Bilgiç said the uncertainty surrounding default emission values has eased significantly after producers were able to obtain unofficial emission data, following earlier concerns within the industry that "we are struggling to define our roadmap."
He stated that with benchmark values and carbon prices being determined at the beginning of the year, together with the availability of data obtained through pre-verification audits, the potential cost of CBAM has become calculable. According to Bilgiç, the industry's focus should now shift toward reducing emission values to levels that will not create a significant cost burden while maintaining competitiveness.
Bilgiç noted that, for the time being, only Scope 1 emissions are expected to have a financial impact. However, he added that Scope 2 emissions will likely also become subject to financial obligations after 2027.
He also said EAF steel producers are primarily focusing on reducing electricity-related emissions through renewable energy investments. However, discussions continue over whether investments made outside production sites can directly contribute to lowering emission values. Under the current framework, Bilgiç argued that such investments are unlikely to provide benefits beyond reducing grid emission factors. He added that assumptions suggesting solar power plant (SPP) investments could reduce CBAM costs or enable the production of "green steel" will become a greater topic of debate once Scope 2 emissions are included in CBAM's financial liability framework.
Bilgiç said that while producers have begun conducting internal assessments regarding Scope 1 emissions, the industry has yet to engage in sufficient sector-wide discussions. He therefore shared his views on Scope 1 emissions and the measures that can be taken by EAF steel producers.
He stressed that Scope 1 emissions should not be regarded solely as an issue for senior management or environmental departments. Rather, they are fundamentally determined by all materials used in melting, casting and rolling processes, as well as by the consumption of energy sources other than electricity. According to Bilgiç, the selected metallurgical and thermal processes determine both the type and level of consumption. He emphasized that neither technical processes nor the quantity and type of materials consumed are absolute. Nevertheless, most EAF producers continue to regard their existing production processes as fixed and beyond discussion.
According to Bilgiç, the first step toward reducing Scope 1 emissions is to abandon the perception that current EAF metallurgical processes represent the only correct approach and instead redesign them with carbon costs in mind. He added that successful decarbonization will require process designers and plant operators to be actively involved in the transition.
Bilgiç stated that the consumption volumes and embedded emissions of scrap, ferroalloys, electrodes, refractories, natural gas, oxygen, carbon additives and other production inputs account for the largest share of Scope 1 emissions. He emphasized that consumption levels are not fixed but depend on both the type of material used and the steelmaking process, making them open to optimization. Such optimization, he said, would reduce both material consumption and emissions, meaning that Scope 1 decarbonization efforts at EAF plants would also contribute to lower production costs.
Bilgiç noted that process transformation can only be achieved through the development of new metallurgical process designs within the limits imposed by the laws of thermodynamics and thermokinetics. He acknowledged that replacing existing practices with new processes would neither be easy nor quick, and that resistance to abandoning conventional production methods should be expected. In particular, he said, the use of chemical energy in EAF operations is likely to become one of the most debated and strongly defended process practices.
He added that technologies such as artificial intelligence, digital twins, metallurgical and thermal modelling, digitalization and lean manufacturing will play a decisive role in the design and implementation of new processes. According to Bilgiç, apart from the electrification of certain thermal processes, Scope 1 decarbonization is less about selecting off-the-shelf technologies developed by others and more about improving the efficiency and capability of the metallurgical process itself.
Bilgiç stated that the CBAM benchmark value for EAF steel producers stands at 0.11 tonnes of CO₂ per tonne of rolled steel product, while sustainability reports indicate that the best-performing producer in Türkiye currently records approximately 0.22 tonnes of CO₂ per tonne for the same product.
He noted that pre-verification audits have enabled producers to gain a clearer understanding of their own emission values. To remain competitive, he argued, current emission levels must first be reduced by roughly half and then continue declining toward net-zero emissions through an ongoing decarbonization process. While acknowledging that this will not be easy, Bilgiç said the pathway forward is already clear.
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