The CBAM definitive period started on 1 January 2026. Every tonne of cement, iron and steel, aluminium, fertiliser, hydrogen and electricity entering the EU this year will eventually need certificates, surrendered by the authorised declarant by 30 September 2027. A Turkish producer has no filing duty of its own, but every shipment it cannot back with verified actual emissions will be declared on EU default values plus a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028, and the importer will want that cost back in the price.
This piece is written for the producer side: who the threshold actually applies to, what the calendar looks like, how much default values really cost and what has to be ready at the plant before an EU-accredited verifier can sign off on real data.
What changed on 1 January 2026
The financial obligation applies to goods imported from 1 January 2026 (Regulation (EU) 2023/956, Article 36(2)), in its version amended by the Omnibus Regulation (EU) 2025/2083. Methodology sits in Implementing Regulation (EU) 2025/2547, default values in (EU) 2025/2621, the free allocation adjustment in (EU) 2025/2620 and verification in (EU) 2025/2546.
For a producer, three things matter. Importers now pay rather than report: one certificate per tonne of embedded emissions. Default values are no longer neutral, because they carry a mark-up. And actual values can only be used once an accredited verifier has confirmed them. A declaration based on default values needs no verification; one based on actual values does.
Who the 50-tonne threshold applies to
The threshold applies to the EU importer, not to you. An importer whose total net mass of CBAM goods from all suppliers stays at or below 50 tonnes in a calendar year is exempt (Article 2a, Annex VII). The figure is cumulative: two 40-tonne consignments make 80 tonnes, and once the threshold is crossed, all goods imported that year are in scope (Article 2a(2)).
So "I only ship this customer 30 tonnes a year" is not an argument. If the same customer buys 200 tonnes elsewhere, your 30 tonnes are declared too. Electricity and hydrogen do not count toward the threshold and are covered at any quantity.
Importers above 50 tonnes must hold authorised CBAM declarant status (Articles 5 and 17). Those who applied by 31 March 2026 may keep importing while their application is decided (Article 17(7a)).
Key dates
| Date | What happens | Legal basis |
|---|---|---|
| 1 Jan 2026 | Financial obligation starts | Art. 36(2) |
| 31 Mar 2026 | Deadline to apply and keep importing pending a decision | Art. 17(7a) |
| 1 Sep 2026 | Verifier registration opened in the CBAM Registry | Art. 10a |
| 1 Feb 2027 | Certificate sales open on the common central platform | Art. 20(1) |
| 31 Mar 2027 | First quarterly holding: certificates for at least 50% of embedded emissions | Art. 22(2) |
| 30 Sep 2027 | First annual declaration and surrender, for 2026 imports | Art. 6(1), 22(1) |
| 31 Oct 2027 | Request to repurchase excess certificates | Art. 23 |
| 1 Nov 2027 | Remaining 2026 certificates cancelled without compensation | Art. 24 |
In 2026 the certificate price is published quarterly as an average of EU ETS auction prices (Implementing Regulation (EU) 2025/2548). Published so far: Q1 2026 €75.36, Q2 €75.28, Q3 €82.32. The Q4 price is due on 4 January 2027. From 2027 prices are weekly.
Default values and the mark-up
The EU publishes default embedded emissions by country and CN code. The tables were corrected by Implementing Regulation (EU) 2026/1740, published on 31 July 2026 and applicable retroactively from 1 January 2026, so any cost estimate built on the original tables earlier this year should be rerun. Some clinker and cement codes are now split at 10-digit TARIC level (white versus grey clinker, for example).
The tabulated values no longer include the mark-up. The rule is set out in the introduction to Annex I:
| Import year | Cement, iron and steel, aluminium, hydrogen | Fertilisers |
|---|---|---|
| 2026 | 10% | 1% |
| 2027 | 20% | 1% |
| 2028 onwards | 30% | 1% |
Goods declared on verified actual values carry no mark-up. Scope also differs by sector: iron and steel, aluminium and hydrogen count direct emissions only, cement and fertilisers count direct and indirect. Renewable energy certificates, whether Turkish YEK-G or I-REC, are not accepted for actual indirect emissions.
Free allocation adjustment
As long as EU producers receive free allowances, importers surrender correspondingly fewer certificates. The deduction is net mass × CBAM factor × cross-sectoral correction factor (CSCF) × benchmark (Implementing Regulation (EU) 2025/2620). The CSCF is set at 100% for 2026 to 2030.
The CBAM factor falls each year (Directive 2003/87/EC, Article 10a(1a)):
| Year | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | 2032 | 2033 | 2034 |
|---|---|---|---|---|---|---|---|---|---|
| CBAM factor | 97.5% | 95% | 90% | 77.5% | 51.5% | 39% | 26.5% | 14% | 0% |
Same product, same tonnage, same emissions: the bill still grows every year. The Commission has proposed a different phase-out path (COM(2026) 616), but it has not been adopted, so estimates should use the path in force.
