CBAM – Carbon Border Adjustment Mechanism Verification

CBAM – Carbon Border Adjustment Mechanism Verification

A new era has begun for Turkish companies exporting to the EU. The European Union's Carbon Border Adjustment Mechanism (CBAM), officially entered its definitive phase on 1 January 2026, making independent verification of embedded carbon emissions mandatory for products in the cement, iron & steel, aluminium, fertiliser, electricity and hydrogen sectors exported to the EU.

As QSI Belgelendirme, our company DANEM Verification & Validation, based in Riga, Latvia, has submitted an accreditation application to LATAK, and our accreditation is expected to be published shortly. Document your embedded emissions under CBAM requirements; accurately calculate your CBAM certificate costs at the EU border and manage your commercial risk.

What is CBAM?

Introduced under the EU's European Green Deal policy, CBAM (Regulation (EU) 2023/956 and 2025/2083) aims to apply a carbon cost to carbon-intensive goods imported into the EU equivalent to that borne by EU producers. The mechanism is designed to prevent carbon leakage and create a level playing field on a global scale.

Sectors covered:

  • Iron and steel (crude steel, rolled products, steel pipes, etc.)
  • Aluminium (primary aluminium, profiles, foil, etc.)
  • Cement
  • Fertilisers (ammonia, nitric acid, nitrogen-based fertilisers)
  • Electricity
  • Hydrogen

Turkish producers exporting more than 50 tonnes of these products per year to the EU are required to document their embedded emissions through authorised verifiers.

Why is Verification Required?

TopicExplanation
Legal obligationFrom 2026 imports onwards, embedded emissions must be confirmed by an accredited verifier
Financial impactFrom 2027, CBAM certificates must be purchased; certificate price is linked to the EU ETS price (~€75/tCO₂e)
On-site audit in first yearRemote audits are not accepted for 2026 data verifications; on-site visits are mandatory
Penalty riskNon-compliance results in a penalty of €100 per tonne
Competitive advantageOnce Turkey's national ETS (TR-ETS) is recognised, carbon prices paid domestically may be deducted from CBAM costs

QSI CBAM Verification Process

  1. Application and Scope Definition: The verification scope is determined according to product types, production processes and export volumes. The calculation methodology required by CBAM (actual values or default values) is agreed with the client.
  2. Review of Emissions Data: The monitoring plan, energy consumption data, process emissions and supply chain data are examined. System boundaries (direct and indirect emissions) are defined in accordance with applicable standards.
  3. On-Site Audit: A physical site visit is conducted for the first verification year (2026 data); measurement systems, record-keeping procedures and data flows are reviewed on-site.
  4. Verification Report: A verification report signed by the accredited verifier is issued in accordance with Annex IV of the CBAM Regulation, ready for use by the EU importer in their CBAM declaration.
  5. Positive Opinion / Limited Assurance: A positive opinion or limited assurance statement is issued depending on the verification scope and evidence obtained.
  • Regulation (EU) 2023/956 – CBAM Regulation (primary legislation)
  • Regulation (EU) 2025/2083 – CBAM Omnibus Amending Regulation (in force: 20 October 2025)
  • Commission Implementing Regulation (EU) 2023/1773 – Transitional phase reporting rules
  • CBAM definitive phase implementation accreditation requirements (EA-6/03 guidance)
  • EN ISO/IEC 17029 – Accreditation standard for validation and verification bodies

Why QSI?

  • Latvian Accreditation (LATAK): Our accreditation process through our company DANEM Verification & Validation based in Riga, Latvia, is expected to be completed shortly.
  • EU-Recognised: Reports issued under the GAC Inc. MLA framework carry international validity.
  • Sector Experience: Hundreds of emissions verification assignments in the steel, aluminium, cement and fertiliser sectors.
  • One-Stop Service: CBAM verification + ISO 14064 carbon footprint + TR-ETS MRV verification under one roof.
  • Reliable Data: Using actual emission values yields significantly lower CBAM costs compared to default values.

Frequently Asked Questions

Who is required to have CBAM verification?

Verification is mandatory from 2026 imports onwards for all producers exporting more than 50 tonnes (net mass) in total per year of CBAM-covered products to the EU. Those below this threshold are exempt.

When is the verification report required?

The verification report for 2026 embedded emissions must be ready for inclusion in the annual CBAM declaration due 30 September 2027 by the authorised CBAM declarant in the EU.

If I use default values, do I still need verification?

Yes. Both businesses using actual values and those using default values are subject to verification. Default values are set based on EU Commission reference emission intensities and are generally significantly higher than actual values. Verifying actual emission data is the most effective way to optimise your CBAM costs.

What will happen when Turkey's ETS (TR-ETS) comes into effect?

If TR-ETS is recognised by the EU as an equivalent carbon pricing system, Turkish producers will be able to deduct the carbon price paid domestically from their CBAM liability. Reliable MRV infrastructure and accredited verification are critical for achieving this equivalence.

Is the verification report prepared in English?

QSI offers bilingual report options in Turkish and English. The final report for the EU importer's use is prepared in a format compliant with EU legislation.

Request a Quote

For information about our CBAM verification services and to request a quote, please contact us.

Tel: +90 312 472 60 67     E-mail: info@qsi.com.tr

Web: www.qsi.com.tr

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