On this page
- CBAM obligations for EU importers in the definitive period
- From quarterly reports to an annual declaration
- Why real supplier data reduces your CBAM cost
- Our CBAM support for importers
- How a Turkey-based team gets data from Turkish plants
- Supplier contract clauses for CBAM data
- How an importer project runs
- What we need from you
- What drives cost and timeline
If you import steel, aluminium, cement or fertilisers from Turkey, your CBAM bill depends on data that sits in your suppliers' plants. We collect that data in Turkish, check it, and prepare it for your annual CBAM declaration, so you can declare actual embedded emissions instead of default values with a mark-up.
CBAM obligations for EU importers in the definitive period
Since 1 January 2026, an importer bringing more than 50 tonnes of CBAM goods into the EU in a calendar year must be an authorised CBAM declarant. The threshold counts cement, iron and steel, aluminium and fertilisers together. Hydrogen and electricity are not covered by it, and once the 50 tonnes are passed, every tonne imported that year is in scope.
| Obligation | Rule |
|---|---|
| Authorisation | Authorised declarant status before importing above 50 tonnes. Applications filed by 31 March 2026 allowed imports to continue while pending. |
| Annual declaration | Filed in the CBAM Registry by 30 September for the previous year. The first covers 2026 imports and is due by 30 September 2027. |
| Certificate purchase | On the common central platform from 1 February 2027. Certificates for 2026 imports are priced at the 2026 quarterly average for the quarter of import. |
| Quarterly holding | From 2027, certificates covering at least 50% of embedded emissions of goods imported since the start of the year must be held at each quarter end. |
| Verification | Actual embedded emissions must be verified by an accredited verifier. Otherwise default values apply. |
| Repurchase | Excess certificates can be repurchased on request after surrender, by 31 October of the surrender year. Certificates from two years earlier still held on 1 July are cancelled. |
An indirect customs representative can apply for authorisation and act as declarant for the importer. An authorised declarant can also delegate the filing to a third party established in the EU, but stays responsible for the content.
From quarterly reports to an annual declaration
During the transitional period (October 2023 to December 2025) importers filed quarterly CBAM reports under Implementing Regulation (EU) 2023/1773, and many relied on estimates or default values. The last quarterly report, for Q4 2025, was due by 31 January 2026.
The definitive period works differently. There is one declaration a year, it carries a financial obligation, and actual figures must be verified. Data that was acceptable in a quarterly report, such as an unverified supplier email with a single emissions figure, will not support a declaration. Importers therefore need a supplier data process that runs through the year, not a scramble before 30 September.
Why real supplier data reduces your CBAM cost
The number of certificates you surrender equals embedded emissions, minus the free allocation adjustment and any carbon price effectively paid in the country of origin. The free allocation adjustment is based on EU benchmarks, so in 2026 it removes most of the obligation for goods made close to the benchmark. What remains is largely the gap between the declared emissions and the benchmark.
Default values for each country and CN code, set by Implementing Regulation (EU) 2025/2621 as corrected by Implementing Regulation (EU) 2026/1740, carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). For many products this widens the gap considerably. A supplier with verified actual data below the default can lower your certificate count, and the difference grows each year as free allocation falls.
Turkey has no carbon price that qualifies for a deduction yet. Its ETS Regulation entered into force in August 2026 with a pilot phase and free allocation, and the EU rules on recognising third-country carbon prices were still in draft in October 2026. Plan on no deduction for Turkish goods in 2026 and 2027.
Our CBAM support for importers
Supplier mapping and data collection
We start from your customs data: imports by CN code, country of origin, supplier and installation. For each Turkish supplier we identify the producing installation (which is not always the seller), contact the plant in Turkish, explain what is needed and why, and collect the emissions data with supporting evidence.
Plausibility checks
Each supplier figure is checked against the default value, the EU benchmark, typical values for the production route and the supplier's own previous submissions. We look for missing precursors, wrong CN codes, indirect emissions left out for cement or fertilisers, and data for the wrong reporting period. Implausible data goes back to the supplier with specific questions.
Declaration inputs
We prepare a consolidated data set per CN code and installation for your annual declaration: quantities, specific embedded emissions, production route, verification status and the free allocation adjustment inputs. You or your customs representative file it in the CBAM Registry. We do not act as declarant.
Authorisation and certificate planning
We help prepare the authorised declarant application and estimate the certificates needed each quarter from 2027, so cash flow for the 50% holding requirement is planned in advance.
How a Turkey-based team gets data from Turkish plants
Most importer data requests fail for practical reasons. The request goes to a sales contact who does not know what embedded emissions are, arrives in English, asks for a template the plant has never seen, and gives no reason to prioritise it. Our consultants call the plant's environment or energy manager in Turkish, refer to the Turkish MRV reports the plant already prepares, and explain the link between the data and the plant's own export price.
Where a supplier has never done a CBAM calculation, we can carry it out on site through our CBAM embedded emissions calculation service, paid by the importer or the supplier as agreed. One verified data set then serves all of that supplier's EU customers.
Supplier contract clauses for CBAM data
Many importers still buy CBAM goods under contracts written before 2026. A short CBAM annex avoids disputes later. The points we suggest covering are:
- The supplier's duty to provide specific embedded emissions per product and installation, split into direct and indirect, for each reporting year.
- A delivery date for the data that leaves time for verification, for example by the end of the first quarter after the reporting year.
- Who appoints and pays the accredited verifier, and access for the verifier's site visit.
- What happens if verified data is not supplied, such as a price adjustment based on the difference from default values.
- Confidentiality of production and process data shared with the importer or its consultant.
We do not draft legal contracts, but we can give your lawyers the technical content for these clauses and explain to Turkish suppliers what they are signing up to.
How an importer project runs
- Import analysis (1 week). Customs data for the reporting year, CN codes in scope, 50 tonne threshold check, supplier list.
- Supplier outreach (2 to 6 weeks). Contact, explanation, data request in Turkish, follow-up calls.
- Data review (1 to 3 weeks). Plausibility checks, questions back to suppliers, verification status for each data set.
- Default value comparison (1 week). Cost estimate with actual data and with default values, by supplier and CN code.
- Declaration package (1 to 2 weeks). Consolidated inputs for the CBAM Registry, method notes, evidence file.
- Ongoing cycle. Quarterly updates for certificate holding and supplier changes.
What we need from you
- Customs import data for CBAM goods (CN code, net mass, origin, supplier, date)
- Supplier contact details and any data already received
- Your EORI number and authorisation status
- Name of your customs representative, if one files on your behalf
What drives cost and timeline
The number of suppliers and installations matters most, followed by how many already have verified data and how many need an on-site calculation. Importers with a few large suppliers are quicker than traders with dozens of small ones. Start supplier work early in the year, because verifier capacity is limited and the first verification of each installation needs a site visit.
For the full picture of the mechanism, see our CBAM consulting page and the guide to CBAM changes in 2026.