CBAM Consulting for Exporters to the EU

CBAM consulting is about one number: the tonnes of CO2 embedded in each tonne of cement, steel, aluminium, fertiliser, hydrogen or electricity that enters the EU. We calculate that number at the producing plant, prepare it for an accredited verifier and hand it to the EU importer in the form the CBAM Registry expects. Our team is based in Turkey, the largest non-EU supplier of several CBAM goods, and works in Turkish with plant staff and in English with importers.

What is CBAM

CBAM, the Carbon Border Adjustment Mechanism, is an EU charge on the greenhouse gas emissions embedded in certain imported goods. Set up by Regulation (EU) 2023/956, it requires EU importers to buy CBAM certificates priced at the EU carbon price, so that imported cement, iron and steel, aluminium, fertilisers, hydrogen and electricity carry a carbon cost similar to EU-made products.

The mechanism mirrors the EU Emissions Trading System (EU ETS). EU plants pay for their emissions through ETS allowances, and as their free allowances are phased out between 2026 and 2034, CBAM applies the same cost to imports. The importer pays, but the data comes from the non-EU producer. That is why CBAM has become a supplier issue for every Turkish plant that ships these goods to Europe.

The legal base is Regulation (EU) 2023/956, amended by the simplification regulation Regulation (EU) 2025/2083, with detailed rules in a set of Commission implementing acts adopted in late 2025. The European Commission CBAM pages carry the current guidance and certificate prices.

CBAM timeline and deadlines

CBAM moved from a reporting exercise to a financial obligation on 1 January 2026. The dates below reflect the regulation as amended by the 2025 Omnibus and the position as of October 2026.

Which goods and companies CBAM covers

CBAM applies to goods listed by Combined Nomenclature (CN) code in Annex I of the regulation. The CN code on the customs declaration decides whether a shipment is in scope, so the first check is always a product list matched against Annex I.

Three groups carry the work. The EU importer, or an indirect customs representative acting for it, holds the legal obligation as an authorised CBAM declarant. The non-EU operator, meaning the plant that makes the goods, holds the emissions data. Customs representatives and freight forwarders sit in between and often coordinate the paperwork.

Since the Omnibus amendment, importers that bring in 50 tonnes or less of CBAM goods per calendar year (across cement, iron and steel, aluminium and fertilisers combined) are exempt. Hydrogen and electricity are outside this exemption. If an importer goes over 50 tonnes at any point in the year, all of that year's imports fall under CBAM. The threshold removes many small buyers of screws or fittings, but nearly all industrial volumes remain in scope.

How CBAM is calculated and paid

The importer declares the embedded emissions of the goods it imported in the previous year and surrenders one CBAM certificate per tonne of CO2e. Three deductions reduce that number.

1. Free allocation adjustment. EU producers still receive some free ETS allowances until 2034, so the obligation is reduced by an amount based on the EU benchmark for that product. The method is set in Implementing Regulation (EU) 2025/2620.
2. Carbon price paid in the country of origin. Under Article 9, a carbon price effectively paid abroad, net of any rebate or compensation, can be deducted. The implementing rules were still in draft in October 2026.
3. Actual rather than default values. Where the producer cannot supply verified data, the importer must use the Commission's default values, which include a mark-up. Under Implementing Regulation (EU) 2025/2621 the mark-up is 10% in 2026, 20% in 2027 and 30% from 2028 for most goods, and 1% for fertilisers.

In 2026 the free allocation adjustment removes most of the cost for a plant performing close to the EU benchmark. The emissions above the benchmark are paid in full. That is why an inefficient plant, or a plant that falls back on default values with a mark-up, faces a much higher bill than a well-documented one, even in the first year.

What CBAM means for Turkish producers

Turkey is one of the main exporters of steel, cement, aluminium and fertilisers to the EU, so its plants received importer data requests early in the transitional period. Many of them already report verified emissions under the Turkish monitoring, reporting and verification (MRV) regulation, which follows EU ETS principles. That is a useful starting point, but CBAM asks for more: emissions attributed to each production process, precursor data, product-level specific embedded emissions and CN code mapping.

Turkey's Climate Law No. 7552, published on 9 July 2025, created the legal basis for a national emissions trading system. The Turkish ETS Regulation entered into force on 27 August 2026 and starts with a pilot phase, and a market operation regulation followed on 21 October 2026. During the pilot, allowances are expected to be allocated free of charge, so a Turkish exporter should not count on a CBAM deduction for a carbon price paid in Turkey in 2026 or 2027. We track the Carbon Market Board decisions and will update clients when a deductible price exists.

Common gaps in CBAM data from suppliers

Most of the supplier data we reviewed during the transitional period would not pass verification in its original form. The problems repeat from plant to plant.

