What EU solar buyers need to know about country defaults, installation data and supplier evidence in 2026.
CBAM is no longer a future reporting requirement. The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. For European buyers importing covered iron and steel products from outside the EU, carbon has therefore moved into the commercial file alongside drawing, steel grade, coating, price and delivery.
For the solar sector, one distinction matters immediately: CBAM does not apply because a product is used in a solar project. It applies according to the customs classification of the imported product. Kıraç Metal’s customs broker currently uses CN 7326 — “other articles of iron or steel” — for these exports. CN 7326 is included in the CBAM iron-and-steel scope.
The legal obligation sits with the importer. The data usually starts with the supplier.
For the mass-based CBAM sectors, the current regime uses a single annual 50-tonne threshold at importer level. Where imports are subject to CBAM, the authorised EU declarant must account for the embedded emissions associated with the imported goods and surrender the corresponding CBAM certificates. The first annual declaration covering 2026 imports is due by 30 September 2027.
But the importer cannot manufacture the supplier’s production data after the event. That is why CBAM is becoming a supplier-qualification issue as well as a customs and compliance issue.
Country default and installation data are not the same thing.
The European Commission has established default values by exporting country and covered good. For iron and steel, the selected total default value is increased by 10% for 2026, 20% for 2027 and 30% from 2028 onwards.
Alternatively, an importer can use actual emissions data from the producing installation when the applicable calculation and verification requirements are met. A country default is a regulatory fallback. It does not describe the actual performance of every factory in that country. Verified installation data can.
That means two suppliers offering the same structural product at the same commercial price can still create different CBAM positions for the buyer — particularly where one can substantiate actual production emissions and the other cannot.
What should an EPC or developer establish before award?
• Which CN classifications apply to the supplied structural-steel products?
• Which installation actually produces them?
• Are the underlying production and material records retained in a usable form?
• Will verified actual emissions data be available, or will a country default apply?
• Can the evidence chain support the importer’s CBAM file when reporting and verification are required?
Where Kıraç Metal stands
Kıraç Metal manufactures solar structural steel in Türkiye for international customers. Its 2026 CBAM calculation and data-readiness work has begun, with current work focused on product classification, producing-installation data, traceability and preparation for the technical calculation and verification path.
This is deliberately not presented as a completed or verified “CBAM-ready” report. The commercial objective is to build the underlying data chain so that relevant information can be supplied when European customers require it and the applicable verification process is reached.
For European solar procurement teams, the question is therefore changing. The structural steel still has to meet the drawing, specification, delivery programme and commercial target. The supplier increasingly also needs to support the emissions position that the buyer may ultimately have to defend.
Primary sources
• European Commission — CBAM definitive regime — https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en
• European Commission — CBAM communication and news / 50-tonne threshold and actual vs default values — https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-communication-and-news_en
• European Commission — corrected default values and legislation — https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en
• Commission Implementing Regulation (EU) 2026/1740 — https://eur-lex.europa.eu/eli/reg_impl/2026/1740/oj/eng