The carbon bill is issued at the border.
The EU's Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026. The liable party is the importer in the EU: anyone importing more than 50 tonnes of CBAM goods a year must become an authorised CBAM declarant, file a declaration by 30 September each year and surrender certificates equal to the emissions embedded in the goods. Certificates go on sale from February 2027; the first declaration, for 2026 imports, is due 30 September 2027. The Turkish exporter files nothing but supplies installation-level emissions data — without it the buyer uses the Commission's default values and the difference lands in the price.
Who is liable, who is not
CBAM is an import obligation. The party that files the declaration, buys and surrenders the certificates is the importer established in the EU — or the indirect customs representative acting for it. The exporter in Turkey has no direct declaration obligation towards the EU authorities.
But the importer can only declare with the emissions embedded in the goods, and that data comes from the production installation. For the Turkish producer CBAM is therefore experienced as a data-supply and pricing obligation: if data is missing, the buyer declares with higher default values, the cost rises and comes back to the negotiating table.
- Authorised CBAM declarant
- An EU importer bringing in more than 50 tonnes of CBAM goods a year must hold this status. According to DEHSt (Germany's competent authority), those who applied by 31 March 2026 could keep importing while awaiting a decision; after that date, imports without the status are restricted.
- Indirect customs representative
- May declare on the importer's behalf and then also assumes the CBAM obligation. On the Turkish exporter's DDP sales this role is critical: whoever lodges the import declaration is looked to for the CBAM declaration.
- Turkish producer / exporter
- Files nothing, buys no certificates. Calculates embedded emissions at installation level, has them verified by an accredited verifier where needed, and passes them to the buyer.
Which goods are in scope
Six sectors in the definitive period: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. In Turkey's exports to the EU, iron and steel and aluminium products are most affected — sheet, sections, pipe, wire, fasteners and aluminium semi-finished goods included. The full list of codes is in Annex I of the CBAM Regulation; confirm whether your product is in scope from the EU CN equivalent of your 12-digit tariff code, not from the sector name.
| Sector | Typical products | 50-tonne threshold |
|---|---|---|
| Iron and steel | Flat and long products, pipes, wire, screws and bolts, castings | Applies |
| Aluminium | Ingots, sheet, sections, foil, aluminium structures | Applies |
| Cement | Clinker, cement, calcined clay | Applies |
| Fertilisers | Ammonia, nitric acid, urea, nitrogen and mixed fertilisers | Applies |
| Electricity | Electricity exported to the EU | Does not apply — obligation from the first import |
| Hydrogen | Hydrogen | Does not apply |
Product groups are a summary; the binding list is the CN codes in Annex I of the Regulation. No rate, amount or emission factor is given on this page.
How the 50-tonne threshold works
The Omnibus Regulation (EU) 2025/2083 removed the €150-per-consignment exemption and replaced it with a threshold of 50 tonnes net mass per importer per calendar year. The threshold applies to iron and steel, aluminium, cement and fertilisers; for electricity and hydrogen the obligation runs from the first kilogram. An importer below the threshold does not need to become an authorised declarant.
What it means for the exporter: your small EU customers may stay below the threshold; a large customer whose total crosses it with your shipment incurs the obligation and asks you for the data. The threshold is not per consignment but the sum of all the importer's CBAM imports.
What is asked of the Turkish producer
- Embedded emissions: the greenhouse gas emitted directly at the installation in producing the goods (tonnes CO₂e per tonne of product), calculated by the Regulation's method. In the definitive period, indirect emissions (electricity consumption) also count for some sectors.
- Actual or default values: if actual values are used, emissions are monitored, recorded and verified by an accredited verifier; a copy of the verification report is submitted with the CBAM declaration. Where data is missing, the Commission's published default values are used — no verification needed, but for most installations the values are higher than their real emissions.
- Installation identity: the buyer names the production installation and its country in the declaration; producers sharing their data through the CBAM registry speed the process up.
- Contract clause: data delivery deadline, verification cost and who bears the certificate cost — these are not in the Regulation but in your sales contract.
Have the emissions data ready before shipment, not when asked. The buyer records the data at import, not at year end. A producer with data ready is, in the buyer's eyes, a cheaper supplier than one whose goods will be declared on default values — even at the same list price.
