A policy paper by Türkiye’s Centre for Economics and Foreign Policy Studies (EDAM) argues that the European Union’s Carbon Border Adjustment Mechanism (CBAM) could disadvantage exporters with lower-emission production if they cannot provide verified emissions data. The paper says the ability to document emissions may shape commercial outcomes even when production is less carbon-intensive than that of competing suppliers.
Verification and default values
Released on 3 November, the study, “Is CBAM a Sign of Green Protectionism? A Perspective from Türkiye,” was co-written by Can Selçuki and Ulaş Zal Akkaya. It examines CBAM’s effects on Turkish industrial competitiveness and compares Türkiye with Brazil, India and South Africa, whose exporters face similar European market-access requirements.
The researchers argue that the main competitive risk may come from the administrative burden of proving emissions, rather than from carbon pricing itself. They question whether regulatory default emissions values could lead to unequal commercial outcomes when producers cannot demonstrate actual emissions through acceptable verification systems.
Under the definitive CBAM regime, European importers must calculate covered products’ embedded emissions using the applicable legal methodology. Where appropriately verified actual emissions cannot be established, default emissions values may have to be used. EDAM says that if a default exceeds an installation’s actual emissions, the resulting commercial burden may be higher than it would be with sufficiently documented production data.
Türkiye’s steel industry is central to the analysis because electric-arc-furnace production accounts for an important share of its output. Scrap-based electric-arc-furnace production can have lower direct emissions than conventional integrated steelmaking, but its total carbon performance depends on raw materials, electricity supply and production conditions. The paper says any emissions advantage may not be reflected in the cost of imports into Europe without data meeting EU requirements.
Implications for regional exporters and finance
EDAM identifies Serbia, Montenegro and Bosnia and Herzegovina, as well as other Southeast European exporters, as immediately affected by CBAM’s implications. Steel and aluminium manufacturers may compete on emissions performance, while European customers need a defensible link between production installations, reported emissions and imported goods.
The paper identifies production records, fuel consumption, electricity data, precursor allocation and independent verification as factors in industrial competitiveness. It says the issue also extends to financial institutions: a steelmaker with relatively low emissions but poor documentation may face weaker export pricing or less certain customer contracts than a competitor with similar emissions and a complete verification file.
To preserve fair competition, EDAM argues for credible national emissions records, effective domestic carbon pricing and predictable European recognition of eligible foreign carbon payments. It also calls for verified actual data to replace default values under transparent and consistent rules. The study describes “verification capability as an emerging trade advantage” and treats possible green protectionism as a policy argument, not an established legal finding against EU CBAM.