Worked example: 1,000 tonnes of hot-rolled flat steel
Inputs are hypothetical; coefficients are official. Origin Türkiye, CN 7208 10 00, 1,000 tonnes, blast furnace/BOF route (C). EU default value 2.428 tCO₂e/t, benchmark 1.370. For the actual-value case we assume a verified specific embedded emission of 1.90 tCO₂e/t and a producer SEFA based on the same route benchmark.
| Default value | Actual value (hypothetical 1.90) | |
|---|---|---|
| Embedded emissions | 1,000 × 2.428 = 2,428 t | 1,000 × 1.90 = 1,900 t |
| 2026 mark-up | × 1.10 = 2,670.8 t | not applied |
| Free allocation adjustment (2026) | 1,000 × 0.975 × 1.370 = 1,335.75 t | 1,335.75 t |
| Certificates (2026) | 1,335.05 | 564.25 |
| Cost at Q1 price €75.36 | €100,609.37 | €42,521.88 |
| Certificates (2027) | 1,612.1 | 598.5 |
| Certificates (2030) | 2,450.85 | 1,194.45 |
In 2026 the gap is about €58,000, or roughly €58 per tonne of steel. By 2030 the default-value shipment needs more than twice as many certificates as the verified one.
Your actual value will not necessarily beat the default; it can also come out higher. Calculate it first, then decide what to hand over. And note that with actual values the free allocation adjustment relies on the SEFA in the producer's report. If the report does not state it, no adjustment is made and the certificate count is overstated.
Moving to actual data: the operator emissions report and verification
What your EU customer really needs from you is an operator emissions report: installation boundary, production processes, direct and, where relevant, indirect emissions per process, precursors, and the resulting specific embedded emissions, following Implementing Regulation (EU) 2025/2547.
Precursors are where projects stall. A plate mill buying slab or billet needs the embedded emissions of that input from its supplier. Without them, a default value is used for the precursor and, according to the Commission's Guidance Document No. 3 of 14 August 2026, the reporting year's mark-up applies to it as well. A clean process of your own will not offset a defaulted precursor.
On verification: actual values must be verified by a verifier accredited for CBAM by a national accreditation body of an EU Member State (Delegated Regulation (EU) 2025/2551, Implementing Regulation (EU) 2025/2546). As of October 2026, accreditation by TÜRKAK is not recognised for CBAM verification; TÜRKAK and the Dutch accreditation body RvA signed a cooperation agreement on 24 June 2026. Third-country operators may register voluntarily in the CBAM Registry (Article 10) and must keep records for four years.
A short list for exporters:
- Confirm in writing which CN codes your EU customers declare; default values depend on the code.
- Split 2026 production data by process: fuels, electricity, process inputs, output, precursor purchases.
- Request embedded emissions data from your precursor suppliers.
- Prepare the operator emissions report and talk to an EU-accredited verifier early. Declarations for 2026 are due in September 2027 and verifier capacity will be tight that summer.
- Write into your contracts who carries the CBAM cost.
Can a Turkish carbon price be deducted?
A deduction is possible only for a carbon price effectively paid in the country of origin, net of rebates and free allocation (Article 9). Under the Turkish ETS pilot, 2026 is a reporting-only year, 2027 allowances are allocated 100% free on a benchmark basis and the 2027 surrender is due in November 2028. For 2026 and 2027 imports there is nothing to deduct. The implementing act on how the deduction is calculated is still a draft. Turkey's Climate Law (No. 7552, Article 8) empowers the government to set up its own border carbon mechanism, but no implementing rules have been published.
A declarant who fails to surrender faces the penalties in Article 26: the EU ETS excess emissions penalty per missing certificate, and three to five times that for unauthorised imports. The penalty is the importer's; the price pressure lands on you.
How Carbolyt handles it
Carbolyt's CBAM module builds the declaration line by line. It looks up the default value by CN code and origin from Implementing Regulation (EU) 2026/1740 (10,910 rows) and the benchmark from (EU) 2025/2620 (2,465 rows), applies the mark-up, the free allocation adjustment and the official quarterly price, and tracks the 50-tonne threshold through the year. The same module covers the operator emissions report, precursor calculation and a 28-field supplier data form, plus a certificate projection to 2034 and the 50% quarterly holding.
Carbolyt does not file declarations. Its XML export is a data handover file for the EU declarant; the binding declaration is the one submitted in the CBAM Registry. For a quick number on your own CN code, the free CBAM calculator works without sign-up (the interface is in Turkish). Deadlines are on the regulation calendar and the full module is described on the platform page.
Frequently asked questions
Does the Turkish exporter file the CBAM declaration?
No. The declaration is filed, and certificates surrendered, by the authorised CBAM declarant in the EU (the importer or an indirect customs representative). The producer's job is to supply embedded emissions data; without it, the importer uses the EU default value plus the mark-up.
When is the first annual CBAM declaration due?
30 September 2027, covering goods imported in 2026 (Regulation (EU) 2023/956, Articles 6(1) and 22(1)). Certificate sales open on 1 February 2027; 2026 imports are priced at the official average for the quarter in which the goods were imported.
What mark-up applies to default values?
10% for 2026, 20% for 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen; 1% for fertilisers. The rule sits in the introduction to Annex I of Implementing Regulation (EU) 2025/2621 as corrected by (EU) 2026/1740. Goods declared with verified actual values carry no mark-up.
Can a carbon price paid under the Turkish ETS be deducted?
Only a carbon price effectively paid in the country of origin can be deducted. The Turkish ETS pilot treats 2026 as a reporting-only year, allocates 100% free allowances for 2027 and sets the first surrender in November 2028, so there is nothing to deduct for 2026 or 2027 imports.
Sources
This article is for information and is not legal advice. Dates and rates reflect the official texts at the time of publication; check the current text before acting.