Is the Article 7(3) markup a flat 10% every year?

No — this is a common misconception. The markup escalates: 10% in 2026, 20% in 2027, and 30% from 2028 onward. Fertilisers are a special case with a flat 1% markup in every year. The escalating schedule is designed to push importers toward verified actual data over time, not stay flat indefinitely.

Why does the markup increase over time?

It's a deliberate regulatory design choice (Art. 7(3), EU Reg 2023/956) — defaults are meant as a bridge while supply chains build up verified emissions reporting capability, not a permanent alternative. The rising cost is the incentive to switch.

Can I mix default and actual values across different suppliers?

Yes. CBAM obligations are calculated per import per CN code — you can use actual verified data for one supplier and a default value for another in the same reporting period.

EU IR 2025/2621 · corrected by IR 2026/1740

Default SEE values and the Article 7(3) markup

When you don't have verified actual emissions data from your supplier, you can use a Commission-published default value instead — at a cost that gets steeper every year.

By Sridhar Mothe · Founder, CarbonAtlas

Last verified: 02 September 2026

The default value mechanism

Every CBAM good has a Commission-published default Specific Embedded Emissions (SEE) value — a conservative, sector-and-route-specific benchmark you can use instead of actual supplier data. These figures come from EU Implementing Regulation 2025/2621 (published 16 December 2025), with a subsequent correction issued in IR 2026/1740.

Using the current, corrected figure matters — a stale default value produces a wrong obligation calculation even if every other input is correct.

The Article 7(3) markup — the real, escalating schedule

Article 7(3) of EU Regulation 2023/956 applies a markup on top of the raw default value whenever it's used instead of actual data. This is where a lot of published guidance (including some of our own earlier internal notes, corrected this session) gets it wrong by citing a flat 10% for every year. The real schedule escalates:

Year	Markup	Multiplier
2026	10%	×1.10
2027	20%	×1.20
2028 onward	30%	×1.30
Fertilisers (all years)	1% flat	×1.01

The gap between the 2026 rate and the 2028+ rate is substantial — on a large default-value import, a 20-percentage-point swing in the markup is a real difference in certificate cost, not a rounding error.

Why this matters for your declaration

If your CBAM declaration software (ours or anyone else's) hardcodes a flat markup rate, every declaration filed from 2027 onward using default values will understate the true obligation.

We found and fixed exactly this class of bug in our own downloadable Excel calculator during this review — worth checking any tool you use, including a spreadsheet built in-house, against the real schedule above.

Frequently asked questions

A Commission-published Specific Embedded Emissions (SEE) figure for a given CN code and production route, used when the actual emissions data from the operator/supplier isn't available or verified. Published under EU IR 2025/2621 (16 December 2025), with a correction issued in IR 2026/1740.

See how CarbonAtlas applies this automatically

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