Every CBAM figure traces to a named public source, and the checks below can be rerun

Four checks that can be rerun from public data

A method description is a claim about how work was done. A check is something a reader can repeat. These four use only the sources listed further down, and each one has a result that is either right or visibly wrong.

1. The trade flows close against Eurostat’s own total

Import volumes are assembled country by country and product by product. Summing the non-EU origin countries, plus Norway, Iceland and Switzerland, must reproduce the extra-EU total that Eurostat publishes separately.

Residual 0.000000% across six sector-period aggregates

2. The per-tonne charges match an independent commercial estimate

For the first quarter of 2026 a trade-price reporting agency published the default-value charge per tonne for several steel and aluminium products by origin country, using the official certificate price of €75.36. The same formula applied to our own parameter set reproduces all nine of those figures.

9 of 9 within €0.50 per tonne

3. The intensity dataset is internally consistent

The country-level intensity dataset from the European Commission’s Joint Research Centre reports direct, indirect and total emissions separately for each country and product. Every triple must add up.

2,382 of 2,382 triples consistent, no exceptions

4. The plant-level calibration holds across three regulators

Plant activity data is scaled to measured emissions using mandatory reporting from Australia, the United States and Canada. For integrated blast-furnace steelworks the scaling ratio agrees closely across all three, which it need not have done.

Australia 0.99 (2 plants) · United States 0.98 (7) · Canada 0.96 (1)

Two caveats are worth stating plainly. The sample is small: two plants in Australia and one in Canada. And the Port Kembla value sometimes quoted as a verification point is one of the two Australian plants, so it is a consistency check rather than an independent test. The United States ratio, drawn from seven plants reporting to a different regulator under different rules, is the stronger evidence, and it is the agreement between regulators rather than any single number that carries the weight.

The calculation, in five steps

CBAM charges an importer for the emissions embedded in a good, less a free allocation set by an EU benchmark. The exposure estimate follows that structure.

Fix the legal parameters. Product scope, country default values, free-allocation benchmarks, the transitional factor, the sector mark-up and the certificate price all come from the Regulation and its implementing acts. Nothing here is estimated.
Measure the flow. Tonnes and values of goods in scope, by origin country and product code, from the EU’s own trade database.
Build the default-value bill. What an importer pays if no verified emissions data is supplied. This is an upper bound by construction: the default values carry a deliberate mark-up, and the regulation is designed so that using them is never the cheaper option.
Build a comparison path. Where measured or officially published intensity exists, the same calculation is run against it. Country-level intensity comes from the Joint Research Centre; plant-level measurement exists only where a regulator publishes it.
Take the difference. The gap between the two paths is what accurate, verified emissions data is worth to that exporter. Where the gap is near zero, verification will not reduce the bill and the exporter’s only options are to abate or to sell elsewhere. This is a measure of the gap between two published parameter sets, not a saving that any particular importer will realise; what an individual consignment pays depends on its own verified data.

Sources and licences

17 sources are published under terms that permit derived analysis with attribution. A further 7 are named but their data is not reproduced here, either because the publisher’s terms do not permit it or because the terms could not be verified. Where a source is marked as cited only, the figures on this site are our own, and the source is named so that a reader can go and check it.

Source	Publisher	Licence	What it is used for
CBAM Regulation and implementing acts	Publications Office of the EU (EUR-Lex)	Reuse authorised under Decision 2011/833/EU; editorial content CC BY 4.0	Annex I scope, benchmarks, CBAM factor, certificate-price rule
Climate TRACE v6 asset-level inventory	Climate TRACE coalition	CC BY 4.0	Plant identity and annual activity. Its emission factors are route constants, not measurements
Country default values (IR 2026/1740) and benchmarks (IR 2025/2620)	European Commission / EUR-Lex	Reuse authorised under Decision 2011/833/EU	Default embedded emissions by country and CN code; free-allocation benchmarks
EU ETS verified emissions	European Environment Agency	EEA standard re-use policy	European installation-level verified emissions used as a comparison point
EU trade by origin (DS-045409)	Eurostat	Reuse for commercial and non-commercial purposes authorised provided the source is acknowledged	Tonnes and value of CBAM goods imported into the EU27 by origin country
Emissions-intensity determinations	Clean Energy Regulator (Australia)	CC BY 4.0, as above	Product-level measured intensity, including the Port Kembla check value
Facility greenhouse gas registry, 2015-2024	Ministry of Environment (Taiwan)	Government open data declaration	Measured direct and indirect emissions by plant
Finance Act 2026 Part 5 and CBAM statutory instruments	UK Parliament / legislation.gov.uk	Open Government Licence v3.0	UK CBAM scope, rate formula and relief rules
GHG intensities of steel, fertiliser, aluminium and cement (JRC134682)	European Commission, Joint Research Centre	CC BY 4.0 (© European Union 2023)	Country-level direct and indirect intensity by CN code; the comparator behind the 2026-09-16 correction
Global Iron and Steel Tracker; Global Cement and Concrete Tracker	Global Energy Monitor	CC BY 4.0	Plant identity, owner, production route and capacity
Greenhouse Gas Reporting Program, reporting year 2023	US Environmental Protection Agency	US federal government work; published as open data	Measured facility emissions for 430 US plants in six CBAM-relevant sectors
Greenhouse Gas Reporting Program, reporting year 2024	Environment and Climate Change Canada	Open Government Licence – Canada	Measured facility emissions for Canadian steel, aluminium and cement plants
Merchandise exports by commodity, state and destination	Australian Bureau of Statistics	CC BY 4.0	Independent cross-check of the Australian export leg
Mineral Commodity Summaries 2026	US Geological Survey	Public domain (17 U.S.C. 105)	National cement and ammonia production used for scale checks
Overseas trade statistics	HM Revenue & Customs (UK)	Open Government Licence v3.0	UK import volumes for the UK CBAM leg
Relative CBAM Exposure Index	World Bank	CC BY 4.0	Third-party index reproduced as a direction check
Safeguard Mechanism facility emissions and baselines	Clean Energy Regulator (Australia)	CC BY 4.0; derived use attributed as 'Based on Clean Energy Regulator material licensed under a Creative Commons Attribution 4.0 licence'	Measured Scope 1 emissions used to calibrate and to verify
Allowance price explorer cited, not reproduced	International Carbon Action Partnership	Information purposes only; attribution required; full terms unresolved	Carbon prices in other jurisdictions, cited not reproduced
Ammonia production energy benchmarking cited, not reproduced	International Fertilizer Association	Free download; redistribution not granted	Context only
Company sustainability and financial reports cited, not reproduced	BlueScope Steel Limited	Company copyright	Company-disclosed figures, cited with attribution
Euro foreign exchange reference rates cited, not reproduced	European Central Bank	Reuse permitted with attribution; commercial republication of the data requires prior written authorisation	Currency conversion only. The rate series itself is not republished here
Mandatory GHG accounting and reporting system cited, not reproduced	Ministry of the Environment / METI (Japan)	Site terms not yet verified verbatim	Japanese site-level emissions, cited but not reproduced
National greenhouse gas emission statements cited, not reproduced	Greenhouse Gas Inventory and Research Center (Korea)	No explicit licence statement located	Company-level Korean emissions, cited but not reproduced
Third-party studies: Sandbag, Global Efficiency Intelligence, worldsteel, Fastmarkets cited, not reproduced	Various publishers	Copyright of each publisher; no reuse licence	Independent estimates compared against ours. Quoted briefly with attribution, never reproduced

