The preliminary values of the CBAM calculation are voted on by the committee

The European Commission's Committee on the Carbon Dioxide Emissions Regulation Mechanism (CBAM) has adopted the final amendments to the technical implementation acts, which form the basis for calculating the costs of CBAM – part of the EU comitology process – and lay the vital foundations for the final stage of the implementation of the instrument with financial responsibility, starting in January.

After numerous revisions, the implementing acts describing the technical application of the CBAM criteria and default values have been approved by the committee with a sufficient number of votes from Member States, and they are now expected to be formally submitted for adoption before the end of the year.

Despite official recognition, these estimated values still exist on a preliminary basis and will be subject to further revision after adoption as the CBAM passes its final stage.

Back in November, McCloskey published exclusive information on the main calculated CBAM values, which detailed the higher-than-expected costs that EU importers may face when calculating default CBAM obligations.

Since then, the "worst-case scenario" faced by steel importers has become even worse: default values have increased for a number of countries of origin (such as China), and the baseline values have been revised downward after the overall decline to accommodate projections for the Baseline Emission Control System (ETS) benchmarks for 2026-2030 and a decrease to the control values associated with direct iron reduction (DRI).

For example, on December 10, McCloskey learned of a new deal to supply an entire vessel (40-50 thousand tons) of Indian-made hot-rolled carbon roll (HRC) to an Italian buyer at a price equivalent to about 430 euros per ton of CFR in Italy, which may be terminated in case of default. With emission values, the cost per ton of CBAM will be about 270 euros/ton – almost 13.5 million euros with full shipment.

McCloskey calculated the potential costs of CBAM for a number of product categories, as originally demonstrated for importing carbon HRC from major sources.:

CBAM Declarations and Calculations

CBAM is best viewed as a mirror of the EU's ETS, setting carbon costs at the border according to what an installation in a third country would pay if it operated inside the EU.

Simplified formulas for calculating additional CBAM import costs are shown below.:

The price of carbon has already been paid

Little is known yet about how any carbon price already paid will be recognized and accounted for under CBAM, although the European