A front-end engineering design (FEED) approach is being used to treat CBAM readiness as an engineering, metering, data and commercial-control system rather than an end-of-year ESG report. The stated objective is to connect each tonne of exportable production to a defensible embedded-emissions value, a verified data trail and a buyer-ready CBAM evidence pack.
CBAM enters its definitive regime from 1 January 2026. EU importers, or indirect customs representatives, importing more than a 50-tonne annual mass threshold of CBAM goods must have authorised CBAM declarant status, declare embedded emissions and surrender CBAM certificates annually.
The core covered sectors are cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The certificate price is tied to EU ETS allowance prices, with possible deduction where a carbon price has already been paid in the country of production.
Product boundary and CN-code assessment for Serbian producers
For a Serbian producer using Turkish raw materials and selling into the EU, FEED logic starts with a hard product and CN-code boundary assessment. Tyres or rubber products are not included in the current core CBAM sector list as finished goods.
Even where exported finished products are not directly captured by the core sector list, the commercial risk remains. EU buyers may request product carbon footprint information, supplier emissions evidence, steel-input emissions data, electricity origin details and process-energy data.
The FEED scope also includes forward compatibility with potential downstream CBAM expansion requested by buyers. This results in a requirement for plant design that is CBAM-ready even when direct capture of the exported finished product is not yet established.
Five engineering blocks for CBAM-ready MRV systems
The FEED package is structured around five engineering blocks. The first block focuses on production-boundary engineering to define which production lines, utilities and auxiliary systems belong to each product family.
Production-boundary scope includes mixing, curing, extrusion, calendering, bead-wire preparation, steam generation and compressed air. It also covers boilers, thermal-oil systems, electricity intake, internal transport and waste streams.
The FEED output for this block is described as a process-flow diagram plus an emissions-boundary map. The map is intended to show where direct emissions, electricity-related indirect emissions and supplier-embedded emissions enter the product.
Metering and data-control architecture for reporting readiness
The second block addresses MRV data architecture with a metering and data-control philosophy comparable to technical QA. The FEED design specifies meters and data points for gas consumption, electricity consumption and steam.
Additional specified measurement coverage includes fuel oil/LPG if used. It also includes production mass, scrap and rework tracking.
The architecture extends to batch numbers for production control and raw material lots for traceability. It also requires supplier declarations and export shipment references as part of the reporting dataset.
The CBAM Registry and reporting framework is described as being developed around structured importer and operator reporting. Access for non-EU installation operators is referenced, requiring internal MRV systems capable of exporting clean structured data rather than manually reconstructed spreadsheets.
Supplier carbon passport integration for Turkish inputs
The third block covers supplier MRV integration through a supplier carbon passport concept for Turkish raw-material suppliers. The FEED design introduces material-specific data requirements from suppliers.
Material categories listed include steel wire, carbon black, synthetic rubber and natural rubber. It also includes chemicals, textiles and packaging where relevant to the supply chain inputs.
The FEED approach emphasizes separating actual supplier data from default values. It also targets identification of high-emission inputs and maintaining a procurement ranking based on price, quality, delivery and carbon intensity.
This procurement ranking is positioned as both a compliance input and an operational tool within the supply chain management process. The intent is to use carbon intensity information alongside commercial criteria during sourcing decisions.
Calculation engine design aligned with verification rules
The fourth block focuses on calculation and verification readiness under EU definitive-period implementing rules. These rules cover verification principles and methods for calculating embedded emissions using actual emissions and product-level calculation logic.
The FEED model is described as including a formal calculation engine with controlled formulas. It should maintain version history, emission factors and a source hierarchy while documenting data gaps.
The calculation system is also expected to include uncertainty flags and an approval workflow. The practical output is described as either a CBAM calculation workbook or a digital dashboard linking production volume, energy use, input materials and emissions allocation by product, customer and shipment.
Buyer evidence packs built from site boundaries to verification status
The fifth block covers buyer-facing commercial documentation required by EU customers. Buyers are described as seeking assurance that supplier data can support their own CBAM filing, customs position and supply-chain audit needs.
The FEED package should therefore produce a recurring EU buyer evidence pack containing product description details. It should also include CN-code logic and the production-site boundary used for embedded-emissions calculations.
Additional items listed are energy data, supplier-material declarations, calculation methodology and quality-control sign-off. Responsible persons and verification status are included as part of the evidence pack content.
This documentation set is described as attachable to contracts, tenders and framework supply agreements. It supports recurring exchange of structured evidence rather than one-off reporting artifacts.
Project phasing: Pre-FEED through commissioning shadow MRV
The work is divided into Pre-FEED, FEED, detailed design and operational commissioning phases. In Pre-FEED, products are mapped together with EU buyers, raw-material flows and energy sources alongside CBAM exposure considerations.
The output in Pre-FEED is described as a CBAM exposure matrix. The matrix shows which products are directly covered by CBAM rules, indirectly exposed through inputs or commercially exposed through EU buyer requirements.
In FEED, the company designs the full MRV system including meters, data owners, supplier forms and emissions calculations. The same phase covers IT architecture, document control practices, verification pathway definition and assembly of the buyer pack content.
During detailed design, meters or measurement points are installed or upgraded along with ERP/MES interfaces. Laboratory controls are referenced along with invoice matching processes plus supplier declaration templates and document retention systems.
Commissioning includes a three-month shadow MRV period comparing production data with invoices, energy meters, supplier data and exported shipments. Any gap between operational reality and reported emissions must be closed before the resulting dataset is used with EU buyers.
Control-room deliverables: dashboards, registers and monthly close procedures
The final deliverable is described as a CBAM-ready production control room rather than a PDF policy document. It should include a product-emissions dashboard plus a supplier carbon-risk register tied to sourcing inputs.
Other listed components include a metering matrix paired with a calculation engine. A RACI chart supports roles across responsibilities while monthly MRV close procedures manage ongoing reporting operations.
The deliverable set also includes a verification file index plus an EU buyer declaration template. For management reporting needs referenced in the scope, the system should show where decarbonisation CAPEX has the highest return across multiple levers including electricity procurement changes to traceable low-carbon supply.
The management view should also track reducing steam intensity through process changes such as improving curing efficiency. Additional levers listed include replacing high-emission input suppliers, lowering scrap levels and negotiating differentiated pricing with EU buyers requiring defensible low-carbon supply chains.
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