German stainless steel distributor Gerber Steel has announced that it has formally notified the European Commission of what it calls serious deficiencies in the default emission 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. In the opinion of Gerber Steel, the data set contains significant errors and internal inconsistencies that could undermine the correct application of CBAM.
Errors identified in the default values for stainless steel
After an initial technical assessment, Gerber Steel reported numerous violations in materials, especially in the default values assigned to Taiwan in the category of products from stainless steel.
The company cited missing emissions data, apparently incorrect numbers and conflicting assumptions about the carbon intensity of different stages of production. The publication also contains technical inaccuracies. In some cases, published figures imply that processed foods produce higher emissions than more highly processed processed products, a result that Gerber Steel said does not reflect industry realities.
Concerns about non-country-specific assumptions
Gerber Steel also noted that the defaults attributed to Taiwan do not appear to be based on a country-specific emissions data set. Instead, the numbers appear to replicate defaults applied to other sources.
The company says this approach is particularly problematic given the structural characteristics of Taiwan's stainless steel industry, which relies heavily on electric arc furnace-based production, which should not be considered equivalent to the characteristics of other manufacturing plants.
Broader implications for trust to CBAM
At Gerber Steel estimates that the identified deficiencies are unlikely to be limited to a single country or product segment. Therefore, the company considers it likely that similar inaccuracies may exist in products of other origins and products subject to CBAM.
On this basis, Gerber Steel states that a comprehensive
