The Turkish Cement Manufacturers’ Association (TURKCIMENTO) has issued a formal statement on the EU’s Carbon Border Adjustment Mechanism (CBAM), responding to omnibus legislative amendments published by the European Commission on 17 October 2025 and implementing regulations that came into force in December 2025.
TURKCIMENTO sets out a precise concern. Turkish cement producers use national monitoring, reporting, and verification (MRV) systems that follow EU standards to measure and document their emissions at plant level. The data these systems generate is verified and shows actual carbon output well below the levels that CBAM’s default values assume. Because CBAM does not currently recognise national MRV data from Turkey, producers face carbon costs calculated on default figures that bear no relation to what their plants emit. The Association warns that this makes CBAM function, in effect, as a non-tariff trade barrier against Turkish cement.
“Priority of the Turkish cement sector is the meticulous preparation and verification of emission reports within the scope of CBAM. However, any problems in the verification process of actual values would turn the gap between actual and default values into a serious financial burden,” said Volkan Bozay, CEO of TURKCIMENTO.
“When this difference is calculated based on current EU Emissions Trading System (ETS) prices, it increases the carbon cost per ton of clinker from approximately €20 to €80. The resulting amount even exceeds the average unit price of products exported to the EU, directly threatening the economic sustainability of exports.”
CBAM could affect EU consumers
“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. As no country-specific default value has been defined for Türkiye, the application of the highest emission coefficients under the ‘other countries’ category places our sector at an unfair disadvantage,” Bozay explained.
“The actual data declared by our members exporting to the EU during the CBAM transition period in Türkiye show that emissions for grey cement clinker are at the level of 0.88 tCO₂/ton. In contrast, the default value used for Türkiye under EU legislation is 1.551 tCO₂/ton. This difference leads to additional costs that do not reflect actual emission performance.”
“In its current form, CBAM could increase costs that will ultimately be reflected in final product prices, affecting EU consumers as well. Activating verification capacity on time and revising default values realistically is therefore critical. Otherwise, the mechanism may risk conflicting with the fundamental principles of the Customs Union,” Bozay added.
Offsetting Indirect Emissions by Renewable Energy
Bozay also drew attention to some technical issues that need to be clarified in practice:
“Our 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 need for clear rules that will allow these investments and the declared actual production data to be recognized in indirect emission TURKCIMENTO.”
TURKCIMENTO Shares Proposed Solutions: “CBAM Shouldn’t Turn into a Trade Barrier”
Volkan Bozay also shared the solutions proposed by TURKCIMENTO:
“To prevent CBAM from becoming a de facto trade barrier, national values based on EU-aligned MRV data should be used instead of general ‘Other Countries’ default values. Until the verification infrastructure becomes fully operational, actual emission data should be taken as the basis and disproportionate financial burdens should be avoided.
Otherwise, as a system that fails to distinguish between low-carbon production and the most carbon-intensive production, CBAM will not effectively support low-carbon manufacturing and may instead function as a non-tariff technical barrier.
In this regard, it is also crucial to clarify the secondary regulations and technical aspects of the EU’s internal legislation related to accreditation processes as soon as possible, including the final list of organizations accredited under CBAM, which has not yet been fully defined in practice.”
