The CBAM Default Value Mark-Up Rises Until 2028 — Here Is the Schedule

By Ahmed Medhat · Published9 May 2026 · Updated 3 September 2026

The CBAM Default Value Mark-Up Rises Until 2028 — Here Is the Schedule

Annex IV point 4.1 of Regulation (EU) 2023/956 sets a default at the average emission intensity of each exporting country for the good — with a fallback, where reliable country data cannot be applied, to the average of the 10 exporting countries with the highest emission intensities. On top of that baseline sits a mark-up, and the mark-up increases over time.

If your EU buyer is using default values now, their cost exposure is growing automatically — even if EUA prices stay completely flat.

What EU default values are

Under Implementing Regulation (EU) 2026/1740, whose Annex I replaced the table in IR (EU) 2025/2621 with effect from 1 January 2026, EU default values are set for each good (CN code) and country of origin. From 2026 they are increased by a mark-up, which IR (EU) 2025/2621 explains as accounting for installations whose emissions are higher than the average emission intensity of the producer country (recital 4).

For example, the default value for rebar (CN 7214 20 00) in the table for ‘Other countries and territories’ is 3.996 tCO₂e/t before the mark-up (Implementing Regulation (EU) 2026/1740, Annex I).

The mark-up schedule

The mark-up is a fixed percentage set in Implementing Regulation (EU) 2026/1740, Annex I, and it rises over time:

• 2026: +10% (fertilisers +1%). Applies now: the default value is increased by 10%.
• 2027: +20% (fertilisers +1%). Published, not a projection.
• 2028 onwards: +30% (fertilisers +1%). Applies from 2028 onwards: the default value is increased by 30%.

There is no gap in that schedule to go and look up. Implementing Regulation (EU) 2026/1740, Annex I, introductory part sets all three years in one sentence: "For goods in the cement, iron and steel, aluminium and hydrogen sectors, the mark-up shall be 10 % for the year 2026, 20 % for the year 2027 and 30 % for the year 2028 and onwards." The following sentence puts fertilisers at 1 % for 2026 and onwards.

For a buyer who uses EU default values, the baseline is your exporting country's average rather than your own performance, and from 2028 the 30% mark-up is added to it.

A worked example for rebar

Inputs: the default value for rebar (CN 7214 20 00) in the table for ‘Other countries and territories’, 3.996 tCO₂e/t, and the mark-ups in Implementing Regulation (EU) 2026/1740, Annex I.

• 2026 (+10%): 4.396 tCO₂e/t
• 2027 (+20%): 4.795 tCO₂e/t
• 2028 onwards (+30%): 5.195 tCO₂e/t

A verified actual value replaces the default and carries no mark-up.

The CBAM factor

The mark-up is not the only figure that changes each year. The CBAM factor, which scales the free allocation adjustment deducted from embedded emissions, is 97.5% in 2026, 95% in 2027 and 90% in 2028, falls each year after that, and no longer applies from 2034 (Directive 2003/87/EC, Article 10a(1a)).

What to tell your EU buyer

While your buyer uses EU default values, the mark-up on them rises each year to 2028 and the CBAM factor falls each year to 2034. Your verified actual value replaces the default.

Use the DeCarbonPro Gap Analysis tool to see the default value for your goods and its 2026, 2027 and 2028 mark-ups.