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
CBAM declarations are quarterly; reports are uploaded to the EU CBAM Registry portal. If independent verification is required, you engage one of the Big Four (KPMG, EY, PwC) — we provide the underlying infrastructure; they sign off.
A Pragmatic Note for Smaller Exporters
If your EU exports are below ~150 tonnes/year you may be exempt. Our recommendation nonetheless: start measuring now. Two reasons:
- The 2027 threshold is expected to drop
- Your customers (Mercedes, Bosch and other large EU buyers) will request your emissions data to complete their own reports regardless of thresholds
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.