What We Learned from the First Reporting Periods
Three quarterly reporting periods have passed since the Carbon Border Adjustment Mechanism (CBAM) transitional period began. The first CBAM report was due at the end of January 2024, and the process has revealed several important lessons. According to the European Commission's assessment, a significant proportion of importers encountered serious data gaps during the first reporting period (European Commission, 2024).
Common Errors and How to Fix Them
Gaps in Embedded Emissions Data
The most frequent issue in early reports was the inability to obtain sufficient emissions data from suppliers. Many EU importers received no response when requesting facility-level emissions data from their Turkish suppliers.
Solution: Start supplier communication at the beginning of the reporting period, at least six weeks before the report deadline. Data request forms should clearly specify the calculation methodology and required data format.
Incorrect Use of Default Values
Frequent errors occurred in the use of default values permitted under Implementing Regulation 2023/1773. Some importers applied incorrect default values by mismatching their product categories (European Commission CBAM FAQ, 2024).
Since the use of default values has been limited to 20 percent of total embedded emissions from July 31, 2024, planning the transition to actual data should start now.
Failure to Include Indirect Emissions
In some product categories — particularly steel and aluminium — the requirement to report indirect emissions was overlooked. According to the Implementing Regulation, indirect emissions from electricity consumption must be included in the embedded emissions calculation for certain products (Commission Implementing Regulation 2023/1773, Annex III).
CBAM Transitional Registry Usage Errors
At a technical level, issues also arose with the registry platform itself. Particular confusion occurred around correctly entering CN (Combined Nomenclature) codes and reporting country of origin at the country level rather than the facility level.
Practical Recommendations for Exporters
Standardize Your Data Preparation Process
Submitting data in the same format for each quarterly report reduces the workload for both your importer and your own team. A greenhouse gas inventory aligned with ISO 14064-1 provides the foundation for this standardization (ISO, 2018). Create a standardized data package template that includes: facility-level Scope 1 emissions by source, indirect emissions from electricity consumption, production volumes by product type, specific emissions per tonne of product, and the emission factors used with their sources. Once this template is established, quarterly updates become a data refresh rather than a from-scratch exercise.
Build Verification Capacity Now
During the definitive period starting in 2026, embedded emissions data will need to be verified by accredited verifiers. Building familiarity with verification processes during the transitional period is a strategic investment. The verification market for CBAM is still developing, with limited accredited verifier capacity particularly in Turkey. Contacting potential verifiers early, understanding their requirements, and conducting a voluntary "dry run" verification during the transitional period positions you ahead of the rush that will occur when verification becomes mandatory.
Track Carbon Pricing Information
The carbon price in the country of origin can be deducted from CBAM certificate costs during the definitive period. While Turkey does not yet have an operational emissions trading system, Climate Law 7552 has established the legal framework for TR-ETS. Monitoring the secondary legislation process and ETS pilot preparations is important — when TR-ETS becomes operational, every Euro of carbon price paid in Turkey will be deductible from CBAM costs (Regulation 2023/956, Article 9).
Preparing for the Next Reporting Period
The third quarterly report (July-September 2024) is due by the end of October 2024. Before that deadline:
- Start supplier communication at the beginning of August
- Review your embedded emissions calculation methodology
- Check your default value usage against the 20 percent limit
- Verify whether indirect emissions are included where required
Key Takeaway: While reporting errors during the transitional period do not result in financial penalties, treating each report as a serious rehearsal is essential preparation for the definitive period ahead.
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