Introduction
We usually argue that verified actual data beats default values. That is true for most low-carbon producers — but not for everyone, and not in every year. An honest assessment sometimes points the other way. This article sets out when CBAM verification is, and is not, worth the effort.
The Choice
An EU importer can use the EU default value for your goods (no verification needed, but the value is conservative and carries a rising mark-up), or your verified actual data (which can be much lower, but requires accredited verification). The right choice depends on four things: your actual emissions, your volume, the year, and the cost of verifying.
When the Default Can Be the Better Choice
| Situation | Why default may win |
|---|---|
| Very low EU volume | The total exposure is small; verification cost may exceed the saving |
| 2026 specifically | Only 2.5% of emissions are charged, so the saving from actual data is small this year |
| Actual emissions near or above the default | Verification would not lower the bill — or could raise it |
| Short remaining supply relationship | The multi-year payoff that justifies verification is not there |
When Verification Clearly Wins
Verification pays off when your actual emissions are well below the default (typical for scrap-based electric-arc-furnace steel), your EU volume is meaningful, and you are looking across the whole 2026–2034 ramp, where the charged share climbs to 100%. In that case the avoided cost compounds and easily covers verification.
A Simple Decision Rule
Compare the saving with the cost: (default − actual) × certificate price × CBAM factor × annual volume, summed over the years you expect to supply, against the cost of verification. If the saving exceeds the cost, verify; if not, the default is the rational choice this year. Run your own numbers with the cost guide and calculator — and remember that verifier capacity is tight, so deciding early matters either way (see the verifier crunch).
How EPD Polska / Multicert Can Help
We run that comparison with you honestly — including telling you when verification is not worth it yet. Contact us for an exposure screening.
FAQ
Is it ever rational not to verify?
Yes — for very low volumes, for 2026 alone, or when your actual emissions are not below the default. The default is a legitimate choice, just often an expensive one over time.
Does using the default mean non-compliance?
No. Using default values is fully compliant; it is simply usually more expensive for clean-route producers across the ramp.