Implementation status and Türkiye's exposure — where the default-value gap costs money, and whether EU buyers will turn CBAM data into a supplier-qualification gate.
Türkiye is the EU's single largest cement and clinker supplier (35–39% of EU cement imports). CBAM's default-values table charges Turkish clinker at 1.551 tCO₂/t for the definitive period (IR (EU) 2025/2621), while TÜRKÇİMENTO puts actual grey-clinker intensity near 0.88 tCO₂/t. At the Q1 2026 price of €75.36/tCO₂e that raw gap is worth roughly €50 per tonne of clinker before the free-allocation adjustment — but what a verified producer can actually sell is the change in the importer's certificates payable after that adjustment, not the emissions gap itself. Either way the driver is missing verified MRV data, not carbon.
Four months into the definitive phase — authorised CBAM declarants now required at the border, first surrender deadline 30 September 2027 — the central question isn't the charge. It's whether EU buyers convert CBAM documentation into a supplier-qualification gate; by Q4 2026 the test is whether verified installation-level CBAM data starts appearing in EU RFQs and 2027 framework renewals. A separate 17 December 2025 Commission proposal (COM(2025) 989) would extend CBAM scope to ~180 downstream steel- and aluminium-intensive products.