CBAM is the European Union’s Carbon Border Adjustment Mechanism.

The mechanism links the greenhouse gas emissions embedded in certain products imported into the EU customs territory to the carbon price under the EU Emissions Trading System.

CBAM is not a customs duty in the conventional sense; it is a climate-policy instrument that brings the embedded emissions of imported products closer to the EU’s carbon-pricing framework.

Manufacturers within the EU face carbon costs under the EU Emissions Trading System. Moving production to countries with lower carbon costs, or replacing EU products with more carbon-intensive imports, creates a risk known as “carbon leakage.”

CBAM aims to reduce this risk by pricing embedded emissions in imported products and to encourage producers outside the EU to move towards lower-emission production.

The current core scope consists of specified products and inputs in the following sectors:

• cement,
• iron and steel,
• aluminium,
• fertilisers,
• electricity,
• hydrogen,
• certain precursors and downstream products defined in the annex to the legislation.

Scope is not determined solely by the name of the sector. What matters is whether the product’s CN/customs classification appears in Annex I of the CBAM Regulation. Not every product in the same sector is automatically covered.

If the customs code of the final product is not listed under CBAM, the product may not be directly covered. However, inputs such as steel or aluminium used in production may be affected by CBAM costs within the supply chain.

The EU is also evaluating the future expansion of the scope. Manufacturers currently outside the direct scope should therefore begin monitoring material-based emissions data and supplier carbon performance.

No. The legally obliged party is generally the authorised CBAM declarant importing the product into the EU, or the indirect customs representative under the conditions set out in the legislation.

The EU importer submits the declaration and surrenders the required CBAM certificates. The manufacturer in Türkiye is responsible for supplying its customer with accurate, traceable and, where required, verified emissions data at facility and product level.

For this reason, the view that “the importer pays the charge, so it does not concern us” is commercially incorrect. The importer may reflect the resulting cost in price negotiations, supplier selection or contractual terms.

The 2025 simplification introduced a single annual mass-based threshold of 50 tonnes per EU importer for CBAM goods other than electricity and hydrogen. Importers whose annual imports remain below this threshold are generally exempt from CBAM obligations.

The threshold is assessed according to the EU importer and its annual total imports, not per exporter in Türkiye or per shipment. Electricity and hydrogen are excluded from this mass-based exemption. The product code and import structure must be checked separately.

During the transitional period from October 1, 2023 to December 31, 2025, the principal obligation was emissions reporting; no CBAM certificates were surrendered.

The definitive period began on January 1, 2026. The deadline for the first annual CBAM declaration and certificate surrender covering 2026 imports is September 30, 2027. The sale of certificates corresponding to 2026 emissions will begin in 2027.

Embedded emissions are the greenhouse gas emissions associated with the production of a product covered by CBAM. The calculation is not simply the factory’s total carbon footprint divided by product tonnage.

The production process, installation boundaries, direct emissions, indirect emissions where applicable, precursors used, production quantity and the calculation methods defined in the legislation must be considered together.

For this reason, a corporate carbon footprint and a CBAM product-emissions calculation are related, but they are not the same report.

Although the required information varies by product and production route, the following data may be requested:

• installation and production-process information,
• product and precursor quantities,
• fuel consumption and fuel characteristics,
• process-related emissions,
• electricity consumption and relevant emission factors,
• production quantity and product-level allocation method,
• specific embedded-emissions value,
• any carbon price effectively paid in the country of origin,
• verification report and supporting records.

The data must be traceable through meters, invoices, inventory records, laboratory results and production reports.

During the definitive period, actual emissions values used in declarations must be verified in accordance with CBAM rules. Verification does not examine only the final figure; it also assesses the monitoring plan, data sources, calculation method, control environment and risks of material misstatement.

It is therefore not enough for the manufacturer to prepare a table at year-end. The metering and record system must produce verifiable data throughout the year.

Default values may be used under the conditions permitted by the legislation. However, a default value may not reflect the installation’s actual performance and may make the advantage of a low-carbon producer invisible.

For the EU importer, missing, late or unverifiable data creates cost uncertainty and compliance risk. This may affect the manufacturer’s price negotiations, order continuity or evaluation as a new supplier.

The basic principle is that the relevant embedded emissions of the imported product are covered by CBAM certificates reflecting the EU ETS carbon price. Adjustments corresponding to free allocation provided to EU producers and an eligible carbon price effectively paid in the country of origin may also be taken into account under the applicable rules.

Therefore, as the product’s carbon intensity decreases, the potential CBAM liability faced by the importer also falls. The final calculation is not merely a simple multiplication; it is performed according to the product, period and applicable adjustments.

If a carbon price has effectively been paid in the country of origin for the embedded emissions, it may be deducted from the CBAM obligation in accordance with the required evidence and EU rules.

However, general environmental taxes, voluntary carbon credits or every sustainability expenditure do not automatically qualify as a “carbon price paid.” Eligibility, actual payment and deduction conditions must be documented in accordance with the legislation.

Its impact is not limited to an additional cost. CBAM also:

• changes the customer’s supplier-selection criteria,
• adds carbon intensity to product pricing,
• creates metering and verification costs,
• can provide a competitive advantage to lower-emission manufacturers,
• accelerates investments in energy, raw materials and production routes,
• brings data responsibility and cost sharing into export contracts.

Between two manufacturers with similar carbon intensity, the one that provides higher-quality and more reliable data may also gain a commercial advantage.

No. Renewable electricity may reduce indirect emissions for certain products, but it does not by itself eliminate process emissions, fossil-fuel use or carbon-intensive precursor inputs.

An effective reduction plan must consider energy efficiency, electricity supply, fuel switching, process technology, recycled raw materials, product design and supplier data together. How each measure is reflected in the CBAM calculation must be verified against the applicable calculation rules.

1. Confirm product scope: Check the CN/customs codes of exported products against CBAM Annex I.

2. Define installation and process boundaries: Identify production routes, precursors and data owners.

3. Establish a monitoring system: Build a measurement and record chain for fuel, electricity, process emissions and production data.

4. Calculate product emissions: Prepare specific embedded-emissions values according to the CBAM methodology.

5. Prepare the data for verification: Make evidence, internal controls and calculation files auditable.

6. Build a reduction roadmap: Prioritise projects according to emissions impact, investment cost and commercial value.

7. Clarify customer contracts: Define the data format, delivery date, confidentiality, default-value risk and cost sharing clearly.

Zerbon treats CBAM preparation not merely as a reporting exercise, but as a shared issue of production, energy and commercial competitiveness.

After product scope and data gaps are identified, the installation’s energy flows, process emissions, metering infrastructure and production records are assessed. A verifiable data system and technical emissions-reduction projects are then combined within the same roadmap.

The objective is not merely to send an emissions figure to the customer, but to identify implementable engineering projects capable of reducing that figure.