• A single site-wide emissions figure divided by total production, with no split between production processes or products.
• Precursors bought from other plants left out, so a steel tube carries only the emissions of the tube mill.
• Indirect emissions omitted for cement or fertilisers, or added for steel where they are not part of the obligation.
• Figures for the wrong period, often a financial year or a single month, instead of the reporting year.
• Product carbon footprint results under ISO 14067 or an EPD offered as CBAM data, although the boundaries and rules are different.
• No evidence trail behind the number, which makes verification impossible.

Each of these either overstates the importer's cost or forces a fall-back to default values. Fixing them at source, once, is cheaper than repeating the conversation with every EU customer.

Penalties and enforcement

An authorised declarant that does not surrender enough certificates by 30 September pays a penalty aligned with the EU ETS excess emissions penalty, EUR 100 per tonne of CO2e indexed to inflation, and still has to surrender the missing certificates. Importing above the 50 tonne threshold without authorisation can lead to a higher penalty set as a multiple of that amount, and customs authorities can refuse to release undeclared goods. National competent authorities check declarations, and the Commission can review them within set time limits.

Our CBAM consulting services

We work on both sides of the border. Most projects start with a Turkish producer whose EU customers need data, or with an EU importer that needs data from Turkish suppliers.

For producers and exporters of CBAM goods

We define the installation boundary and production processes, map products to CN codes, set up a monitoring methodology in line with Implementing Regulation (EU) 2025/2547, and calculate direct and indirect specific embedded emissions for each product group. The result is a verification-ready emissions report and the data set your EU customers need for their declarations. Details are on our CBAM embedded emissions calculation page.

For EU importers and customs representatives

We collect real emissions data from Turkish suppliers, check it for plausibility, compare it with default values and prepare the inputs for your annual CBAM declaration in the CBAM Registry. We also help with the authorised declarant application and the quarterly certificate holding plan. See CBAM support for EU importers.

Verification readiness

From 2026, actual embedded emissions used in a CBAM declaration must be verified by a verifier accredited under Delegated Regulation (EU) 2025/2551. Ekol Çevre is not a verifier. We prepare the monitoring documentation, evidence files and data trail the verifier will check, attend the site visit with your team and close any findings.

How a CBAM project runs

1. Scoping (1 to 2 weeks). Product list against Annex I, sales to the EU by CN code, existing MRV and energy data, and the importers that need data.
2. Installation and process mapping (2 to 3 weeks). Site visit, boundary definition, production processes, source streams, precursors bought in or made on site, electricity supply.
3. Monitoring methodology (2 to 4 weeks). Calculation or measurement approach per source stream, metering and laboratory evidence, data flow and control activities, written up as monitoring documentation.
4. Calculation (2 to 3 weeks). Attributed emissions per process, specific embedded emissions per product, comparison with default values and EU benchmarks.
5. Importer communication (1 week). Data sets for each customer, an English summary of method and assumptions, and a channel for follow-up questions.
6. Verification support (timing set by the verifier). Pre-verification review, site visit support, response to findings.
7. Annual cycle. Updated data for each reporting year and changes when products, fuels or suppliers change.

A single-product plant with good MRV data can be ready in six to eight weeks. An integrated steel works or a multi-product fertiliser site usually needs three months or more.

Data we need from you

What you receive

• A product and CN code scope analysis against Annex I
• Monitoring methodology documentation for the installation
• Emissions calculation workbook with a full audit trail
• Specific embedded emissions per product, direct and indirect
• Importer data sets in the Commission communication template or an agreed format
• A gap list and evidence index for the accredited verifier

What drives the cost and timeline of CBAM compliance

We quote per project after scoping. The main drivers are the number of production processes and CN code groups, whether precursors are made on site or bought in, the quality of existing metering and laboratory data, and whether the plant already has a Turkish MRV monitoring plan. Importer projects scale with the number of suppliers and how responsive they are. Annual updates cost much less than the first year, because the methodology and data flows are already in place.

Why a Turkey-based CBAM team helps

Most of the effort in CBAM sits inside the plant: reading fuel invoices, matching meters to processes, interviewing the energy manager and the quality laboratory. Our consultants do this in Turkish, on site, from offices in İzmir, Ankara and Kocaeli, which are close to the main steel, cement and aluminium clusters. We also know the Turkish MRV regulation and the new ETS rules, so the CBAM data and the national reporting stay consistent.

For EU importers this means one contact who can reach Turkish suppliers directly, explain what the data is for and return it in English with the method documented. For Turkish producers it means one data set that serves several EU customers instead of answering each questionnaire separately.

Related services and guides

CBAM data overlaps with product carbon footprints and corporate inventories. Plants that already calculate a product carbon footprint under ISO 14067 can reuse much of the activity data, although the CBAM boundaries are narrower. For background reading, start with our guide What is CBAM and the summary of changes in the 2026 definitive period.