A Practical Guide for Turkish Exporters 2026
The EU Carbon Border Adjustment Mechanism (CBAM) entered its full, payment-obligating phase on 1 January 2026. The transitional reporting period ended. The bills have started.
Turkey is the third most affected country globally — behind only Russia and China. Turkish industry faces projected CBAM costs of €138 million per year by 2027, rising to €2.5 billion annually by 2032 (EBRD / Turkish Ministry of Environment, 2025). For steel, cement, and aluminium exporters shipping to EU buyers, this is not a future planning exercise. Certificates are being purchased by your EU customers right now, based on the emissions data you are or are not providing them.
Turkish steel predominantly uses electric arc furnace (EAF) technology, producing approximately 0.5–0.8 tonnes of CO₂ per tonne of steel. Chinese blast furnace production emits 1.8–2.1 tCO₂/tonne. At current EU ETS prices (~€65/tCO₂e, April 2026), this gives Turkish EAF steel a CBAM cost advantage of roughly €80–85 per tonne over Chinese supply. European buyers who understand this will actively prefer Turkish suppliers. Most do not yet understand it.
Under CBAM, the EU importer bears the legal obligation to purchase certificates. If the Turkish exporter cannot supply actual, verified emissions figures, the importer is required to use the Commission's conservative default benchmark values — which are significantly higher than real EAF emissions. An uncommunicating Turkish exporter makes their EU buyer more expensive. This is already damaging supplier relationships in 2026.
Turkey adopted a domestic Emissions Trading System in late 2025. If the EU recognises this system as equivalent, CBAM obligations for Turkish exporters could be partially or fully offset. Negotiations are active. This does not change your obligations today — but it materially changes the medium-term cost picture.
Single most important recommendation: Establish a verified emissions measurement and reporting process for your EU-bound production immediately. Send that data to your EU buyers before they ask. This single step reduces their CBAM certificate costs, strengthens your relationship, and positions you as a preferred, forward-looking supplier.
The Carbon Border Adjustment Mechanism is a carbon tax on imports into the European Union, calibrated to the price of carbon within the EU's own Emissions Trading System (EU ETS). Its purpose is to prevent "carbon leakage" — the situation where EU producers, burdened with carbon costs domestically, lose market share to imports from countries with lower or no carbon pricing.
Under CBAM, when a European company imports steel, cement, aluminium, fertilisers, electricity, or hydrogen, it must purchase CBAM certificates equivalent to the embedded carbon emissions in those products. The certificate price tracks the EU ETS price, which stood at approximately €50–75/tCO₂e in April 2026.
CBAM is not paid by the Turkish exporter. It is paid by the EU importer. However, this distinction is less meaningful in practice than it sounds. The CBAM cost either gets negotiated into the price (reducing what the EU buyer will pay for Turkish goods) or absorbed by the EU importer who then seeks lower-carbon suppliers. Either way, Turkish exporters who ignore CBAM will find their products becoming commercially less attractive.
| Period | Obligation |
|---|---|
| Q4 2023 – Q4 2025 | Transitional phase: EU importers report embedded emissions quarterly; no payment required |
| 1 January 2026 | Definitive phase begins: certificate purchase and surrender required |
| 31 May 2027 | First annual certificate surrender deadline (for full-year 2026 imports) |
| Ongoing | Annual cycle: import data reported → certificates purchased → surrendered by 31 May |
The transitional phase is over. Companies that treated CBAM as a future concern now face compliance requirements for all 2026 imports.
Turkey's exposure is a function of two factors: the volume of CBAM-covered goods exported to the EU, and the carbon intensity of Turkish production processes.
Turkey exports significant quantities of steel (particularly reinforcing bar, wire rod, and hot-rolled coil), cement clinker, and aluminium products to EU markets. The EU is Turkey's largest trading partner, with €96 billion in bilateral trade in goods in 2024 (European Commission DG Trade).
The EBRD, in its joint assessment with the Turkish Ministry of Environment, calculated that:
Only Russia (dominant in fertilisers and metals) and China (dominant in steel volume) face greater aggregate exposure globally.
Identify your top 5 EU export customers for steel, cement, or aluminium. Ask them directly whether they have begun CBAM reporting and what emissions data they hold for your products. This conversation should happen in April–May 2026, not after the reporting deadline.
Turkey exported approximately €3.2 billion in iron and steel to the EU in 2024. Covered products include hot-rolled and cold-rolled flat products, reinforcing bar (rebar), wire rod, and steel tubes. This is the sector where CBAM costs are highest in absolute terms and where the EAF advantage is most powerful.
Clinker and cement exports from Turkey to the EU are fully in scope. Cement is inherently carbon-intensive — approximately 0.7–0.9 tCO₂ per tonne of clinker. Turkey is a major cement exporter, particularly to southern and eastern European construction markets.
Also covered from 1 January 2026: Aluminium (primary and secondary), Fertilisers (urea, ammonium nitrate), Electricity, and Hydrogen. The full report details each sector's specific HS codes, emissions benchmarks, and commercial implications for Turkish exporters and EU buyers.
The full report also covers: what is not in scope (and when that will change), whether company size matters, and how to run a quick audit of your EU export invoices to calculate your buyers' CBAM exposure today.
Financial impact tables, the 8-step compliance roadmap, contract clause templates, the EAF advantage analysis, and your 90-day action plan — all in one document.