The Financial Cost of Missing Supplier Data

Think you can just pay a fine later if you don't get data from your suppliers? Think again. In the Definitive Period, if you rely on default values because you lack actual data, the EU won't just charge you the standard rate—they will apply a 'Mark-Up' (penalty multiplier).

Tiered Default System

The system prefers "Actual Data." If that's missing, it falls back to increasingly penalizing defaults:

1. Actual Data (Best) - Supplier provides verified emissions data
2. Country-Specific Defaults (Medium) - Average carbon intensity for that country
3. EU Average Default (Worst) - Often the highest-emitting benchmark

The Mark-Up Penalty

To discourage laziness, regulations propose adding a punitive "mark-up" to default values, artificially inflating your carbon liability. This means:

• Higher certificate costs per tonne
• Reduced competitiveness vs. compliant importers
• Potential flagging for enhanced scrutiny

The ROI of Data Collection

For an importer bringing in 10,000 tonnes of steel annually, the difference between actual data and EU defaults could be:

• With actual data: €450,000/year
• With EU defaults + mark-up: €1,400,000/year
• Potential savings: €950,000/year