Selling to Europe After CBAM: What Turkish Exporters Need to Know

The EU is Türkiye's largest market: 42.7% of Türkiye's goods exports went to the EU in 2025, and Türkiye was the EU's fifth largest trade partner.¹ That makes EU climate and sustainability rules a business issue for thousands of Turkish companies, not only for heavy industry.

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CBAM: from reporting to paying

The EU Carbon Border Adjustment Mechanism (CBAM) covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. After a transitional reporting phase from 2023 to 2025, the definitive regime applies from 1 January 2026.² Key dates and facts:

• Importers bringing in less than 50 tonnes of CBAM goods a year are exempt, after a simplification adopted in 2025. The Commission says this frees about 182,000 importers while still covering more than 99% of emissions.³

• CBAM certificates go on sale in February 2027. For 2026 the Commission publishes a quarterly price: EUR 75.36 for the first quarter and EUR 75.28 for the second.⁴

• The first annual CBAM declaration and surrender of certificates, covering 2026 imports, is due by 30 September 2027.⁵

• The Commission has proposed extending CBAM to about 180 downstream products with high steel and aluminium content, such as machinery parts and appliances, from 1 January 2028. This proposal is not yet law.⁶⁷

The importer in the EU pays, but the exporter supplies the data. Without verified emissions data, importers must use default values that include mark ups, which makes the product more expensive to bring into the EU.⁸

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Türkiye's own carbon market

Türkiye adopted its Climate Law, Law No. 7552, published in the Official Gazette on 9 July 2025.⁹ The Carbon Market Board decided in September 2026 that the pilot phase of the Turkish emissions trading system covers 2026 and 2027 emissions for power generation, cement, iron and steel, aluminium and fertilisers. In 2026 installations report only; the price mechanism starts from 2027.¹⁰ Under CBAM, a carbon price actually paid in the country of production can reduce the certificates owed, if it is properly documented.⁸

Other EU rules on the way

• Deforestation (EUDR): applies from 30 December 2026 for large and medium operators and from 30 June 2027 for micro and small operators.¹¹ Relevant for supply chains of commodities such as wood, rubber, coffee and cocoa.

• Due diligence (CSDDD): after the 2026 amendment it applies to very large companies from July 2029, and limits how much information they can request from SME suppliers.¹²

• Textiles: the EU plans an ecodesign act with a Digital Product Passport for textiles and apparel, with adoption planned for the fourth quarter of 2027.¹³

A checklist for exporters

• Know which of your products fall under CBAM codes today, and which could fall under the downstream proposal.

• Prepare a monitoring plan for your installation and send your EU customers annual emissions reports using the official template.⁸

• Book an accredited verifier early; verified actual data replaces default values.⁸

• Register in the CBAM Registry operator portal to share data once with all your EU customers.¹⁴

• Keep records of any carbon price you pay under the Turkish system.

• Ask your exporter association about Green Deal compliance support under the export support decision.¹⁵

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Buyers on Turki.sh increasingly ask for sustainability data with their quotes. Suppliers who can show it stand out.

This article is general information, not legal advice. EU and Turkish rules are changing quickly; check the official sources before you act.

Sources

1. European Commission, DG Trade, EU trade relations with Türkiye

2. European Commission, Carbon Border Adjustment Mechanism

3. European Commission, Officially published: simplifications to CBAM (20 October 2025)

4. European Commission, Price of CBAM certificates

5. European Commission, Webinar follow up: CBAM emissions calculation, declarations and certificates (30 September 2026)

6. European Commission, Press release IP/25/3088 on extending CBAM (17 December 2025)

7. European Commission, Commission welcomes Council agreement strengthening CBAM (12 June 2026)

8. European Commission, Guidance No. 2: Quick guide for non EU operators on CBAM implementation (14 August 2026)

9. Resmî Gazete No. 32951, 9 July 2025, İklim Kanunu No. 7552 (copy hosted by TÜRMOB)

10. T.C. İklim Değişikliği Başkanlığı, TR ETS pilot uygulama dönemi, KPK/2026/1 duyurusu

11. Council of the EU, Deforestation: Council signs off targeted revision (18 December 2025)

12. European Commission, Corporate sustainability due diligence

13. European Commission, Digital Product Passport: textiles and apparel

14. European Commission, CBAM Registration Guide factsheet

15. T.C. Ticaret Bakanlığı, İhracat destekleri