CBAM for Turkish exporters: what your EU buyer will ask you for

Who declares? Not the Turkish exporter

The CBAM obligations, meaning the authorisation, the annual declaration and the surrender of certificates, sit with the importer in the EU or with the indirect customs representative acting for it (Articles 3(15) and 5 of Regulation (EU) 2023/956). A producer or exporter in Türkiye does not buy CBAM certificates and does not file a declaration.

• If the party that clears the goods in its own name is established outside the EU, for example a Turkish seller that handles import clearance itself, an indirect customs representative established in the EU must hold authorised CBAM declarant status (Article 5(2)).
• The 50-tonne threshold is counted per importer: if your EU buyer’s imports in the four sectors stay at or below 50 tonnes net in a calendar year, it is exempt. A buyer that expects to pass it will still ask you for data. Electricity and hydrogen are not covered by the threshold.
• The declarant reports embedded emissions either with actual values or with the Commission’s default values. Actual values come from your installation and must be verified by an accredited verifier.

What data your EU buyer will ask for

According to the Commission’s guidance for operators outside the EU (Guidance No. 2, 14 August 2026), an installation whose actual values are to be used prepares the following every year:

• Installation details: name, address, registration number, location (coordinates) and main activity, also needed to register in the CBAM Registry (Article 10(2) of the Regulation).
• Production processes and routes: for example blast furnace/basic oxygen furnace or electric arc furnace, primary or secondary aluminium, and which CN codes each process produces.
• Specific embedded emissions in tCO₂e per tonne of good: direct emissions; for goods whose indirect emissions count, such as cement and fertilisers, the electricity consumed and its emission factor; and the embedded emissions of precursors.
• Precursors: the CBAM goods you buy in, such as billets or clinker, with the installation and country where they were made, the quantities and, if you use actual data, the supplier’s verification report. Without supplier data, the default value of the precursor’s country of production is used.
• Qualifying parameters for some goods, such as the clinker content of cement or the forms of nitrogen in mixed fertilisers.
• Data for the free allocation adjustment: the “embedded free allocation” of your goods, the free allocation they would receive if made in the EU, which depends on the production route and the CBAM benchmark.
• Any carbon price paid in the country of origin, with evidence.
• The verification report: actual values come with a positive report from an accredited verifier.

The reporting period is the calendar year in which the goods were produced, and not earlier than 2026. Where the time of production cannot be established with sufficient evidence, goods imported in 2026 use 2026. The data travels in the Commission’s operator’s emissions report template; Guidance No. 2 states that its use is mandatory under Article 10 of Implementing Regulation (EU) 2025/2547.

How to share your data: the CBAM Registry (O3CI)

The Commission strongly advises operators outside the EU to register in the O3CI module of the CBAM Registry. You upload your installation and emissions data once, have them verified there and share them with every declarant that imports your goods; declarants see the summary they need, not the full report. Registration is made at the operator’s request and is valid for five years (Article 10 of the Regulation).

1. Create an EU Login account (a company email address is recommended) and set up two-factor authentication. Each user registers individually.
2. Submit an access request in the O3CI portal: company details, registration number, user role, and one PDF with the company registration certificate, proof of representation (for example a power of attorney) and the ID of the authorised representative. Documents are preferably in English or with a courtesy translation.
3. Once the Commission has validated the request, enter your installations and emissions data and work with your verifier through the Registry.
4. Your EU buyer shares its EORI number with you so that it can find your installation in the Registry.

Without registration you send the same template to each buyer separately, and buyers then have to ask you for the complete emissions and verification reports in case of a review.

Verification: who and when

• Actual values can only be used if they were verified by a verifier accredited for CBAM by a national accreditation body in the EU. Only national accreditation bodies in EU (and EEA) countries can grant CBAM accreditation; verification companies established outside the EU may apply to any EU body that offers it.
• Verification is done per installation: the verifier visits your site and issues one verification report per installation.
• In the Commission’s timeline, verifiers can register in the CBAM Registry from 1 September 2026 and the first verifications (documentation review, site visit) start then; the first verification reports can be issued from January 2027; buyers finalise their 2026 declarations by 30 September 2027.
• The Commission advises contracting a verifier early to avoid the bottleneck at the end of the period. The list of accredited verifiers will be published on its verification page.
• Verification under the TR ETS is a separate system: under the Turkish Emissions Trading System Regulation, verification bodies are accredited by the Turkish Accreditation Agency (TÜRKAK). That accreditation on its own does not cover CBAM.

