CBAM 2026: Carbon Border Adjustment Mechanism Compliance Guide for Turkish Exporters

As of January 1, 2026, the rules of global trade have been rewritten. The Carbon Border Adjustment Mechanism (CBAM), implemented by the European Union (EU) in line with its “Green Deal” objectives, is no longer just a reporting process; it has become a direct matter of cost and customs law for our exporters.

As Esenyel & Partners, we have prepared this guide containing critical updates to help Turkish exporters protect their competitiveness in the European market and manage the legal risks of this new era.

2026 Definitive Implementation Period: What Has Changed?

The “transition period” between 2023 and 2025 has ended. Starting with the year 2026, two fundamental obligations have come into effect for companies exporting goods to the EU in the covered sectors (Iron-Steel, Aluminum, Cement, Fertilizer, Electricity, and Hydrogen):

• Authorized CBAM Declarant Status: It is now mandatory for companies or representatives importing these products into the EU customs territory to hold “Authorized CBAM Declarant” status. Trade conducted through importers who do not possess this status faces the risk of rejection at customs.
• Financial Obligation (Certificate Purchase): Starting from the first quarter of 2026, CBAM certificates must be purchased for the embedded emissions of imported products. According to April 2026 data, certificate prices exceeding the 75 Euro per ton threshold have once again proven the importance of cost management.

Key Risks Faced by the Turkish Exporter

The volume contractions observed in the first quarter of 2026 in exports to the EU, Turkey’s largest trading partner, particularly in markets like Italy and Spain, demonstrate how critical the compliance process is.

Legal and Commercial Risks

• Administrative Fines: Missing or incorrect declarations may lead not only to goods being held at customs but also to heavy administrative sanctions imposed by EU member states.
• Contractual Disputes: Clauses in export contracts regarding who will bear the carbon cost and who holds liability in case of violation of data sharing obligations are now of vital importance.
• Data Accuracy and Default Values: If the producer cannot declare emission data according to EU standards, EU authorities will use the highest emission rate for the product as a basis. This means the exporter will pay a much higher carbon tax at customs.

Strategic Roadmap: How to Ensure Compliance?

As Esenyel & Partners, the compliance steps we recommend to our clients are as follows:

1. Legal Audit: Revision of all contracts in the supply chain in accordance with CBAM obligations.
2. National ETS Tracking: Establishing the legal infrastructure to deduct the carbon taxes paid within the framework of Turkey’s own Emission Trading System (ETS) and Climate Law from the costs in the EU.
3. Verification Processes: Minimizing costs through a “real emission” declaration by having emission data verified by accredited institutions.

Esenyel Partners is By Your Side

With our deep-rooted experience in the fields of international trade law, customs disputes, and maritime trade; we manage the customs disputes of Turkish exporters during the CBAM process and offer strategic consultancy for full compliance with carbon border adjustments.

The green transformation is not just an environmental responsibility, but a struggle to survive in the global market. You can contact our expert team to minimize your legal risks in this struggle.