Turkey faces the largest absolute CBAM exposure of any single country — Iron & Steel dominates, with Aluminium and Fertilisers as secondary sectors.
Turkey is one of the EU's largest steel suppliers, exporting approximately 6 million tonnes per year of rebar, wire rod, flat products and tubes. Turkey's steel sector is predominantly EAF-based (scrap-fed), which carries lower embedded emissions than blast furnace routes. Aluminium exports include primary ingots and semi-fabricated products. Fertiliser exports include urea and ammonium nitrate. Note: Turkish cement carries no country-specific default value in IR (EU) 2026/1740 Annex I — the "Other countries and territories" fallback applies for any cement exports.
Source: IR (EU) 2026/1740 Annex I, which replaced the Annex I of IR (EU) 2025/2621 from 1 January 2026 · Default = the published total-emissions value · Net cost adds the Annex I mark-up once — 10% in 2026 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, 1% for fertilisers · Used when verified actual data is not provided
| Product | Sector | Default tCO₂e/t | Net cost 2026 €/t | Net cost 2030 €/t |
|---|---|---|---|---|
Grey Portland cement CN 25232900 | Cement | 1.4400 | €116.26 | €72.58 |
Anhydrous ammonia CN 28141000 | Fertilisers | 2.2700 | €168.28 | €88.89 |
Urea (solid) CN 31021019 | Fertilisers | 1.5100 | €111.94 | €59.13 |
Ammonium nitrate CN 31023090 | Fertilisers | 2.6000 | €192.74 | €101.81 |
Steel semi-finished (BF-BOF) CN 72071114 | Iron & Steel | 2.3097 | €186.48 | €116.41 |
Unwrought aluminium CN 7601 | Aluminium | 1.7000 | €137.25 | €85.68 |
Hydrogen CN 28041000 | Hydrogen | 10.8200 | €873.58 | €545.33 |
Net cost = default tCO₂e/t × €75.28 (Q2 2026, official price of CBAM certificates) × CBAM phase-in factor (2.5% in 2026, 48.5% in 2030). Actual liability depends on verified embedded emissions and SEFA benchmark deduction. Values shown are for illustrative default scenario only.
Carbon pricing in Turkey: Turkey enacted Climate Law No. 7552 in July 2025 establishing a pilot ETS. As of 2026, the scheme is in a monitoring and verification phase and does not yet impose an enforceable carbon cost on CBAM-covered production.
Türkiye enacted Climate Law No. 7552 in July 2025 and its secondary legislation followed in August 2026, but the pilot phase allocates allowances free against benchmarks. Article 9 deducts only a price that has been effectively paid, net of any free allocation or rebate, so there is nothing yet for a declarant to evidence. Plan 2026 and 2027 declarations on that basis; if the scheme starts charging, the deduction follows the payment, not any approval of the scheme.
Our reading of Turkey's own published measures as at September 2026, not an EU-published value — third-country carbon policy changes without warning. Confirm the current position with advisers in the country of production before pricing anything on it.
Turkey's steel sector is predominantly EAF (scrap-fed), but Annex I publishes no EAF row for Turkey at any CN code — an unverified Turkish exporter is therefore assigned the BF/BOF route (C) default of 2.3097 tCO₂e/t, increased by the Annex I mark-up. A verified EAF actual is typically far below that, so verification cuts the chargeable gap substantially. It does not usually remove it: the benchmark deducted from a scrap/EAF good is route (E) at 0.066 tCO₂e/t [IR (EU) 2025/2620 Annex point 5, Column B], not the 1.364 tCO₂e/t that applies to the BF/BOF route. Verifier engagement is high-value for Turkish EAF producers; BF-BOF producers face the full default cost.
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Book a demoDefault values sourced from IR (EU) 2026/1740 Annex I (European Commission). Net costs are illustrative — actual liability depends on verified embedded emissions, SEFA benchmark deduction, and the applicable CBAM phase-in factor. Not legal or compliance advice.
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