Regulation 12 min read

Getting CBAM-ready in 90 days with U2 Carbon

Manufacturers exporting to Europe must submit CBAM reports as of Q3 2026. A realistic 90-day roadmap from data to report, with checkpoints and common pitfalls.

Mustafa Altınışık CSO · U2 Soft

What is CBAM and why 90 days?

The Carbon Border Adjustment Mechanism (CBAM) is the EU's border carbon levy. Firms exporting cement, iron-steel, aluminium, fertiliser, hydrogen, or electricity must now report embedded carbon emissions of exported goods and purchase EU ETS certificates accordingly. The transition period is over; from Q3 2026, real certificate purchases begin.

This isn't a small compliance project. In practice, a 3-layer data chain is set up: plant-level process data → product-level emission factor → shipment-level certificate. Each must be auditable and retroactively verifiable.

Phase 1 (Weeks 1–3): Data inventory

Common first mistake: "We have an emission factor table, we'll wrap this up". No. First you need to know where to source data from:

  • Direct emissions (Scope 1): Fuel consumption on the production line, kiln gas, process-related CO₂. Meter data, SCADA output, manual form if needed.
  • Electricity-based (Scope 2): MWh at the plant meter × country grid emission factor. Türkiye's 2024 grid factor: ~0.42 kgCO₂/kWh.
  • Supplier data (Scope 3 / upstream): Inputs like iron ore, coke, alumina. From your supplier: EPD certificate or CBAM declaration.

Phase 2 (Weeks 4–8): Methodology choice

CBAM allows two methodologies: default values (simple but expensive) and installation-specific (harder but realistic). Starting with default and transitioning to installation-specific within 12 months is the right strategy for most firms.

In U2 Carbon, we flag the methodology choice as a key decision because:

  • Default is usually 30–50% more expensive (upper values are used)
  • Installation-specific requires measurement infrastructure + EU-accredited verifier
  • Switching between them means recomputing the baseline

Phase 3 (Weeks 9–12): Pilot report and verification

Run a pilot report for one quarter, ideally Q1 data. During this period:

  1. Walk the calculation's audit trail (each number traces to which source?)
  2. Identify missing data points (missing meter, missing EPD)
  3. Select an EU-accredited verifier (booking before Q3 is essential; calendars fill up)
  4. Accept the first emission factor as your baseline

Three common mistakes

1. Top-down accounting instead of mass balance. "We made 100k tons annually, 30% went to the EU, so take the ratio" — wrong. Each shipment has its own embedded carbon. Mass balance is the rule.

2. No checks on the EPD certificate. The supplier's EPD must be verified for date, scope, and verifier identity. An invalid EPD will make your report fail.

3. Distributing electricity equally. If you measure at the main panel, that electricity isn't allocated equally to all products. Line-level submetering or per-process allocation is essential.

Takeaway

CBAM falls under "compliance" but is really a data maturity project. The most critical investment for being ready in 90 days isn't a spreadsheet — it's the measurement points in your plant and your supplier contracts. U2 Carbon automates the calculation; setting up the right data flow is the customer's job. Done in this order, you're ready before Q3.