A sales manager at a steel-structure manufacturer reads the email from the German customer for the third time: “Could you send us your product-level embedded emissions data and your suppliers’ carbon data by the end of next month?” There’s no template on hand, and no one is sure whose job it is to ask suppliers for this. Finance knows the financial data, production knows the process data, but no one owns the emissions figure that ties them together. In 2026, most manufacturers in Türkiye selling into the EU face the same picture.
Why CBAM and CSRD are asking suppliers for data
The EU’s Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026; companies importing into the EU in the covered sectors (iron and steel, cement, fertilisers, aluminium, electricity, hydrogen) must declare a product’s embedded emissions. The first certificate surrender and payment obligation starts on 30 September 2027, but data collection has to start now — 2026 shipment data cannot be reconstructed retroactively later.
Large EU companies under the CSRD/ESRS E1 standard, meanwhile, must disclose Scope 3 emissions — the indirect emissions that sit outside their own operations, in the supply chain. In many sectors, the largest share of total carbon footprint comes not from direct production but from the supply chain, which is exactly why an EU buyer ends up asking its supplier in Türkiye for data. Contract language between importer/buyer and supplier is also expected to expand around data sharing, verification responsibility, and default-value risk.
The result: an exporting SME has to collect and standardise both its own data and — where applicable — its own suppliers’ data, and be ready to produce it quickly whenever a request lands.
Why the data stays scattered
In most companies, emissions/energy data sits fragmented across three places:
- In accounting/ERP — energy bills, fuel purchases, shipment records exist, but as expense line items, not under an “emissions” label.
- In production/MES systems — machine run hours and raw-material consumption exist but aren’t matched to a carbon calculation.
- In email and spreadsheets — when a customer request arrives, someone collects it by hand, and the process starts from zero again next time.
When these three sources aren’t linked, every request turns into firefighting. Data quality also stays low: inconsistent units, missing periods, assumptions mixed in with measurements — which creates a trust problem on the EU buyer’s side too.
How to build a digital supply-chain data flow
Setting this up generally follows this order:
- Supplier segmentation. Not every supplier carries the same priority. Suppliers with a high share of spend and whose products fall under CBAM/CSRD scope are addressed first; smaller, lower-volume suppliers go into a second wave.
- A standard data template. Define clearly which data point is requested, in which unit, for which period (see the table below). Without a template, every supplier sends data in a different format and merging it stays manual.
- A collection channel. Using a supplier portal or an ERP-linked form instead of email improves both data quality and collection speed. Even a simple web form at small scale produces a more traceable result than an email thread.
- ERP/data-warehouse integration. Once collected data is matched against existing shipment/production/purchasing records in the ERP, product-level emissions calculation becomes automatic — no need to recalculate from scratch on every request.
- Verification and version logging. Keeping a record of who entered what data and when makes it far easier to produce evidence for an independent verifier (accredited under CBAM’s Implementing Regulation 2018/2067).
Which data points to collect
| Category | Example data | Typical source |
|---|---|---|
| Energy consumption | Electricity, natural gas, fuel (kWh/m³/litre, per period) | Bills, meters, ERP expense lines |
| Production volume | Product/batch-level production quantity | MES, production planning module |
| Raw materials/inputs | Quantity and source of key inputs from suppliers | Purchasing, ERP supplier record |
| Transport | Shipment distance, mode (road/sea/air) | Logistics, delivery note |
| Emission factor | Conversion coefficient by source used | Official emission factor databases (covered in our Scope 1-2-3 guide) |
This table is a starting point; sector and product group may require additional line items. Where a request needs an exact figure or threshold, confirm current regulation or check with your advisor.
Data quality and verification points to watch
- Separate default values from measured data clearly. CBAM default values are a temporary convenience; a supplier that can provide real measured data stays in a more credible position with the buyer.
- Unit consistency. Mixing kWh with MWh, or tonnes with kg, causes serious errors when data is merged — units should be fixed at the template stage.
- Period consistency. Mixing monthly, quarterly, and yearly data produces a wrong total; the calculation period needs to be settled upfront.
- Evidence trail. When a verifier asks “where does this number come from,” it should be traceable all the way back to the invoice or record.
Practical first steps for an SME supplier
For an SME that is itself someone else’s supplier, the process usually starts by clarifying which product groups fall under CBAM/CSRD scope, then checking where existing energy/production data actually lives — in the ERP, on paper, or not recorded at all. If it isn’t recorded at all, building a basic measurement/record discipline first — then digitalising it — is the healthier order. Clarifying exactly which data point is actually being requested, before rushing into a large software purchase, avoids unnecessary spend.
Where İkiz Eksen fits in
İkiz Eksen measures production/energy data and moves it into ERP/data infrastructure on the digital transition side, while making the same data exportable in the format CBAM/CSRD expects on the green transition side — which is exactly the intersection this article is about: the twin transition. Scope ranges from a data-collection flow integrated into an existing ERP to full supplier segmentation, depending on the project. Organisations wanting a clear assessment on this can send a request through the contact form.
Frequently Asked Questions
My EU customer is asking for supplier data, but my suppliers are small businesses that don’t keep records. What should I do?
Start with the highest-volume, most critical suppliers first. Instead of asking a small supplier for detailed measurement right away, ask them to establish a basic energy/raw-material record discipline first; digital data collection can follow over time. Some large buyers tolerate default-value use for a defined transition period — clarify this directly with your buyer.
Can I keep collecting data with spreadsheets, or do I need software?
With a small number of suppliers and low request frequency, spreadsheets can hold up for a while. But as the number of suppliers, request frequency, or verification needs grow, a manual process becomes error-prone and time-consuming; past a certain point, portal/ERP integration takes less effort overall.
Who verifies the data I collect from suppliers?
Under CBAM, product-level embedded emissions data is confirmed by an independent verifier accredited under EU Implementing Regulation 2018/2067. Under CSRD, the large buyer company’s own audit process may question the traceability of supplier data.
How long does this take to set up?
It depends on scale and existing data maturity; a template and collection process alone can be set up in a few weeks, while ERP integration and full automation can be a project spanning months. Clarifying exactly which data point is genuinely being requested before committing to a large-budget solution saves time.
Can one ERP module hold both production and emissions data?
Most ERPs don’t come with emissions calculation built in; but if production/energy/purchasing modules are configured correctly, emissions calculation can be added as a layer built on top of that data. It’s worth evaluating the existing ERP’s data structure before choosing a module.
Sources
European Commission CBAM page (taxation-customs.ec.europa.eu) · EUR-Lex CSRD/ESRS E1 text · GHG Protocol Scope 1-2-3 framework · EU Implementing Regulation 2018/2067 (verifier accreditation). Confirm current thresholds, dates, and figures after the publication date.