CBAM 2026 Countdown: A Readiness Guide for Turkish Manufacturers Exporting to the EU

The European Union's Carbon Border Adjustment Mechanism (CBAM) began its transition period in 2023 and enters full force on 1 January 2026. Affected products: iron-steel, aluminium, cement, fertilisers, hydrogen and electricity. Turkish manufacturers exporting these goods must declare embedded carbon emissions per product in an audit-ready report. If you can't substantiate your numbers, the EU will apply the default (worst-case) carbon levy.

What Data Does a CBAM Declaration Need?

The report expects three data layers:

• Direct emissions (Scope 1): fuel combustion and process emissions on your site (natural gas, coal, process CO₂)
• Indirect emissions (Scope 2): emissions from purchased electricity and heat (Türkiye grid factor via TEİAŞ)
• Product embedded emissions: per-unit kgCO₂e derived from the BOM and energy intensity of your line

For the report to be accepted, the methodology must align with the GHG Protocol Corporate Standard and ISO 14064-1, and every emission factor must be traceable (DEFRA, EPA, IPCC, TÜV).

Five Steps to Readiness

1. Data Inventory (by March 2026)

Collect the last 12 months of fuel invoices, electricity consumption reports and production output. If you run an ERP, export the data directly — collecting it from Excel is slow and error-prone.

2. Scope Determination

List the products you export to the EU and their Harmonised System / TARIC codes. CBAM only covers specific codes; outside that list no declaration is needed.

3. Emission-Factor Selection

For purchased electricity use the Türkiye grid factor (0.442 kgCO₂/kWh, 2024 data), natural gas per DEFRA, process emissions per IPCC. The Birasyo Sustainability module ships these factors updated; you only enter consumption.

4. Product Carbon Footprint (PCF)

Per product: BOM × line energy intensity × emission factor = kgCO₂e. Manageable in Excel for 10 SKUs, unworkable at 50+. Birasyo calculates PCF inside the production module — change the recipe and the footprint updates automatically.

5. Reporting and Verification

The CBAM transition period reporting was quarterly — the final quarterly report was due 31 January 2026 covering Q4 2025. From 1 January 2026 the cadence becomes annual: the first annual CBAM declaration is due 30 September 2027 covering calendar year 2026, and every 30 September thereafter.

Reports are uploaded to the EU CBAM Registry portal. Independent verification must be performed by a verifier accredited under EU Implementing Regulation 2018/2067 (the same accreditation framework as the EU ETS) — specifically authorised for CBAM. This is a defined regulatory category, not a "Big Four" monopoly: accredited verifiers include TÜV NORD, Bureau Veritas, DNV, SGS, DEKRA and others. Birasyo provides the underlying data and audit trail; the accredited verifier performs the assurance engagement and signs the verification report.

A Pragmatic Note for Smaller Importers

The CBAM de minimis threshold introduced via the 2025 Omnibus simplification package is 50 tonnes per importer per year (cumulative across all CBAM goods, with limited exemptions for power and hydrogen). Importers below this threshold are exempt from full obligations.

Our recommendation nonetheless: start measuring now, even if your buyers fall below the threshold. Two reasons:

1. Future legislative reviews may tighten the threshold
2. Your customers (Mercedes, Bosch and other large EU buyers) will request your emissions data to complete their own reports regardless of any importer-side exemption

How Birasyo Maps to CBAM

Our Sustainability module is live today (Scope 1-2, emission-factor library, target management, TSRS reporting). Product Carbon Footprint (PCF) ships in 2026 Q3, aligned with the first CBAM reporting periods. If you export to the EU, start data collection today — January 2026 is closer than it sounds.

Request a tailored assessment of your export profile through demo; the request is routed to a sustainability consultant.

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Update — 28 April 2026: This article was revised based on expert reader feedback. Three corrections were applied: (1) the de minimis threshold under the CBAM Omnibus is 50 tonnes/importer/year (not the earlier 150 tonnes figure), (2) the reporting cadence transitioned from quarterly (final report 31 Jan 2026 for Q4 2025) to annual from 1 Jan 2026, with the first annual declaration due 30 Sep 2027, and (3) verification must be performed by a verifier accredited under EU Implementing Regulation 2018/2067 specifically for CBAM — not a "Big Four" monopoly. Thanks to Saul Rubins (Product, Supply Chain Sustainability and Compliance Manager) for the careful read.