What CBAM default values cost your EU buyer, worked through for Indian steel

CBAM is paid by the EU importer, the authorised CBAM declarant. For an Indian exporter that can sound like someone else's problem. It isn't. The importer's bill depends on emissions data only the exporter can provide, and buyers are already comparing suppliers on it. This guide works through the numbers for one common product using the official tables.

How the bill is calculated

For each tonne of a CBAM good, the importer surrenders certificates equal to its embedded emissions, less an adjustment for the free EU ETS allowances that EU producers of the same product still receive. In simplified form:

Each certificate is priced from EU ETS auctions. For 2026 imports the Commission publishes a quarterly price: €75.36 for Q1 and €75.28 for Q2 2026. From 2027 the price is published weekly.

Default values and the mark-up

When the exporter supplies no actual data, embedded emissions come from country- and product-specific default values. Those were set by Implementing Regulation (EU) 2025/2621 and corrected by Implementing Regulation (EU) 2026/1740, published on 31 July 2026 and applying retroactively from 1 January 2026. Defaults carry a mark-up designed to make them more expensive than real data: 10% in 2026, 20% in 2027 and 30% from 2028 (fertilisers stay at 1%).

Worked example: Indian hot-rolled flat steel

Take CN heading 7208, flat-rolled hot-rolled steel. The corrected default for India is 4.28 tCO2e per tonne of direct emissions (indirect emissions are not in scope for steel), with production route (C). The benchmark for that route is 1.37 tCO2e per tonne. Holding the certificate price at the Q2 2026 level of €75.28, and the correction factor at 1:

Two things push the cost up at once: the mark-up grows, and the free-allocation deduction shrinks as the CBAM factor falls. With carbon prices unchanged, the same shipment costs the importer about 28% more in 2028 than in 2026, and about 44% more by 2030.

What real data changes

When the importer declares actual embedded emissions from your installation, the mark-up disappears and the country default is replaced by your own intensity. The adjustment for actual data uses a different benchmark column and includes each precursor's own adjustment, so the exact saving depends on your process and your supply chain. It has to be calculated per installation; you can't read it off a table.

What is certain is the direction. An efficient mill that can evidence its emissions is compared against a marked-up national average, and that comparison is how an EU buyer chooses between two otherwise identical offers.

A checklist for exporters

• Confirm the CN codes you ship and whether your EU customers exceed the 50-tonne annual de minimis threshold. Most regular industrial buyers will.
• Define each installation and its production process, and identify its production route.
• Collect fuel, electricity and process data for the reporting period, with the bills and meter records behind them.
• List your precursors and their suppliers, and request their embedded emissions, since precursors count toward yours.
• Keep the calculation and its evidence together so an accredited verifier can re-perform it.
• Send your EU buyer the communication file well before their 30 September 2027 declaration deadline.

ZeroCarbon's CBAM module runs this calculation from the official default-value and benchmark tables, compares actual data against the marked-up default for each CN code, and prepares the exporter-to-importer communication file. We're onboarding Indian steel and aluminium exporters as design partners.