Buyer
When can you send the 2026 figures?
Embedded Emissions Management System
CBAM certificate price, Q2 2026:€75.28 / tCO₂eDon't pay the default value.
From your meter, ERP and lab data — the product-level* embedded-emissions file the EU accepts.
sample data
CN 7214 · 2026
Ø12 ribbed rebar0.68
Ø16 ribbed rebar0.67
Billet 130×1300.54
Wire rod 5.50.71
Profile L500.74
Angle bar0.73
Welded mesh0.80
CN 7214 20Ribbed rebar · EAF
0.68 tCO₂ / t
Embedded emissions · Annex IV · Q1 2026
Direct emissionsMeter + fuel analysis0.41
Precursor (billet)Supplier declaration0.27
ElectricityOut of scope, definitive regime—
Default value (2026, mark-up included)2.541 tCO₂e/t
− Your verified value: 0.68 tCO₂e/t
= Difference per tonne, at most€140.10
In 2028 the mark-up is 30% → at most €174.88/t
Declaration status2026
Data collected
Calculation complete
Evidence chain
Verifier
Delivered to buyer
Buyer
Ravenna, Italy
CBAM definitive regime
Definitive regime starts:1 January 2026Certificate sales open:1 February 2027First declaration and surrender:30 September 2027Certificate price, Q2 2026:€75.28Sectors in scope:6De minimis threshold:50 t/yrSteel scope:Direct emissionsVerification:Accredited verifier
Your own numbers
What does declaring on the default value cost you?
- Raw default value
- 1.41 tCO₂e/t
- With mark-up, computed (2026 10%)
- 1.551 tCO₂e/t
Pick a product and enter your annual export volume.
The gap between the default value and the real one
With no data of your own, you are priced on the default value. And that value grows every year.
Cement
Grey cement clinkerCN 2523 10 00Actual value, Turkish clinker0.88 tCO₂/t
Applicable default value, 20261.551 tCO₂e/t
Gap76%
Türkiye is listed in Annex I but its clinker rows are blank, so the "other countries" fallback applies (grey clinker 1.410 × the 10% mark-up for 2026). It is year-specific and attaches to TARIC 2523 10 00 90. Clinker and cement (CN 2523 29 00) are separate CBAM goods.
Actual value: TÜRKÇİMENTO (members represent ~94% of the sector). Default: IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740.
Steel
Hot-rolled flat productCN 7208Raw default value, Türkiye2.428 tCO₂e/t
Applied value, 2026 (10% mark-up)2.671 tCO₂e/t
Applied value, 2028 (30% mark-up)3.156 tCO₂e/t
2026 to 2028+18%
Unlike cement, Türkiye has its own listed values for steel in Annex I; this row is not a fallback. Marked-up figures are not published there — IR (EU) 2026/1740 removed those columns — and are derived from the total-emissions column. The benchmark deducted as the free-allocation equivalent depends on the production route, and its mapping to these CN rows is not yet verified, which is why the simulator gives steel as an upper bound.
IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740.
If you sell steel, cement or aluminium into the EU, the carbon in your product is now a line on your buyer's invoice.
See the CBAM timelineMeters
SCADA
MES
LIMS
ERP
Weighing
Shifts
Recipes
Energy
Fuel
Power
Precursors
One place for the whole declaration.
From raw plant data to a verified file.
Data collection from meters, SCADA, ERP and the lab
Data sources
Natural gas meterModbusLive
Electricity meterModbusLive
Production (ERP)RESTDaily
Fuel analysisLIMSMonthly
WeighingCSVPer shift
PrecursorSupplierDeclaration
Product-level maths Annex IV method, per CN code
Annex IV · calculation
Fuel combustion0.286
Process emissions0.074
Heat (imported)0.050
Precursor0.270
Total0.68
Verification pack with the evidence chain a verifier asks for
Verification file
PDFMeter calibration certificate
PDFFuel analysis report 2026-03
CSVProduction records Q1
XMLPrecursor declaration
XLSXCalculation ledger
PNGSystem boundary diagram
Handover to the buyer in the format their declaration needs
sample data
Ravenna, ItalyXML · CBAM
Hamburg, GermanyXLSX
Fos-sur-Mer, FrancePDF + XML
Cost by line which furnace drives your per-tonne load
Load by line · tCO₂/t
EAF 10.58
EAF 20.64
Rolling 10.71
Rolling 20.92
Reheating furnace0.66
Threshold 0.78 · sector benchmark
Five systems, none of them talking
This is what one product's emissions declaration looks like today.
