Insight

With manufacturing capabilities in Turkey, sales and logistic centres in nine countries as well as a robust logistics network, Norm Holding and its affiliated companies have been conducting carbon emissions accounting for the past four years, enabling the company to adapt quickly and efficiently register for the third country operator’s portal.

However, the process for compliance with the Carbon Border Adjustment Mechanism (CBAM) regulation has reinforced the critical importance of robust energy data monitoring systems, particularly within production operations. Mahmut Öztürk, CEO at Norm Holding, highlights: “We closely monitor all announcements and regulations relating to CBAM. To promptly meet customer demands we have also prepared and shared site specific reports using the official European Commission communication templates. Internally, we have enhanced our ERP system to generate production reports based on CN codes, allowing us to track emissions at the product level.” 

Norm is also providing direct, one to one support for its suppliers requiring assistance with CBAM-related topics, sharing knowledge and experience to achieve transformation across the supply chain, particularly in the context of CBAM reporting. All collected data is then reviewed internally and supported with appropriate documentation. This collaborative approach contributes to developing a more resilient and transparent supply chain for its customers – something that Mahmut believes will become a deciding factor. He explains: “Although we have not yet observed a substantial reallocation of orders, there is a clear trend towards preferring suppliers with robust CBAM aligned reporting capabilities and verifiable sustainability performance. Specifically in the steel sector, a shift from traditional blast furnace operations to electric arc furnace technology is gaining momentum, driven by the demand for lower embedded emissions. Moreover, the recycled content ratio is becoming a key differentiator in procurement criteria, which is why Norm Holding is well positioned to support its partners with lower emission product alternatives and traceable material sourcing.”

To further serve its customers, Norm has also completed its registration for the third country operators portal and has successfully registered five of its production facilities that manufacture CBAM covered products. Mahmut underlines: “With a commitment to transparency, all this information is shared with our customers via their EORI number. We are aware, however, that some EU importers are facing challenges in accessing detailed emissions data through the portal, as it currently provides less information than the communication template. We are committed to closely monitoring these issues and remain hopeful that they will be resolved in the near term.”

“Several areas of uncertainty remain regarding CBAM, particularly in relation to embedded emissions calculation methodologies, verification standards and the treatment of indirect emissions,” continues Mahmut. “Further clarification is also needed on how CBAM will be aligned with the EU Emissions Trading System (ETS) and other regional regulatory frameworks.”

He adds: “While the proposed Omnibus Regulation introduces certain facilitations for EU importers, it would be beneficial to extend similar digital solutions to third-country operators to improve data traceability and quality in embedded emissions reporting. The principles governing the verification processes set to begin in 2026 have not yet been finalised and the secondary legislation is still awaited. It has been indicated that verifiers may be located anywhere globally, provided the EU accredits them, but more specific guidance is necessary to ensure consistency and credibility in implementation.”

Mahmut concludes: “CBAM is not an endpoint, but a starting point for broader transformation. We are planning additional investments in areas such as renewable energy, electrification of production processes, as well as granular product level carbon accounting. These initiatives will enhance our overall sustainability performance and enable us to align more closely with the climate targets of our customers.”