel for scrap-based EAF in the finalized document.
Default values by country
The document seen by Fastmarkets also established default emissions values that importers must use under CBAM when actual emissions data is not reported and/or cannot be verified. It applies to all CBAM goods except electricity and provides a harmonized, country-specific and product-specific framework to calculate embedded emissions for customs declarations.
The document also clarifies how default values must be selected: if a country is not listed, importers must use the “other countries and territories” table; if a country is listed but no value is provided for a particular CN code, the “other countries” figure still applies, Fastmarkets understands.
This is supposed to ensure that no imported CBAM good enters the EU without an emissions reference point.
For each CN code, the document provides default values for:
- Direct emissions,
- Indirect emissions (electricity-related),
- Total emissions
It also includes future annual mark-ups for 2026, 2027 and 2028-onward. Notably, default values generally rise annually through 10% (2026), 20% (2027) and 30% (2028-onward). These mark-ups reflect CBAM’s phase-in and the declining availability of free allowances in the EU Emission Trading System (ETS).
Using the information from the documents’ drafts, Fastmarkets has calculated CBAM costs for a range of steel products.
Calculations were made without the 10% markup.
Market reaction
Sources noted that, for some origins, default values were set at higher levels compared with previous leaked drafts, pushing costs of these products significantly upward.
For China, for example, December review default values for steel slab were set at 3.167 tCO2e per tonne produced, compared with 1.75 tCO2e per tonne outlined in the previous documents. That will push CBAM costs for Chinese slab to around €144 ($168) per tonne — “quite unmanageable,” according to market sources.
For Brazil, defaults were only slightly higher, which makes it a “manageable” supplier under the CBAM regulation.
For Indonesia and India, very high defaults were confirmed in the documents.
“Recently big cargoes of Indian and Indonesian hot-rolled coil were booked to Europe. I wonder how those can be custom-cleared, considering the CBAM update,” a buyer in Italy said.
Notably, a deal for Indonesian HRC was reported at €490 per tonne CFR earlier in December.
A transaction for a large tonnage of India-origin HRC was heard around $510 per tonne CFR recently, for first-quarter 2026 arrival.
“The price was extremely low, with CBAM risks on the buyer side, but with [CBAM] costs for Indian HRC over €200 per tonne — the final price doesn’t look so sexy anymore,” a second buyer said.
Another source noted the “punitive nature” of default values markups.
“If you have default value of over 3 [tCO2e per tonne of steel], it’s quite impossible to move to under 2 [tCO2e per tonne of steel] within a year. These [high default values and mark-ups] are supposed to stimulate countries to report and verify actual emissions,” a buyer in the Benelux area said.
