DECISION BRIEF
What the rule requires
The EU Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956, puts a carbon price on imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity entering the Union. The transitional reporting period ran from 1 October 2023 to 31 December 2025; the definitive regime has applied since 1 January 2026.
Regulation (EU) 2025/2083, in force since 20 October 2025, reshaped it. It introduced a single mass-based de minimis of 50 tonnes of cumulative net mass of CBAM goods per importer per calendar year — which does not apply to hydrogen and electricity — postponed the start of certificate sales to 1 February 2027, moved the annual declaration deadline to 30 September, and cut the quarterly certificate-holding requirement to 50% of embedded emissions. The Commission states the threshold exempts around 90% of importers while still covering about 99% of embedded emissions.
Who is affected, and from when
Built for: Exporters of cement, iron and steel, aluminium, fertiliser, hydrogen and electricity to the EU, and the sustainability, export and finance teams around them.
Legally, the duty sits with the EU importer, who must hold authorised CBAM declarant status before CBAM goods can be released for free circulation. A Turkish producer is never the declarant and never surrenders a certificate.
Commercially it lands on the Turkish exporter anyway. The declarant has to report embedded emissions per consignment, and the only credible source of that figure is the installation that made the goods. If you ship covered goods into the EU, installation-level verified emissions data is becoming a condition of the order rather than a reporting favour.
The first hard date for goods shipped during 2026 is 30 September 2027, when the first annual CBAM declaration and certificate surrender fall due. Certificate sales to declarants open on 1 February 2027.
What to do next
- Ask each EU customer whether they clear the 50-tonne de minimis for your product line. Below it they are exempt and no data has to flow at all — that answer alone can retire a compliance project.
- Set your monitoring boundary at the installation and production process, not at company level. A corporate carbon footprint is the wrong number and will be rejected.
- Have the figures verified by an accredited verifier, and start early: verification capacity inside Türkiye is the constraint, which is why TÜRKAK moving to accept CBAM verifier accreditation applications matters (tracked below).
- Fund it. Türk Eximbank’s green export credit — up to EUR 20m per company — is aimed squarely at CBAM sectors, and the Trade Ministry’s Responsible programme pays half of Green Deal consultancy — both are in the funding coverage below.
- Read the Türkiye ETS hub next. A carbon price actually paid in the country of production can be deducted from the CBAM liability under Article 9 of Regulation (EU) 2023/956, which is the whole strategic argument for the domestic system.
Coverage boundary
This hub covers the EU mechanism and what it asks of Turkish suppliers. Türkiye’s own emissions trading system has its own page, and the UK CBAM is not tracked here.