CBAM Compliance Puts Turkish Metal Supply Chains Under Scrutiny

The introduction of the European Union’s Carbon Border Adjustment Mechanism is increasing compliance requirements across metal supply chains linking Turkey, Serbia and EU markets. For Serbian producers of steel and aluminium products, emissions data from Turkish raw-material suppliers is becoming an essential component of export documentation as CBAM moves from a reporting framework to a system with direct financial implications.

Under the definitive CBAM regime, which entered into force on 1 January 2026, EU importers of covered products must operate through an authorised CBAM declarant, report embedded emissions and surrender CBAM certificates tied to the price of allowances under the EU Emissions Trading System (EU ETS). The European Commission reported a first-quarter 2026 CBAM certificate price of €75.36 per tonne of CO₂ equivalent. The regulatory framework allows deductions for eligible carbon costs already paid during production, increasing the importance of emissions traceability throughout international supply chains.

Metal Trade Volumes Increase Compliance Importance

The requirements are particularly relevant for Serbia because of the scale of its metals trade with the European Union. In 2025, EU imports from Serbia included approximately €599 million of iron and steel products and around €863 million of non-ferrous metals. Trade flows in the opposite direction also included substantial volumes of metal products.

The significance of these trade relationships means CBAM compliance is becoming an operational issue for producers, processors and exporters operating within integrated regional supply chains.

The challenge extends beyond customs procedures. Serbian exporters must increasingly demonstrate, on a product-by-product and batch-by-batch basis, the embedded emissions associated with steel and aluminium inputs sourced from Turkey and subsequently processed in Serbia before being shipped to EU customers. As a result, Turkish production data is becoming part of the evidentiary framework supporting Serbian exports.

Serbian Producers Operate Across Different Carbon Profiles

Serbia’s metals industry includes producers operating under different manufacturing models and emissions profiles. HBIS Serbia operates an integrated steel facility in Smederevo with annual production capacity of approximately 2.2 million tonnes. The company manufactures flat-steel products including hot-rolled coil, cold-rolled coil, pickled coil and tinplate.

Metalfer focuses on scrap-based steelmaking and long-product manufacturing, operating across rebar, wire rod and coil production chains. In the aluminium sector, Impol Seval serves international markets through production of rolled aluminium products and has undertaken furnace-modernisation investments aimed at reducing gas consumption and energy use. These differing production routes create varying emissions characteristics, increasing the importance of accurate emissions accounting for exported products.

Turkish Suppliers Become Part of Emissions Reporting Chains

For Serbian steel producers and processors, a number of Turkish suppliers are relevant within potential procurement networks. Among flat-steel and coated-steel producers, Erdemir manufactures hot-rolled, cold-rolled, galvanised and tin- or chrome-coated flat products.

In long products and semi-finished materials, Kardemir Çelik operates across steelmaking, billet production, profiles, rebar and wire rod manufacturing. The aluminium supply chain includes companies such as Eti Alüminyum, which operates in bauxite processing, alumina production and cast aluminium manufacturing.

Assan Alüminyum produces flat-rolled aluminium products, including sheet, foil, coil and pre-painted materials, with declared installed capacity of up to 360,000 tonnes and exports to more than 70 countries. Other relevant suppliers include ASAŞ, active in extrusions, flat-rolled products and aluminium systems, and Teknik Alüminyum, which manufactures aluminium coil, sheet and strip products across multiple alloy categories. The supplier landscape is treated as a potential sourcing map rather than confirmation of direct commercial relationships unless supported by invoices, customs records or mill certificates.

Customs Classification Drives CBAM Obligations

The determination of CBAM obligations depends on customs classifications rather than broad commercial product descriptions. EU guidance requires companies to identify imported products according to Combined Nomenclature (CN) codes and collect installation-level information from the facilities where those products are manufactured. The mechanism currently covers sectors including iron and steel, aluminium, cement, fertilisers, electricity and hydrogen, together with selected precursor and downstream products.

