Trade flows
Import volumes and values come from Eurostat Comext, dataset DS-045409 (EU trade by CN8), annual data for 2024 and 2025, reporter EU27, flow import, by partner country. We query the 570 eight-digit CN codes that have a CBAM benchmark, i.e. all CBAM goods except electricity. Imports from EU member states, Iceland, Liechtenstein, Norway and Switzerland are excluded because CBAM does not apply to them. Quantities are net mass.
Default values and benchmarks
For every CN code and country we take the default embedded emissions from Annex I to Implementing Regulation (EU) 2025/2621 — the most specific row covering the code, including the mark-up for the year. Where the country is not listed or shows no value, the value for “other countries and territories” applies, as the regulation requires. The free allocation adjustment uses the default benchmark (column B) from Implementing Regulation (EU) 2025/2620 for the production route the default value table names for that country.
Exposure
exposure = tonnes × max(0, default value − benchmark × CBAM factor) × certificate price
We use 2025 volumes as a proxy for 2026 and later, the 2026 Q3 certificate price of €82.32 for every year, a CBAM factor of 97.5 % (2026), 51.5 % (2030) and 0 % (2034), and a cross-sectoral correction factor of 1.
What the estimate is — and is not
- It is an upper estimate: every tonne is priced at the default value. Importers using verified actual emissions from their suppliers will pay less, often much less.
- It ignores the 50-tonne threshold, below which small importers pay nothing, and any deduction for carbon prices paid abroad.
- It does not model price changes, trade diversion or the proposed extension to downstream products.
- Trade statistics are revised; figures are rebuilt when Eurostat updates the data.
Data last built: 2026-11-04. Corrections are welcome by email.