CBAM benchmarks by production route: why the same product can cost very different amounts
In 2026 most of the embedded emissions are offset by free allocation, but how much depends on the benchmark, and the benchmark depends on the production route.
- Certificates = embedded emissions minus benchmark x 97.5% (2026).
- Benchmarks are set per CN code and production route.
- Free allocation falls to zero by 2034.
- Verified data lets your supplier's actual route apply.
The formula
For 2026 you surrender certificates for the embedded emissions minus a free allocation adjustment: the CBAM benchmark for the good × 97.5% (the share still allocated free to EU producers in 2026) × tonnes (Article 31, Regulation (EU) 2023/956; Implementing Regulation (EU) 2025/2620). The share falls every year to zero in 2034, so the adjustment shrinks and the bill grows.
Benchmarks depend on the production route
The Commission set benchmarks per CN code and per production route, labelled with letters. A blast-furnace steel route and a scrap-based electric-arc route get very different benchmarks, and so do primary and recycled aluminium. Examples from the official table (tCO₂e per tonne):
| Product | Route | Benchmark |
|---|---|---|
| Ammonia | (A) | 1.522 |
| Ammonia | (B) | 1.522 |
| Hydrogen | (A) | 5.089 |
| Hydrogen | (B) | 5.089 |
Same product, different route, different bill
1,000 t of hot-rolled flat steel (CN 7208 51 00) on the official default values. Türkiye's default follows route (C), Thailand's route (E), so they get different benchmarks:
| Origin | Default SEE (t/t, with mark-up) | Benchmark | You surrender for 2026 | Full exposure |
|---|---|---|---|---|
| Türkiye | 2.671 | 1.37 | €109,901 | €219,860 |
| Thailand | 2.112 | 0.072 | €168,081 | €173,860 |
Notice the result: Thailand's default emissions are lower, yet its 2026 bill is higher. Route (E) has a far smaller benchmark, so almost none of its emissions are offset by free allocation in 2026. Lower emissions do not always mean a lower CBAM bill while free allocation lasts.
What this means for you
If your supplier's plant runs a different route from the default's, the default may not match its benchmark. With verified data, the supplier's actual route applies, which is one more reason to collect it. CBAM Compliance applies the benchmark of the route behind each figure and flags lines where the route is assumed.
Frequently asked questions
What is the CBAM free allocation adjustment?
In 2026 you surrender certificates for embedded emissions minus the CBAM benchmark x 97.5% x tonnes. The 97.5% falls each year to 0% in 2034.
Why do CBAM benchmarks differ by production route?
The Commission set benchmarks per CN code and production route, so blast-furnace and electric-arc steel, or primary and recycled aluminium, get different benchmarks and different free allocation adjustments.
Where are the official CBAM benchmarks published?
In Implementing Regulation (EU) 2025/2620 and the Commission's benchmark table.