Derived from Clean Energy Regulator material licensed under a Creative Commons Attribution 4.0 licence. No regulator, agency or data publisher named on this page has reviewed, approved or endorsed this analysis, and nothing here should be read as their view. Contains information from Eurostat and from EU legal texts, reused under Decision 2011/833/EU. Contains public sector information licensed under the Open Government Licence v3.0. Climate TRACE and Global Energy Monitor data under CC BY 4.0. Changes have been made to all of the above.

What is published and what is withheld

The sources are public and the law is public. What is not public is the work of joining them: deciding that a particular plant in one database is the same plant in another, and converting generic activity data into a defensible emissions estimate. That join is the analysis, and it is not published. The table below is the whole of the boundary.

Published in full

The legal parameters and their citations
Every source, with publisher, licence and use
The calculation structure, step by step
The four checks and their results
Corrections, dated, including those that move headline figures
The boundaries below

Result shown, method not

Plant-level estimated intensities, each carrying a label saying whether it is measured, calculated or estimated
Country comparison values
The scaling ratios in check 4 are quoted to two decimal places as evidence; the underlying coefficients by production route are not published

Not published

The cross-source plant identity table linking the asset registers to each other and to regulatory records
The matching rules, thresholds and match scores behind it
Benchmark assignment where the regulation leaves a product without a direct match
6 sources whose terms do not permit republication, or which are used only inside the identity layer

The last of those is enforced rather than promised: the page you are reading is generated by a script that refuses to build if a restricted source is named anywhere in it.

Corrections

Figures that have been published and later changed are listed here with the reason. A method that never corrects itself is not being checked.

16 September 2026 · affects a headline figure

The global value of verified emissions data for steel was revised down from approximately €8.8 billion a year to approximately €3.5 billion on comparable volumes. The earlier comparison used plant activity data scaled by production route. That scaling is sound for sizing a plant, but the underlying factor is a single global constant per route, so it carried no information about which country a plant was in. Replacing it with the Joint Research Centre’s country-level direct intensities changed the answer and changed its shape: the opportunity is now concentrated in one country rather than spread across several.

Two country figures were withdrawn entirely. For India and Russia the EU default value already sits at or above the published measured intensity, so verifying emissions would not lower the bill. Those exporters have no verification incentive at all, which is the opposite of what the earlier figures implied.

5 September 2026

The mark-up applied to fertiliser default values was corrected from 10% to 1%. The implementing regulation sets 10%, rising to 20% and then 30%, for cement, iron and steel, aluminium and hydrogen, but holds fertilisers at 1% throughout. The step is by year for most sectors and flat for one, and the two had been conflated.

What this is not

Not a forecast of what importers will pay. The default-value bill is an upper bound. The actual bill depends on how much verified data each importer obtains, which cannot be observed from outside.
Not a plant-level measurement outside six jurisdictions. Measured emissions exist where a regulator publishes them: Australia, the United States, Canada, Taiwan, Japan and the European Union. Everywhere else the plant layer gives identity, production route, scale and a bounded estimate, and says so on each record.
Not evidence that CBAM has redirected trade. EU imports of goods in scope fell across every sector in the first half of 2026, but the largest single movement is Russia, where sanctions and separate tariff measures are the more direct explanation. Imports from several other origins rose over the same period.
Not complete on the United Kingdom. The UK scheme begins in 2027 and its default values have not been published. The UK figures here are inferred from the allowance price and the statutory rate formula, and will be restated when the values appear.
Not advice. Indicative desktop analysis of public information. Any commercial, financing or compliance decision needs independent verification.