CBAM's Impact on Turkey: Which Sectors Are in Scope?

You will pay the CBAM bill in 2027. But the meter has been running since 1 January 2026.

The European Union's Carbon Border Adjustment Mechanism, CBAM, entered its financial implementation phase on 1 January 2026.

During the transition period, companies were mainly asked to report emissions. In the new phase, the embedded carbon emissions of imported goods create a real financial obligation.

That shift matters a great deal for Turkey. According to data shared by the Türkiye Ministry of Trade, Turkey was the second-largest country by mass sending CBAM-covered goods to the EU during the 2023-2025 transition period, at 18.34 million tonnes.

So CBAM is not a technical regulation that only concerns environmental or sustainability teams. It is a new trade cost that directly affects Turkey's exports to the EU, product pricing, supplier selection, and company competitiveness.

CBAM is designed to put a carbon price on emissions generated in the production of carbon-intensive goods imported from outside the EU.

Its core aim is to close the gap between the carbon cost EU producers face under the EU Emissions Trading System and the cost of imported goods, and to prevent production from shifting to countries with weaker environmental standards.

During the 2023-2025 transition period, companies reported emissions without making any financial payment. As of 1 January 2026, the definitive period began, and 2026 imports became part of the CBAM certificate obligation.

The first annual CBAM declaration, covering 2026 imports, is due by 30 September 2027. Certificate purchases will begin in February 2027.

Certificate prices published by the European Commission:

Prices will be calculated quarterly through 2026 and weekly from 2027 onward.

This is why the 'payment starts in 2027, so we still have time to prepare' mindset is risky. The 2027 declaration and payment will be based on the imports made throughout 2026, and on the product and emissions data being generated today.

Source: European Commission CBAM certificate prices.

CBAM currently applies to specific product groups within six carbon-intensive sectors:

One distinction matters here: a company operating in one of these sectors does not mean every product it makes automatically falls under CBAM. Scope is determined by the CN code specified in the legislation, not by a product's commercial name. Every product therefore needs to be checked at the code level.

Current sector scope: European Commission CBAM sectors.

Automotive, machinery, appliances and textiles are not, on their own, direct CBAM sectors today.

But these companies can be affected indirectly, for three main reasons:

This is particularly relevant for automotive parts, machinery, fasteners, metal household goods and similar products that contain significant amounts of steel and aluminium, which could be affected if scope expands in the future.

That said, planned or proposed scope expansions should not be confused with what is in force today. Companies should assess their current obligations against their products' present CN codes, and track future expansion as a separate risk scenario.

Iron and steel, aluminium, cement and fertiliser products carry an annual 50-tonne threshold under CBAM.

But this threshold is frequently misread. The 50-tonne threshold:

A Turkish producer's shipment to a given EU customer may sit below 50 tonnes on its own. But if that same importer's total imports from different suppliers exceed the threshold over the year, a CBAM obligation can still arise.

If the threshold is exceeded, the obligation may not be limited to the portion above 50 tonnes: the full volume of covered imports for that year can be brought into scope.

So 'our shipment is under 50 tonnes, CBAM doesn't affect us' is not a safe assumption.

The legal obligation under CBAM rests mainly with the EU importer or its indirect customs representative. But the financial and commercial impact can travel back through the supply chain to the Turkish producer.

EU customers will ask for more data. To calculate the embedded emissions of what they buy, EU importers will request plant- and product-level data from Turkish producers. Production volume, raw materials used, energy consumption, fuel types and production route will all become relevant.

Verified data will gain commercial value. If an importer wants to use actual emissions figures rather than default values, that data has to be calculated in line with CBAM rules and verified by an accredited, independent verifier. A producer who can supply verified, low-emissions data can reduce its EU customer's total CBAM cost, and gain an edge over competitors.

Default values can push costs higher. Where verified actual emissions data is unavailable, the European Commission's default values may be used instead. Under current rules relayed by the Türkiye Ministry of Trade, a margin is added to default values: 10% in 2026, 20% in 2027 and 30% in 2028. In the fertiliser sector, that margin is held at 1%. So a producer whose actual emissions are lower than the default value, but who cannot supply supporting data, may end up with an unnecessarily inflated CBAM cost on their product.

Price and margin pressure can follow. Even though the EU importer is the party that buys the CBAM certificate, that cost tends to feed into commercial negotiations. An importer might:

So even where CBAM is not a tax paid directly by the Turkish exporter, it can still affect sale price and profit margin.

CBAM is not only a source of risk. For companies that prepare well, it also offers a chance to differentiate commercially.

Turkish producers that manufacture with lower emissions, keep their data in order, and are ready for independent verification can offer EU customers a lower total import cost.

Capturing that advantage takes more than saying 'our production is environmentally friendly.' Emissions performance needs to be measured, documented and, where required, verified at the product and plant level.

Going forward, carbon data could become one of the standard criteria used in supplier selection, alongside things like quality certification or delivery performance.

Companies that fall under CBAM, or that use CBAM-covered inputs, can start preparing with these steps:

Treating CBAM purely as an annual reporting exercise is not enough. It needs to be handled jointly by sales, finance, procurement, customs and sustainability teams.

A product's competitiveness is never determined by the ex-works price alone.

Customs duties, anti-dumping and countervailing duties, freight, insurance, port charges, VAT and CBAM all need to be assessed together to arrive at a product's true landed cost into the EU.

TradeShield uses product code, origin, destination country, quantity, product value and emissions information to evaluate these costs together, within a single scenario.

With that view, companies can:

Because in the CBAM era, the cheapest quote will not always mean the lowest total cost.

Turkey is one of the EU's most significant suppliers of CBAM-covered goods. So the new system's impact on Turkey will not stay confined to emissions reporting.

Iron and steel, aluminium, cement, fertiliser, electricity and hydrogen are directly in scope today. Sectors that use these as inputs, such as automotive, machinery and appliances, face indirect exposure and the risk of future scope expansion.

The winners will not simply be the companies producing with lower emissions. The companies that stand out will be the ones that can measure their emissions, verify them, and translate that data into pricing decisions.

The CBAM bill may fall due in 2027. But which product, which supplier and which production model shapes that bill is being decided today.

Calculate your total landed cost of imports with TradeShield →

This article is for general information purposes only. It is not legal advice or a formal compliance assessment. Product scope must be checked separately against current CN codes and the legislation in force.

Umut Bakın

Founder and Managing Partner, TorqueFoundry