CBAM for Non-EU Exporters: Getting Out of Default Values Before the First Declaration, with Turkey as the Worked Case

Quick answer: if you export cement, steel, aluminium or fertilisers to the EU and your customers cannot present verified emissions data from your installation, they are charged the default value for your country, plus a surcharge, regardless of how clean your plant actually runs. The associations are lobbying Brussels over how those defaults were set. Lobbying may eventually fix the table; only verified installation data fixes your price. The first declaration your customers must file covers 2026 and is due 30 September 2027, and the data work backs up from that date.

Why defaults punish exactly the efficient producers

Default values are country averages with a deliberate mark-up on top: 10% in 2026, 20% in 2027, 30% from 2028. Averages flatten everything that makes an individual plant competitive. The Turkish figures show the mechanism at full force.

In cement, Turkey, the EU's largest supplier at 4.8 million tonnes in 2025, received no national default at all and falls into the "other countries" bucket at 1.584 tCO2 per tonne of Portland cement for 2026, while reported actual performance of Turkish kilns sits around 0.88. TURKCIMENTO calculated the resulting carbon cost per tonne of clinker rising from roughly 20 to roughly 80 euros, which its CEO noted can exceed the unit price of the exported product.

In steel, roughly 70% of Turkish production runs on the scrap-based electric arc furnace route. The sector's associations report defaults of 2.428 and 2.310 tCO2 per tonne assigned to certain flat products and wire rod, against about 0.70 for real EAF output, and Yalçın Ertan of the Aegean exporters' association called an approach that prices Türkiye above even heavily coal-based origins impossible to accept. The objection is fair. It is also, for now, just an objection. Until the methodology changes or verified data replaces it, the default is the price.

What your EU customers now need from you

The legal obligation sits on the EU importer, but the data can only come from you. Since 1 January 2026, an importer may only declare actual emissions if they are calculated to the CBAM methodology and verified by an accredited third-party verifier. Without that package, your customer pays the default, and then does what buyers do with an unexplained surcharge: reprices you, shifts terms, or moves volume to a supplier who can document a lower number. NLMK Europe's decarbonisation director summed up where importer anxiety has moved: the question is no longer only cost but whether the supplier's data can be trusted. Verified data is becoming a condition of market access, not a nice-to-have.

The path out, in order

1. Map your EU-bound products to their CN codes and identify the applicable default for each destination product. This is your baseline, the number you are trying to beat.
2. Set up installation-level monitoring aligned with the CBAM methodology, covering direct process and energy emissions and the relevant precursors. The monitoring period must cover the production of the goods being declared; data cannot be reconstructed convincingly after the fact.
3. Produce the emissions report per product, in the structure importers need for their declarations.
4. Contract an accredited verifier early. Which bodies are accredited and how their recognition works internationally has been one of the sector's loudest open questions, and capacity will tighten as 30 September 2027 approaches. A verification slot booked late is a default value accepted involuntarily.
5. Hand every EU customer the same verification-ready pack. One verified installation dataset serves all of your importers; the work does not multiply with your customer count.

Turkey-specific realities worth planning around

Two structural points shape the Turkish case and generalise to other origins. First, the absence of a national value is not neutral: the other-countries bucket is constructed punitively, so exporters from unlisted origins carry the widest default-to-actual gap and gain the most from verification. Second, a domestic carbon price only reduces CBAM if it is effectively paid. Turkey's pilot emissions trading scheme runs on full free allocation in 2026, so there is currently no deduction under Article 9 to soften the bill. The associations are pressing for national MRV data to be recognised, and that pressure matters, but its timeline is not yours. A plant controls exactly one lever on its own schedule: its verified number.

The commercial upside nobody mentions in the complaints

A verified 0.9 against a default 2.4 is not just a cost saving for your customer. It is a sales argument against every competitor still stuck on defaults, printable in an offer, and it compounds each year as the mark-up ratchets up. The exporters who treat CBAM data as a product feature rather than a compliance chore will take share from the ones writing position papers.

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