CBAM and Turkey: Europe's Largest Steel Exporter Faces EUR 8B+ Carbon Border Tax
Turkey exports more steel to the EU than any other country — 3–5 million tonnes per year. At current ETS prices and default values, Turkey's annual CBAM exposure exceeds EUR 8 billion. Turkish EAF producers with actual emissions of 0.50–0.70 tCO2/t can save EUR 96–110/t.
Turkey CBAM Exposure by Sector
| Sector | Key companies | EU export volume | Saving at actual vs default |
|---|---|---|---|
| Steel (EAF dominant) | Erdemir, Kardemir, İsdemir, Tosyalı, Çolakoğlu | 3,000,000–5,000,000 t/year | EUR 96–110/t (EAF at 0.50–0.70 tCO2/t) |
| Aluminium (secondary) | Assan Alüminyum, Asaş | 200,000–500,000 t/year | EUR 759–784/t (secondary at 0.40–0.80 tCO2/t) |
| Cement | Çimsa, Akçansa, Lafarge Turkey | 500,000–1,000,000 t/year | EUR 4–26/t |
Turkish ETS: Future Partial Offset
Turkey is developing its own Emissions Trading System (Turkish ETS) under the Climate Law (Law No. 7339). The Turkish ETS is expected to become operational in 2026–2027. Once operational, Turkish manufacturers paying Turkish ETS costs may be eligible for a partial CBAM deduction under Article 9 — but only with verified documentation of ETS compliance costs. The Turkish ETS price is expected to start at TRY 100–200/tCO2 (approximately EUR 3–6/tCO2) — significantly below the EU ETS price.
Sector-specific deep dives for Turkey
Türkiye's CBAM Exposure at a Glance
Türkiye is Europe's second-largest steel supplier, with geographic proximity to the EU making it uniquely exposed to CBAM. Total annual CBAM exposure is estimated at €800 million–€1.2 billion, primarily from steel. Türkiye's high share of electric arc furnace (EAF) production — approximately 70% of total steel output — is a structural advantage that gives Turkish producers some of the best CBAM economics among major exporters.
Sector-by-Sector Breakdown
Steel: Turkish EAF steel typically achieves actual embedded carbon of 0.5–0.9 tCO₂/t, compared to the EU default of 2.18 tCO₂/t. This represents a potential saving of approximately EUR 100–140 per tonne at current ETS prices. Major EU-exporting entities include Erdemir (Ereğli Demir ve Çelik), İsdemir, Habaş, and Çolakoğlu Metalurji. The Turkish grid emission factor is approximately 0.45 tCO₂/MWh, which is favourable for EAF producers compared to coal-heavy grids. See Türkiye steel CBAM deep dive →
Cement: Türkiye is a significant cement exporter to the EU via Çimsa, Nuh Çimento, and Oyak Çimento. Turkish cement producers have invested in alternative fuels and raw material substitution, achieving clinker-to-cement ratios below the EU average. Actual embedded carbon for Turkish cement is typically 0.60–0.70 tCO₂/t, below the EU default of 0.766 tCO₂/t.
Domestic Carbon Pricing Context
Türkiye launched a voluntary emissions trading pilot in 2022 and is developing a mandatory ETS aligned with the EU ETS. Under Article 9 of CBAM Regulation 2023/956, if Türkiye's ETS becomes operational and covers the same sectors as CBAM, Turkish producers may be eligible for partial deductions from their CBAM certificate obligations. This is a significant policy development to monitor.
How Turkish Producers Should Prepare
TÜRKAK (Turkish Accreditation Agency) is the national accreditation body for ISO 14065 verification in Türkiye. Local verifier capacity is strong, with Bureau Veritas, SGS, and TÜV Rheinland all having established Turkish operations. Turkish EAF steel producers should prioritise actual-value documentation as a matter of urgency — the savings potential is among the highest of any CBAM-covered country.
Find accredited verifiers: Türkiye CBAM Verifier Directory →
Frequently Asked Questions
What is Turkey's total annual CBAM exposure?
Turkey's annual CBAM exposure exceeds EUR 8 billion across steel, aluminium, and cement — based on current export volumes and EU default values. Turkish EAF steel producers documenting actual values can reduce this significantly.
Does Turkey have a carbon price eligible for CBAM deduction?
Not yet. Turkey is developing its own ETS (Turkish ETS) which may provide a partial CBAM deduction in future. Currently, Turkish manufacturers pay the full CBAM certificate cost with no deduction.
What is Turkey's grid emission factor?
Turkey's national grid emission factor is approximately 0.45 tCO2/MWh — lower than South Africa or India due to a more diversified energy mix including hydro, natural gas, and growing renewables.
Which Turkish steel companies face the highest CBAM exposure?
Erdemir (ArcelorMittal), Kardemir, İsdemir, Tosyalı, and Çolakoğlu are Turkey's major EU steel exporters. All face significant CBAM exposure from 2026.
Where can Turkish manufacturers find ISO 14065 accredited CBAM verifiers?
See the Turkey verifier directory at /verification-directory/turkey/ for TÜRKAK ISO 14065 accredited CBAM verification firms.
Calculate your CBAM saving → · Find a verifier → · What is embedded carbon? →