CBAM Readiness

For steel, aluminium, cement and fertiliser trade from Türkiye into the EU, 2026 is the year CBAM became real. On 1 January 2026 the mechanism moved into the definitive period: every tonne of covered goods entering the EU now carries embedded emissions the importer must cover with CBAM certificates. The EU importer declares and pays, but the data that sizes the obligation comes from the installation in Türkiye.

Alalëa works as a CBAM consultant at exactly that junction. We calculate an installation's embedded emissions under EU rules, make the data ready for verification, and help deliver it to EU customers on time and in a form that holds up. This page is written for both sides of the trade: Turkish exporters answering their customers, and EU importers and multinational groups that buy from Turkish plants and need data they can rely on.

Who CBAM affects

CBAM covers six product groups: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Scope is checked against Annex I of the CBAM Regulation by eight-digit Combined Nomenclature (CN) code; a four-digit heading can contain both covered and non-covered codes.

The 50-tonne threshold introduced by the 2025 simplification applies per importer, to the total annual net mass imported. A buyer importing less than 50 tonnes a year of cement, iron and steel, aluminium and fertilisers is exempt; there is no threshold for hydrogen and electricity. It applies to the importer, not the exporter, and according to the Commission keeps more than 99% of covered emissions in the system, so data requests from regular EU buyers will continue.

Indirect exposure matters too: a customer that exports to the EU will ask for embedded emissions if you supply it with precursors. A Commission proposal of 17 December 2025, not yet adopted, would also extend scope from 2028 to steel- and aluminium-intensive finished goods.

What a Turkish supplier needs to deliver

Based on the Commission's Guidance Document 2 for non-EU operators (14 August 2026), an EU customer will ask for:

• Installation description: installation boundaries, production processes and production routes, with a written monitoring plan for each process.
• Direct emissions: emissions determined by calculation or measurement, plus measurable heat flows between processes.
• Indirect emissions: for cement and fertilisers only, the electricity consumed and its emission factor.
• Precursors: quantity, origin and embedded emissions of purchased precursors.
• Product-specific parameters: for example, the clinker ratio in cement.
• Data for the free allocation adjustment: information used to calculate the free allocation the installation would receive if it were in the EU.
• Carbon price paid: where relevant, evidence of a carbon price actually paid in the country of production.
• Verification report: if actual data is to be used, a positive opinion from a verifier accredited in the EU.

This travels in the operator emission report, standardised by Regulation (EU) 2025/2547. The calculation runs per calendar year: emissions attributed to each production process are divided by its activity level to give specific embedded emissions per tonne.

A corporate inventory or product carbon footprint is a solid base, but it is not CBAM data: the Commission's guidance stresses that embedded emissions follow EU ETS rules and may differ from GHG Protocol or ISO 14067 calculations. Our note on what to do when a customer requests a PCF explains where the overlaps end.

Default values or actual data?

When a supplier cannot provide verified actual data, the EU importer uses the country-specific default values published by the Commission. For the definitive period they were set by Implementing Regulation (EU) 2025/2621, corrected in July 2026 by 2026/1740. Crucially, default values carry a punitive mark-up:

For fertilisers the mark-up is 1%. The Commission states openly that, because of the mark-up, using verified actual data will be more advantageous in most cases.

Three further reasons favour actual data:

1. Default values do not reflect your route. A national average ignores a more efficient process, a higher scrap share or a cleaner electricity source, so a below-average producer is priced against itself.
2. Some products have no Türkiye value. In the Commission's August 2026 information file, the Türkiye row has no country-specific value for grey clinker and grey Portland cement. The "other countries and territories" value then applies, based on the average of the ten exporting countries with the highest emission intensity.
3. Defaults also change the free allocation adjustment. With default values, the adjustment is calculated on the production route shown for that country; with actual data, the installation's own route and precursor shares are used.

The commercial consequence is simple: verified actual data is now part of price negotiations. Of two Turkish producers selling the same product, the one with verified data offers its buyer a lower and more predictable obligation, and for EU buyers a verified operator emission report has become a sourcing criterion.

How the certificate obligation is built

The importer buys CBAM certificates, but both sides need to talk about the same numbers. Following the Commission's Questions and Answers document:

Certificates to surrender = Imported quantity (t) × (Specific embedded emissions − Specific embedded free allocation) − Emissions corresponding to the carbon price effectively paid in the country of origin

• Free allocation adjustment: the obligation is reduced by the free allocation an EU producer would receive for the same product, calculated with CBAM benchmarks and the CBAM factor in the EU ETS Directive. According to DEHSt, the factor is 97.5% in 2026 and 95% in 2027, and declines step by step until 2034. In other words, the net obligation grows every year.
• Certificate price: the Commission calculates it as the volume-weighted average of EU ETS auction clearing prices. For 2026 imports the price is published quarterly; from 2027 it is published weekly. We do not forecast prices; current values are on the Commission's CBAM certificate price page.
• Carbon price paid: Article 9 of the CBAM Regulation allows a deduction for a carbon price effectively paid in the country of origin. Rebates and compensation, such as free allocation, are netted out of the deduction. As of October 2026, the implementing act that will set the evidence rules does not appear as adopted on the Commission's legislation page.

