Pier Compliance

Product Safety and Regulatory Compliance Expert

CBAM Compliance Services

End-to-end CBAM compliance and process management under the Carbon Border Adjustment Mechanism CBAM compliance is mandatory for EU importers of in-scope goods and increasingly decisive for non-EU exporters—including Turkish manufacturers supplying cement, steel, aluminium, fertilisers, electricity, and hydrogen to European customers. According to the EU CBAM framework under Regulation (EU) 2023/956, embedded emissions must be evidenced, quarterly reporting cycles must be reliable during the transitional period, and CBAM certificate exposure must be planned like any material cost line from the definitive period onward. Poorly managed CBAM compliance creates supply-chain friction, margin pressure, declaration risk, and enforcement exposure. The task is not periodic paperwork alone, but a joined-up programme spanning embedded emissions calculation, carbon footprint reporting, verification, and CBAM certificate planning. Pier Compliance acts as the managing advisor across that full chain: we align EU CBAM regulations with your product portfolio, installation data, and export model, and we carry the work from transitional reporting (1 October 2023–31 December 2025) through to the structures and evidence expected when the definitive period begins on 1 January 2026.

Compliance Snapshot

What This Covers

CBAM compliance under EU Regulation (EU) 2023/956 requires EU importers of in-scope goods to report embedded emissions (direct and indirect), prepare for verification, and—from the definitive period—surrender CBAM certificates aligned with EU ETS carbon pricing. Pier Compliance manages scope, carbon footprint reporting, supplier data programmes, and transition-to-definitive readiness.

Who Is Affected

  • EU importers and indirect customs representatives placing CBAM-covered cement, steel, aluminium, fertilisers, electricity, or hydrogen goods on the EU market
  • Non-EU producers and Turkish exporters supplying plant-level embedded emissions data to EU customers
  • Finance, sustainability, and procurement teams modelling CBAM certificate exposure and carbon cost management
  • Organisations building audit-ready EU CBAM reporting workflows before the definitive period (from 1 January 2026)

Key Obligations

  • Quarterly CBAM reports during the transitional period (1 October 2023–31 December 2025) via the EU CBAM Transitional Registry
  • Embedded emissions calculation using default values or verified installation data; indirect emissions where required
  • Verification of embedded emissions data for the definitive period and annual CBAM declaration
  • Purchase and surrender of CBAM certificates linked to verified embedded emissions at import

How Pier Compliance Helps

  • HS/CN-level CBAM scope mapping and product-level carbon footprint reporting architecture
  • Supplier onboarding, data SLAs, and gap closure for embedded emissions evidence
  • Transition-period reporting packs with internal controls and version discipline
  • Certificate strategy, cost scenarios, and operational handover to authorised CBAM declarant structures

Common compliance questions

What is CBAM?
The Carbon Border Adjustment Mechanism (CBAM) is the EU’s carbon border levy under Regulation (EU) 2023/956. It requires reporting—and from 2026, financial settlement—of embedded emissions in imports of cement, steel, aluminium, fertilisers, electricity, hydrogen, and selected precursors.
Who needs CBAM compliance?
EU importers (or their indirect customs representatives) of CBAM goods must report embedded emissions. Non-EU producers—especially in Türkiye—must supply installation-level data when EU customers or authorised CBAM declarants request it.
How to calculate embedded emissions?
According to EU CBAM implementing rules, embedded emissions combine direct emissions from production and, where applicable, indirect emissions from electricity use. Calculations use default values or verified installation data per the applicable methodology.
What is the CBAM reporting timeline?
The transitional period runs from 1 October 2023 to 31 December 2025 with quarterly CBAM reports. The definitive period begins 1 January 2026, when verified emissions, annual declarations, and CBAM certificate surrender apply.
How does CBAM affect Turkish exporters?
EU importers increasingly require credible embedded emissions data, methodology documentation, and verification readiness from Turkish suppliers exporting steel, aluminium, cement, and related goods.
What does Pier Compliance provide for CBAM?
End-to-end CBAM compliance support: scope analysis, embedded emissions modelling, transition-period EU CBAM reporting, verification coordination, authorised declarant assessment, and CBAM certificate strategy.

What is CBAM?

CBAM—the Carbon Border Adjustment Mechanism—is the EU’s carbon border adjustment instrument designed to prevent carbon leakage and preserve fair competition between EU producers subject to the EU Emissions Trading System (EU ETS) and imports of carbon-intensive goods. In direct answer: CBAM requires importers to report embedded greenhouse gas emissions in targeted products and, from the definitive period, to surrender CBAM certificates whose price follows the EU ETS. The legal basis is Regulation (EU) 2023/956, part of the EU Fit for 55 package. According to EU CBAM guidelines, the mechanism operates in two phases: • Transitional period: 1 October 2023 to 31 December 2025—quarterly reporting of import volumes and embedded emissions (direct and, where applicable, indirect emissions) via the EU CBAM Transitional Registry; no certificate purchase yet. • Definitive period: from 1 January 2026—imports channelled through authorised CBAM declarants, verified embedded emissions, annual CBAM declarations, and surrender of CBAM certificates. For exporters outside the EU, CBAM is often experienced first as a customer and importer data requirement—but the commercial and compliance stakes are the same: credible carbon footprint reporting and verification-ready evidence.

