TÜRKÇİMENTO: Actual Emissions Must Be Taken into Account

Carbon Border Adjustment Mechanism (CBAM) Default Values Pose a Risk for Cement Exports

The Turkish Cement Manufacturers’ Association (TÜRKÇİMENTO) has stated that the current implementation of the European Union’s Carbon Border Adjustment Mechanism (CBAM) poses a risk of effectively becoming a non-tariff trade barrier for the Turkish cement industry.

The omnibus legislative amendments published by the European Commission on 17 October 2025 and the implementing regulations that entered into force in December 2025 are creating serious financial pressures on Turkish cement exports, particularly due to the default emission values to be applied to third countries.

In his assessment of the issue, TÜRKÇİMENTO CEO Volkan Bozay stated: “The Turkish cement sector has been operating within a monitoring, reporting, and verification (MRV) system aligned with the EU since 2015. Low-emission dry-process kilns are used at all our facilities, and our actual emission performance is well below the default values. Because no country-specific default value has been defined for Turkey, the application of the highest emission coefficients under the ‘other countries’ category places our sector at an unfair disadvantage. In the first 11 months of 2025, TÜRKÇİMENTO members, representing approximately 94 percent of the sector, produced 75 million tons of clinker. Turkey is also the main supplier of the EU’s clinker and cement imports,” he said.

Bozay emphasized that the current default values do not reflect real production conditions and continued as follows: “The actual data declared by our members exporting to the EU during the CBAM transition period in Turkey show that emissions for grey cement clinker are at the level of 0.88 tCO₂/ton. In contrast, the default value used for Turkey under EU legislation is 1.551 tCO₂/ton. This difference leads to additional costs that do not reflect actual emission performance and brings discussions regarding the fair and accurate implementation of CBAM.”

It Will Also Affect EU Citizens

Stressing that any delays or problems in the verification process of actual values would turn the gap between actual and default values into a serious financial burden, TÜRKÇİMENTO CEO Volkan Bozay stated: “When this difference is calculated based on current EU ETS prices, it increases the carbon cost per ton of clinker from approximately 20 Euros to 80 Euros. The resulting amount even exceeds the average unit price of products exported to the EU, directly threatening the economic sustainability of exports. If CBAM is implemented in this form, a significant portion of the additional cost incurred will be reflected in final product prices and will ultimately affect consumers in the EU as well. Therefore, the timely activation of verification capacity and the realistic updating of default values are of critical importance. This situation could also result in an outcome that is not fully compatible with the fundamental principles of the Customs Union.” On the other hand, Bozay also drew attention to some technical issues that need to be clarified in practice: “Our cement sector is focused on increasing the use of renewable electricity. However, for a small-to-medium-sized cement plant to fully meet its own consumption from renewable energy, a solar power plant capacity of approximately 50–70 MW is required. Making an investment of this size within or immediately adjacent to the factory site and connecting it directly is often not technically feasible. Therefore, producers have to realize their renewable energy investments at different locations. Within the scope of CBAM, there is a need for clear rules that will allow these investments and the declared actual production data to be recognized in indirect emission calculations. In addition, there are regulatory uncertainties in areas such as embedded emission methodology, electricity emission coefficients, and free allocation adjustments when the final product is cement.” Bozay expressed the proposed solutions to ensure fair competition conditions while preserving CBAM’s environmental objectives as follows: “Our sector’s priority is the meticulous preparation and verification of emission reports within the scope of CBAM. However, especially in the initial years, there is a possibility of delays in verification processes and insufficient verifier capacity. On-site visits and initial verification procedures may take longer than expected. In such a case, the application of default values that do not reflect actual emission performance may disproportionately affect producers with low carbon intensity. Turkey’s possession of an MRV system similar to that of the EU since 2015 provides an important assurance for both exporters and importers in terms of enabling assessments based on real data. In order to prevent CBAM from turning into a de facto trade barrier, it is important to allow the use of national values based on data from MRV systems aligned with the EU, instead of general default values under the ‘Other Countries’ heading. Until the verification infrastructure becomes fully operational, actual emission data should be taken as a basis and disproportionate financial burdens should be prevented.

Otherwise, as a system that fails to distinguish between low-carbon production and the highest carbon-intensive production, the CBAM will not go beyond being a non-tariff technical barrier, rather than effectively supporting low-carbon production. In this respect, it is of great importance that secondary regulations and technical issues in the EU’s internal legislation related to accreditation processes—such as the final list of accredited organizations under CBAM that has yet to be clarified in practice—are clarified as soon as possible.”