EU Carbon Border Adjustment Mechanism (CBAM): What Changed for Exporters in 2026?

The EU Carbon Border Adjustment Mechanism (CBAM) aims to apply a carbon cost to embedded emissions generated during the production of certain imported goods. Traceability of product, installation and emissions data has become crucial for businesses supplying EU markets from Türkiye.

Which product groups are covered?

The main CBAM sectors currently cover iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Obligations must be assessed against the product's customs classification and the legislation in force; sector names alone are not enough.

What does the 50-tonne threshold mean?

For EU importers, subject to certain scope exceptions, an annual single mass-based threshold of 50 tonnes of CBAM goods applies. This threshold does not generally exempt all exports by a Turkish producer. Specific provisions, including those for electricity and hydrogen, must be checked separately.

What information should producers in Türkiye prepare?

• Map CBAM-covered products to their relevant production installations
• Production volumes, energy consumption, process emissions and appropriate emission factors
• Product-level embedded emissions calculations and the methodologies used
• Data sources, monitoring plans, calculation trails and retained evidence
• Suitable data and verification outputs for use by the EU importer's declaration

Verification requirements

Reporting actual emissions values may trigger independent verification obligations under the CBAM framework. Verification performed under ISO 14064 or ISO 14067 should not automatically be treated as CBAM verification. The verifier's relevant CBAM accreditation and scope must be assessed separately.

Pricing and commercial impact

Certificate costs are linked to EU ETS allowance prices. Embedded emissions, applicable rules, in certain cases carbon prices already paid in the country of production, and the EU ETS free allocation framework may influence the calculation. Assuming a single fixed 'carbon tax' amount can therefore be misleading.

Official sources

• European Commission — CBAM Definitive Regime
• European Commission — CBAM Verification
• EU CBAM Regulation — EUR-Lex