Carbon tax, CBAM and Turkey: 2026+ scenarios for exporters

The European Union launched the Border Carbon Adjustment Mechanism (CBAM) to reflect the carbon price it pays domestically on imported products. Reporting was mandatory during the transition period; As of 2026, financial liability for embodied emissions begins. Turkey is a major supplier of emissions-intensive goods such as cement, iron and steel, aluminium, fertilizer and electricity to the EU — so the “carbon tax” is no longer a distant EU issue, but a cash flow issue for Turkish industry.

How does CBAM work?

Embodied greenhouse gas emissions (direct and indirect) in the production of certain goods imported into the EU are reported; An adjustment payment is made based on the EU ETS price. The aim is to prevent carbon leakage and create equal competition conditions with domestic producers. The scope initially opened with a limited product list; Expansion discussions continue.

Cost pressure on Turkey

According to research institutions' scenarios, the cost of CBAM without a national ETS could reach hundreds of millions of euros at mid-carbon prices; With the increase in prices and export volume, estimates reaching billion euros are included in the literature. The total CBAM burden of carbon-intensive sectors in the 2026–2034 period is modeled in the band of tens of billions of euros. The exact figure depends on politics and exchange rate; The message is clear: delaying increases costs.

Climate Law (7552) and SKDM

The Climate Law, which came into force in July 2025, created the legal framework for national ETS and greenhouse gas reporting. Border carbon price regulation (SKDM) and green financing instruments are also on the agenda. What it means for the exporter: emissions data is no longer just a sustainability report, it's a matter of official compliance and cost.

Difference between carbon tax and CBAM

“Carbon tax” is generally the government-imposed price per CO₂e (national ETS or indirect tax). CBAM is the correction applied to imports at the EU border. The (future) ETS cost you will pay when producing in Turkey and the CBAM cost in the EU affect each other; To reduce the risk of double payments, the national system must be ready for EU-compatible data sharing.

What should industry do? (Preparation list)

• Embedded emission calculation on a product basis (facility + supply inputs)
• Auditable metering for electricity and fuel (OSOS, meter hierarchy)
• Primary data request from suppliers (Scope 3 preparation)
• Carbon price scenario: 50–150 €/tCO₂e stress test
• Efficiency and solar investment — “mitigation” is the cheapest loan
• Continuity with systems similar to ISO 50001 / ISO 14064

The role of digital infrastructure

Emission factors and production data used in CBAM reports must be consistent. Annual collection with Excel files remains weak in auditing. Real-time energy monitoring, invoice reconciliation and normalization to production unit reduce cost and strengthen the report.

Conclusion

CBAM is a call for structural transformation for Turkish industry. The carbon tax debate goes in the same direction in the EU and Turkey: measure, price, reduce. ENOPTIMAL makes your energy and therefore your carbon footprint visible with production and consumption management; You can request a CBAM preparation meeting from the contact form.