CBAM for Turkish exporters
For a Turkish company shipping steel or aluminium into the EU, CBAM does not send you a bill — the legal obligation sits with your EU customer, the importer. What it does is put a price, from 2026, on the carbon embedded in the steel, aluminium, cement and fertilisers you export, and that price is worked out on your goods' emissions. So the practical demand it makes of a Turkish exporter is data: your EU buyer will ask you for verified embedded-emissions figures, and if you cannot supply them they fall back on marked-up default values that make your goods costlier to import than a rival's.
What is CBAM?
CBAM — the Carbon Border Adjustment Mechanism — is the European Union's tool for putting a price on the carbon emitted in producing carbon-intensive goods imported into the EU. It was established by Regulation (EU) 2023/956 and amended by the 2025 "Omnibus" simplification Regulation (EU) 2025/2083, and it entered its definitive period on 1 January 2026 after a transitional, reporting-only phase that ran from 2023 to 2025, according to the European Commission.
"The Carbon Border Adjustment Mechanism (CBAM) is the EU's tool to put a fair price on carbon emitted during the production of carbon-intensive goods that are entering the EU"
Which goods does CBAM cover?
CBAM covers imports in six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, per the European Commission. As of 6 July 2026, that six-sector list is the whole of CBAM's scope. A separate Commission proposal adopted on 17 December 2025 would extend coverage to around 180 downstream steel and aluminium products from 1 January 2028, but it is not yet in force. If you export steel, aluminium, cement or fertilisers to the EU, your product is in scope today; electricity and hydrogen are covered too, but they sit outside the small-importer exemption described below.
Does CBAM apply to me if I am the exporter, not the importer?
CBAM's legal obligations fall on your EU customer — the importer — not on you as the Turkish exporter. It is the importer who has to account for the carbon embedded in the goods and, from 2027, buy and surrender CBAM certificates against it. Only an authorised CBAM declarant can claim the carbon-price deduction described later, per the European Commission's CBAM Questions and Answers. Your role is different but decisive: the importer's bill is calculated on the embedded emissions of your goods, so they will come to you for verified emissions data. In practice CBAM reaches a Turkish exporter through the customer's purchase terms, not through a filing you make to Brussels yourself.
What happens in 2026, and what happens in 2027?
2026 is not a year in which anyone pays. CBAM's definitive period began on 1 January 2026, but 2026 is only when financial liability starts to accrue — no CBAM certificate is bought or surrendered during it. Under the Omnibus amendment, the first CBAM declaration and the buying and surrender of certificates for 2026 imports fall in 2027, with the declaration due by 30 September 2027, per the European Commission's CBAM Questions and Answers. So for a Turkish exporter the two years split cleanly: 2026 is when your EU customers start needing your verified emissions data, and 2027 is when the money attached to it moves.
What is the 50-tonne exemption?
The 50-tonne exemption releases an importer from CBAM obligations if their total CBAM-goods imports stay under 50 tonnes a year. Introduced by Regulation (EU) 2025/2083 (in force from 20 October 2025) and applying from 1 January 2026, it is a single, mass-based de minimis threshold: an importer whose aggregate annual imports of CBAM goods do not exceed 50 tonnes is exempt. It covers iron and steel, aluminium, fertilisers and cement — but not electricity or hydrogen — according to the European Commission. It is measured by weight, and it replaced the transitional phase's earlier value-based rule, so the old per-consignment figure no longer applies. The European Commission estimates the threshold will exempt approximately 182,000 importers, mostly SMEs and individuals, while still covering over 99% of the emissions in scope.
"Companies importing less than 50 tonnes of goods subject to CBAM annually will be exempt from CBAM obligations."
— European Commission, "Officially published: Simplifications for the CBAM"
For you, the point is that this threshold is assessed on your EU customer's total annual CBAM imports, not on any single shipment and not on your own output. A large importer clears 50 tonnes quickly; a small buyer taking the occasional consignment may sit under it and owe nothing.
What emissions data does my EU customer need from me?
