CBAM 2026: a definitive-period guide for Turkish exporters

01What changed in the definitive period?

During the transitional period, from October 2023 to December 2025, CBAM was a reporting obligation only. From 2026 the importer in the EU must buy and surrender CBAM certificates for the embedded emissions of covered goods. The legal obligation sits with the importer, but the party that produces and evidences the emissions data is the Turkish manufacturer. Your data therefore directly sets your EU customer’s carbon cost.

With the Omnibus simplification regulation (Regulation (EU) 2025/2083), published in October 2025, the EU changed several rules for the definitive period: it introduced a new exemption threshold, moved the declaration deadline and lowered the share of certificates that must be held each quarter.

02Who is covered?

• Sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
• 50-tonne threshold: for iron and steel, aluminium, cement and fertilisers, imports below 50 tonnes in total per importer per year are out of scope. If the threshold is crossed during a year, all imports of that year become subject to the obligation. The exemption does not apply to electricity and hydrogen.
• Authorised CBAM declarant: importers who expect to exceed the threshold need this status. A customer without it may not be able to bring your goods into the EU smoothly, so check that your EU customers and their customs representatives are ready.

03Timeline and cost

• 2026: the embedded emissions of goods entering the EU are calculated for this year; the financial obligation arises from this year’s imports.
• February 2027: CBAM certificates go on sale on the EU’s central platform.
• End of every quarter from 2027: declarants must hold certificates covering at least 50% of their annual obligation (80% under the previous rule).
• 30 September 2027: annual CBAM declaration and certificate surrender for 2026.

The certificate price is linked to the EU Emissions Trading System (EU ETS) price: 2026 imports are priced on 2026 ETS prices, and weekly averages apply from 2027. The number of certificates to surrender is reduced in line with the free allocation given to EU producers; as free allocation is phased out, the cost rises year on year.

04Actual data or default values?

For each product the importer can use either verified actual emissions or the default values published by the European Commission. Default values are deliberately set high and become more expensive through staged mark-ups; where reliable country data is missing, they are based on the average of the highest-emitting exporters.

• Actual values must be verified by an accredited verifier; a physical site visit is expected for the first verification.
• Plants using electric arc furnaces, renewable energy or recent efficiency investments can offer a clearly lower cost with their actual data than with default values.
• Suppliers without measured and verified data become steadily more expensive and riskier for EU buyers.

05Carbon price paid in Türkiye

CBAM allows a carbon price actually paid in the country of origin to be deducted. From 2027 the European Commission will publish reference values for carbon prices in third countries.

In Türkiye, the Emissions Trading System Regulation entered into force on 27 August 2026. The system starts with a pilot phase and covers installations emitting more than 50,000 tonnes of CO₂e a year. The scope and rules of the pilot phase will be set by the Carbon Market Board. How far a carbon price paid under the Turkish ETS can be deducted from the CBAM cost will depend on how the system operates; if you are in scope, it pays to plan monitoring and reporting for both systems together.

06What should you do now?

1. Confirm your scope: list the CN codes of the goods you sell into the EU and their annual volumes per customer.
2. Set up installation-level monitoring: calculate direct emissions and, where required, indirect emissions from electricity use, per product.
3. Plan verification: engage an accredited verifier early; the first verification requires a site visit.
4. Talk to your customers: put the data-sharing format, timeline and the split of carbon costs into the contract.
5. Reduce embedded emissions: energy efficiency, renewable electricity and raw-material choices turn directly into a competitive advantage.
6. Check whether the Turkish ETS applies to you: if you have monitoring-plan and reporting obligations, keep them consistent with your CBAM data.