Reduce CBAM Costs: 4 Strategies for Exporters

The €12,000 Question: How Much Can You Actually Save?

Here's a number that surprises most SME exporters: the difference between using EU default values and providing your own verified emissions data can be €12,000 or more per year for a typical steel exporter — by 2034, when free allocation ends.

In 2026, with the correct CBAM formula (embedded emissions − benchmark × 97.5%), the savings from efficient production are substantial from day one:

Scenario	Emissions Factor	2026 Cost (correct formula)	2034 Cost (100%)
EU default value (BF-BOF)	2.30 t CO₂/t	€14,460	€34,500
Your actual data (efficient)	1.50 t CO₂/t	€2,460	€22,500
Annual savings	—	€12,000	€12,000

2026 formula: (Emissions − 1.370 × 97.5%) × 200t × €75. BF-BOF benchmark: 1.370 tCO₂/t. ETS price ~€75/tCO₂.

This post gives you four practical strategies to reduce your CBAM costs.

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Strategy 1: Provide Actual Emissions Data (Not Defaults)

Impact: HIGH | Effort: MEDIUM | Savings: 20-40%

This is the single most impactful thing you can do. When you don't provide verified emissions data, your EU importer uses EU default values — which are deliberately conservative (i.e., higher than most actual emissions).

Default Value Markup by Year

Year	Default Value Markup
2026	+10% above benchmark
2027	+20% above benchmark
2028	+30% above benchmark
2029+	+30% above benchmark

Default values carry an extra markup on top: 10% in 2026, rising toward 30% by 2028. This means using defaults isn't just less accurate — it's deliberately more expensive.

What You Need to Collect

Data Point	Why It Matters	How to Get It
Production route (BF-BOF, EAF, DRI)	Determines base emission factor	Mill records
Energy consumption (electricity, gas, coal)	Direct emissions calculation	Utility bills
Raw material inputs	Precursor emissions	Procurement records
Electricity source	Grid emission factor	Supplier contracts

Real Example: Steel Rebar (CN 7214) from Turkey

Based on EUA price of ~€75/tCO₂ (2026 estimate)

Data Type	Emissions Factor	2026 Cost per 100t (correct formula)	2034 Cost per 100t (100%)
EU default (Turkey, BF-BOF)	2.10 t CO₂/t direct	€5,730	€15,750
Actual data (efficient EAF)	0.350 t CO₂/t direct	€2,100	€2,625
Savings	—	€3,630 per shipment	€13,125 per shipment

2026 formula: (Emissions − Benchmark × 97.5%) × 100t × €75. BF-BOF benchmark: 1.370. Scrap-EAF benchmark: 0.072 (IR 2025/2621).

Note: The EU default value for Turkish BF-BOF steel is higher than many facilities' actual emissions. Providing verified data from your efficient EAF process saves money.

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Strategy 2: Optimise Your Production Route

Impact: VERY HIGH | Effort: HIGH | Savings: 40-70%

The production route is the single biggest determinant of your CBAM cost. If you have flexibility in how you produce, this is where the largest savings come from.

Steel Production Routes Compared

Route	Emissions (t CO₂/t)	2026 Cost (after benchmark deduction)	2034 Cost (100%)	vs. BF-BOF
BF-BOF (blast furnace)	1.85 – 2.30	€38.55 – €72.30/t	€139 – €173/t	Baseline
DRI-EAF (direct reduced iron)	1.10 – 1.50	€47.33 – €77.33/t	€83 – €113/t	-35%
Scrap-EAF (recycled)	0.40 – 0.70	€24.75 – €47.25/t	€30 – €53/t	-45%

Formula: (Emissions − Route benchmark × 97.5%) × €75. Benchmarks: BF-BOF 1.370, DRI-EAF 0.481, Scrap-EAF 0.072 (IR 2025/2621).

Note: These ranges represent full production route emissions. Actual figures vary by facility efficiency, raw material mix, and energy sources.

Aluminium Production (Annex II)

Under CBAM, aluminium costs are driven by direct emissions only (anode consumption + PFC emissions) — electricity source does not affect the CBAM obligation for this sector.

Period	Direct Emissions (t CO₂/t)	Cost per tonne (correct formula)
2026 (after benchmark deduction)	1.4 – 2.0	€0.98 – €45.98/t
2034 (100% liability)	1.4 – 2.0	€105 – €151/t

2026 formula: (Direct emissions − 1.423 × 97.5%) × €75. Aluminium benchmark: 1.423 tCO₂/t. At 1.4 tCO₂/t, emissions are below the benchmark threshold (1.387 after deduction), resulting in near-zero cost. At 2.0 tCO₂/t, the full excess is chargeable.

Note: Unlike steel, aluminium's CBAM cost is largely fixed by the production process (electrolysis chemistry), not by electricity procurement choices. Savings for aluminium exporters come primarily from improving electrolysis efficiency and reducing PFC emissions.

