Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025 on default values for embedded emissions under the carbon border adjustment mechanism
Source ID
SRC-076
Citation
Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025 on default values for embedded emissions under the carbon border adjustment mechanism
Retrieved and archived to research/ on 15 August 2026 under the D-046 Chapter 3 retrieval gate. research/ is not committed. HTTP 200 first request, 19.9 MB, the bulk being the sector annexes.
Claims
CH3 CBAM channel, load-bearing
Status
READ
Version history
The register keeps changing after the book is fixed in print. Each entry below was added to this row in the order shown.
THE REGULATION PRICES SYRIA BY NAME, IN A BINDING INSTRUMENT IN FORCE, AND THE ANNEXES WERE ON DISK UNREAD WHILE THE DRAFT SAID NO RATE COULD BE QUOTED. Read at the annex tables on 15 August 2026. SECTOR MARK-UPS, verbatim column headers: cement, aluminium, hydrogen and iron and steel each carry '10 % mark-up' for 2026, '20 % mark-up' for 2027 and '30 % mark-up' for 2028 and onwards. FERTILISERS CARRY '1 % mark-up' IN ALL THREE YEARS. SYRIA HAS ITS OWN COUNTRY TABLE. Grey clinker, CN 2523 10 00: direct 1,280, indirect 0,050, total 1,330, rising with the mark-up to 1,463 in 2026, 1,596 in 2027 and 1,729 in 2028 and onwards. Grey Portland cement, CN 2523 29 00: 1,280 direct, 0,100 indirect, 1,380 total, to 1,518, 1,656 and 1,794. Grey hydraulic cements: 1,220, 0,100, 1,320, to 1,452, 1,584 and 1,716. Syrian fertiliser lines carry the 1 per cent mark-up, so anhydrous ammonia moves only from 2,140 to 2,161. THE SYRIAN GRID EMISSION FACTOR IS PUBLISHED AT 0,550 in the indirect-emissions annex, which is sourced to IEA data under a Creative Commons licence the annex names. CONSEQUENCE FOR CHAPTER 3. The mark-up is not an abstraction and the chapter must stop describing it as one. It is a published multiplier on a published Syrian default, escalating from 10 to 30 per cent over three years for cement, and it applies to a country that currently exports almost nothing in scope. Recital 4's stated reason for it is the difficulty of verifying installation-specific data from third countries. UNIT NOTE: the default values are tonnes of CO2e per tonne of goods; the mark-up percentages are applied to the total. Article 2 records that the regulation applies from 1 January 2026 and is to be revised in 2027 at the latest. STATUS PARTIAL, and the audit is the reason: it refused this row at READ because the note itself says part of the document is unread. That is the project's own rule working, and the row was corrected rather than the note softened. THE CHAPTER'S STRONGEST LEGAL INSTANCE, AND IT IS A PRICE ON UNVERIFIABLE DATA WRITTEN INTO LAW. Recital 4 verbatim: 'To ensure the environmental integrity of the CBAM, default values for embedded emissions of goods other than electricity should include a MARK-UP to account for the deviations of an individual installation with emission levels higher than the relevant average emission intensity of the producer country. GIVEN THE DIFFICULTIES TO VERIFY THAT INSTALLATION-SPECIFIC DATA FROM THIRD COUNTRIES IS OF A SUFFICIENTLY HIGH QUALITY, a suitable proxy should be applied to estimate the variations of individual installations compared to the average. Therefore, the proposed mark-up is based on existing deviations of Union installations with respect to Union average altogether.' Recital 3 adds that default values 'need to be proportionate and necessary' and are set on 'a conservative approach that ensures that embedded emissions are not underestimated'. SUPERSEDED 15 August 2026: this row previously said the annexes were not yet read and that no number from the instrument could be printed. They are now read and the Syria table is set out above.