Don't pay the default value.
CBAM, Turkish ETS and TSRS from one dataset, with evidence. The world's best reduction practices, in your plant's numbers.
Regulations we build on
CBAM
Carbon Border Adjustment Mechanism
EEMS: embedded emissions per product, O3CI package and buyer summary.
Basis: EUR-Lex 2023/956 · EUR-Lex 2025/2547 · EUR-Lex 2025/2621
Regulation pageTurkish ETS
Turkish Emissions Trading System Regulation
EEMS: monitoring methodology plan (İMP), annual emissions report and verifier package.
Basis: Official Gazette 33353
Regulation pageTSRS 2
Climate-related Disclosures
EEMS: Scope 1-2 calculation infrastructure.
Basis: KGK TSRS 2
Regulation page
What does the default value cost you?
Figures shown are examples
- Annual total difference (€)
- ≈ €1.44 million
- €1,442,658
- 25,000 t × ≈ €57.71/t
- Assuming the whole year at the Q3 2026 price (€82.32) — example, SEFA excluded, not an amount payable.
Method and sources
- Raw default value
- 1.41 tCO₂e/t
- Default value with mark-up (2026 10%)
- 1.551 tCO₂e/t
Enter your own measured value; no verified sector average exists for this product.
CN 2523 10 00 · Other clinker, incl. grey clinker (TARIC …90)
- Default value applied (2026)
- 1.551 tCO₂e/t
- Your actual value
- 0.85 tCO₂e/t
- Gap
- 0.701 tCO₂e/t (45%)
- Difference per tonne × Q3 2026 price
- €57.71/t
- €82.32/tCO₂e · Q3 2026 imports · Commission, 05.10.2026 · SEFA (IR (EU) 2025/2620) not included — a worked example, not an amount payable
- Difference per tonne, with the 2028 mark-up (default 1.833)
- €80.92/t
- If the Q3 2026 price (€82.32) stayed the same in 2028 — a scenario, not a forecast · SEFA (IR (EU) 2025/2620) not included — a worked example, not an amount payable
This is a worked example — not an upper bound and not an amount payable. The difference is only between the applied default value and the value you entered. The free-allocation adjustment (SEFA) is calculated separately by declaration type — Equations 2–5 for an actual-values declaration, Equation 6 for a default-values declaration (IR (EU) 2025/2620 Annex, pp.6–8) — and is not in this calculation. The exact figure comes out of a plant assessment, with your precursors and production route taken into account.
Choose the import quarter to see €/t. The 2026 price follows the quarter in which the goods are imported, not the production month (Reg. (EU) 2025/2083 Art. 1(17), amended Art. 21(1a), p.16).
The free-allocation adjustment is not calculated the same way for the two declaration types (IR (EU) 2025/2620 Annex, points 3 and 4, pp.6–8); the actual-values side also recurses over precursors. The cross-sectoral correction factor has been published as 100% for 2026–2030 (ID (EU) 2026/1862 Art. 1, p.3). Because the SEFA terms are not in this calculation, no amount payable is computed for any good. The default-value increase grows by year: 10% in 2026, 30% in 2028, each year with its own rate (IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740, opening paragraph, p.4). Marked-up values are not published in Annex I; IR (EU) 2026/1740 removed those columns.
IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740 · Commission official HTML table row (price-cbam-certificates), snapshot 05.10.2026; no official page number · law: Reg. (EU) 2025/2083 Art. 1(17), amended Art. 21(1a), p.16; IR (EU) 2025/2548 Art. 1, pp.2–3
Other clinker including grey clinker, TARIC 2523 10 00 90 — the "other countries" fallback: Türkiye is listed in Annex I but its clinker cells are blank. White clinker (…10) is a separate row; this value does not extend to it.
Declarations from one place.
Data collection meter to lab
Product-level calculation Annex IV, per CN code
Verification file with evidence chain
Buyer hand-off EU importer (target)
Cost per line highest per-tonne line
Example user threshold 0.78 · not an official or measured sector benchmark
Short answers.
How high is the default value?
The Commission sets default values on the conservative side. You close the gap with real data.
Source: EUR-Lex 2025/2621
Is Türkiye's carbon price deducted?
A documented price actually paid is deductible only when declaring with real data. Free allocation is not a payment.
Source: EUR-Lex 2025/2083
Are small shipments exempt?
The exemption applies if an importer's annual net mass stays within 50 tonnes. Electricity and hydrogen imports are not exempt.
Source: EUR-Lex 2025/2083
Who chooses the verifier?
Under the Turkish ETS you do not choose: the central MEDAS system assigns the verification body (Turkish ETS Regulation Art. 30(2)), except for installations subject to the Public Procurement Law. Under CBAM, verifying a declaration based on actual emissions is the declarant's obligation (CBAM Regulation Art. 8(1)); if you have opted to register in the CBAM registry (Art. 10(1)), as a registered operator you have your embedded emissions verified by an accredited verifier (Art. 10(5)(b)).
Source: Official Gazette 33353 · EUR-Lex 2025/2083
How long must you keep records?
Under the Turkish ETS you keep all relevant data and records for at least 10 years. Under CBAM, as a registered operator you keep the verification report and calculation records for 4 years after verification.
Source: Official Gazette 33353 · EUR-Lex 2025/2083
Where is the EEMS server?
EU server (Helsinki, Finland); the panel opens in your browser.
Do your systems need to change?
Nothing is written to your systems; one read-only program that connects only outbound over HTTPS is installed at the plant. Your IT team provides a read-only database user for the ERP.
Does AI produce numbers?
No, the engine calculates every number. Any sentence of AI-written text that contains a number is dropped before display.
What happens to your data if you leave EEMS?
Your data is yours: you download your plant package with one click. It is a ZIP with JSON data, evidence files, reports and a hashed manifest.
What is the İMP deadline for pilot installations?
Pilot-period installations submit their first monitoring methodology plan (İMP) by 27 January 2027. The Climate Change Presidency extended the deadline by its notice of 14.10.2026 (Approval 18814, Provisional Art. 3(1)).
Source: Climate Change Presidency notice 14.10.2026 · Official Gazette 33353