Your EU customer needs the actual, verified embedded emissions of the goods you ship. In the definitive period the European Commission says embedded emissions should be based on actual verified data; an authorised declarant may fall back on default values for CBAM goods other than electricity only where verified actual data is not available. Those default values, set in Implementing Regulation (EU) 2025/2621, are deliberately marked up so that using real data is usually the cheaper option. The mark-ups are 10% in 2026, 20% in 2027 and 30% from 2028 onwards, with a lower 1% mark-up for the fertiliser sector from 2026 onwards, per the European Commission's CBAM Questions and Answers.
"These mark-ups are 10% in 2026, 20% in 2027, and 30% from 2028 onwards. A lower mark-up of 1% applies to the fertiliser sector from 2026 onwards."
— European Commission (DG TAXUD), CBAM Questions and Answers
The practical message is that not supplying data does not stop your goods entering the EU — it just makes them dearer. If you give your EU buyer verified emissions figures, they are used directly; if you do not, the buyer uses the marked-up defaults, and the mark-up climbs each year. Credible, verified emissions data is what keeps your goods competitive against a supplier who provides it.
Can a carbon price paid in Türkiye be deducted?
Yes in principle, but not in practice today. Article 9 of Regulation (EU) 2023/956 lets an authorised CBAM declarant reduce the certificates it surrenders by a carbon price already effectively paid in the country of origin, supported by certified evidence and net of any rebate, according to the European Commission. Two things qualify that today. First, the detailed method for calculating the deduction is still to be set by an Article 9(4) implementing act the Commission plans for 2026, so the deduction rules are not yet finalised. Second, and more immediately: Türkiye does not currently have an operating carbon price to deduct. Türkiye's first Climate Law (Law No. 7552) has been in force since its publication in the Official Gazette on 9 July 2025 and establishes the legal basis for a national emissions trading system run by the Directorate of Climate Change, which entered a 2026–2027 pilot phase for facilities emitting over 50,000 tonnes of CO2 in CBAM sectors, per the Directorate of Climate Change. That system is legislated and piloting — it is not yet a live carbon price. As of mid-2026, a Turkish producer has no domestic carbon charge to set against a CBAM bill.
"If importers can prove that a carbon price has already been paid during the production of the imported goods, the corresponding amount can be deducted."
Why does this matter for a Turkish exporter?
Because the EU is Türkiye's biggest goods market and the CBAM sectors are exactly where Türkiye sells most into it. In 2025, 42.7% of Türkiye's exported goods went to the EU, which remained its largest goods export partner by a wide margin, according to the European Commission's DG Trade. The covered sectors then line up with Türkiye's export strengths. On Eurostat's 2024 data, Türkiye was the EU's single largest destination for iron and steel exports (€6.2 billion) and its third-largest source of iron and steel imports (€3.5 billion). On Eurostat's 2024 data, Türkiye was also the third-largest source of the EU's aluminium imports, supplying €2.8 billion — 9.4% of the EU's €29.5 billion of aluminium imports — behind Norway (€4.4 billion; 15.0%) and China (€3.9 billion; 13.1%). These are full-year 2024 baselines; EU steel safeguard and quota rules are actively reshaping the steel picture, so treat them as where the trade stood in 2024, not as this year's position. Either way, those are the flows CBAM now sits on top of — which is why the request for verified emissions data lands on so many Turkish exporters.
Where this leaves you — and where we fit
The verified embedded-emissions figures your EU customer asks for come out of the same records you already keep. Our carbon ledger derives your emissions from your bookkeeping entries, and it prepares CBAM reports — one per quarter and per EU customer — so you have a verified figure to hand your importer instead of leaving them to marked-up defaults. This is part of Carbon Accounting, which is generally available. A dedicated EU-disclosure product, Carbon EU, is at design-partner stage — built, but not yet on general sale, and we are looking for the first companies to shape it. Neither files anything with the EU on your behalf: the CBAM obligation stays with your importer, and you stay in control of the numbers you provide.
Last reviewed against its primary sources on . Every figure on this page is quoted from the regulator, standard-setter or statistical office named beside it. Regulatory thresholds and deadlines change — check the linked source before you rely on it.