The EU Carbon Border Adjustment Mechanism (CBAM) moved from its transitional phase into the definitive period on 1 January 2026. Producers of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen that sell into the EU now have to give their EU customers verifiable, product-level embedded emissions data. Where that data is missing, the EU declarant falls back on default values, which usually means a higher cost. Sales of CBAM certificates are currently expected to start in February 2027. 360 Soft builds and deploys CBAM emissions reporting software that collects this data from your production, energy, purchasing and ERP systems, calculates it according to the methodology, produces a verifier-ready evidence file and generates the emissions reports you share with your EU importer.
The problem: who is affected and why now
Legally, the obligation sits with the EU importer, the authorised CBAM declarant. But the content of the declaration, the embedded emissions, only exists at the producer, at the installation outside the EU. That is why EU buyers are asking their suppliers for more detailed and verified data every quarter. In practice, the following groups are affected:
- Producers exporting in-scope goods to the EU: crude steel, flat and long products, fasteners, primary and processed aluminium, clinker and cement, nitrogen fertilisers, hydrogen and electricity.
- Intermediate producers in the supply chain: companies that make precursors for in-scope goods and sell them to another producer, because precursor emissions are carried into the final product.
- Trading companies and intermediaries: exporters who must pass producer data on to their EU customer.
- Groups with EU subsidiaries: where intra-group imports put both the declaration and the data burden inside the same group.
Spreadsheets and one-off consultant reports were enough for quarterly reports in the transitional phase. In the definitive period, data has to be repeatable, traceable to source documents and ready for third-party verification, year after year and for every product your customers buy.
Regulatory background: key CBAM concepts
| Concept | What it means |
|---|---|
| Authorised CBAM declarant | The EU-based party allowed to import CBAM goods and file the annual declaration. |
| Embedded emissions | Greenhouse gases released in producing the goods, including relevant precursors. |
| Direct emissions | Emissions from the production processes at the installation itself. |
| Indirect emissions | Emissions from the electricity consumed in production; relevant for some sectors only. |
| Default values | Values published by the European Commission and used when actual data is not available; typically less favourable. |
| Precursors | Input materials whose own embedded emissions are added to the final product. |
| Verification | Independent check of actual emissions data by an accredited verifier. |
| Carbon price paid | A carbon price already paid in the country of origin, which may be deducted under the rules. |
| CBAM certificate | The instrument the declarant surrenders, priced in line with the EU ETS. |
The Turkish side: Climate Law and the national ETS
Our team operates from Türkiye, where the Climate Law adopted in 2025 lays the foundation for a national emissions trading system. A carbon price paid under a domestic ETS may become relevant to CBAM deductions in the future, so the software keeps that data structure ready. For producers in other countries, the same logic applies to their local carbon pricing schemes, and local rules in the buyer’s or producer’s country always apply in addition to the EU regulation.
What the software does: modules and features
| Module | Core functions | Benefit |
|---|---|---|
| Installation and product modelling | Define installations, production processes, routes and CN codes | One consistent model behind every report |
| Activity data collection | Fuel, raw material, electricity and production volumes from ERP, meters and files | No manual re-keying, fewer errors |
| Emission calculation engine | Calculation-based and measurement-based methods, emission factors, mass balance | Methodology-compliant, repeatable figures |
| Precursor management | Track precursors and their embedded emissions, internal and purchased | Correct product totals across the chain |
| Supplier data portal | Request, collect and validate data from your own suppliers | Replaces e-mail and spreadsheet chasing |
| Allocation | Allocate installation emissions to products and periods | Product-level specific embedded emissions |
| Evidence and audit trail | Link every figure to source documents, versions and approvals | Faster, cheaper verification |
| Customer reporting | Generate the communication template and customer-specific reports | Quick answers to EU importers |
| Dashboards | Emission intensity per product, site and customer | Management visibility and reduction planning |
What data is typically needed
- Production volumes per product and CN code, by period
- Fuel consumption (natural gas, coal, coke, diesel) and their net calorific values
- Raw materials and precursors, with origin and supplier data
- Electricity consumption by process, plus grid or contract emission factor where relevant
- Process emissions sources such as carbonates and electrodes
- Meter readings, invoices, laboratory analyses and calibration records as evidence
Architecture and integrations
The system runs in your cloud tenant or on-premises. It connects to SAP, Microsoft Dynamics, Oracle, Logo, Netsis and other ERP systems through APIs, database views or scheduled file transfers, and to energy monitoring systems, SCADA historians and laboratory systems where available. A web portal serves internal users, suppliers and, optionally, your EU customers. Calculation logic is versioned, so a report from last year can always be reproduced exactly as it was submitted. Data can be exported in formats your customer’s CBAM registry workflow can use.
Implementation process: steps and typical durations
| Step | What we do | Typical duration |
|---|---|---|
| 1. Discovery | Products, CN codes, installations, systems and customer requirements | 1–2 weeks |
| 2. Methodology design | Boundaries, production routes, calculation methods, data sources | 2–3 weeks |
| 3. Data integration | ERP, meter and file connectors; supplier portal set-up | 3–6 weeks |
| 4. Calculation and testing | Build the model, back-test against historical reports | 2–4 weeks |
| 5. Evidence pack | Audit trail, document links, verifier walkthrough | 1–2 weeks |
| 6. Go-live | Training, first customer reports, handover | 1–2 weeks |
| 7. Operation | Support, regulatory updates, optional data operations | Ongoing |
The durations above are typical ranges, not commitments; a single-installation producer moves faster than a group with several sites and many precursors. A team can typically start within 1–2 weeks of signing.
