CBAM Carbon Border Adjustment for Exporters: Data Guide

Who Is This Guide For?

This guide is for businesses that export products such as iron and steel, aluminium, cement or fertilisers to the European Union, or that supply companies manufacturing these products. The CBAM carbon border adjustment mechanism adds a new data obligation to exporting, and a common question follows: when an EU buyer asks for emissions data, what exactly should we prepare, and how? Below you will find a step-by-step answer, a document checklist and the points that need particular care.

What Is CBAM and Which Exporters Does It Affect?

CBAM (Carbon Border Adjustment Mechanism) is an EU regulation that puts a price on the carbon emissions released in producing certain goods entering the EU. Its aim is to apply to imported goods the same carbon cost that EU producers already bear, and to prevent production shifting to countries with looser rules.

The regulation currently covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Its scope is not limited to raw materials; certain intermediate and finished products made from them are also listed by customs tariff code. So even if you do not think of yourself as a "steel producer", the regulation concerns you if the code of the product you export appears on the list.

The formal obligation sits with the EU importer: they submit the declaration and obtain the required certificates. However, to declare correctly the importer needs actual emissions data from the producer. Where no data is provided, default values set by the EU may be used; these may not reflect your real performance and can increase your buyer's costs.

In short, CBAM is not a direct tax on the exporting producer, but it is a direct matter of competitiveness. CBAM effectively takes the company-wide emissions picture down to the level of individual products and installations.

How Do You Prepare Emissions Data for CBAM?

CBAM data is prepared by calculating the embedded emissions per product on the basis of installation-level measurements and records. It is not a one-off calculation but a monitoring system repeated at regular intervals. When building this system, the energy and fuel data gathered through corporate carbon footprint consultancy provides a strong starting point.

1. Check whether your products are in scope

The first step is to compare the customs tariff code of every product you ship to the EU with the CBAM product list. List the products in scope separately by the installation and production line where they are made.

2. Define installation boundaries and production processes

For a robust calculation, it must be clearly documented which parts of the installation and which production processes are included. If out-of-scope products are made at the same site, this is the stage to decide how energy and raw material consumption will be allocated between products.

3. Monitor direct and indirect emissions

Direct emissions come from burning fuel and from the production process itself; indirect emissions come from the electricity consumed in production. Since the type of emissions included in the declaration varies by sector, monitoring both separately is the safest approach.

4. Calculate embedded emissions per product

Total emissions for the relevant period are divided by the production volume for the same period to give a per-product value. If you buy in intermediate materials that are themselves in scope (for example, a semi-finished product bought for a steel product), their emissions should be requested from the supplier and added to the calculation.

5. Share the data with your buyer and prepare for verification

The calculated values are passed to the importer in line with the communication format set out by the EU. In the definitive phase of the regulation, data is expected to be checked by an accredited verifier, so every figure should be backed by a documented source.

CBAM Data Preparation Checklist

The key documents and information you should have ready for CBAM are listed below. This list will help you respond quickly and consistently to data requests from your buyer.

• Customs tariff codes of products exported to the EU, matched against the CBAM list

• Installation name, address, location details and description of production lines

• Fuel types and consumption volumes (invoices, meter readings)

• Electricity consumption records and, where possible, the electricity supplier's emission factor

• Quantity records of raw materials and inputs that generate process emissions

• Production volumes by period (per product and per line)

• Supplier emissions data for purchased in-scope intermediate materials

• A written description of the calculation method, emission factors and assumptions used

• Calibration records for measuring equipment

• Documents relating to any carbon price paid in the country of origin

• The person responsible for the data and the internal approval process

Common Mistakes and Points to Watch

A common mistake is assuming CBAM is solely the EU importer's concern and being caught unprepared by a data request. When a buyer asks for data at short notice, a business with scattered records either supplies an estimated figure or has to accept the default value.

Other points where businesses get stuck in practice:

• Assigning site-wide energy consumption directly to the in-scope product without separating out-of-scope products.

• Leaving out the emissions of purchased intermediate materials, or never asking suppliers for this data.

• Trying to use a corporate carbon footprint report instead of CBAM data; the corporate report looks at the company as a whole, while CBAM requires data per product and per installation.

• Not putting the calculation method in writing; if the method is not documented, the same figure cannot be reproduced in the next period and problems arise during verification.

• Sending different figures to different buyers; a single data set and a single responsible person keep things consistent.

As the implementing rules continue to evolve, it is also important to keep track of the current state of EU requirements and of Turkish climate legislation. A method that is correct today should be reviewed whenever the rules are updated.

Notes for Exporters in Antalya

In Antalya, CBAM is particularly relevant to industrial businesses exporting directly or indirectly to the EU, such as metalworking, aluminium joinery and profiles, and building materials manufacturing. Fresh fruit and vegetables and ornamental plants, which are among the region's prominent exports, are not within the current scope, and tourism businesses have no direct obligation under this regulation.

That said, the indirect effect should not be overlooked. Local firms supplying semi-finished products or components to a larger exporter may receive emissions data requests from their customers. Businesses supplying construction and building materials to EU projects may face the same question.

Given that the scope of the CBAM carbon border adjustment mechanism may widen in future, keeping energy and production records in good order now is a sensible step for any business that exports or supplies exporters.

Frequently Asked Questions

Under CBAM, does the exporter or the importer submit the declaration?

The declaration obligation lies with the EU importer. However, the importer reports the product's embedded emissions on the basis of data provided by the producer. In practice, therefore, supplying accurate and documented data becomes essential for the exporter's relationship with the buyer.

How do I know whether my product falls under CBAM?

You can find out by comparing your product's customs tariff code with the CBAM product list published by the EU. Because the list is organised by code rather than by sector name, some finished products may fall within scope alongside raw materials. If you are unsure, it is advisable to check together with your customs broker and environmental consultant.

What happens if we do not provide emissions data for CBAM?

Where actual data is not provided, default values set by the EU may be used. These values may not reflect your installation's real performance and may mean higher costs for your buyer. This can put you at a disadvantage against competing suppliers.

Is a corporate carbon footprint calculation enough for CBAM?

On its own it is not enough, but it is a good starting point. A corporate calculation covers the company as a whole, whereas CBAM requires data calculated per product and per installation according to specific methodological rules. The energy and fuel records collected for the corporate calculation can form the basis of the CBAM calculation.

Contact Us

If you export to the EU or supply an exporter, let us assess together how ready your emissions data is for CBAM. Get in touch with any questions, and we can build a data preparation plan suited to your installation.

Written by Selin Sevinç, Environmental Engineer (MSc), Asel Çevre Danışmanlık.