CBAM for Turkish exporters: who is liable, which goods The carbon bill is issued at the border.

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 Türkiye 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 Türkiye'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.

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 import. 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.

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.

Türkiye'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 Türkiye the statutory basis for that structure is Climate Law no. 7552; installations in scope were given a period to obtain greenhouse gas emission permits.

Update, 10 Sep 2026: the implementing regulation has been published. The Turkish Emissions Trading System Regulation appeared in the Official Gazette of 27 August 2026, no. 33353, and entered into force on the date of publication (art. 41/1). It is made under Climate Law no. 7552 of 2 July 2025 and article 792/D of Presidential Decree no. 4 (art. 3/1).

What the regulation governs falls under two heads (art. 2/1): the monitoring, reporting and verification of greenhouse gas emissions from the activities listed in Annex 1, together with the obligations of verifiers and operators; and the operations required to run the Emissions Trading System.

For an exporter the practical position is unchanged, but the thing to watch has sharpened: it is no longer whether a law will pass, but how the price mechanism will work from 2027. If your installation is within the pilot scope, calculating the emissions embedded in your product does two jobs at once: supplying your CBAM buyer and reporting under the national system. The Climate Change Presidency published the pilot's procedures and principles on 1 October 2026 (sub-installations, benchmarks, free allocation, reporting and verification); the surrender obligation starts with 2027 emissions. The deadline for the first monitoring methodology plans was extended to 27 January 2027, and the Energy Market Regulatory Authority's regulation on operating the Turkish ETS market was published in Official Gazette No. 33407 of 21 October 2026. That regulation provides for an optional "complementary allowance price" auction for 2026 emissions (temporary Art. 2), on dates to be set by the Climate Change Presidency. Whether such a payment can be deducted under CBAM depends on the EU rules; we will check again once an auction opens.