Carbon price paid in Türkiye and the TR ETS

The EU side: a declarant may deduct a carbon price effectively paid in the country of origin, net of any rebate or other compensation (Article 9 of the Regulation). According to the Commission’s Q&A, allowances allocated free of charge under an ETS count as such a rebate. Where default values are used, the deduction can only be made by reference to yearly default carbon prices, which the Commission may determine from 2027 (Article 9(4)).

The Turkish side, according to the official sources:

• Climate Law No. 7552 (Official Gazette of 9 July 2025) provides for an emissions trading system with a pilot phase before it applies in full. Free allowances may be allocated on the basis of historical emissions or benchmarks.
• The Turkish Emissions Trading System Regulation was published in the Official Gazette of 27 August 2026 (issue 33353) and entered into force that day.
• According to the Climate Change Presidency’s announcement of 3 September 2026, the Carbon Market Board (KPK/2026/1) decided that the pilot phase covers emissions of 2026 and 2027; it applies to category B and C installations in electricity generation, cement, iron and steel, aluminium and fertilisers; in the 2026 system year installations only report; the price mechanism starts with the 2027 system year; and free allocation in the pilot phase is 100 % on a benchmark basis.

The upshot: because the 2026 system year is reporting only, no carbon price is paid under the TR ETS for 2026 emissions. How much can be deducted from 2027 depends on the details of the TR ETS price mechanism and on the Commission’s implementing act under Article 9.

How to avoid default values

• Monitor your installation’s emissions with the CBAM methodology, have them verified by an accredited verifier and share the result with your buyers. Verified actual values take away the mark-up on default values.
• Ask your suppliers for verified data on precursors. Without it the default value of the precursor’s country of production applies, and if that country cannot be identified, the highest values (Annex IV).
• If your buyer does use default values, goods originating in Türkiye take the Türkiye table of Annex I; for codes where that table shows “–”, the “Other countries and territories” value applies. Find your product and its marked-up value in the Türkiye table.
• Put numbers on the difference with the CBAM calculator: for 1,000 tonnes of rebar, a value 0.5 tCO₂e/t lower is 500 certificates less, about €41,000 at the Q3 2026 price (same production route).

Practical checklist

1. Check the CN codes of what you sell to the EU against Annex I to the CBAM Regulation.
2. For each EU customer, identify the importer (or indirect customs representative) and ask whether it passes the 50-tonne threshold.
3. Define your installation boundaries, production processes and routes, and map each CN code to its process.
4. Write a monitoring plan (in English for the verifier, in Turkish for your staff).
5. Collect data for calendar year 2026: fuels and materials, electricity consumed and its source, measurable heat, precursors with supplier data, production volumes.
6. Add the qualifying parameters for your goods (for example clinker content) and the information needed for the free allocation adjustment.
7. Contract a CBAM-accredited verifier early and plan the site visit.
8. Register in the O3CI module of the CBAM Registry and ask your buyers for their EORI numbers.
9. Prepare the operator’s emissions report in the Commission template and share it with your buyers once verified.
10. If you are in the TR ETS, follow its reporting obligations separately and keep evidence of any carbon price you pay.
11. Keep the calendar with your buyers: the first declaration and surrender are due on 30 September 2027. All dates are on the CBAM deadlines page.

How Karbonet helps

In Karbonet you keep your installations, your goods (CN code, sector, production route) and, for each good, the yearly declaration data (production volume, direct emissions, electricity consumed and its factor, precursors, carbon price paid); the app calculates the specific embedded emissions. A simulator compares the cost with default and with actual values and produces a one-page savings sheet for your EU buyers, alongside a CBAM PDF report with an installation-level annex. You can give your verifier a time-limited, read-only access link. Karbonet does not replace the verifier or the CBAM Registry, and the declaration is filed by the EU importer. More on the CBAM software page.