Commission quietly corrects CBAM default values: IR 2026/1740 applies retroactively from January 1, 2026

The European Commission has corrected the CBAM default values that declarants have been using since the start of the definitive phase. Commission Implementing Regulation (EU) 2026/1740, adopted on July 20, 2026 and published in the Official Journal on July 31, 2026, corrects Implementing Regulation (EU) 2025/2621 as regards Annexes I and IV, the annexes that carry the default values for the definitive period. The correction applies retrospectively from January 1, 2026.

The retroactive effect is the part that matters. Every importer who calculated 2026 embedded emissions with the original figures must now switch to the amended annexes, because the corrected values replace the erroneous ones for the full calendar year. The Commission published no press release and no corrected Excel tables alongside the regulation, according to trade press coverage, and the first warning most companies saw came not from Brussels but from Finnish Customs on August 3.

What IR 2026/1740 corrects

Implementing Regulation (EU) 2026/1740 corrects technical errors in chart figures and commodity codes in Annexes I and IV of Implementing Regulation (EU) 2025/2621, the regulation that sets the default values for the definitive period. The underlying default values were adopted on December 16, 2025 and published in the Official Journal on December 31, 2025, one day before they began to apply. Seven months later, the Commission has now replaced the two affected annexes in full.

The errors sat in the two data layers declarants touch most. Erroneous chart figures distort the emission values a declarant reads off the tables, and erroneous commodity codes can point a product to the wrong default value entirely. Goods are matched to default values through their CN codes, so a wrong code in the annex has the same practical effect as a misclassification by the importer, a problem Spanish steelmakers quantified this week at roughly EUR 300 per tonne of CBAM liability for misclassified pipes. Importers of goods under Chapters 72 and 73 can cross-check affected products against the CBAM steel CN codes list.

The table below summarizes the timeline of the correction.

Why the retroactive application matters for 2026 declarations

Because IR 2026/1740 applies retrospectively from January 1, 2026, any declarant who used the erroneous default values for imports made this year must recalculate with the amended Annexes I and IV. Default values are the mandatory fallback for importers who hold no verified actual emissions data from their suppliers, and those importers must use them for the 2026 declarations due September 30, 2027. A calculation performed in February with the original annex is not grandfathered; the corrected value is the legally applicable one for the entire year.

The financial stakes depend on which products moved. Default values for the definitive period are set per country and per product and carry a punitive mark-up above the country-specific average, 10 percent in 2026 for most sectors and rising to 30 percent from 2028, as explained in the CBAM default values guide. A corrected chart figure shifts the certificate liability in direct proportion, since the CBAM calculation multiplies emissions per tonne by import volume, the 2.5 percent CBAM factor for 2026, and the quarterly certificate price. Importers budgeting certificate purchases ahead of the February 1, 2027 sales opening should re-run those numbers before committing to a volume, especially with the Q3 certificate price tracking above Q2.

A correction without a press release or corrected Excel tables

Trade press, not the Commission, brought the correction to general attention. The Stainless Espresso market briefing, republished by steelnews.biz on August 4, reported that "there was no press release and no corrected Excel tables on the relevant DG TAXUD CBAM pages," and that the change surfaced only as a small note inside an expandable box on the TAXUD website. Companies that work from the downloadable tables rather than the Official Journal text would have no reason to know their reference data had changed.

The same coverage argues the fix is narrower than the problem. According to Stainless Espresso, "so far, the Commission has exclusively and explicitly corrected only its technical errors," while logical inconsistencies and unrealistic figures in the default values remain uncorrected, with the next substantive review due by December 2027 at the latest. The briefing's conclusion is blunt: "EU companies must therefore pay for the European Commission's errors, whether those errors are politically intended or not." That criticism is the analysts' view, but the seven-month gap between publication and correction is a matter of record, and it lands amid broader complaints about the mechanism's administration, in the same week that 65 organizations filed submissions asking Brussels to fix the certificate rules.

Finland is the first national authority to warn importers

Finnish Customs (Tulli) published a notice on August 3, 2026 telling companies that declarants using default values must ensure they apply the new amended annexes of IR 2026/1740. Tulli is the first national competent authority to translate the Official Journal publication into an operational instruction for importers, and its notice confirms the two facts declarants need: the corrected annexes apply retroactively from January 1, 2026, and the errors concerned chart figures and commodity codes.

Tulli also drew the boundary of the change: "calculations regarding CBAM certificates will remain the same." The method is untouched. What changes is the input data, the default emission values themselves, not how embedded emissions convert into certificates. Whether or not other national authorities follow with equivalent notices, importers registered outside Finland should not wait for their own authority before acting, because the Official Journal text binds them either way.

What declarants should do now

Every declarant relying on default values should re-run the 2026 emissions figures against the amended Annexes I and IV before certificate sales open on February 1, 2027. Five steps cover the correction:

• Identify every 2026 import line where default values, not verified actual data, supplied the emissions figure
• Pull the corrected Annexes I and IV from IR 2026/1740 in the Official Journal, not from previously downloaded tables
• Recalculate the affected embedded emissions and compare the result against the original figures
• Adjust the certificate budget for the September 30, 2027 CBAM declaration
• Document both calculations, since the declaration file should show the corrected values were applied

What the correction means for exporters

The correction also resets the benchmark for suppliers. Non-EU producers win or lose customers on the gap between their verified actual emissions and the default value their EU buyer would otherwise pay, a dynamic covered in why default values hurt exporters. A corrected default value changes that gap, in either direction, so exporters who priced their verification effort against the December figures should re-check the comparison. The verification route itself is opening on schedule: verifier registry registration begins September 1, giving suppliers a concrete path to replace default values with site-specific data for future reporting periods.

The episode is a reminder of how the definitive phase actually runs. The rules sit in the Official Journal, the working tools lag behind them, and national authorities fill the communication gap. Declarants who treat the EUR-Lex text of IR 2026/1740 as the single source of truth, and who re-check their default-value calculations now rather than in the summer of 2027, lose an afternoon. Those who file from stale tables risk declaring against annexes that ceased to be law retroactively on January 1, 2026.