Carbon data management as a service
Many producers do not have the people to run data collection every month. Our carbon data management service can take over collection, validation, supplier follow-up and report preparation on top of the software, with a dedicated team that works remotely, on-site or in a hybrid model. It also pairs well with digital product passport software and ISSB-aligned sustainability reporting software, which reuse the same emissions data.
Cost factors
We do not publish fixed prices because the scope varies a lot between producers. These are the factors that drive effort and cost:
| Factor | Effect on cost |
|---|---|
| Number of installations and production routes | Each site and route needs its own model and data flows |
| Number of products and CN codes | More products mean more allocation rules and reports |
| Precursor complexity | Purchased and internal precursors add calculation and supplier work |
| ERP and system landscape | Clean APIs are quicker than legacy databases or manual files |
| Supplier data collection | Portal set-up, supplier onboarding and follow-up effort |
| Measurement-based methods | Continuous emissions monitoring adds integration work |
| Ongoing data operations | Whether your team or ours runs monthly collection and reporting |
Comparison: spreadsheets, off-the-shelf SaaS and custom software
| Criterion | Spreadsheets and consultant reports | Off-the-shelf SaaS | Custom, integrated software (360 Soft) |
|---|---|---|---|
| Integration with ERP | Manual | Limited connectors | Direct integration with your systems |
| Repeatability | Low; depends on individuals | Good | High; versioned calculation logic |
| Fit for complex precursors | Weak | Varies | Modelled to your production routes |
| Audit trail | Scattered files | Usually good | Full, linked to source documents |
| Data ownership | Yours, but fragmented | On the vendor platform | Yours, in your environment |
Measuring success: KPI table
| Indicator | What it measures | Why it matters |
|---|---|---|
| Share of products with actual data | Products reported on actual values versus defaults | Defaults usually cost your customer more |
| Report turnaround time | Days from period end to customer report | EU buyers expect quick answers |
| Data completeness | Required fields filled with evidence attached | Determines verification readiness |
| Verification findings | Number of issues raised by the verifier | Lower means less rework and cost |
| Emission intensity trend | tCO2e per tonne of product over time | Basis for reduction and pricing discussions |
Data security, confidentiality and data protection
Emissions data reveals production volumes, recipes and energy costs, so it is commercially sensitive. The system uses role-based access, encryption in transit and at rest, single sign-on options and full logging. Suppliers only see their own data, and customers only see the reports you release to them. Contractually, we work under a B2B service agreement with IP assignment of the custom code to you, an NDA, and a data processing agreement under the GDPR with Standard Contractual Clauses (or the UK IDTA where applicable). As a Turkish company we also comply with KVKK, the Turkish data protection law.
Checklist for choosing software and a partner
- Does the solution support both calculation-based and measurement-based methods?
- Can it model your precursors and production routes, not just a single factor per product?
- Does every figure link back to source documents for the verifier?
- Is the calculation logic versioned so past reports can be reproduced?
- Does it integrate with your ERP rather than relying on uploads?
- Can suppliers submit data through a portal with validation?
- Who owns the code and the data at the end of the contract?
- Can the partner also run data operations if your team is stretched?
Why 360 Soft
We combine software engineering with operational delivery. The same company that builds the platform can provide the team that runs it, from a single analyst to a team of 200+ people, remote, on-site or hybrid, with 24/7 shifts where needed and a replacement process if a team member changes. Our team works from Istanbul, close to many of the steel, aluminium, cement and fertiliser producers that export to the EU, and we work in English with international customers. See also our software outsourcing services and SAP consulting.
Frequently asked questions
What is CBAM?
The EU Carbon Border Adjustment Mechanism puts a carbon price on certain imported goods, in line with the EU ETS, based on the emissions embedded in those goods.
Which sectors are in scope?
Iron and steel, aluminium, cement, fertilisers, electricity and hydrogen, including certain downstream products such as fasteners.
When did the definitive period start and what changed?
It started on 1 January 2026. Reporting is now annual, data must be verifiable, and declarants will have to surrender certificates for embedded emissions.
When will CBAM certificates be purchased?
Certificate sales are currently expected to begin in February 2027, covering emissions of goods imported from 2026. Check the latest Commission guidance, as dates can change.
Who is the authorised CBAM declarant?
The EU-based party authorised to import CBAM goods and submit the annual declaration, typically your EU importer or its customs representative.
How are embedded emissions calculated?
Installation emissions are measured or calculated, attributed to production processes and divided by production volume, then precursor emissions are added.
Why are default values a disadvantage?
Default values are deliberately conservative, so they usually produce higher embedded emissions and a higher certificate cost than verified actual data.
Does the software replace verification?
No. Verification is done by an accredited verifier. The software makes it faster by linking every figure to its evidence and keeping a full audit trail.
We use SAP. Can it integrate?
Yes. We integrate with SAP and other ERP systems through APIs, database views or scheduled file transfers, depending on your landscape.
How long does implementation take?
Typically 8–16 weeks for a first go-live, depending on the number of installations, products, precursors and systems involved.
How do we collect data from our suppliers?
Through a supplier portal with structured forms, validation rules and reminders, so precursor data arrives complete and with evidence.
Can you also run data collection for us?
Yes. Our carbon data management team can run monthly collection, validation, supplier follow-up and report preparation on top of the software.
Let us build your CBAM data infrastructure together
Tell us which products, sites and systems are involved and we will come back with a scoped proposal and a realistic timeline. Call or WhatsApp us on +90 850 335 10 87, write to info@360-soft.com, message us directly on WhatsApp, or use the contact page. 360 Soft Marketing Yazılım ve Danışmanlık Ltd. Şti., Nidakule Ataşehir Batı, Barbaros Mah. Begonya Sk. No:1 D:2, 34746 Ataşehir/İstanbul.
