CBAM Default Values and Verifier Gap: Taiwan Exporters

Three developments around the EU Carbon Border Adjustment Mechanism (CBAM) came in mid-October. Carbon Pulse's CP Daily of 18 October reported that a global fertiliser producer told the Carbon Forward Expo in London that EU importers are already sourcing CBAM goods from countries with lower country default values. HM Revenue & Customs (HMRC) published the UK's CBAM default values on 16 October. In the same week, several industry representatives raised the lack of accredited verifiers at a dialogue with the European Commission.

All three come back to one point: when an exporter cannot provide verified actual emissions data, EU and UK importers must calculate the carbon cost with default values.

Key terms: default values, actual emissions and verification

• Embedded emissions: the greenhouse gases emitted to make one tonne of a product, in tonnes of carbon dioxide equivalent (CO₂e).
• Actual emissions: values that an installation monitors and calculates under the CBAM method and that an accredited verifier has verified.
• Default values: values set in advance by the authorities and used when there are no verified actual emissions; they are usually high.
• Mark-up: an extra percentage the EU adds to default values, so that relying on them costs more each year.

1. The EU sets default values by country, and importers compare

On 16 December 2025 the European Commission adopted Implementing Regulation (EU) 2025/2621, which sets the CBAM default values that apply from 2026. Values are listed by product code (CN code) and country of origin; where a country has no value of its own, the value for "other countries and territories" applies.

Under the correcting Implementing Regulation (EU) 2026/1740, a mark-up is added to total emissions when default values are used: 10% in 2026, 20% in 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, and a flat 1% for fertilisers. The correction was published in the Official Journal on 31 July and applies retroactively from 1 January 2026. Taiwan's economic division at its mission to the EU explained that Taiwan's country-specific values for CN 7218 to 7223 (stainless steel) were transcription errors and have been deleted, so the "other countries and territories" values now apply, and that the mark-up is now calculated automatically in the CBAM Registry.

Default values differ widely between countries. A cost calculation published in March by the European Fastener Distributor Association (EFDA), using 2026 default values including the 10% mark-up and an assumed certificate price of €80, gives the following CBAM costs per tonne of imported fasteners:

• Taiwan (CN 7318 14 99): default value 2.978 t CO₂e, about €131.85.
• Vietnam (CN 7318 15 68): 3.025 t CO₂e, about €135.61.
• India (CN 7318 15 62): 6.292 t CO₂e, about €396.97.
• China (CN 7318 15 75): 7.013 t CO₂e, about €471.03.

The examples use different sub-codes, so they show orders of magnitude only. The same calculation shows that Vietnamese fasteners using actual emissions would cost about €51.84 per tonne, far below the €135.61 with default values.

Carbon Pulse also reported that Ukrainian exporters are already losing EU business as buyers demand financial guarantees for future CBAM payments. CBAM certificates for 2026 imports go on sale only in February 2027, but importers are already building the carbon cost into purchasing decisions.

2. The UK publishes its CBAM default values

The UK CBAM starts on 1 January 2027 and covers five sectors: aluminium, cement, fertilisers, hydrogen, and iron and steel. On 16 October HMRC published default values for all five, along with guidance on monitoring, verification, record keeping and rates.

The UK approach differs from the EU's in two ways:

• UK default values do not vary by country of origin; each CBAM good has one value, for example 1.375 t CO₂e per tonne of Portland cement and 3.332 t CO₂e per tonne of coach screws (CN 7318 11 00).
• A CBAM return that uses default values cannot later be amended with actual emissions data.

Importers must use the default values if they are not reporting verified actual emissions. UK CBAM rates reflect the carbon price in the UK Emissions Trading Scheme (UK ETS) and, from 1 January 2027, will be published before the start of each quarter.

3. Too few accredited verifiers

EU rules require actual emissions to be verified by independent verifiers accredited by a national accreditation body (NAB) of an EU member state. Verifiers based outside the EU can apply to any NAB that offers the service.

The Commission's state of play of 7 October shows:

• 24 NABs have agreed to provide CBAM accreditation, and 18 are accepting applications.
• Only seven accept applications from third-country verifiers: COFRAC (France), ESYD (Greece), Accredia (Italy), RvA (Netherlands), PCA (Poland), SNAS (Slovakia) and Swedac (Sweden).
• The Commission expected the first verifiers to be accredited around September 2026 and will publish the list on its website; as of 19 October no list had been published.

