The cement default value trap: the gap between default and actual emissions costs importers triple

Updated October 12, 2026: the default values are now given as the Annex I values (Ukraine 1.380, "Other countries" clinker 1.410) with the 2026 mark-up shown as a separate step, and the free allocation paragraph now separates the default-value and actual-value benchmark bases.

The most expensive number in a cement importer's 2026 CBAM file is the one nobody measured. Calculations reported by Argus put the CBAM cost of importing 10,000 tonnes of Ukrainian grey Portland cement at about €663,000 on the default value versus about €195,000 on verified actual emissions, a factor of 3.4 at a certificate price of €75. With verifier registration in the CBAM Registry open since September 1, the route out of that gap now formally exists, but no accredited verifier does yet. That combination, a six-figure spread per shipment and a verification market still at zero, is the trap cement importers need to plan around before the first declaration falls due on September 30, 2027.

What the Argus arithmetic shows

Importing 10,000 tonnes of Ukrainian grey Portland cement in 2026 costs about €663,000 in CBAM on a default of 1.51 tCO₂e per tonne, versus about €195,000 on actual emissions of 0.91 tCO₂e per tonne, at a CBAM certificate price of €75, according to calculations reported by Argus. The Annex I default for Ukraine, CN 2523 29 00, is 1.380 tCO₂e per tonne, or 1.518 with the 10 percent mark-up for 2026, close to the 1.51 in the Argus calculation. The two scenarios describe the same physical shipment. The €468,000 difference buys nothing except the absence of a verified emissions figure.

The warning attached to those numbers is about expectations. Hendrik Schuldt, managing director of the carbon compliance consultancy Carboneer, told the Argus Mediterranean Solid Fuels Forum in May 2026 that a "false sense of security" exists among companies assuming they will be able to use verified emissions values, when the working assumption for now is that companies fall back on defaults.

The table below sets the two documented cement cases side by side.

Both figures predate the July correction round, in which the Commission corrected the default values Excel and lowered all 46 genuine numerical replacements through Implementing Regulation (EU) 2026/1740. Lower defaults narrow the gap at the margin. They do not close a spread of this size, because the spread comes from the structure of the CBAM default values themselves: a country-average or bucket-average figure, plus a deliberate mark-up of 10 percent in 2026, rising to 20 percent in 2027 and 30 percent from 2028.

Turkey sits in the "other countries" bucket

Turkish clinker carries a default value of 1.410 tCO₂e per tonne, 1.551 with the 2026 mark-up, against a declared sector actual of 0.88 tCO₂ per tonne, because the Türkiye table in Annex I shows a dash for grey clinker and the "Other countries and territories" value applies instead. That is the complaint the Turkish Cement Manufacturers' Association (Turkcimento), whose members account for roughly 94 percent of the sector, put on record on February 25, 2026, arguing that CBAM in this form risks becoming a non-tariff trade barrier for Turkish cement.

Turkcimento CEO Volkan Bozay grounded the actual figure in transitional-period reporting: "The actual data declared by our members exporting to the EU during the CBAM transition period in Turkey show that emissions for grey cement clinker are at the level of 0.88 tCO₂/ton." On the cost consequence, Bozay said: "When this difference is calculated based on current EU ETS prices, it increases the carbon cost per ton of clinker from approximately 20 Euros to 80 Euros." Turkey is the largest cement exporter to the EU, and clinker carries the full calcination emissions of the CBAM cement chain, so the bucket assignment lands on the highest-volume, highest-intensity trade flow in the sector.

Why the gap hits at the full certificate price

The free allocation adjustment is a benchmark-based amount per tonne that does not grow with the emissions declared, so the gap between the two emissions figures feeds through to the certificate bill at close to the full certificate price. Under Implementing Regulation (EU) 2025/2620, the default path deducts the CBAM factor (97.5 percent in 2026) times the Column B default benchmark, which is 0.666 for grey Portland cement and for grey clinker. The actual-value path deducts on a different basis: the Column A process benchmark plus the free allocation embedded in precursors such as clinker. Neither deduction rises with the emissions figure, so the adjustment shrinks both bills without closing the distance between them.

The Argus figures confirm the arithmetic. The Ukrainian shipment's emissions gap is 0.60 tCO₂e per tonne, or 6,000 tCO₂e across 10,000 tonnes, which at €75 per certificate is €450,000, close to the €468,000 difference between the two published approximations. Certificate prices are drifting the wrong way for anyone hoping the gap deflates on its own: the official Q2 2026 certificate price came in at €75.28, and Q3 has been tracking above it. Each euro added to the certificate price adds roughly €6,000 to the cost of this one shipment's unverified gap.

The trap is verifier timing, not a legal bar

Nothing in the CBAM rules prevents an importer from declaring verified actual emissions for 2026 imports; the constraint is that the verification must exist before the September 30, 2027 declaration, and the verification market is only now being built. Actual values for the 2026 reporting year remain fully usable in the first declaration. What stands between an importer and the €195,000 scenario is capacity and calendar, on three counts:

• Zero accredited CBAM verifiers exist anywhere in the EU as of early September 2026. The Commission's verification page states that the first verifiers are expected to receive accreditation around September 2026, and its list of accredited verifiers is still empty
• Implementing Regulation (EU) 2025/2546 makes a physical site visit at the non-EU installation mandatory in the first year an installation is verified, with only a narrow exception for serious, extraordinary and unforeseeable circumstances, so every 2026 verification includes travel to the plant
• The registry timeline is compressed: verifier registration opened September 1, registry access for accredited verifiers follows no earlier than September 30, and the Commission's timeline has accredited verifiers issuing their first verification reports in the CBAM Registry from January 2027

Stack those dates against the declaration deadline and the window for verifying a 2026 dataset, site visit included, is roughly twelve months, shared across every installation in every CBAM sector whose importers want actual values. Cement importers are competing for the same scarce verifier slots as steel and aluminium importers, with a larger share of each tonne's product value riding on the outcome.

What cement importers can do before the 2027 declaration

The €468,000 question is answered in the next few months, not in September 2027, because supplier data and a verifier slot both take lead time. Four steps protect the actual-values option:

1. Request installation-level emissions data from each cement supplier now, using the supplier data request generator to specify the CBAM data points the verifier will later check
2. Model both scenarios per supplier with the CBAM cost calculator, so the certificate budget for the February 1, 2027 sales opening reflects the default cost, with the verified cost as the target
3. Track accreditation as it happens and approach candidate verification bodies early, since the accredited CBAM verifiers list will fill in country by country from September
4. Re-run any default-based provisioning against the corrected Excel published August 10, and document which file version each calculation used

The default value is the price of doing nothing. For cement, doing nothing costs more than three times as much.