Worked example: how verified data can cut a steel importer's CBAM bill

This is an illustrative example based on typical figures, not a client result.

A UK-based steel distribution business importing approximately 8,000 tonnes of hot-rolled coil annually from Turkish and Indian mills faced a substantial projected CBAM certificate liability when full obligations came into force.

Working with a CBAM specialist, the business undertook a three-stage review. First, a complete audit of its supplier base identified that two mills — accounting for 61% of import volume — were already operating verified monitoring plans compatible with EU CBAM requirements. Second, the business renegotiated its data-sharing agreements to receive quarterly verified emissions reports directly from those suppliers, replacing the default EU benchmark values it had previously been using.

The result: by substituting actual verified embedded emissions data for the conservative default benchmark figures, the business reduced its calculated CBAM certificate obligation by 34% — a meaningful cost saving ahead of the first full compliance period.

Key lesson: default benchmark values are intentionally conservative. For importers with established supplier relationships, investing in verified emissions data almost always reduces liability.

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