CBAM is usually presented to Turkish exporters as a cost. On a verified scrap-EAF route it can work the other way — but only verified, only per installation, and only measured in certificates payable.
Under the EU Carbon Border Adjustment Mechanism, an importer who cannot produce verified installation-level emissions data is charged on default values. For CN 7308 steel structures of Turkish origin, the default total-emissions value is 5.520 tCO₂e per tonne. The 2026 mark-up takes that to 6.072.
Separately, the same Annex assigns Türkiye a production-route indicator of (C), carbon steel based on blast furnace / basic oxygen furnace. That indicator does not calculate the default emissions value. It selects which CBAM benchmark is used in the free-allocation adjustment under Article 31. The two numbers sit in different columns and do different work.
So a Turkish producer that actually runs scrap through an electric arc furnace can establish a verified figure of its own, under Implementing Regulation (EU) 2025/2547, below the default it would otherwise be charged on. What is worth selling is not the emissions gap by itself. It is the difference in the importer's certificates payable after the free-allocation adjustment and any carbon price recognised as already paid at origin.
Most wrong CBAM claims come from treating two different quantities as though they were the same thing.
| Quantity | What it is | Where it comes from |
|---|---|---|
| Actual embedded emissions | What the installation genuinely emits per tonne, calculated and independently verified | Impl. Reg. (EU) 2025/2547 |
| Default value | What is used when no verified figure is supplied, plus a phased mark-up | Impl. Reg. (EU) 2025/2621, as corrected by IR (EU) 2026/1740 |
| CBAM benchmark | An input to the free-allocation adjustment. It is not a measurement of anyone's emissions | Impl. Reg. (EU) 2025/2620; Art. 31 of Reg. 2023/956 |
| Carbon price paid at origin | Potentially deductible where genuinely and effectively paid | Reg. (EU) 2023/956 |
| Certificate price | Published quarterly by the Commission in 2026 | DG TAXUD |
| Certificates payable | The output after the relevant adjustments — the number that becomes a cost | Calculated per import |
A single per-tonne figure for Turkish steel is meaningful only if those inputs and their assumptions are stated.
CBAM Annex I lists iron and steel at CN chapter 72 and then names specific headings, including 7308. Transmission towers and lattice masts are named in the heading. Solar PV mounting is not named as a category. Where a mounting structure is classified under CN 7308, it is in CBAM scope, but complete systems, kits and tracker assemblies require product-specific customs classification. Ferrous waste and scrap at CN 7204 is excluded from Annex I.
Default values exist so that the absence of data does not become the cheaper route. A mark-up is applied to the total-emissions default: 10% for 2026, 20% for 2027 and 30% from 2028 for the relevant sectors.
| Input | Value | Source |
|---|---|---|
| Türkiye default, CN 7308 — total emissions | 5.520 tCO₂e/t | IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740 |
| Production-route indicator assigned to Türkiye for 7308 | (C) Carbon steel based on BF/BOF | same Annex |
| Marked-up figure actually applied | 5.520 × 1.10 = 6.072 for 2026 | mark-up rule in the Annex opening paragraphs; calculated in the CBAM Registry |
| Certificate price, Q1 2026 | €75.36 / tCO₂e — published 7 April 2026 | DG TAXUD |
| Certificate price, Q2 2026 | €75.28 / tCO₂e — published 6 July 2026 | DG TAXUD |
| Certificate price, Q3 2026 | €82.32 / tCO₂e — published 5 October 2026 | DG TAXUD |
We deliberately do not publish a headline “CBAM costs €X per tonne” figure. Multiplying a default by a certificate price ignores the free-allocation adjustment under Article 31 and any carbon price already paid at origin. Any per-tonne figure is quarter-specific and installation-specific.
Under the embedded-emissions methodology, off-spec products, by-products, waste and scrap that are excluded from the originating process's activity level are assigned zero embedded emissions when they enter another production process. That does not make the resulting EAF product zero-carbon — the furnace's own emissions still count — but it is a real structural advantage for a scrap-fed route over an ore-based one.
In 2025, electric arc furnaces produced 72.2% of Türkiye's total crude steel, against 27.8% from integrated plants. That is a national crude-steel figure. It does not establish the production route or embedded emissions of any particular exporter or CN 7308 product.
The default emissions value and the production-route indicator do different jobs. The indicator determines the benchmark used in the free-allocation adjustment when defaults are used. It does not determine the emissions default itself.
For CN 7308, route (C) carries a higher free-allocation benchmark than the scrap-EAF route. On the default pathway, that higher benchmark creates a larger credit against the importer's CBAM obligation. Verification can therefore reduce the embedded-emissions obligation substantially while also reducing the associated free-allocation credit. The commercial gain is the net change in certificates payable, not the raw emissions gap.
The mark-up sits inside the embedded-emissions obligation. The CBAM phase-in sits inside the free-allocation term. The certificate price is then used to convert certificates into euro cost.
