On 30 July 2026, the European Commission published Commission Implementing Regulation (EU) 2026/1740, replacing both Annex I and Annex IV of the CBAM default values regulation (EU) 2025/2621. While at first glance the update may look like a technical correction, the practical implications for importers and CBAM reporting teams are significant.
Our review of the legacy December 2025 dataset against the new replacement annexes identified several changes, affecting country-specific default values, benchmark logic, product code mappings, fallback calculations and precursor values. For companies relying on default values to estimate CBAM exposure, this means that historical 2026 calculations may no longer be accurate.
The regulation introduces several categories of corrections:
1.
The most important point is that the previous Annex I and Annex IV tables are no longer valid. The replacement annexes become applicable retroactively from 1 January 2026, meaning importers should revisit any calculations performed using the earlier dataset.
2.
The Commission corrected missing and inaccurate production-route indicators for several products. In practice, this means that benchmark matching must now respect the production route where one is defined, while avoiding assumptions where no route distinction exists.
3.
Several CN and TARIC code mappings were updated. Examples include:
For organizations maintaining internal CBAM master data, code mapping tables should be reviewed and refreshed.
4.
A number of country-specific default values contained errors or omissions in the previous release.
The most notable correction concerns Taiwan steel products (CN codes 7218-7223). Several Taiwan-specific values were removed because they had been published incorrectly. As a result, imports now fall back to the corresponding “Other Countries and Territories” values, which are generally lower.
Additional country-specific values that were previously omitted have also been reinstated, while some records were intentionally removed, changing which fallback value applies.
5.
The Commission removed the pre-calculated mark-up columns that had been included for 2026, 2027 and 2028.
Instead, companies should calculate adjusted values directly from total emissions:
This reduces rounding inconsistencies and aligns calculations with the legal methodology.
The biggest impacts identified
32 changes are linked to Taiwan, including 28 steel product defaults. Once the erroneous country values were removed, the calculations automatically shifted to fallback values.
In our test cases, the resulting default emissions values were typically 40-60% lower, creating substantial reductions in illustrative CBAM costs.
Several country-specific values that were omitted in the previous version have now been reinstated.
Examples include:
Because the restored values are lower than the generic fallback used previously, the resulting CBAM exposure decreases significantly.
For example:
Not every correction results in lower emissions.
For Angola iron ore (CN 26011200), the country-specific value was removed, meaning the calculation now uses the fallback value. Because the fallback is higher, default emissions increase.
Four Tunisia-related aluminium code corrections were introduced.
Two obsolete records were removed, while two codes received corrected values:
The direction of impact therefore depends entirely on the imported product code.
Two Annex IV aluminium precursor values were corrected.
Importantly, these values apply only when the country of production of the precursor cannot be identified. They should not be treated as a general fallback mechanism for standard imports where country information is available.
For CBAM reporting teams, the key messages are straightforward:
The publication of Regulation (EU) 2026/1740 is more than a housekeeping exercise. Although targeted corrections were identified, some of them materially change applicable default emissions values and therefore affect estimated CBAM costs.
The largest impact comes from the correction of Taiwan steel defaults, but the regulation also restores missing country-specific values, updates fallback outcomes, corrects product codes and resets certain precursor calculations. Together, these changes reinforce the need for organizations to revisit their 2026 CBAM calculations and ensure that they are working from the latest legally applicable reference data.
Source: Commission Implementing Regulation (EU) 2026/1740, available on EUR-Lex: View regulation.