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TürkçeCBAM is not a reporting exercise. It is a financial risk.
Recarbeng OÜ helps Exporters Outside The EU and EU importers turn CBAM from a cost burden into a competitive advantage — through engineering-grade emission data, pre-verification support, and regulatory expertise.
Why default values are your competitor's advantage
When actual emission data is not available, EU importers apply EU-assigned default values. Those values are intentionally conservative and often well above real plant performance. The cost difference flows straight into price negotiation and supplier selection.
Default Values Are Prudential
For goods other than electricity, the regulation bases default values on country averages plus a mark-up, and can fall back to worse-performing EU installations where reliable country data is unavailable. If your real emissions are lower, your buyer still budgets against the higher number unless you provide a robust actual-data package.
The Cost Falls on Your Buyer — And Then on You
Your EU buyer purchases CBAM certificates based on embedded emissions in your goods. Higher declared emissions mean higher certificate costs, which quickly feed into procurement decisions, annual budgeting, and net price negotiations.
Accredited Verifier Capacity Is a Real Constraint
From 2026, actual values in the definitive period need verification support. Companies that wait too long risk using defaults simply because their data pack, methodology, and evidence file are not ready in time for verifier review.
The Clock Is Not on Your Side
EU buyers set supply-chain prices months in advance. If your emissions file is not verification-ready before commercial planning starts, your buyer may price 2027 deliveries using conservative assumptions — and move to a supplier that came prepared.
Three service tiers. One integrated approach.
Whether you are a Exporters Outside The EU building an emission-data baseline or an EU importer seeking to reduce CBAM certificate costs, Recarbeng OÜ provides end-to-end support grounded in engineering methodology and role-appropriate compliance boundaries.
Emission Data Advisory
For Exporters Outside The EU in steel, aluminium, cement, fertilisers, and hydrogen, we build your actual-emission data foundation from production-process data.
- Scope 1 and relevant indirect-emission calculation per product unit
- CBAM-aligned MRV setup and documentation logic
- Default-versus-actual gap analysis
- Process, mass-balance, and precursor data structuring
- Customer-ready CBAM data package
- Annual emission intensity benchmarking
Verification Readiness Support
We prepare your complete emissions-data package to the standard expected by accredited verifiers — reducing verification time, cost, and rejection risk.
- Pre-verification audit of data quality and internal controls
- Alignment with Regulation (EU) 2023/956 Annex IV and Implementing Regulation 2025/2547
- Production-process boundary definition
- Precursor material emission tracing
- Indirect-emission review where applicable
- Liaison support with independent accredited verifiers
Supply Chain Cost Reduction
For EU importers sourcing from Turkey, we extract actual-emission data from your suppliers and convert it into measurable CBAM certificate savings.
- Supplier-emission data collection and validation
- CBAM certificate cost modelling and budgeting scenarios
- Supplier readiness assessment
- Annual CBAM cost forecast
- Supplier engagement templates
- Ongoing regulatory monitoring
From first contact to verified data package
A structured four-step process designed to move fast — because your buyer's pricing cycle will not wait.
Free Scope Assessment
We assess your products against CBAM HS codes, identify which goods fall within scope, and quantify your current default-value exposure. No cost.
Data Collection & Calculation
We work with your production and engineering teams to collect process-level energy and material data and calculate actual embedded emissions per tonne.
Pre-Verification Package
We prepare a complete, verifier-ready emissions-data package aligned with EU requirements and buyer documentation needs for the CBAM Registry process.
Ongoing Advisory
CBAM rules evolve — including default-value revisions and potential scope expansion. We keep your competitive position current and your data process repeatable.
The bridge between Tallinn, Brussels and Ankara
Engineering-grade technical capability, full EU legal standing, and direct knowledge of Turkish industrial operations — in one firm.
EU-Based Legal Entity
Recarbeng OÜ is registered in Estonia (Registry Code 17414220), a full EU member state. We operate under EU law and issue EU-compliant documentation.
Engineering-First Methodology
Our founder is a mechanical engineer specialising in carbon capture and industrial decarbonisation. We calculate emissions from process data — not spreadsheet assumptions.
Direct Turkish Industrial Knowledge
We understand Turkish steel, aluminium, cement, and fertiliser production. We speak the plant language — literally and technically — for faster, more accurate data collection.
Current Regulatory Mastery
We actively monitor the CBAM framework, the definitive-period calculation rules, the authorised declarant rules, and verification principles. Your advice stays current and implementation-focused.
EU 2023/956CBAM Regulation — Core framework establishing scope, annual declaration, certificate system, and the role of the authorised CBAM declarant.
EU 2025/2547Calculation Methodology — Detailed embedded-emissions calculation methods, including combined use of actual and default values for complex goods.
EU 2025/2549Authorised CBAM Declarant — Operational rules for applying via the CBAM Registry and for delegation mechanics.
EU 2025/2546Verification Principles — How verifier activities, site visits, and risk-based verification procedures are structured.
EU 2025/2551Verifier Accreditation — Requirements for accredited verifiers and independent review of verification reports.
Questions we solve before they become CBAM costs
The wording below reflects the current definitive-period CBAM framework and the operational boundaries between importer, exporter, declarant, and verifier.
Can exporters outside the EU file the annual CBAM declaration?
No. The annual declaration is filed by the authorised CBAM declarant through the CBAM Registry. The exporter’s task is to deliver accurate installation and product data that the declarant can rely on.
What happens if the importer is not established in the EU?
In that case, the indirect customs representative becomes central. If the importer is not established in a Member State, the indirect customs representative applies for the authorisation and carries the relevant CBAM role.
When are the annual declaration and certificate surrender due?
For goods imported in 2026, the first annual declaration is filed by 30 September 2027 and the first surrender of CBAM certificates also takes place by 30 September 2027. Recarbeng helps clients prepare the underlying data package well before those deadlines.
Do actual values always need verification?
Where actual values are used in the definitive period, the operator’s emissions report must be ready for accredited verifier review. We prepare the evidence file and methodology; the independent verification itself remains separate.
Why not just rely on default values?
Because default values are conservative by design. If your plant performs better than the default, the buyer may still pay certificate costs as if you were a higher-emission supplier. That commercial gap can cost more than the data work needed to avoid it.
Can Recarbeng act as the legal declarant or accredited verifier?
No. Recarbeng does not step into the legal role of the authorised CBAM declarant and does not present itself as the independent accredited verifier. Our role is engineering support, data-pack preparation, verification readiness, and importer-exporter coordination.
Let's calculate what CBAM actually costs you — today.
Book a free 30-minute scope assessment. We will identify which of your products fall within CBAM scope, estimate your current default-value exposure, and outline a clear path to defensible actual-emission data.