Actionable Steps

1. Audit your current production route — What's your actual emission intensity?
2. Explore alternative fuels — Can you switch from coal to gas or renewables?
3. Increase scrap usage — For steel producers, every 10% increase in scrap ratio reduces emissions
4. Consider renewable PPAs — Power purchase agreements for electricity

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Strategy 3: Claim Carbon Price Deductions

Impact: MEDIUM | Effort: LOW | Savings: Variable (depends on national carbon price)

If your country has a carbon pricing mechanism (carbon tax, ETS, or similar), you can deduct the carbon price already paid from your CBAM obligation.

Countries with Carbon Pricing That Qualify for Deduction

Country	Carbon Price (2026 est.)	Potential Deduction
China (national ETS)	~€10/tonne CO₂	Partial deduction
South Korea (K-ETS)	~€25/tonne CO₂	Partial deduction
Turkey (planned ETS)	TBD (expected 2025-2026)	Future deduction
India (planned carbon tax)	TBD	Future deduction
Brazil (planned)	TBD	Future deduction

How to Claim the Deduction

1. Obtain official documentation of carbon price paid (tax receipt, ETS compliance certificate)
2. Convert to EUR using the official exchange rate
3. Submit to your EU importer with your CBAM declaration
4. Keep records for at least 5 years (audit trail)

Example: If you pay €25/tonne CO₂ in your country's ETS, and your CBAM liability is €75/tonne, your net CBAM cost is €50/tonne — a 33% reduction.

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Strategy 4: Improve Energy Efficiency

Impact: MEDIUM | Effort: MEDIUM | Savings: 10-25%

Every unit of energy you save directly reduces your embedded emissions. This isn't just good for the environment — it's good for your CBAM bill.

Quick Wins for Energy Efficiency

Action	Typical Energy Saving	CBAM Impact
Insulate furnaces and pipes	5-10% fuel reduction	5-10% emission reduction
Recover waste heat	3-8% energy savings	3-8% emission reduction
Optimise production scheduling	2-5% energy savings	2-5% emission reduction
Upgrade to efficient motors	3-7% electricity savings	3-7% indirect emission reduction
LED lighting & smart controls	1-3% electricity savings	Minor but cumulative

The Compounding Effect

Efficiency Improvement	2026 Savings (correct)	2030 Savings	2034 Savings
5% energy reduction	€1,388	€1,758	€1,850
10% energy reduction	€2,775	€3,516	€3,700
15% energy reduction	€4,163	€5,273	€5,550

Based on a 200t steel exporter at the BF-BOF low end (1.85 tCO₂/t). 2026 savings: (Emissions reduction × 200t × €75). ETS price estimates: €75 (2026), €95 (2030), €100 (2034).

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Combined Strategy Impact

Here's an illustrative scenario showing what happens when a 200-tonne steel exporter applies all four strategies together, viewed through the 2034 lens (when full liability kicks in):

Starting point: BF-BOF production, EU default values → €34,666/year

Step	Action	Resulting Emissions Factor	2034 Cost
1	Switch to verified Scrap-EAF data (Strategies 1 + 2 combined)	~0.55 t CO₂/t	~€8,290
2	Apply a 10% energy efficiency gain (Strategy 4)	~0.50 t CO₂/t	~€7,536
3	Claim a home-country carbon price deduction of ~20% (Strategy 3)	—	~€6,029

Result: from €34,666 down to roughly €6,000/year — a ~83% reduction.

Important: This is an illustrative scenario, not a guarantee. Your actual savings depend on whether switching production routes is feasible for your facility, whether your country's carbon price qualifies for deduction, and how much of your energy efficiency potential you can realistically capture. Treat the ~70-85% range as a ceiling to aim for, not a baseline to expect.

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Key Takeaways

1. Actual emissions data is the cheapest, most impactful strategy (saves 20-40%)
2. Production route optimisation has the highest potential savings (40-70%)
3. Carbon price deductions are often forgotten — claim them if eligible
4. Energy efficiency improvements compound over time
5. Combined strategies can realistically reduce costs by 70-85% for exporters with route flexibility

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Track Your Numbers with CbamTrack

CbamTrack helps you apply all four strategies:

• Compare default vs. actual values — See your savings instantly
• Track ETS prices — Know your current and projected costs
• Generate reports — Ready-to-send data for EU customers
• Monitor deadlines — Never miss a reporting date
• Analyse anomalies — Catch data issues before they cost you

Start free — no credit card required. Try the free CBAM calculator or sign up at cbamtrack.com/sign-up

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Sources

• EU Regulation 2023/956 — CBAM main regulation (Annex VIII phase-out schedule)
• IR (EU) 2025/2621 — Default emission values and steel/aluminium benchmarks
• IR (EU) 2025/2548 — Transitional and definitive phase rules
• IR (EU) 2025/2620 — Benchmark values for free allocation
• European Commission CBAM page

Last updated: July 2026 | Sources: EU Regulation 2023/956, CBAM Implementing Regulation 2025/2548, EU ETS Auction Data