CBAM: Strategic Considerations for Thai Exporters

Actual Values represent the greenhouse gas emissions generated during the specific production process of an individual manufacturing facility. These values are calculated using real operational data such as: 

◾ Energy consumption 

◾ Production data 

◾ Raw material usage 

◾ Process emissions 

 

The calculation must follow the methodologies specified under the EU CBAM regulations and is generally supported by a robust emissions monitoring system. 

 

Advantages of Actual Values

◾ Higher reporting accuracy 

◾ Reflects the true carbon performance of the facility

◾ Potentially lowers future CBAM certificate costs

◾ Strengthens credibility with European customers

◾ Supports ESG and sustainability reporting initiatives 

 

Actual Values are particularly suitable for organizations that already perform Carbon Footprint assessments, GHG inventories, or sustainability reporting. 

Default Values are standardized emissions factors established by the European Commission. They may be used when facility-specific emissions data is unavailable or cannot yet be reliably calculated.

This approach requires considerably less data collection and provides a practical solution during the early stages of CBAM implementation.

However, Default Values are generally conservative and may be significantly higher than the actual emissions generated by efficient manufacturers.

 

Advantages of Default Values

◾ Easier implementation

◾ Limited data collection requirements

◾ Suitable for companies beginning CBAM compliance

◾ Useful during the transition period

 

Limitations

◾ May overestimate product emissions

◾ Potentially increases future CBAM certificate obligations

◾ May reduce competitiveness in the European market

◾ Expected to become less acceptable as CBAM regulations mature

1. Evaluate Future Carbon Costs 

Comparing Actual Values with Default Values enables companies to estimate future CBAM-related costs. If Actual Values are lower than the Default Values, reporting actual emissions can reduce embedded carbon emissions and potentially decrease the number of CBAM certificates required. Conversely, if Actual Values are currently higher, Default Values may offer a temporary reporting option. Nevertheless, companies should continue improving emissions performance and prepare for eventual Actual Value reporting. 

2. Meet Customer Expectations 

European customers increasingly expect suppliers to provide transparent, facility-specific emissions data. Companies capable of demonstrating verified Actual Values can: 

◾ Enhance customer confidence 

◾ Support sustainable procurement requirements 

◾ Strengthen long-term business relationships 

◾ Differentiate themselves from competitors 

As sustainability becomes an important purchasing criterion, emissions transparency is rapidly becoming a competitive advantage. 

3. Prepare for Future Regulatory Changes 

The EU has indicated that CBAM will progressively rely more heavily on Actual Emissions reporting. 

Although Default Values currently serve as a transitional solution, businesses should view them as a short-term measure rather than a permanent compliance strategy. 

Investing in emissions monitoring systems today will help organizations remain compliant and competitive as CBAM requirements continue to evolve.

For Thai exporters, the most effective long-term strategy is to progressively transition from Default Values to Actual Values. Organizations should begin by:

◾ Establishing reliable GHG emissions data collection systems

◾ Calculating product-specific emissions using internationally recognized methodologies

◾ Improving production efficiency to reduce carbon intensity * Verifying emissions data where appropriate

◾ Integrating carbon management into overall ESG and sustainability strategies

 

Early preparation not only supports regulatory compliance but also strengthens business resilience and market positioning in an increasingly carbon-conscious global economy.