What a default value actually costs a Ghanaian exporter
Europe's carbon border rules assume the worst when you cannot prove otherwise. For producers who could prove a better number, that assumption is expensive.
Current as of September 2026. This area is changing quickly — check the position before acting on anything here.
The Carbon Border Adjustment Mechanism left its reporting-only phase on 1 January 2026. Importers of covered goods must now hold authorised declarant status, and the emissions embedded in what they buy carry a certificate cost. That single change converts your emissions from a disclosure exercise into a line in your customer's cost of goods sold.
The timing is worth being precise about, because a lot of commentary is not. No certificates are bought during 2026. The first annual declaration and surrender falls due on 30 September 2027, covering goods imported in 2026. The liability is accruing now; the invoice arrives later. Your customer therefore has roughly a year to decide who they want to be buying from when it does.
Which means the question is no longer whether you report. It is what number gets used when you do not.
How defaults work
Where actual emissions data is unavailable, default values apply. Those defaults are set conservatively, on the reasonable principle that a system which assumed the best would be trivially gamed. Conservative here means they are drawn from the higher end of what a producer of that good might emit.
For a producer with an old, inefficient process, the default is roughly fair. For a producer with a modern process and a better-than-average number, the default is a penalty for not filling in a form. And since 2026 the defaults carry a deliberate mark-up on top — 10% this year, 20% in 2027, 30% from 2028 — so the penalty grows each year.
The Ghanaian case
It is often said that Ghana's grid is low-carbon. That was true when Akosombo supplied most of the country's power. It is not true now: in 2025, thermal plants — mostly gas — produced about two-thirds of Ghana's electricity, and hydro about a third.
For the goods where CBAM bites hardest, that matters less than it sounds. Iron, steel and aluminium are charged on direct emissions only — the furnace and the process, not the grid. What decides the bill is how efficiently a particular plant runs, measured at installation level, against a default that has been marked up to be worse than reality.
Which means the advantage exists only in the version of the world where the number is documented. Undocumented, an efficient producer and an inefficient one are assigned the same default, and the efficient producer subsidises the other at the border.
Updated October 2026. An earlier version of this piece described Ghana's grid as low-carbon. Energy Commission figures show it is now mostly gas-fired, and the section above has been corrected.
Your carbon number exists whether or not you measure it. The only question is who calculates it, and whether they have any reason to be generous.
What proving it requires
Reporting actual emissions is not a matter of quoting a national grid factor. The regime requires data at installation level, broken down by CN code — the specific goods you ship, from the specific plant that produced them.
Most producers do not currently track energy and process emissions at that granularity. Production is aggregated monthly, electricity arrives as one bill for the site, and process inputs are recorded for cost accounting rather than emissions. Getting from there to an installation-level figure is a data engineering problem before it is a carbon problem.
Then it has to survive a verifier. Using actual emissions rather than defaults requires third-party verification by an accredited body, including an on-site audit in the first year and assessment against a 5% variance threshold. Verification capacity is finite and tightening. If verification is late or fails, default values apply anyway — which means the work only pays off if the underlying records were built to be checked.
One relief worth knowing: a de minimis threshold of 50 tonnes applies, aggregated across all covered goods per importer per calendar year. Below it, no obligation arises.
The order things will happen in
The regulatory deadline is not what will reach you first. Your buyer will. Procurement questionnaires asking for verified emissions data are already circulating, because the importer is the one holding the certificate cost and they would rather buy from someone who lowers it.
By the time a formal requirement lands, the suppliers who prepared early will have been shortlisted, and the rest will be negotiating on price against an assumption nobody made in their favour.
And the perimeter is moving outward. A proposal to extend CBAM to steel and aluminium-intensive downstream products from 2028 is in the EU legislature, with both the Council and Parliament arguing for a wider list of goods than the Commission originally put forward. If you make finished metal goods rather than raw material, the question is when rather than whether.