The CBAM factor is 97.5% for 2026 and falls to zero by 2034. The uniform cross-sectoral correction factor is 100% for each year from 2026 to 2030 under Commission Implementing Decision (EU) 2026/1862.
The following is an illustration of the mechanism, not a quotation for anybody's goods. The verified-case emissions figure and precursor mix are assumptions; installation-specific actuals must come from the operator's verified report.
| On defaults | On verified actuals | |
|---|---|---|
| Embedded-emissions obligation | 5.520 × 1.10 = 6.072 tCO₂e | 0.750 tCO₂e — assumed |
| Benchmark applied | 1.491 — route (C), default pathway | 0.112 process-related + precursor chain, 0.1835 in total — illustrative |
| Article 31 free-allocation adjustment | −1.454 | −0.179 |
| Carbon price paid at origin | −0 | −0 |
| Certificates payable | 4.618 | 0.571 |
| At the Q1 2026 price of €75.36 | €348.01 | €43.03 |
Illustrative euro values use the certificate liability rounded to three decimals as displayed above; registry calculations using unrounded inputs can differ by a few cents.
The important point is the mechanism. Verification reduces the emissions obligation but can also reduce the free-allocation credit. The net buyer value is the difference in certificates payable after both effects.
Türkiye's emissions trading system has moved from proposal to implementation. The Türkiye Emisyon Ticaret Sistemi Yönetmeliği was published in the Resmî Gazete on 27 August 2026.
That does not make Türkiye exempt from EU CBAM and does not make the Turkish ETS automatically equivalent to the EU ETS. Under Article 9 of Regulation (EU) 2023/956, the relevant question is whether a carbon price has been effectively paid for the declared embedded emissions, after rebates or other compensation are taken into account.
For 2026, where no carbon price has actually been paid, we model the Turkish carbon-price term at zero.
From 2027 onward, zero is no longer a safe blanket assumption. Where the Turkish system creates a real net carbon payment for the relevant emissions, that amount may become relevant to the Article 9 calculation if it can be evidenced under the EU rules. Free allocation, rebates and other compensation reduce the amount that can be recognised.
A Turkish carbon-price payment can therefore potentially reduce certificates payable without Türkiye becoming exempt from CBAM. Actual-emissions claims remain subject to the EU CBAM verification framework.
“CBAM benchmarks show what a scrap-EAF producer will document.” They do not. Benchmarks are inputs to the free-allocation adjustment. Actual embedded emissions are calculated separately under Implementing Regulation (EU) 2025/2547.
“Annex I explicitly covers solar mounting systems.” It does not. Solar mounting is in scope where the specific goods classify under an in-scope CN code such as 7308.
“Türkiye is 72% electric arc furnace, so Turkish structural steel is low-carbon.” The 72.2% figure is national crude-steel output. It says nothing by itself about a specific exporter's goods.
“The December 2025 proposal already brings downstream solar goods into CBAM.” It does not. Parliament adopted amendments on 15 September 2026 and referred the file back for interinstitutional negotiations. The proposed 2028 downstream extension is still not law and does not change the current 2026 classification test.
“Turkish steel carries about €100 a tonne of CBAM cost.” There is no single defensible number without the product, route, quarter, free-allocation adjustment and origin-carbon-price assumptions.
We do not verify emissions. That belongs to the installation and an accredited verifier under the EU methodology. Nor do we file CBAM declarations.
Our side is commercial. Once a verified figure exists, we take it and turn it into the argument a European buyer's procurement team can act on: where the emissions data has to appear, how the importer's certificate exposure changes, what that difference is worth in a price negotiation and which buyers are already asking for it.
If the verification does not exist yet, the first question is whether the gap is large enough to justify the cost and work of verification. Sometimes it is not.
Where the goods are classified under CN 7308, yes. Solar mounting is not named in Annex I, so complete systems, kits and tracker assemblies need product-specific customs classification before the position is relied on in a contract. The proposed downstream extension remains under negotiation and does not change the current 2026 classification test.
There is no single number. Start with actual verified embedded emissions or the applicable default, then account for the Article 31 free-allocation adjustment, any qualifying carbon price effectively paid at origin and the Commission certificate price for the quarter of importation. The Q3 2026 certificate price is €82.32 / tCO₂e, published by the Commission on 5 October 2026.
Yes, where verified installation-level data produces a materially lower net certificate burden for the EU buyer than the relevant alternative. The commercial argument is the buyer's certificates payable and landed-cost exposure, not a generic “green” claim.
30 September 2027, covering calendar year 2026.
Yes. The current single mass-based threshold is 50 tonnes, applied at importer/calendar-year level across the relevant covered sectors under Regulation (EU) 2025/2083.
Regulatory and calculation inputs rechecked through 6 October 2026. Certificate prices and regulatory detail change over time; check the current primary text before relying on any number in a contract.
The useful question is not what CBAM costs you.
It is whether the difference between the default route and a verified actual figure is large enough to be commercially worth documenting — and which buyers will care.