Talk about the CBAM cost when quoting. On a DDP sale the party lodging the import declaration carries CBAM; on FCA/FOB it is the buyer. Without a sentence such as "CBAM certificate cost for the buyer's account / included in the price", January 2027 brings a surprise.
Timeline and certificate price
- 1 January 2026
- Definitive period began; quarterly transitional reporting gave way to the annual declaration.
- 31 March 2026
- DEHSt's date for authorised declarant applications; applicants by this date could keep importing while awaiting a decision.
- February 2027
- CBAM certificates go on sale on the central platform; certificates for 2026 imports are bought after this date.
- 30 September 2027
- First annual CBAM declaration and certificate surrender, for 2026. Every 30 September thereafter.
Price: the certificate price is tied to the EU ETS allowance auction price — according to the Commission, as a quarterly average for 2026 and a weekly average from 2027. We give no current price on this page; auction data is followed on European Commission and EEX publications. Certificates not surrendered attract penalties under Article 26 of the Regulation; repeated breaches can lead to revocation of the authorisation.
Turkey's ETS and the deduction
The CBAM Regulation allows a carbon price actually paid in the country of origin to be deducted from the certificate obligation. In Turkey, Climate Law No. 7552 entered into force on 9 July 2025 and established a national emissions trading system; installations in scope were given three years to obtain greenhouse gas emission permits. As at this page's last check, no procedure for deducting a carbon price paid in Turkey under CBAM had been put into practice; this section will be updated when it is.
When it goes wrong
No data, default values applied
The producer has not calculated its emissions; the buyer declares on the Commission's default value. Because the value is higher than the real emissions, the certificate cost rises and arrives at the next price negotiation as a "CBAM difference".
The contract never mentions CBAM
Sold DDP; the party lodging the import declaration also took on the certificate cost. The price is from a 2025 list; the margin will erode in 2027.
The "small customer, below threshold" assumption
The threshold is not per consignment but the importer's annual total. When it is crossed in the second half of the year, the buyer asks for data retroactively.
The verification report came late
Actual values were to be used but no accredited verifier was booked; when it misses the declaration date, the buyer falls back to default values.
Frequently asked
Who pays the CBAM charge?
Legally, the EU importer: it buys the certificates and files the declaration. Commercially, the cost flows into the price according to the delivery term and the contract. Under DDP the seller effectively carries it, under FCA/FOB the buyer; in both cases it is a matter of negotiation.
What do you do as a forwarder?
We do not file the declaration — that is the customs broker's and the importer's job. Our job is to make sure the tariff code, net mass and production installation on the shipping documents are consistent with the CBAM declaration, and to find out in advance from our EU agent which document the importer wants and when.
How do I know whether my product is in scope?
From the CN codes in Annex I of the Regulation. The first eight digits of the Turkish tariff code correspond to the EU CN code; check the list from that code. Sector names mislead — some iron and steel products are out of scope, some fasteners are in.
Sources
- European Commission — CBAM definitive regime Start 01.01.2026, 50-tonne threshold, authorised declarant, sectors, certificate price mechanism (quarterly average 2026, weekly from 2027) · taxation-customs.ec.europa.eu · accessed 5 Sep 2026
- DEHSt (German Emissions Trading Authority) — CBAM definitive regime from 2026 31.03.2026 application date, first declaration 30.09.2027, certificate sales from February 2027, net-mass and calendar-year basis of the 50-tonne threshold, accredited verification for actual values, Art. 26 penalties · dehst.de · accessed 5 Sep 2026
- EY — EU adopts CBAM Omnibus Regulation Regulation (EU) 2025/2083: adopted 08.10.2025, OJ 17.10.2025, in force 20.10.2025; €150 exemption removed, 50-tonne threshold introduced · ey.com · accessed 5 Sep 2026
- Official Gazette of Türkiye — Climate Law No. 7552 (09.07.2025 / 32951) Establishment of the national ETS; three-year period for emission permits · resmigazete.gov.tr · accessed 5 Sep 2026
This page is for information only and is not legal, tax or customs advice. The binding text is Regulation (EU) 2023/956 as amended; national competent authorities' implementation timetables may differ by member state. No certificate price, emission factor or amount is given on this page.
Change log
- Page published. Dates verified on the European Commission and DEHSt pages, the Omnibus Regulation reference on the EY alert. To be updated when the Turkish ETS deduction is put into practice.