Beginning in January 2026, certain exports to the European Union—including steel and aluminum—will face charges under the EU’s Carbon Border Adjustment Mechanism (CBAM), based on their greenhouse gas emissions intensity. When facility-specific data is unavailable, the EU will assign default values, which must be based on the most reliable data available, including from exporting countries. In February, the U.S. International Trade Commission (ITC) released a report using detailed data from U.S. producers to estimate emissions intensity for steel and aluminum—offering a more accurate alternative to the EU’s existing data source, a 2023 report from the Joint Research Centre (JRC), which likely overstates U.S. emissions. This memo argues that the ITC’s findings better align with CBAM standards and should be used to determine default values for U.S. exports.