CBAM: The New Hidden Cost in Your Cement and Clinker Budget
The EU's Carbon Border Adjustment Mechanism is now live. For buyers importing cement or clinker from Turkey and North Africa, it's creating a cost you can't fully quantify yet, and that uncertainty is itself a risk worth managing.
5 May 2026
CBAM: The New Hidden Cost in Your Cement and Clinker Budget
A practical guide for procurement teams and CFOs importing cement or clinker into the EU, and why the cost uncertainty may be bigger than the cost itself.
5 May 2026
The EU's Carbon Border Adjustment Mechanism is now live.
From 1 January 2026, CBAM moved into its definitive phase. Commercial-scale EU importers of cement and clinker above the de minimis threshold now need to account for the embedded carbon emissions in those imports. The financial obligation relates to goods imported from 2026 onwards, with certificate purchase and surrender for 2026 imports expected to take place later in 2027.
If you're procuring cement or clinker from outside the EU, particularly from Turkey, Egypt, or North Africa, this adds a new layer of cost to every tonne you bring in. And right now, the size of that cost is genuinely difficult to pin down.
Here's the problem: the numbers are not yet clear.
CBAM costs are calculated using embedded emissions data from the exporting producer. If that data has been independently verified, importers pay a rate based on actual emissions intensity. If it hasn't, which is the case for many suppliers right now because verification timing and capacity remain uncertain during 2026, importers fall back onto a default value set by the European Commission.
For Turkish cement and clinker, the concern is that no country-specific default value has yet been confirmed. Turkish industry bodies have argued that, in the absence of such a value, cargoes are being exposed to the broader "other countries" default. Türkçimento has reported actual grey clinker emissions of around 0.88 tCO₂/t during the CBAM transition period, compared with a default value of 1.551 tCO₂/t. Industry estimates suggest this could move the carbon cost from around €20/t to around €80/t of clinker at current EU ETS price levels.
To put that in context: Turkish clinker was trading at around $44-48/t FOB in early 2026. An €80/t CBAM charge at default values would exceed the cost of the product itself.
What this means for procurement.
Even where a Turkish or Egyptian supplier intends to pursue verification, the timeline is constrained. The process requires a full year of data, and accredited verifiers for third-country installations are not yet widely available. That means many EU buyers are currently working with a CBAM cost that sits somewhere between €20/t and €80/t per tonne of clinker, and they don't yet know where in that range they will land.
Here's a simplified illustration of how that uncertainty plays out across a typical procurement position:
| FOB Price $/MT | Freight $/MT | CBAM (verified) €/MT | CBAM (default) €/MT | All-in delivered cost difference | |
|---|---|---|---|---|---|---|
Jan 26 | 46 | 17 | ~20 | ~80 | ~€60/MT unknown | |
Feb 26 | 45 | 18 | ~20 | ~80 | ~€60/MT unknown | |
Mar 26 | 47 | 16 | ~20 | ~80 | ~€60/MT unknown |
For a buyer taking 10,000 MT per month, a €60/t difference between verified and default assumptions creates up to €600,000 per month of budget and provisioning uncertainty. That may not be an immediate cash payment in 2026, as settlement comes later, but it is a real commercial exposure when pricing, contracting, and forecasting.
The uncertainty is the risk.
Most procurement teams are used to managing price risk. They model scenarios, set budgets, and negotiate with suppliers. But CBAM introduces a new kind of uncertainty that sits outside both the supply contract and the standard pricing index.
It doesn't show up in the FOB price. It doesn't move with the Platts benchmark. It's a function of carbon data, verification timelines, EU ETS certificate prices, and policy, none of which procurement teams have traditionally needed to track.
This is exactly the kind of exposure where a financial overlay can help. Not by replacing your supply agreement, but by giving your budget a defined cost to work with, separate from the physical transaction, so that finance and procurement can plan with confidence rather than provisioning for a worst-case scenario that may or may not materialise.
What to do now.
Whether or not you're ready to use a financial instrument, there are steps every procurement team should take immediately:
Ask your supplier directly whether they are pursuing CBAM verification, and on what timeline
Understand which default values apply to the origin of your supply, and what they mean for your cost base
Work with finance to model the budget impact across verified and default scenarios
Consider whether a fixed price overlay on part of your forecasted volume would give your budget the certainty it needs
CBAM calculations can also be affected by EU benchmark adjustments, the phasing out of free allocation, and any recognised carbon price already paid in the country of origin, so buyers should treat the figures above as commercial estimates rather than final compliance costs.
CBAM is not going away, and the verification bottleneck is temporary. But the exposure between now and when that settles is real, and it compounds every month you're not planning for it.
The strongest position is not to wait for certainty that won't come quickly. It's to plan around the range, and use the tools available to reduce it.
If you'd like to understand how a price protection structure could help manage that exposure alongside your existing supply arrangements, get in touch and we'll walk you through it.