The EU’s Carbon Border Adjustment Mechanism (CBAM) moved from a reporting-focused transitional period into its definitive period — where the financial obligation begins — on 1 January 2026. If you manufacture iron and steel, aluminium, cement or fertilisers and sell into the EU from Türkiye, this shift directly changes what your European customer will ask of you.
This article lays out, plainly, what actually changed in the definitive period, where the obligation sits, what happens on which date, and the data an exporter needs to have on hand.
From transitional to definitive: what changed?
During the transitional period that started in October 2023, the obligation was reporting only: EU importers of CBAM goods declared the embedded emissions of those goods every quarter, with no financial cost attached.
The definitive period is a different picture. Embedded emissions now have to be verified by an accredited verifier, and the EU importer buys and surrenders CBAM certificates for those emissions. Carbon has, for the first time, become a real cost line.
The six covered sectors are unchanged: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The EU is considering widening the scope in the coming years, so a product that sits outside the list today could enter it in the medium term.
Where does the obligation sit? The exporter’s real role
This is the point most often misread: the CBAM obligation legally sits with the importer inside the EU, not with the manufacturer in Türkiye. The party that buys the certificate, files the declaration and makes the payment is the EU company holding authorised CBAM declarant status.
That does not mean the Turkish manufacturer can relax. The importer has to know the embedded emission value of the product, and it will ask you for that data. Emissions that cannot be supplied or credibly documented are calculated using default (high) values for the importer — which means a more expensive certificate and weaker competitiveness.
In practice the equation is simple: the supplier who can provide verified, traceable emission data gets preferred. The supplier who cannot loses the price advantage and, over time, the order. This competitive pressure is CBAM’s real impact on Turkish exporters.
Timeline: what happens on which date?
The start of the definitive period and the first payment are not the same date. The simplifications adopted in late 2025 pushed part of the financial obligation forward, not earlier.
| Date | What happens |
|---|---|
| 1 January 2026 | Definitive period begins; emissions must be verified by an accredited verifier |
| 1 February 2027 | Sale of CBAM certificates begins (postponed from 1 January 2026) |
| 30 September 2027 | First CBAM declaration and first actual payment for 2026 imports |
The dates may look distant, but the preparation window is narrow. The emissions to be declared on 30 September 2027 belong to products made throughout 2026. The production data you collect today is the foundation of the document that lands on the table a year and a half from now.
What the new 50-tonne threshold (Omnibus) means
The Omnibus regulation (Regulation (EU) 2025/2083), which entered into force on 20 October 2025, introduced a single mass-based exemption to simplify compliance: firms importing less than 50 tonnes net of CBAM goods per year are exempt. This threshold applies to all CBAM goods except hydrogen and electricity.
According to the European Commission, the threshold leaves roughly 90% of importers out of scope while keeping about 99% of embedded emissions in scope. The logic: many small importers are relieved of the burden, while the high-volume imports that produce the vast majority of emissions stay under scrutiny.
For exporters, the reading matters: if your EU customer buys under 50 tonnes a year, a CBAM obligation may not arise. But if you sell to several EU customers, or your customer is a high-volume buyer, the threshold is most likely exceeded. We recommend confirming how the threshold applies to your specific case with your EU buyer and a compliance advisor.
What exporters need ready: verified emission data
In the definitive period, only documentable data counts. The core inputs your customer will expect:
- Embedded emissions per product (direct and indirect, in tonnes of CO₂ equivalent)
- A definition of the production process and system boundary used to calculate them
- A traceable record of energy and fuel consumption
- A calculation method consistent with EU methodology
- Accredited verifier approval in the definitive period
This is not information you can derive from an invoice or an estimate. It has to rest on measurement — from the floor, from the machine, from the meter. The point where most manufacturers get stuck is not the absence of data; it is data scattered across Excel sheets, shift logs and separate systems.
The path to ready data: measure, transform, sustain
This is where İkiz Eksen’s approach works. First, measurement: collecting production and energy data from the floor and bringing it into one place. On the digital transition side, machine data collection and meter integration build this foundation.
Then, moving it into software: connecting the scattered data to a structure that can calculate emissions per product. This backbone draws on the Qera track record — 100+ ERP deployments across 15+ sectors and 550+ customers — and Microsoft Azure infrastructure. Once production, energy and cost data meet on the same axis, the CBAM report comes out of the system rather than out of manual effort.
Finally, the compliance layer: arranging the calculated emissions according to EU methodology and presenting them ready for an accredited verifier. Verification and certification are performed by accredited bodies; İkiz Eksen prepares this process on the data side and coordinates it, working with solution partners. Our green transition service covers exactly this measure–software–compliance chain.
We run these three steps from a single team, turnkey, across Türkiye. To clarify where to start for your CBAM-covered products, you can request an assessment call through the contact form.
Frequently Asked Questions
Will the Turkish manufacturer make the CBAM payment?
No. The party that buys the CBAM certificate and makes the payment is the importer in the EU (the authorised CBAM declarant). The Turkish manufacturer has no direct payment obligation to the EU. However, the importer requests embedded emission data from the manufacturer to calculate certificates correctly; failing to supply it creates a commercial disadvantage.
Which products are covered by CBAM?
In the definitive period, six sectors are in scope: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Whether your product is covered is determined by its customs tariff (CN/HS) code; confirm the EU product list and borderline cases with your compliance advisor.
What does the 50-tonne threshold mean for me?
The threshold looks at the EU importer’s annual net import mass, not the individual manufacturer. If your EU customer imports under 50 tonnes of CBAM goods a year, an obligation may not arise. With sales to multiple customers or a high-volume buyer, the threshold is usually exceeded. Confirm your own situation with your buyer.
When is the first actual payment?
The first CBAM declaration and the related first actual payment for 2026 imports are due on 30 September 2027. Certificate sales begin on 1 February 2027. This means the emission data for products made throughout 2026 needs to be collected properly starting now.
I have never measured my emissions — where should I start?
Start by making production and energy data collectable from the floor; measurement, not estimate or invoice, is the basis. Once the data sits in one system, emissions per product can be calculated and prepared for accredited verification. İkiz Eksen builds this chain end to end; you can review our solutions.
The regulatory and timeline information in this article is based on the European Commission and official EU sources. As CBAM rules are updated frequently, we recommend confirming the obligation for your own product and volume with an official source or a compliance advisor.