For steel products, exporters must identify whether imported inputs consist of billets, slabs, hot-rolled coil, cold-rolled coil, coated sheet, wire rod, bar products, tubes, fastener materials or other covered categories.

The CBAM methodology also requires information relating to scrap content, alloy composition and emissions associated with precursor materials. Scrap-based production routes are treated differently from primary steel production pathways, but claims regarding recycled content must be supported by documented evidence.

Aluminium Reporting Requires Product-Level Data

The same classification principles apply to aluminium products. Products within the CBAM scope include unwrought aluminium, powders, rods, bars, profiles, wire, plates, sheets, strip, foil, tubes, fittings and several downstream aluminium goods. Aluminium scrap remains outside the CBAM perimeter.

The reporting methodology distinguishes between primary and secondary aluminium production and requires information relating to direct emissions, indirect emissions during transitional phases, precursor materials and, where applicable, process emissions including perfluorocarbons. These requirements are increasing demand for plant-level production data throughout the supply chain.

Procurement Standards Expand Beyond Traditional Criteria

To support compliance requirements, Serbian exporters purchasing metal products from Turkey are increasingly required to maintain detailed procurement documentation.

A minimum emissions-compliance file typically includes supplier and plant identification, CN codes, non-preferential origin data, batch or heat numbers, mill certificates, product weights, production-route information, direct emissions measured in tonnes of CO₂ equivalent per tonne of product, precursor emissions, electricity-consumption data, emission factors, scrap content, alloy composition, records of any carbon costs paid and confirmation that information can withstand third-party verification.

Traditional sustainability documentation, ISO certifications, I-REC claims and renewable-energy marketing materials may provide supporting information but do not replace installation-level emissions data required under CBAM methodologies. The commercial implications extend beyond regulatory compliance. EU buyers increasingly evaluate suppliers based on the strength of emissions documentation supporting imported products.

Exporters able to provide verified low-carbon emissions data for Turkish-origin inputs can support pricing, contractual eligibility and customer confidence. Where plant-level emissions information is unavailable, buyers may seek discounts, impose additional contractual protections, delay customs processing or transfer future CBAM-related liabilities through supply agreements.

Turkish Climate Policy Influences Future Reporting

Developments within Turkey are also affecting the compliance environment. Türkiye adopted its first Climate Law in July 2025, creating the legal foundation for a national emissions trading system. A pilot phase for the Turkish ETS is expected to begin during 2026.

While these measures do not eliminate CBAM obligations, they increase pressure on Turkish steel and aluminium producers to generate monitoring, reporting and verification data compatible with EU requirements. Over time, such systems may also support claims relating to deductible carbon costs where payments satisfy EU eligibility criteria.

Downstream Products Face Growing Regulatory Attention

The European Union has indicated plans to examine the extension of CBAM requirements to additional downstream products while strengthening anti-circumvention measures. For Serbian exporters, this creates potential exposure beyond primary steel, aluminium and semi-finished materials.

More highly processed products, assemblies and metal-intensive manufactured goods may come under increased scrutiny, particularly where regulators identify risks of production activities relocating outside the European Union to avoid carbon-related costs. As a result, procurement strategies are increasingly incorporating emissions-data readiness alongside conventional commercial considerations.

For companies including HBIS Serbia, Metalfer, Impol Seval and downstream manufacturers using Turkish inputs, supplier evaluation is expanding beyond price, quality, delivery performance and payment terms to include installation-level emissions data, verification standards, precursor traceability and the ability to provide repeatable evidence for individual shipments.

Within this framework, suppliers are increasingly expected to provide not only steel, aluminium, billet, foil, coil or profile products, but also verified emissions information capable of supporting CBAM declarations throughout the supply chain. Serbian exporters, in turn, are building documentation systems designed to connect Turkish-origin raw materials, Serbian processing operations and EU import declarations through a consistent chain of origin, carbon-cost and embedded-emissions data.

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