Under the definitive regime, goods in scope may be imported into the EU only by an authorised CBAM declarant. Omnibus I introduced a de minimis threshold of 50 tonnes net mass per importer per calendar year for cement, iron and steel, aluminium and fertilisers; electricity and hydrogen stay outside it. The annual declaration and surrender date moved to 30 September. For 2026 emissions the first surrender falls on 30.09.2027, so no certificate cash outflow arises during 2026 — but data gathering has to start now.
Producers in the six sectors
Installations making cement, iron and steel, aluminium, fertilisers, electricity or hydrogen must calculate embedded emissions at installation level.
Exporters selling into the EU
The duty rests with the EU importer, but reaches the Turkish seller as contract clauses and data questionnaires.
EU subsidiaries of Turkish groups
An EU-established affiliate acting as importer carries the authorised declarant obligations directly.
- 01Authorised CBAM declarant status is required before importing; without it, goods in scope cannot enter the EU.
- 02An embedded emissions calculation must be produced per installation and per product, precursor inputs included.
- 03Accredited verification is mandatory wherever actual values are used, and requires a site visit at the producing installation.
- 04The annual CBAM declaration and the certificate surrender fall due on 30 September — 30.09.2027 for the 2026 year.
Overview
The Carbon Border Adjustment Mechanism (CBAM) puts a price on the greenhouse gas emissions released in producing certain goods imported into the EU. It is not a tax: it works through certificates that the importer buys and surrenders, closing the carbon cost gap between producers inside the EU Emissions Trading System and imported goods.
The instrument is Regulation (EU) 2023/956 (OJ L 130, 16.05.2023). Only reporting was required during the transitional period from 01.10.2023 to 31.12.2025; the definitive regime has applied since 01.01.2026. It was simplified by Regulation (EU) 2025/2083 of 08.10.2025 — Omnibus I — whose amendments took effect on 20.10.2025.
Scope and thresholds
Scope is limited to six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Omnibus I introduced a de minimis threshold of 50 tonnes net mass per importer per calendar year for cement, iron and steel, aluminium and fertilisers. It is cumulative across all relevant CN codes and measured per importer, whatever the number of indirect customs representatives. Electricity and hydrogen carry no de minimis — obligations arise from the first import. The Commission estimates it exempts roughly 90% of importers while still capturing roughly 99% of emissions.
Key obligations
Goods in scope may now be imported only by an authorised CBAM declarant; importers that had applied by 31.03.2026 could continue importing provisionally (TARIC code Y238). The declarant establishes embedded emissions from actual verified values or from the Commission default values. Verification by an accredited verifier is mandatory only where actual values are used, and it requires a physical site visit at the producing installation. Omnibus I moved the annual declaration and surrender date from 31 May to 30 September and cut the quarterly certificate holding requirement from 80% to 50%.
The critical point for Turkish exporters
There is no quarterly certificate-holding obligation during 2026: certificate sales open on 01.02.2027, and the first declaration and surrender for 2026 emissions fall on 30.09.2027. The common commentary claim that certificates must be bought each quarter through 2026 is simply wrong. The cash impact is deferred; the data collection is not, because 2026 emissions cannot be reconstructed later.
A deduction is available for a carbon price paid in the third country, but only where it has been effectively paid and is legally binding; voluntary carbon credits and internal carbon pricing do not qualify. The volume surrendered is further reduced by the CBAM factor, tracking the phase-out of free allocation: 2.5% for 2026, 5% for 2027, 10% for 2028, 22.5% for 2029, 48.5% for 2030 and 100% by 2034. The cash effect in 2026 is therefore modest; the cliff arrives from 2029–2030. Figures published by the German emissions trading authority DEHSt put the first-quarter 2026 certificate price, announced on 07.04.2026, at EUR 75.36.
What this means for Turkish companies
The legal obligation sits with the EU-established importer, not with the Turkish producer, who is not a direct addressee. The effect arrives contractually: EU buyers write emissions data, verification evidence and warranties or indemnities on data accuracy into their purchase agreements. Preparation has four parts — building the installation-level emissions calculation including precursors; voluntary registration in the O3CI portal, which lets verified data reach EU customers and actual values be used instead of the less favourable defaults; documenting any carbon price paid in Türkiye; and negotiating proportionate data clauses.
Verification capacity is the one real bottleneck. Verifiers may register in the Registry from 01.09.2026, and the same pool must cover thousands of installations across Türkiye, China, India, the UAE and Egypt before September 2027, so booking a verifier and the mandatory site visit should not be left late.
Domestic groundwork is being laid in parallel. Law No. 7552 (İklim Kanunu, the Climate Law), published in the Official Gazette on 09.07.2025, provides the basis for a national emissions trading system, with a pilot phase covering installations emitting more than 50,000 tCO₂ per year — electricity, cement, iron and steel, aluminium, fertilisers, ceramics, chemicals and refining — and binding compliance periods for 2028–2030 and 2031–2035. Until a carbon price is actually paid in Türkiye, Turkish exporters bear the gross CBAM cost.
The proposed extension
On 17.12.2025 the Commission proposed extending CBAM to downstream steel and aluminium products from 01.01.2028. The Council agreed a general approach on 12.06.2026 covering some 180 downstream product codes — machinery, vehicle components, domestic appliances, fabricated metal goods, construction equipment — and the Parliament ENVI Committee held an indicative vote on 06.07.2026. A plenary vote is expected in September 2026, with the Council aiming for final agreement before end-2026. This is a proposal; it has not been adopted and is not in force (as of July 2026). If adopted, scope would widen materially for Turkish exporters of domestic appliances, automotive components and machinery, who are currently outside it.
Enforcement and penalties
Enforcement runs against the importer. Splitting consignments artificially to stay below the de minimis threshold is expressly prohibited, and circumvention attracts penalties of EUR 300 to 500 per tonne. The sharpest practical consequence, though, is not a fine: without authorised declarant status the goods cannot be imported at all. For the Turkish exporter the exposure is commercial rather than legal: missing or unverifiable emissions data pushes the buyer onto default values, and that cost returns through the contract.
Related content
For the reporting side of the same demand see the CSRD record, and for the other large source of traceability requests the EUDR record. Implementation is covered in our ESG and Sustainability focus, and the German corridor in our Expansion into Germany focus.
Entry into force & amendment history
- 01.02.2027
Certificate sales open
Sales of the CBAM certificates covering 2026 emissions begin on this date.
- 01.09.2026
Verifier registration
Accredited verifiers may register in the CBAM Registry from this date.
- 01.01.2026
Definitive regime began
The reporting-only transitional period ended and authorised declarant status became mandatory.
- 20.10.2025
Omnibus I in force
Regulation (EU) 2025/2083 brought in the de minimis threshold and the simplified timetable.
Official Sources
Amending Regulation (EU) 2025/2083 · EUR-Lex eur-lex.europa.euDefinitive regime guidance · DEHSt dehst.deCBAM FAQ · Turkish Ministry of Trade ticaret.gov.tr