One file
One calculation. One verification. One declaration.
Lab
analysis-2026-03.pdf
Meter
Natural gas consumption
CBAM Regulation
Annex IV — calculation
Inbox
3,209 unread
Shared drive
[draft] declaration v7
ERP
Output: 12,400 t billet
Excel
calc_final_FINAL.xlsx
Consultant
Revision notes
Product · Reinforcing bar Verified
Direct emissionsMeter + fuel analysis0.41
Precursor (billet)Supplier declaration0.27
ElectricityOut of scope, definitive regime—
Total embedded emissions0.68 tCO₂/t
Default value (2026, mark-up included)2.541 tCO₂e/t
− Your verified value: 0.68 tCO₂e/t
= Difference per tonne, at most€140.10
In 2028 the mark-up is 30% → 3.003 tCO₂e/t, difference at most €174.88/t · CN 7214 · certificate price €75.28 (Q2 2026)
We don't interpret the regulation. The method is written into the product.
See the calculation methodSystem boundary
Fuel combustion
Process emissions
Heat and steam
+ Embedded emissions of precursors
Electricity — out of scope for iron and steel in the definitive regime
The methodology is built in. System boundaries, precursors and measurement rules, per Annex IV.
Direct embedded emissions are determined as the sum of the direct emissions within the system boundaries of the production process and the direct embedded emissions of the relevant precursors.
CBAM Regulation (EU) 2023/956
Annex IV — Calculation of embedded emissions
Verificationaccredited
- Measurement equipment calibration
- Data flows and controls
- System boundary accuracy
- Precursor evidence
- Calculation is reproducible
It comes out verifier-ready. The evidence chain an accredited verifier looks for is already in the file.
Under the definitive regime, embedded emissions are verified by an accredited verifier and the verification report accompanies the declaration.
Implementing Regulation (EU) 2025/2621
Verification and accreditation rules
Producer
Embedded emissions declaration
CN 7214 20 · 0.68 tCO₂/t
EU importer
Authorised CBAM declarant
It drops straight into your buyer's declaration. The EU importer reports your figures as the authorised CBAM declarant.
The authorised CBAM declarant declares, for each calendar year, the embedded emissions of the goods imported and surrenders the corresponding certificates.
CBAM Regulation (EU) 2023/956
Articles 6–8 — Declaration, calculation, verification
The verifier bottleneck
There are no verifiers yet.
While verifiers are scarce, the plant that gives its verifier least to do goes first.
0
Accredited CBAM verifiers in the EU
7 of 24
Bodies accrediting third-country verifiers
11
Activity groups — one does not cover another
The Dutch accreditation body RvA has an agreement with TÜRKAK.
European Commission, 24 July 2026 · Delegated Regulation (EU) 2025/2551, Annex I
Let us produce a sample declaration from your own data.
One product, one production line, two weeks. You end up holding a file that is ready for verification.
Many plants.One declaration.
Group structure, separate lines, and a different format for every EU buyer.
The Commission sets default values on the conservative side, for producers with no actual data. With real figures, you close that gap yourself.
Your buyer needs your embedded-emissions figure for their declaration. What is shared is a product-level emissions intensity, not your production recipe.
Under the definitive regime, embedded emissions are verified by an accredited verifier and the report is annexed to the declaration.
For iron and steel, aluminium and hydrogen, the definitive regime covers direct emissions only. Cement and fertilisers also include indirect emissions.
A carbon price effectively paid can be deducted if documented — but only where your embedded emissions rest on actual data; a default-value declaration closes that route. Free allocation is not a payment. Türkiye's ETS regulation was published on 27 August 2026, leaving the pilot's scope and free-allocation rate to the Carbon Market Board. No effectively paid price exists today — one arises once installations short of allowances buy on the market.
Where measurement is absent, a calculation-based method applies; both require records and evidence. An unsupported estimate does not survive verification.
The declaration for 2026 imports is filed on 30 September 2027. Your buyer will want the figures long before that, so in practice your clock runs earlier.
Imports under 50 tonnes a year per importer are exempt. A single container of steel clears that threshold on its own.
From your supplier. If you buy billet, clinker or alumina, they need a product-level declaration too — building that chain is your job.
No. The EU importer buys certificates. The price is the average of EU ETS auction clearing prices: weekly is the rule, but a one-year exception applies for 2026 — that year's imports are priced on a quarterly average.
Don't pay the default value.
One product, one production line. A sample declaration ready for verification within two weeks.