Which sectors does CBAM cover?

Who needs CBAM compliance first? EU importers—and their non-EU suppliers—of carbon-intensive product families listed in Annex I to Regulation (EU) 2023/956. The headline CBAM sectors are: 1. Cement and cement clinker 2. Electricity 3. Fertilisers (including ammonia and nitric acid precursors) 4. Iron and steel (including pig iron, DRI, and selected downstream goods) 5. Aluminium (unwrought and selected aluminium products) 6. Hydrogen and certain related precursor chemicals EU policy direction under the Carbon Border Adjustment Mechanism points to a gradually widening perimeter beyond these initial CBAM sectors. Even producers not squarely in scope today should treat early readiness—embedded emissions calculation capability and carbon footprint reporting discipline—as a supply-chain and customer expectation, not only a regulatory checkbox.

How does the CBAM process work?

How does CBAM compliance work in practice? It spans data capture, embedded emissions calculation, verification, quarterly or annual reporting, and—from 2026—certificate surrender. Readiness must be built before goods arrive at the EU border.

Transition-period reporting

During the CBAM transitional period (1 October 2023–31 December 2025), EU importers and indirect customs representatives must submit quarterly CBAM reports covering import volumes and embedded emissions information. According to EU CBAM implementing rules, reports are filed through the EU CBAM Transitional Registry. This phase is where companies harden carbon footprint reporting architecture, methodology choices (default vs actual values), and traceability ahead of mandatory verification in the definitive period.

Authorised CBAM declarant structure

From the definitive period starting 1 January 2026, imports of CBAM goods must be declared by an authorised CBAM declarant registered with the competent authority. Your import model, representation arrangements, and internal responsibility map therefore need to be clarified well in advance of this deadline.

Emissions calculation and verification

How to calculate embedded emissions for CBAM? Direct emissions from production processes and, where relevant, indirect emissions from electricity must be calculated under the applicable CBAM methodology and supported by evidence. According to EU CBAM guidelines, installation-level data is preferred over default values where feasible. Incomplete, inconsistent, or non-verifiable data becomes a compliance and cost risk in later reporting windows—especially when independent verification becomes mandatory.

Annual declaration and certificate delivery

In the definitive period, authorised CBAM declarants submit an annual CBAM declaration of verified embedded emissions and surrender the corresponding CBAM certificates. This is simultaneously a technical accounting exercise and a financing and purchasing-planning exercise tied to EU ETS-linked certificate prices.

CBAM certificates and cost impact

Each CBAM certificate represents one tonne of CO₂ equivalent embedded emissions not already covered by a carbon price in the country of origin. Certificate prices are not fixed; they track the EU ETS allowance price, which makes carbon cost management a live treasury and procurement topic. In short: CBAM compliance in the definitive period means purchasing and surrendering certificates matching verified embedded emissions on imported goods. Weak embedded emissions data or delayed verification directly increases certificate exposure and commercial risk. According to EU CBAM regulations, compliance therefore requires more than template submission. Teams need: • Credible installation-level carbon footprint reporting • Defensible embedded emissions calculation logic (default values vs verified data) • A CBAM certificate strategy integrated with pricing, contracting, and customer dialogue For high export volumes, CBAM is already a board-level competitiveness issue—not a niche environmental disclosure.

What happens if CBAM is not managed properly?

Gaps in CBAM compliance rarely stay purely administrative. Under EU CBAM regulations, depending on circumstances, companies can face operational, financial, and reputational pressures:

Incorrect or incomplete declarations

Material misstatements in embedded emissions reporting or CBAM declarations can trigger correction obligations, additional certificate costs, and strained customer relationships.

Administrative penalties

Serious or repeated non-compliance with EU CBAM reporting or certificate rules can lead to financial sanctions and structured remediation expectations under the national CBAM framework.

Supply-chain disruption

Failures in carbon footprint reporting, verification timelines, or certificate planning ripple into shipment schedules, contract performance, and supplier audits.

Loss of customer trust

EU customers expect disciplined EU CBAM reporting and transparent embedded emissions evidence; weak data governance undermines confidence and tender eligibility.

Operational delays

Border and customs-related friction, combined with internal rework on embedded emissions calculation, erodes delivery reliability and margin.

