What Data Turkish Suppliers Will Be Asked to Provide to Their EU Buyers Under CBAM in 2026

The European Union's Carbon Border Adjustment Mechanism (CBAM) moves from its transitional phase to definitive implementation starting 1 January 2026, with full financial obligations from EU importers beginning then. For Turkish suppliers selling into the EU in the affected sectors, this means your EU buyers will now ask for emissions data in a more structured way, and may price your goods differently if you cannot provide it. This guide explains what's actually expected and how to prepare.

What CBAM is, briefly

CBAM is the EU's mechanism to put a price on carbon emissions embedded in certain imported goods, equivalent to what EU-based producers pay under the EU Emissions Trading System (ETS). It is designed to prevent "carbon leakage": companies relocating production outside the EU to avoid carbon costs.

In practice, EU importers buying CBAM-covered goods must:

1. Report the embedded emissions of the goods quarterly during the transitional phase, which ran from October 2023 to the end of 2025 (no financial cost)
2. For goods imported from 1 January 2026, purchase and surrender CBAM certificates corresponding to those emissions; certificates go on sale on 1 February 2027 and the first annual declaration is due by 30 September 2027
3. From 2026, declare actual embedded emissions verified by accredited verifiers

The cost falls on the EU importer. But the data flows from the non-EU producer. That's where you, the Turkish supplier, come in.

Which sectors are affected

CBAM covers these product categories (CN-coded):

• Iron and steel (most of CN chapters 72-73)
• Aluminium (most of CN chapter 76)
• Cement (CN chapter 25)
• Fertilisers (CN chapter 31)
• Hydrogen
• Electricity (cross-border)

For Türkiye, this is significant because iron, steel, aluminium and cement are major export categories to the EU. Many Turkish manufacturers will be affected.

What your EU buyers will ask for

If you are a Turkish supplier shipping CBAM-covered goods into the EU, expect requests in the following format:

1. Embedded emissions per ton of product.

Measured in tonnes of CO2-equivalent per tonne of goods. Includes both direct emissions (from your production process, Scope 1) and certain indirect emissions (notably from electricity used in production, Scope 2).

2. Calculation methodology.

The EU prefers actual measured emissions, calculated according to specific rules in CBAM Implementing Regulations. Default values are available but penalise the importer (typically higher than actual). So you'll be asked to provide actual data, not defaults.

3. Verification status.

By 2026, verified data is preferred. Verification is performed by an accredited verifier (a third-party body). Costs vary but are not trivial.

4. Frequency of update.

The importer's CBAM declaration is annual from 2026, so data is needed for each calendar year. Many buyers still ask for interim updates during the year.

How to prepare your operations

If you are a Turkish manufacturer in a CBAM-covered sector, three practical preparation steps:

Step 1: Identify your installation boundary.

Define exactly which production processes count as "your production" for CBAM purposes. This is often the most contested step. Includes upstream processes you own; excludes purchased intermediates.

Step 2: Set up emissions accounting.

Track:

• Fuel consumption (natural gas, coal, fuel oil) and convert to CO2 using IPCC emission factors
• Electricity consumption (multiplied by the Turkish grid emission factor, which is publicly available)
• Process emissions (e.g., calcination CO2 in cement production)
• Production output in tonnes

Divide total emissions by total production = embedded emissions per tonne. This becomes your headline number.

Step 3: Document for verification.

Even before formally engaging a verifier, organise your data so that an external auditor could check it. Maintain:

• Monthly fuel consumption logs with invoices
• Electricity meter readings or invoices
• Production output records
• Process flow descriptions
• Emission factor sources cited

This documentation will be requested. Having it ready in advance is the difference between a smooth verification and a frantic one.

What is and is not changing in 2026

Changing: The financial obligation applies to goods imported from 1 January 2026. EU importers buy the certificates for 2026 imports from 1 February 2027 and surrender them by 30 September 2027. The certificate price is linked to the EU ETS auction price and is published by the European Commission (CBAM page).

Changing: Default values become less favourable, meaning if you don't supply actual data, your EU buyer pays more in CBAM costs, which they pass back to you as price pressure.

Changing: Verification becomes effectively required for credible reporting.

Not changing in 2026: the list of covered sectors. In December 2025 the Commission proposed extending CBAM to downstream steel and aluminium products from 1 January 2028. The proposal is still in the EU legislative process, so follow it if you make such products.

Not changing: Türkiye is not an EU member, so Turkish manufacturers do not pay CBAM directly. Your EU buyer does. But the cost flows back to you through pricing if you cannot demonstrate low embedded emissions.

A note on costs and competitive positioning

Some Turkish exporters worry CBAM is an existential threat. The reality is more nuanced:

• If your production is genuinely low-emission (using more electric arc furnace steel, more renewable electricity, etc.), CBAM may actually advantage you over competitors with higher-emission production.
• If your production is high-emission, you face price pressure from EU buyers who will either source elsewhere or demand discounts equivalent to the CBAM cost.

The strategic response is to measure honestly, identify the largest emission sources, and prioritise the highest-impact reductions (typically electricity sources and process efficiency).

How Birasyo helps

Birasyo's Sustainability module tracks production-linked emissions data alongside your normal ERP operations. Fuel consumption, electricity and production output are all already in your ERP. The Sustainability module aggregates this into the format your EU buyers need: emissions per tonne of product, broken down by source, ready for verification. We have built-in support for the CBAM data template that EU importers use.

Explore Birasyo Sustainability module

What to do now

CBAM in 2026 is a data requirement that flows back through pricing rather than a tax on Turkish exporters. Companies that prepare data systematically will preserve their EU market position; those that don't will face price pressure or lost business. The data needed already exists in most companies, and it needs to be organised, attributed correctly and verified. Starting in 2026, the EU buyer expects you to be ready.