Türkiye is the European Union’s largest cement supplier, about 38.9 percent of EU cement imports in 2024, so it is the most exposed source by volume under CBAM. A higher-carbon thermal production mix raises default-value risk, and no Türkiye-specific cement default exists, so verified actual installation data is the main lever to lower a declared figure.
Why Türkiye is the most exposed cement origin
Türkiye is the largest supplier of cement and clinker to the European Union, at about 38.9 percent of roughly 11.3 million tonnes of EU cement and clinker imports in 2024. That single-origin share is close to the whole of North Africa combined, which places Türkiye ahead of every other cement source on CBAM exposure by volume. Cement spans CN 2523 plus 2507 00 80 and counts both direct kiln emissions and indirect electricity emissions, so a high thermal share in the production mix pushes the embedded figure upward.
EU cement and clinker suppliers by share of 2024 imports:
| Origin | Share of EU cement imports 2024 |
|---|---|
| Türkiye | about 38.9 percent |
| Ukraine | about 14.5 percent |
| Algeria | about 14.1 percent |
| Egypt | about 8.9 percent |
| Tunisia | about 7.9 percent |
Why default values raise the risk
Embedded emissions are declared either from a country-of-origin default value carrying a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028, or from verified actual installation data. No Türkiye-specific cement default value is published, since the Türkiye workbook sheet shows dashes for clinker and Portland cement, so a default-based Türkiye position falls back to the “_Other Countries and Territories” fallback default. On a higher-carbon thermal energy mix, a marked-up fallback default is a conservative estimate that can overstate an efficient plant’s real emissions.
The lever: verified actual installation data
Verified actual data is the route that lowers a declared figure, because an efficient modern kiln with a lower clinker factor can declare below the fallback default. CBAM has required actual rather than estimated data since 1 August 2024, and the final declaration must be checked by an independent verifier accredited under Commission Delegated Regulation (EU) 2025/2551. As a CBAM consultant, GreenSutra calculates embedded emissions and prepares installation data for that independent verification through its CBAM consulting service. The CBAM cost calculator sizes the exposure product by product and year by year, and the CBAM guide sets out the reporting steps.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM · Eurostat trade statistics (2024)