The EU timeline: verifiers can register in the CBAM Registry and start verification from September 2026, issue the first verification reports from January 2027, importers can buy certificates from February 2027, and declarations for 2026 are completed in September 2027.

In Taiwan, the Ministry of Environment met the Ministry of Economic Affairs and 20 domestic greenhouse gas verification bodies on 13 February. The ministry said the companies most affected are about 2,600 makers of iron and steel products, and that according to EU data published at the end of 2025, Taiwan is the 13th-largest source of CBAM imports, at about 3.74 million tonnes. The verification bodies cited frequent changes to EU rules, a lack of officially recognised training material, and unclear accreditation procedures and criteria.

The Climate Change Administration's summary of the EU verification rules also notes that in the first year subject to verification, the verifier must visit the site in person, that errors above 5% count as material misstatements, and that a company may not hire a consultant who helped write its monitoring plan or emissions report to carry out the verification.

Possible directions for Taiwan

• Compare default values with actual emissions product by product: exporters can confirm CN codes with their EU and UK importers, look up default values on the Ministry of Economic Affairs' Green Trade portal or in the EU regulations, and estimate how much actual emissions data would save. Stainless steel values (CN 7218–7223) have been corrected, so quotes or contracts based on the old figures should be rechecked.
• Book verification early: the first year requires a site visit, only seven NABs accept third-country applicants, and verification reports for 2026 must be ready before the September 2027 declaration. Exporters can check that a verifier's accreditation scope covers their product group and avoid consultants who helped build their monitoring systems.
• Get precursor emissions data from suppliers: for fasteners and wire, most emissions come from purchased wire rod or billets, so verified data from suppliers is needed to declare actual values.
• Prepare separately for the UK: UK default values are the same for every country and cannot be replaced once used, so steel and aluminium exporters to the UK need actual emissions data before the first returns in 2027. For progress on linking the UK and EU carbon markets and mutual CBAM exemption, see UK–EU ETS linking.
• Consider the carbon fee together with CBAM: Taiwan's carbon fee can be deducted under the EU CBAM if actual payment is proven; see Taiwan's carbon fee and ETS dual track.

Sources

• Carbon Pulse, CP Daily Newsletter (18 October 2026, paywalled; only the free summaries are cited), including "EU importers opting to source from countries with lower CBAM country default values", "UK publishes default emission values for CBAM imports", "Industries raise lack of CBAM verifiers at meeting with EU climate chief" and "Ukrainian exporters lose EU business as CBAM costs bite early": https://carbon-pulse.com/561477/
• HM Revenue & Customs, Check the default values for the Carbon Border Adjustment Mechanism (CBAM) (16 October 2026): https://www.gov.uk/government/publications/check-the-default-values-for-the-carbon-border-adjustment-mechanism-cbam
• HM Revenue & Customs, Rates for the Carbon Border Adjustment Mechanism (CBAM) (16 October 2026): https://www.gov.uk/guidance/rates-for-the-carbon-border-adjustment-mechanism-cbam
• European Commission, Verification of CBAM emissions (including the State-of-play CBAM accreditation of 7 October 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en
• European Commission, The European Commission publishes guidance for CBAM verifiers and accreditation bodies (24 August 2026): https://taxation-customs.ec.europa.eu/news/european-commission-publishes-guidance-cbam-verifiers-and-accreditation-bodies-2026-08-24_en
• Taiwan Mission to the EU, Economic Division, via the MOEA international trade portal, on the correction of Annexes I and IV of the CBAM default values regulation (31 July 2026): https://wto.cnfi.org.tw/news_detail.php?c_id=66556
• European Fastener Distributor Association (EFDA), CBAM cost calculation in 2026 (March 2026): https://www.nfda-fastener.org/assets/docs/EFDA-CBAMcostscalculationin2026.pdf
• Ministry of Environment (Taiwan), press release on CBAM preparation with verification bodies (13 February 2026): https://enews.moenv.gov.tw/moenv-news/zh-tw/News/1894
• Climate Change Administration (Taiwan), EU CBAM accreditation and verification rules: https://www.cca.gov.tw/affairs/cbam/regulations/cert/25858.html
• Ministry of Economic Affairs Green Trade portal, CBAM default value lookup: https://www.greentrade.org.tw/CBAM/default
• Climate Change Administration (Taiwan), EU CBAM carbon fee deduction rules (26 March 2026): https://www.cca.gov.tw/affairs/cbam/regulations/deduction/25856.html