Türkiye plans its own CBAM: What the new Green Deal Action Plan means for importers
CBAM Weekly – Issue 120
Ankara anchors carbon pricing in its action plan to 2030
On 10 November, Türkiye published its updated Green Deal Action Plan 2026–2030 in the Official Gazette, in the middle of COP31 in Antalya. A dedicated policy area on carbon pricing brings together the Turkish emissions trading system, work on the EU CBAM and a national CBAM in four objectives and 14 actions. This matters for EU importers because Türkiye is the EU's second-largest supplier of CBAM goods and 47 percent of its exports of these goods go to the EU.
Turkish emissions trading is meant to lower CBAM costs
The legal basis is Climate Law No. 7552, in force since 9 July 2025. The regulation on the Turkish emissions trading system (TR ETS) followed on 27 August 2026. According to the action plan, the carbon price paid under the TR ETS is to be deducted from the CBAM liability on exports to the EU, preserving the competitiveness of Turkish producers.
It will take years before this turns into an actual deduction. The pilot phase covers emissions in 2026 and 2027. For 2026, installations only report, for 2027 allowances are allocated 100 percent free of charge, and the first surrender is due in November 2028. Article 9 of the CBAM Regulation only allows a deduction where a carbon price has effectively been paid, and any relief in the country of origin must be taken into account. The Commission's draft on the deduction explicitly counts free allocation as such relief (Issue 94). Importers should therefore budget for the full CBAM burden on Turkish goods for 2026 and 2027.
Verification under EU methodology as a second focus
Under the objective on the EU CBAM, the plan provides for sector-specific information activities, continued dialogue with the EU and stronger reporting capacity consistent with EU methodologies and standards. For the TR ETS, verification and accreditation infrastructure is to be strengthened at the same time. Exchanges with Brussels take place in the joint Türkiye–EU CBAM Working Group. According to the state news agency Anadolu, Ankara also intends to convey the sectors' views on default values, calculation methods and verification there. For electricity, the plan sets the goal of a fair mechanism that encourages the use of renewable energy in electricity exports.
The more Turkish installations monitor under EU-compatible rules and have their data verified by accredited verifiers, the more likely importers are to use actual emissions instead of default values. This effect will arrive earlier than any deduction of a Turkish carbon price.
A national CBAM in the other direction
The third objective concerns a Turkish CBAM of its own. It is to be introduced in sectors at high risk of carbon leakage once the TR ETS is in place. To prepare, the government intends to collect data on the emissions-related competitiveness of sectors and products. According to the trade publication SteelOrbis, the plan foresees an impact assessment and the legal framework in 2027, and a data system modelled on the CBAM Registry in 2027 to 2028.
After the UK CBAM, which starts on 1 January 2027, this would create another border adjustment that could also affect deliveries from the EU. The plan does not say which goods would be covered or how a carbon price paid in the EU would be credited. Companies supplying steel, aluminium or cement to Türkiye should follow the process while product lists are still open.
Taiwan follows the same pattern
Türkiye is not the only supplier country aligning its carbon pricing with CBAM. On 2 November, Taiwan's President Lai Ching-te announced that, following the introduction of the carbon fee, Taiwan is now preparing its own version of CBAM and an emissions trading system. He gave no timeline. Like Türkiye, Taiwan is counting on a carbon price paid at home to reduce the burden under the EU CBAM and to keep the revenue in the country. Whether a supplier pays a deductible carbon price, and how much, is thus becoming a purchasing criterion for importers.
Outlook
The TR ETS pilot phase runs until the end of 2027, and the first surrender obligation follows in November 2028. It remains open when the Commission will finally adopt the implementing regulation on the deduction under Article 9. Importers should now ask their Turkish suppliers whether their installations are covered by the TR ETS, which verifier they use and whether they can provide actual emissions data for 2026.
Support
If you would like to understand how Turkish carbon pricing affects your CBAM costs for goods from Türkiye, for instance what deduction is realistic from 2028 and which emissions data you should request from your suppliers, please get in touch at helge@kolum.ai.