Türkiye’s Emissions Trading System is not a tax return. Covered installations must surrender one allowance per tonne of CO₂ equivalent. Part of the allowance is free; the shortfall is bought at the EPİAŞ primary auction or on the secondary market. Surplus can be sold. The legal basis is Climate Law No. 7552; the 2014 GHG Monitoring Regulation is repealed. Our CBAM and carbon-tax guide covers how a domestic ETS interacts with EU border carbon costs.
27.08.2026
Published
Official Gazette 33353
> 50,000 t
ETS threshold
Categories B and C
30 April
Report
Previous calendar year
End of November
Surrender
Last business day of the obligation year
Not a tax: how an allowance works
What is traded is not stack gas but the right to emit one tonne. Equation: free allocation + market purchases ≥ verified emissions. A shortfall must be bought; a surplus may be sold. A cement plant does not “sell carbon”; it may sell unused permits. Typical cement and thermal plants are net buyers.
Who is in? Two filters
First, an Annex I activity (20 MW+ combustion, clinker, iron and steel, glass, refining, selected chemicals…). Then annual emissions. If a site already performs one listed activity, other listed activities at the same site enter without a separate capacity test.
| Category | Annual CO₂e | EPİAŞ surrender |
|---|---|---|
| A | ≤ 50,000 t | No — monitoring and reporting only |
| B | 50,000 – 500,000 t | Yes, mandatory |
| C | > 500,000 t | Yes, mandatory |
Schools, universities, hospitals and defence-industry sites are outside ETS trading; Annex I MRV still applies. Military units, biomass-only plants and R&D/test units are outside the regulation. Natural-gas and crude-oil transmission and storage stay outside ETS until the end of the first implementation period (MRV excepted).
Annex I in brief — who is listed?
- Fuel combustion ≥ 20 MW (except hazardous/municipal waste): thermal power, large CHP, large industrial boilers
- Oil refining (≥ 20 MW), coke production
- Iron and steel, ore sinter/pellet, metal processing ≥ 20 MW, primary/secondary aluminium
- Clinker (rotary kiln ≥ 500 t/day or other furnace ≥ 50 t/day), lime, glass, ceramics, gypsum
- Pulp and paper (≥ 20 t/day); ammonia, nitric/adipic acid, hydrogen/syngas, soda ash
Large electricity users, hotels, solar and wind
Buying many kWh from the grid is not ETS. Emissions are counted at the power plant. Hotels, malls and factories without their own ≥ 20 MW boilers are not listed. A large hotel often uses 3–25 GWh a year — Scope 2, not an allowance. Reaching 50,000 t via grid power alone would take about 107 GWh at the ministry distribution factor (~0.469 t/MWh). That is not a hotel.
| Who / fuel | Approx. electricity | In ETS? |
|---|---|---|
| Producer, Türkiye average (~0.434 t/MWh) | ~115 GWh | Only ≥ 20 MW fossil combustion + B/C |
| Producer, gas (~0.405 t/MWh) | ~123 GWh | Same thresholds |
| Producer, coal/lignite (~0.9–1.1 t/MWh) | ~45–55 GWh | Same thresholds |
| Consumer (distribution, ~0.469 t/MWh) | ~107 GWh | No — Scope 2 |
| Solar / wind / hydro | No stack emissions | No |
Can solar and wind sell on this market?
No. Market participants are defined as ETS-covered operators. The state issues allowances up to the cap; free shares go to B/C installations. “Tonnes avoided” are not sellable allowances. Renewables use the separate YEK-G / I-REC certificate market. Indirect effect: thermal plants buying allowances may lift wholesale power prices; that premium stays on the electricity market. Domestic carbon-credit offsets may cover a Board-set share of surrender — that is not a solar plant selling ETS allowances on EPİAŞ. Grid solar/wind often fails additionality.
Does EPİAŞ alone sell allowances?
EPİAŞ is the market operator: the registry, primary auctions and secondary continuous trading run there. It does not own the allowances. There is no off-exchange sale. EMRA sets the market rulebook.
| Channel | Seller / issuer | What a cement plant does |
|---|---|---|
| Free allocation | State → installation account | Free share (benchmark × activity) |
| Primary market | System / state auction | Buys the shortfall |
| Secondary market | B/C operator with surplus permits | Sells if long; buys if short |
| Reserve | System, strict conditions + price cap | If still short at surrender, if eligible |
Who can post a sell order?
- A category B or C ETS operator that holds allowances (cement, thermal, steel, glass, refining…)
- An installation leaving the scope that has already surrendered and still has a surplus — sell-only until the account is empty
- On the primary market the seller is the state auction, not a company sell order
- Solar, wind, hotels, category A and banks/brokers are not participants under the regulation
You cannot sell paper you do not hold. A cement plant that emits 100,000 t and receives 70,000 free must buy 30,000; it cannot sell. If the kiln is turned down or the site beats the benchmark, the surplus can be sold. 600,000 t is category C: the same rule, six times the surrender volume and category-C penalties.
What if you do not comply?
If the verified report is not filed by 30 April, the regulation’s administrative fines apply — doubled for ETS operators. Operating without a permit is a separate, heavier fine. If allowances are not surrendered, Climate Law Art. 14: twice the higher of the last-three-month primary or secondary average price per missing tonne; that tonne is still due the next year. Missing at least 80% three years in a row cancels the GHG permit; a new permit is withheld for three to six months. Closure or insolvency does not cancel surrender.
Pilot and transition
The system starts with a pilot; the Board sets scope and duration. A GHG permit must be obtained within three years of the Climate Law; during that window a permit is deemed to exist (the Board may extend by two years). Pilot operators file the first Monitoring Methodology Plan within two months of the regulation (the Presidency may extend by six months). The first implementation period has two sub-periods.
Why energy data matters
Free allocation depends on activity level and the benchmark. Without fuel, heat, electricity and production tonnes, both the report and the allowance account stay weak. OSOS, invoice reconciliation and digital metering belong in the same plant file as Scope 1–2 tracking. ENOPTIMAL gathers consumption and generation in one place; you can request an ETS-readiness discussion via the contact form.