What is CBAM? A 2026 guide for Turkey–EU supply chains
What is CBAM, which products does it cover, how do the 2026 definitive regime and the 2027 first declaration work, and where does the cost come from? A plain guide for Turkish exporters and their EU buyers, based on official EU sources.
What is CBAM? CBAM, the EU's Carbon Border Adjustment Mechanism, puts a carbon price on imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, in proportion to the greenhouse gases emitted while those goods were produced. Its definitive regime has applied since 1 January 2026: EU importers declare the embedded emissions of the goods they bring in each year and surrender a matching number of CBAM certificates. The only party that can produce that emissions figure, however, is the manufacturer outside the EU, for example a steel or aluminium producer in Turkey.
This guide explains what CBAM is, which products it covers, how the timeline works, where the cost comes from and what it means for supply chains between Turkey and the EU. It is written both for Turkish exporters and for EU buyers who source from them. All dates and figures come from the European Commission's official CBAM pages and are referenced in the text.
Why does CBAM exist? The idea of carbon leakage
Installations inside the EU have for years bought an allowance under the EU Emissions Trading System (EU ETS) for every tonne of CO₂ they emit. When producers outside the EU do not carry that cost, two risks arise: EU companies may move production to countries without carbon pricing, or more carbon-intensive imports may replace EU-made goods. This is called carbon leakage.
CBAM closes the gap by charging imported goods a carbon cost equivalent to the one EU producers pay. Its legal basis is Regulation (EU) 2023/956, simplified by Regulation (EU) 2025/2083, published in October 2025. The Commission states that the mechanism is designed to be compatible with WTO rules.
Which products does CBAM cover?
CBAM currently covers six sectors, but scope is defined by 8-digit CN (Combined Nomenclature) codes, not by sector names. Being "in steel" is not enough to know your position; each product's CN code has to be checked against Annex I of the regulation.
| Sector | Typical goods in scope | What matters in the calculation |
|---|---|---|
| Iron and steel | Crude steel, flat and long products, tubes, certain fasteners | Embedded emissions of precursors (pig iron, crude steel) are added along the chain |
| Aluminium | Unwrought aluminium, profiles, sheet, foil | Electricity use and anode-related emissions are decisive |
| Cement | Clinker, cement | Process emissions from calcination make up a large share |
| Fertilisers | Ammonia, nitric acid, urea, mixed fertilisers | Non-CO₂ gases such as nitrous oxide (N₂O) are included |
| Hydrogen | Hydrogen | The production route largely determines the result |
| Electricity | Electricity exported to the EU | Separate calculation and declaration rules apply |
At the end of 2025 the Commission also proposed extending CBAM to certain downstream products. That proposal is not yet law, but suppliers of steel or aluminium components should follow it closely.
The CBAM timeline: transitional period, definitive regime and first declaration
The timeline is where most confusion arises. Based on the Commission's official communications, the current position is:
| Period / date | What happens |
|---|---|
| October 2023 – December 2025 | Transitional period: importers filed quarterly reports, with no financial obligation. |
| 1 January 2026 | Definitive regime starts. Importers bringing in more than 50 tonnes of CBAM goods a year must hold authorised CBAM declarant status. |
| During 2026 | The certificate price is published for each quarter. Operators monitor emissions and prepare for verification. |
| February 2027 | Sales of CBAM certificates open on the common central platform; from 2027 the price is calculated weekly. |
| 30 September 2027 | Deadline for the first annual CBAM declaration, covering 2026 imports, and for surrendering the certificates. |
| 2026 – 2034 | As free ETS allowances for EU producers are phased out, the CBAM obligation is phased in at the same pace. |
In practice, the emissions data behind every 2026 shipment will be used in the first declaration in 2027. Buying certificates in 2027 does not mean preparation can wait until 2027. We cover the operator's side of the definitive regime step by step in our guide to the CBAM definitive period. For the price and the number of certificates needed, see our CBAM certificate cost guide.
The 50-tonne threshold: are small importers exempt?
Regulation (EU) 2025/2083 introduced a single mass-based threshold of 50 tonnes per importer per year. An EU company importing less than 50 tonnes in total of CBAM goods from the iron and steel, aluminium, fertiliser and cement sectors in a calendar year is exempt. Once the threshold is exceeded, all imports of that year fall under CBAM. Hydrogen and electricity do not benefit from the threshold.
For a Turkish exporter, a small distributor may be exempt. But according to the Commission, the threshold still keeps more than 99% of in-scope emissions within the system. A manufacturer shipping regularly should assume its buyer is above the threshold.
How is the CBAM cost calculated?
The EU importer pays, but the amount depends on the emissions value supplied by the producer. In simplified terms:
- Embedded emissions: imported quantity × the product's specific embedded emissions (t CO₂e per tonne). This covers direct emissions (fuels and processes), indirect emissions (electricity) where required, and the emissions of relevant precursors.
