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EU Carbon Border Adjustment Mechanism

CBAM / SKDM Compliance Engineering

CBAM is no longer only a transitional-period reporting issue. As of 1 January 2026, definitive-period obligations have started. For the party importing CBAM-covered goods into the EU, where applicable, the obligation is concentrated on theauthorised CBAM declarant. For the producer/exporter in Turkey, the critical need is to prepareproduct-level embedded-emissions data, methodology and evidence filein a defensible way that the customer or EU declarant can use. The required documents and actions must be ready when the accredited independent verifier visits the production facility.

Our Support Areas

  • Setting product and process boundaries in line with CBAM methodology
  • Preparing the data structure for calculating direct and indirect embedded emissions
  • Making records for energy, fuel, production, mass balance and precursor inputs traceable
  • Actual valuesreadiness and establishing the supporting evidence set
  • Preparing technical explanations and support files for the EU customer / authorised CBAM declarant

Company-Specific Services

  • Product/line-based production quantities and mass balance
  • Energy bills, meter data and fuel records
  • Process parameters, auxiliary-equipment consumption and precursor inputs
  • Existing ISO/MRV records, internal audit documents and evidence-file structure
  • The format or questionnaire requested by the EU customer / authorised CBAM declarant

Deliverables

  • Product/line-based embedded-emissions calculation file
  • Evidence package (audit-ready folder structure)
  • Risk matrix and missing-data action plan
  • Methodology note supporting the annual CBAM declaration of the EU declarant
Do Not Be Late in Building Your CBAM Infrastructure

For exports to the EU, verifiable data is becoming as important as the product itself

The transitional period ended on 31 December 2025. For goods imported in 2026, the first annual CBAM declaration will be submitted in 2027; the first certificate surrender will also take place in 2027.

For the producer in Turkey, the real issue is not only producing a calculation file; that file must be clear, consistent and auditable enough to be used by the EU customer or authorised CBAM declarant in the annual CBAM declaration. Especially whereactual valuesare used, the data, methodology and evidence set must be structured at a level suitable for review by an accredited independent verifier.

  • Correct definition of product and process boundaries
  • Actual-data readiness and evidence maturity
  • Reducing default-value risk
  • Technical and controlled responses to the questionnaire of the EU customer / authorised CBAM declarant
Sectoral approach

Focused CBAM / SKDM support for 6 sectors

Not every sector can be managed with the same data logic. Even processes on production lines may require different methodologies. Therefore, attention should be given to process-based infrastructure rather than ready-made packages. Work based on generic packages can create irreversible consequences during an independent verifier’s site visit. Even within the same product family, process route, energy structure, auxiliary inputs and evidence depth can create different risks. That is why we build a sector-based but controlled working model that does not expose internal company know-how.

Aluminium

In the aluminium sector, most indirect emissions are not included in CBAM emissions calculations, but one critical point must be considered. If production route, auxiliary processes, metal flow and precursor inputs are not read together, files that appear technically prepared may not be commercially convincing. Even if indirect emissions are not included in the emissions calculation, they should be calculated, filed with evidence documents and presented to the independent verifier.

When the primary/secondary structure, melting logic, product-line relationship and data defensibility are correctly structured, trust on the importer side is built much faster.

  • Product-line-based data flow
  • Consolidating energy and process data into a single-file logic
  • Controlled technical explanation that can be shared with the customer

Iron and Steel

In iron and steel, CBAM cannot be managed without understanding the production route. Sinter, pig iron, DRI, crude steel, semi-finished and downstream products do not carry the same risk profile.

In this sector, a small data-structure error can affect multiple product families. The real need is to establish a clear and traceable link between process boundary and product declaration.

  • Clarifying precursor material and process flow
  • Structuring the fuel/process distinction
  • Technical response infrastructure for importer questions

Cement

In cement, the emissions story is often read not from the product name, but from composition and production setup. Therefore, the product, clinker relationship and process boundary must speak the same logic.

A common issue in the field is that data exists, but does not come together in the same file with a CBAM perspective. We match composition logic with evidence structure to strengthen the commercial defensibility of the report.

  • Clarifying the product-clinker relationship
  • Traceability of energy and process data
  • Shareable but controlled methodology language

Fertilisers

In fertilisers, final product tonnage alone is not enough. Product composition, process route, intermediate products and energy relationship determine file integrity.

Most companies have production, laboratory and energy data; however, these data do not meet on the same projection under CBAM declaration logic. The value we create is precisely closing this technical gap.

  • Structuring composition and process logic in the same file
  • Organizing precursor data flow
  • Preparation for customer questionnaires

Hydrogen

In hydrogen, marketing language and regulatory language are often not the same. A “low-carbon” claim alone is not enough; production route, energy data, emissions boundary and evidence structure are assessed together.

For this reason, a strong hydrogen file comes not from ambitious wording, but from traceable and consistent data flow.

  • Readiness for actual data use
  • Early establishment of evidence architecture
  • Technical file that builds trust with the importer

Electricity

Electricity requires a different response from other sectors. Here, not only production but also cross-border flow, suitable methodology and document integrity become critical.

The approach of “we have production data” is often not enough. On the electricity side, technical suitability and document suitability must be managed together.

  • Clarifying suitable data boundaries
  • Strengthening document and evidence integrity
  • Defensible file structure for the importer
Key Points to Consider

Why can a CBAM file look ready but still not be ready?

Many companies think they are ready because they have collected energy bills, production quantities and internal reports. However, the risk often does not come from missing data, but from data not speaking within the same methodology.

The most common breaking points we see

  • Incorrect matching of product and process boundary
  • Missing precursor data or auxiliary-process effects
  • Confusing direct and indirect emissions logic
  • Evidence folder not structured according to verification logic
  • Technical explanation shared with the importer being too weak or too open

What do we do differently?

  • We build a defensible data story instead of a single number
  • We prepare shareable documentation without exposing internal know-how
  • We test verification readiness early
  • We build a technical bridge between customer expectations and site reality
Working model

How do we proceed?

  • Scope and product assessment
  • Data map and process-boundary analysis
  • SEE / embedded-emissions calculation structure
  • Evidence file and methodology notes
  • Preparation for the questionnaire of the EU customer / authorised CBAM declarant
  • Gap analysis and risk reduction
  • Verification readiness and technical file organization support
  • Short and clear decision summary for management

First step

Is your CBAM file really ready?

Let us assess your facility’s data maturity, scope clarity and risk areas against the EU customer / declarant together.