How we work: six steps

The output of each step is the input of the next; skipping ahead usually means coming back at the verification stage.

1. CN code and installation mapping

We check every product sold into the EU against Annex I by its eight-digit CN code and link each code to its installation, production process and route, flagging precursors sold and bought. The output is a table showing which product comes from which process and goes to which EU customer.

2. Monitoring methodology and monitoring plan

We define installation boundaries, source streams, measurement points and heat flows between processes, choose between calculation and measurement, assign a meter or document to each data point and set rules for closing gaps. The result is a written CBAM monitoring plan, built on the same measurement infrastructure as any existing Turkish ETS monitoring plan and Monitoring Methodology Plan.

3. Data template exchange with EU importers

Customers each asking for their own format is where exporters lose the most time. We agree with your customers which data is shared, in which template, at what confidentiality level and by when. We propose the Commission's operator emission report template as the common language and assess registration in the O3CI module with you. The same structure is set up in reverse for data coming from your own precursor suppliers.

4. Embedded emissions calculation

For each production process we calculate direct emissions, indirect emissions where they apply, and the embedded emissions of precursors, then divide by activity level to get specific embedded emissions per product. We compare the results with the Türkiye default value (or the "other countries" value) to show the size of the gap and which products should be prioritised for actual data.

5. Verification readiness

Verification is needed only when actual data is used; default values are not verified. Actual data is accepted only with a positive report from a verifier accredited for the sector by a national accreditation body in the EU. The Commission expects the first CBAM accreditations around September 2026, with verification work concentrated in early 2027. We prepare the evidence file: monitoring plan, data flow diagram, metering records, laboratory analyses, calculation sheets and internal control records. Our list of the top 10 things checked in emissions verification summarises what verifiers look at first.

6. Importer communication

We deliver the operator emission report, and the verification report where needed, to each customer and answer follow-up questions up to the declaration deadline. A short explanatory note for your customer's procurement team turns the data into a commercial argument, not only a compliance document. Our view from the supplier side is in CBAM preparation: supplier perspective.

How long this takes depends on the number of installations and products, route complexity, existing metering, data availability from precursor suppliers and verifier scheduling. We review these together in the first conversation.

2026-2027 timeline

In practice, a verified 2026 operator emission report should reach the customer in good time for its declaration, ideally in the first half of 2027, the same window in which Turkish ETS installations submit their verified emission report and Activity Level Report (by 30 April 2027).

How CBAM interacts with the Turkish ETS

CBAM and the Turkish Emissions Trading System meet at the same installations. Under the KPK/2026/1 decisions of the Carbon Market Board and the procedures published on 1 October 2026, the TR ETS pilot period covers 2026 and 2027 and includes only category B and C installations in electricity generation, cement, iron and steel, aluminium and fertilisers. That list overlaps heavily with CBAM. The differences, side by side:

The common ground is measurement: fuel and material flows, meters, laboratory analyses and production records are the same in both systems. We therefore build the CBAM monitoring plan, the ETS monitoring plan and the Monitoring Methodology Plan on a single data model. Our ETS readiness service covers the Turkish side.

On the carbon price deduction, realism is needed. The 2027 pilot free allocation rate is 100% under the benchmark method, and the Commission's Questions and Answers document treats free allocation as compensation netted out of the deductible price, so for an average installation the deduction is likely to stay limited. For installations above the benchmark that buy to cover a shortfall, documenting each TR ETS surrender and purchase at product level may matter later.

Sector-specific points

• Iron and steel: blast furnace versus electric arc furnace routes drive both embedded emissions and the free allocation adjustment; traceability of pig iron, direct reduced iron and semi-finished precursors is critical. See our iron and steel boundary guide.
• Cement: indirect emissions count and the clinker ratio is a product-specific parameter; with no Türkiye default for grey clinker and grey Portland cement, actual data matters even more. See our cement boundary guide.
• Aluminium: primary and secondary routes are treated separately; only direct emissions count under CBAM.
• Fertilisers: process emissions from ammonia and nitric acid production are monitored together with electricity-related indirect emissions.
• Hydrogen and electricity: the 50-tonne threshold does not apply; the obligation arises from the first import.

For EU importers buying from Türkiye

On the buying side, the same work answers your questions from the other direction. Before the 2026 declaration, it helps to know for each Turkish supplier whether a written monitoring plan exists, whether the operator emission report follows the standard template, which verifier will be used and whether that verifier holds EU CBAM accreditation for the sector, and how precursor emissions are being traced. Where a supplier cannot answer, the fallback is the marked-up default value; we can work with your Turkish suppliers directly, in Turkish, to close those gaps.

Why now?

2026 data is being generated right now. A measurement that cannot be reconstructed after year end, an energy flow that cannot be split or an undocumented precursor purchase means default values for 2026. With verifier capacity expected to be tight in early 2027, the monitoring plan and data flow should be in place before the year closes.

At Alalëa we treat CBAM as a data investment that strengthens the relationship between Turkish producers and their EU customers, not just a compliance task. To talk about your products, installations and customers, reach us through our contact page. If you need a corporate inventory first, our carbon footprint service lays the foundation.