- Adjustments: a correction reflects the free allocation EU producers still receive, and a carbon price effectively paid in the country of origin can be deducted.
- Certificate price: linked to the average of EU ETS auction prices. The Commission's published 2026 prices are EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3 (per tonne of CO₂e).
A rough example: before adjustments, 100 tonnes of embedded CO₂e at the Q3 price comes to about EUR 8,232. The real amount will be lower once adjustments apply, but the example shows how a small difference in emissions per tonne grows on the buyer's invoice.
This is why actual data versus default values matters. If the producer does not provide actual data, the importer can use the default values published by the Commission. These are set conservatively and, in the definitive regime, carry a mark-up that rises over time. For an efficient plant, not calculating actual values means handing the buyer an avoidable cost and weakening its own position in price negotiations.
What CBAM means for Turkey–EU supply chains
On paper, CBAM applies to the EU importer. In practice, the obligation travels down the supply chain:
- Data requests: EU buyers are making product- and installation-level emissions data a contractual requirement.
- Verification: in the definitive regime, actual emissions must be verified by an accredited verifier under EU rules. According to the Commission's timeline, the first verification reports can be issued from January 2027.
- Competitiveness: between two suppliers of the same product, the one with lower, verified emissions means a lower CBAM cost for the buyer.
- Carbon pricing in Turkey: Turkey's Climate Law No. 7552 took effect on 9 July 2025, and the Turkish Emissions Trading System Regulation followed in the Official Gazette of 27 August 2026. The system covers installations with annual emissions above 50,000 tonnes of CO₂e, calculated from installed capacity. Under the Carbon Market Board decision, the pilot covers 2026 and 2027 emissions in power generation, cement, iron and steel, aluminium and fertiliser; 2026 is reporting only and the free allocation rate for 2027 is 100%. Because CBAM deducts only a carbon price effectively paid, no automatic reduction should be expected from the pilot. Details are in our Turkey ETS guide.
A short checklist for exporters and their EU buyers
- Map every product sold to the EU to its CN code and check it against the CBAM list.
- Agree with buyers on the format and frequency of emissions data for 2026.
- Document the installation boundary, production processes and monitoring approach.
- Collect fuel, electricity, raw material and production data monthly, with its source.
- Request actual emissions values from suppliers of purchased precursors.
- Talk early to an accredited verifier and, if needed, a consultant.
These steps draw on the same raw data as a corporate carbon footprint. If you already prepare an annual inventory under ISO 14064-1 or the GHG Protocol, the same fuel and electricity data can feed a product-level CBAM calculation.
How Carbonet supports CBAM
Carbonet is carbon footprint and CBAM software developed by LNA Soft in Izmir, Turkey. You define your installation, production processes and products once; Carbonet calculates specific embedded emissions per product from your activity data using the EU methodology, builds the precursor chain and prepares the result for sharing with your EU buyer. You can see the calculation steps on our CBAM embedded emissions calculation page, and an overview for buyers sourcing from Turkey on our CBAM and Turkey page.
Where a consultant is involved, the software does not replace them; it keeps the data organised, traceable and ready for verification, which makes the consultant's and verifier's work easier.
Conclusion
CBAM is now a condition of trade for every heavy-industry producer selling to the EU. The obligation may sit with the importer, but the figure behind the declaration comes from the manufacturer. Accurate, actual and verifiable data lowers the buyer's cost and makes the producer the preferred supplier. The first declaration is due on 30 September 2027, but the data that goes into it is being created today.
To see how embedded emissions would be calculated for your own product, request a demo or write to us directly: info@carbonet.com.tr · WhatsApp +90 533 368 05 99.
Frequently asked questions
Who pays CBAM, the exporter or the importer?
The EU importer files the declaration and surrenders the CBAM certificates. But the embedded emissions value that sets the amount is calculated by the producer, so in practice the cost and the data request reach the exporter.
When are the first CBAM declaration and payment due?
The definitive regime started on 1 January 2026. Certificate sales open in February 2027, and the deadline for the first annual declaration and certificate surrender, covering 2026 imports, is 30 September 2027.
How much does a CBAM certificate cost?
The price follows the average of EU ETS auction prices. In 2026 it is published quarterly: EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3 per tonne of CO₂e. From 2027 it will be calculated weekly.
What happens if the producer does not provide actual emissions data?
The importer can use the Commission's default values. These are conservative and, in the definitive regime, carry a mark-up that increases over time, which usually means a higher cost than an efficient plant's actual value.
Does the 50-tonne threshold exempt exporters?
The threshold applies to the EU importer: a company importing less than 50 tonnes in total of iron and steel, aluminium, fertiliser and cement goods in a year is exempt. Buyers of regular shipments are usually above it.
Is CBAM the same as SKDM?
Yes. SKDM (Sınırda Karbon Düzenleme Mekanizması) is the Turkish name used by Turkish authorities and companies for the same mechanism established by Regulation (EU) 2023/956.