German stainless steel distributor Gerber Steel has announced that it has formally notified the European Commission of what it describes as serious deficiencies in the default emissions values published under the Carbon Border Adjustment Mechanism (CBAM).
The default values in question were published in the Official Journal of the European Union on December 31, 2025. According to Gerber Steel, the dataset contains substantial errors and internal inconsistencies that risk undermining the correct application of CBAM.
Errors identified in stainless steel default values
Following an initial technical assessment, Gerber Steel reported multiple material irregularities, particularly in the default values assigned to Taiwan within the stainless steel product category.
The company cited missing emissions data, evidently incorrect numerical values, and contradictory assumptions regarding carbon intensity at different production stages. The publication also appears to contain technical inaccuracies. In several cases, the published figures imply that semi-finished products generate higher emissions than more highly processed downstream products, a result Gerber Steel says is inconsistent with sectoral realities.
Concerns over non-country-specific assumptions
Gerber Steel further noted that the default values attributed to Taiwan do not appear to be based on a dedicated, country-specific emissions dataset. Instead, the figures seem to replicate default values applied to other origins.
According to the company, this approach is particularly problematic given the structural characteristics of Taiwan’s stainless steel industry, which relies heavily on electric arc furnace-based production, that should not be treated as equivalent to those of other production locations.
Broader implications for CBAM credibility
In Gerber Steel’s assessment, the identified deficiencies are unlikely to be confined to a single country or product segment. The company therefore considers it probable that similar inaccuracies may exist across other origins and CBAM-covered products.
On this basis, Gerber Steel argues that a comprehensive reassessment of the published default values is urgently required.
Legal and economic uncertainty for market participants
Commenting on the issue, Gerber Steel CEO Thorsten Gerber stated that inaccurate or internally inconsistent default values introduce significant legal and economic uncertainty for affected companies.
Gerber Steel has formally requested that the European Commission address the identified shortcomings without delay and issue revised default values that are coherent, technically robust, and reliable.
Mr. Gerber added that the company expects a prompt response from the Commission outlining how the errors will be rectified and how certainty for affected stakeholders will be re-established.
