A proper FEED approach treats CBAM readiness as an engineering, metering, data and commercial-control system rather than an end-of-year ESG report. The stated objective is to build factory operations, supplier-chain inputs, energy procurement and reporting architecture so that each tonne of exportable output can be linked to embedded emissions values supported by a verified data trail. The same architecture is intended to produce a buyer-ready CBAM evidence pack.
EU CBAM definitive regime and covered scope
The CBAM definitive regime starts on 1 January 2026. EU importers, or indirect customs representatives, importing more than the 50-tonne annual mass threshold must have authorised CBAM declarant status. They are required to 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. A deduction may apply 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, the FEED logic begins with a hard product boundary and a CN-code assessment. Tyres or rubber products are described as not being in the current core CBAM sector list as finished goods. Despite that, the source notes that commercial risk can still arise from buyer requests for additional emissions information.
EU buyers may ask for product carbon footprint data, supplier emissions evidence, steel-input emissions information, electricity origin details and process-energy data. The FEED design is described as needing forward compatibility with future downstream CBAM expansion. As a result, the plant is expected to be designed as CBAM-ready even where the exported finished product is not yet directly captured.
Five engineering blocks in the FEED package
The FEED package is structured around five engineering blocks. The first block is production-boundary engineering, which defines which production lines, utilities and auxiliary systems belong to each product family. The scope includes mixing, curing, extrusion, calendering, bead-wire preparation, steam generation, compressed air systems and boilers.
The same boundary definition covers thermal-oil systems, electricity intake, internal transport and waste streams. The FEED output is specified as a process-flow diagram plus an emissions-boundary map. This map is intended to show where direct emissions, electricity-related indirect emissions and supplier-embedded emissions enter the product.
MRV metering and data architecture requirements
The second block focuses on MRV data architecture using 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 use. It also covers fuel oil or LPG if used.
The specified data points include production mass, scrap and rework volumes. Additional inputs include batch numbers for production runs, raw material lots, supplier declarations and export shipment references. The source states that reporting within the CBAM Registry framework is being developed around structured importer and operator reporting with access for non-EU installation operators.
Supplier MRV integration through carbon passporting
The third block addresses supplier MRV integration using what is described as a supplier carbon passport for Turkish raw-material suppliers. Each supplier is expected to provide material-specific data for steel wire and for relevant inputs including carbon black. The list also includes synthetic rubber and natural rubber.
Further material categories named are chemicals, textiles and packaging where relevant. The source describes the strongest commercial position as separating actual supplier data from default values. It also links this separation to identifying high-emission inputs and maintaining a procurement ranking based on price, quality, delivery and carbon intensity.
Embedded-emissions calculation model and verification readiness
The fourth block covers calculation and verification readiness under EU rules adopted for definitive periods. The rules include verification principles and methods for calculating embedded emissions using actual emissions alongside product-level calculation logic. The FEED model is described as requiring a formal calculation engine with controlled formulas.
The calculation engine is specified to include version history, emission factors, source hierarchy, data gaps, uncertainty flags and an approval workflow. The practical output is described as either a CBAM calculation workbook or a digital dashboard. This output links production volume, energy use and input materials to emissions allocation by product, customer and shipment.
Buyer-facing evidence packs aligned with CN-code logic
The fifth block focuses on buyer-facing commercial documentation required by EU buyers. Buyers are described as seeking confirmation that supplier data can support their own CBAM filing, customs position and supply-chain audit rather than only general claims about environmental performance. The FEED package is expected to generate a recurring EU buyer evidence pack.
The evidence pack components listed include product description and CN-code logic along with production-site boundary definitions. It also includes energy data, supplier-material declarations and calculation methodology details. Additional elements named are quality-control sign-off records, responsible persons information and verification status suitable for attachment to contracts, tenders or framework supply agreements.
Pre-FEED through commissioning: MRV shadow period
The work structure is divided into Pre-FEED, FEED, detailed design and operational commissioning. In Pre-FEED, the company maps products, EU buyers, raw-material flows and energy sources alongside CBAM exposure. The result described is a CBAM exposure matrix showing which products are directly covered or indirectly exposed through inputs.
The matrix also distinguishes products commercially exposed through EU buyer requirements. In FEED design work includes meters selection plans, data owners assignment plans, supplier forms preparation approaches and emissions-calculation design along with IT architecture elements such as document control. It also includes a verification pathway plus buyer pack definition.
During detailed design the source lists installation or upgrades of meters plus ERP/MES interfaces integration work. It also includes laboratory controls changes, invoice matching processes improvements, supplier declaration templates preparation and document retention-system setup. In commissioning it specifies a three-month shadow MRV period comparing production data with invoices, energy meters, supplier data and exported shipments.
The source states that any gap between operational reality and reported emissions must be closed before the resulting data is used with EU buyers.
Operational deliverables: control room outputs instead of PDFs
The final deliverable described is 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. Other items listed are a metering matrix and a calculation engine along with an RACI chart for roles.
The control room outputs also include a monthly MRV close procedure plus a verification file index. An EU buyer declaration template is listed as part of the deliverable set. For management reporting purposes the same system should indicate where decarbonisation CAPEX has the highest return based on items such as switching electricity procurement to traceable low-carbon supply.
Other CAPEX-return areas named are reducing steam intensity through process changes such as improving curing efficiency. The list also includes replacing high-emission input suppliers and lowering scrap volumes while negotiating differentiated pricing with EU buyers requiring defensible low-carbon supply chains.
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