In its 2025 trade review, Cement Europe put EU cement-and-clinker imports at approximately 14.2 million tonnes. Türkiye led with 42.9% of volumes, followed by Ukraine at 13.3%, Algeria at 11.9% and Egypt at 11.6%. Tunisia accounted for 6.8% and Bosnia and Herzegovina for 2.5%. The figures describe import volumes for 2025 and are not presented as a verified ranking for the first half of 2026 or as proof of market-share shifts attributable to CBAM.
Competition among Mediterranean suppliers is therefore being tested on multiple fronts rather than on trade shares alone. Türkiye’s position is linked to production capacity, maritime logistics and established relationships with European buyers. North African exporters can also compete using proximity to Mediterranean terminals, access to resources and shipping economics. Yet cement and clinker production involves a specific emissions profile that can complicate any simple link between location and carbon-adjusted competitiveness.
Clinker manufacturing generates CO2 from limestone calcination as well as from fuel combustion, so emissions performance depends on production technology, the use of alternative fuels and the extent of clinker substitution. Electricity costs and other production factors can vary in importance depending on the product supplied and the CBAM calculation methodology applied to that shipment. For European buyers moving into the financial phase, emissions-related costs are expected to sit alongside conventional purchasing criteria such as freight rates and delivered price.
CBAM’s financial phase began in January 2026, requiring importers to account for embedded emissions using either applicable default values or verified actual emissions under the relevant rules. The calculation also includes benchmark-related adjustments and any eligible deductions for carbon prices paid in the country of production. This structure means that transport advantages from geographic proximity may not translate into lower total delivered cost once carbon-related liabilities are included.
Certificate pricing is a further driver of delivered-cost calculations. The third-quarter 2026 CBAM certificate reference price reached €82.32 per tonne of CO2 equivalent, rising from €75.28 in the second quarter. That step-up increases the importance of understanding the emissions associated with imported cement and clinker, particularly when contract terms depend on carbon-adjusted pricing rather than headline supply costs alone.
Product differentiation also matters for compliance calculations. Importers purchasing clinker for subsequent grinding must distinguish it from finished cement because the two products should not be assumed to have identical emissions calculations; their production processes and applicable requirements differ. This distinction can affect how embedded emissions are attributed across supply chains feeding European grinding operations.
Even when delivered prices appear similar, carbon-adjusted outcomes can diverge substantially between suppliers. One producer may offer lower-priced clinker but apply a higher applicable default emissions value, while another may charge more yet provide independently verifiable installation-level emissions data that is accepted under CBAM rules. The final comparison depends on port handling, freight distance, kiln technology and which emissions data are accepted for each shipment under the applicable methodology.
The evidentiary burden creates a potential commercial advantage for producers able to document production processes and substantiate emissions figures, though the magnitude depends on methodology fit and available evidence as well as other delivery costs into the EU market. Neither country-of-origin claims nor company-wide sustainability reporting alone is sufficient to establish shipment-level emissions calculations under CBAM requirements.
Market-share interpretation is also complicated by timing effects around compliance implementation. Imports across several industrial sectors accelerated late in 2025 as buyers prepared for CBAM’s financial phase, while European construction demand has remained uneven. A drop in Turkish cement or clinker sales could reflect unwinding of earlier inventory accumulation, weaker end-market demand or a switch between suppliers rather than a direct CBAM-driven reallocation.
Without comparable monthly EU customs data across categories, it would be premature to attribute changes in market shares directly to CBAM based only on volume movements observed after late-2025 stock-building dynamics. The 2025 trade figures therefore provide a baseline view of the Mediterranean supply landscape but do not establish how trade was redistributed during 2026 once financial obligations began.
For European cement producers relying on imported clinker, CBAM increases dependence on upstream emissions information while allowing domestic grinding operations to continue. Contracting decisions for supply routes and investments in grinding terminals may therefore require carbon-adjusted delivered-cost comparisons rather than reliance on pre-2026 import economics alone. Investors assessing kilns, grinding facilities or alternative-fuel upgrades face additional uncertainty as benchmark-related deductions decline over time.
Across Southeast Europe and wider EU supply chains, competitiveness will continue to hinge on location-based logistics economics alongside production costs tied to energy use and process emissions. However, verifiable installation-level emissions data is positioned—based strictly on existing regulatory mechanics—as an increasingly important factor in determining which Mediterranean routes remain commercially viable as CBAM’s financial implications develop.