How Pier Compliance supports you

CBAM scope analysis • Product- and HS/CN-level scoping against EU CBAM regulations with pragmatic risk notes • Clarification of data ownership and responsibility across your export and import chain Transition-period reporting support • Design of quarterly EU CBAM reporting workflows, carbon footprint reporting templates, and control checklists • Governance for review, approval, and version-controlled submissions to the Transitional Registry Emissions data collection and calculation support • Plant- and route-aware embedded emissions calculation models (direct and indirect emissions) • Evidence registers, data-quality rules, and gap-management playbooks for verification readiness Verification coordination • Structured liaison across internal teams, accredited verifiers, and counterparties • Preparation of file sets aligned with EU CBAM verification expectations and timelines Authorised declarant / import-structure assessment • Assessment of authorised CBAM declarant roles relative to your import pattern • Pragmatic suggestions on contractual clauses and embedded emissions data sharing Certificate and cost-strategy support • Scenario-based CBAM certificate strategy linked to carbon cost management and EU ETS price exposure • Bridge into pricing, customer communications, and procurement planning Internal process and compliance infrastructure • RACI matrices, calendars, revision logs, and document retention discipline for CBAM compliance • Audit-ready CBAM readiness packs for customers and internal assurance

Secure your CBAM programme early

For exporters to the EU, CBAM compliance is no longer a problem that can be parked. The transitional period (ending 31 December 2025) is the window to stabilise embedded emissions calculation, carbon footprint reporting, and verification pathways before definitive-period certificate obligations begin on 1 January 2026. Pier Compliance works with you to design a practical, end-to-end CBAM compliance roadmap—not a paper exercise. If you would like to manage your Carbon Border Adjustment Mechanism obligations in a structured, evidence-led way, we would welcome a conversation.

Short overview video on CBAM

A concise walkthrough of why the Carbon Border Adjustment Mechanism matters for exporters, and how Pier Compliance approaches end-to-end CBAM compliance management.

Tangible deliverables

  • CBAM scope dossier (product list, HS/CN validation, risk commentary against EU CBAM regulations)
  • Embedded emissions dataset and calculation model (templates, logic, evidence index for carbon footprint reporting)
  • Transition-period EU CBAM reporting pack with internal controls
  • Certificate and carbon cost scenario memorandum (definitive-period readiness)
  • Traceable CBAM readiness documentation set

Frequently asked questions

What is CBAM?

CBAM (Carbon Border Adjustment Mechanism) is an EU climate trade instrument established by Regulation (EU) 2023/956. It requires importers to report embedded greenhouse gas emissions in carbon-intensive goods and, from the definitive period, to surrender CBAM certificates priced in line with the EU ETS.

Which sectors are in scope under EU CBAM regulations?

Initial CBAM sectors include cement, iron and steel, aluminium, fertilisers, electricity, hydrogen, and certain precursor chemicals under Annex I of Regulation (EU) 2023/956. The EU plans to extend the perimeter progressively.

How are embedded emissions calculated for CBAM?

Embedded emissions calculation covers direct emissions from the production process and, where relevant, indirect emissions from electricity consumption. Companies may use EU default values or installation-specific verified data under the CBAM methodology.

What is the CBAM transitional period reporting schedule?

During the transitional period (1 October 2023–31 December 2025), importers must submit quarterly CBAM reports through the EU Transitional Registry. No certificate purchase is required in this phase, but data quality and methodology discipline are critical.

When does the CBAM definitive period start?

The definitive CBAM period begins on 1 January 2026. Importers must work through authorised CBAM declarants, submit verified annual declarations, and surrender CBAM certificates corresponding to embedded emissions.

What is carbon footprint reporting under CBAM?

Carbon footprint reporting under CBAM means documenting specific embedded emissions (tCO₂e per tonne of product) at installation level, with traceable energy, process, and precursor data—forming the basis for verification and certificate obligations.

How does CBAM affect Turkish exporters to the EU?

Turkish exporters of steel, aluminium, cement, and related goods face growing EU customer demands for embedded emissions data, CBAM-aligned documentation, and verification-ready evidence—even when the legal importer sits in the EU.

What is an authorised CBAM declarant?

From the definitive period, only authorised CBAM declarants may import in-scope goods into the EU. They file annual CBAM declarations and surrender certificates. Importers and supply-chain partners must align data flows and contracts accordingly.

What are direct and indirect emissions in CBAM?

Direct emissions arise from production processes (e.g. combustion, process chemistry). Indirect emissions reflect electricity used in production. Both may count toward embedded emissions depending on product category and applicable CBAM rules.

What does Pier Compliance provide for CBAM compliance?

Pier Compliance delivers CBAM scope analysis, embedded emissions data architecture, transition-period EU CBAM reporting support, verification coordination, authorised declarant structuring, and CBAM certificate cost modelling for exporters and EU-facing supply chains.

Let us help you run CBAM as a managed programme

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