CBAM & Turkey: a commercial constraint or an industrial opportunity?

CBAM, or MACF in French (Mécanisme d’Ajustement Carbone aux Frontières), in Turkey is now a strategic topic for industrial companies, exporters, and European businesses working with Turkish suppliers. Having entered its definitive phase on 1 January 2026, the Carbon Border Adjustment Mechanism gradually aligns the carbon cost of imports into the European Union with the cost borne by European producers under the EU ETS. At this stage, the sectors covered remain the same: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The European Commission is considering expanding this scope by 2030.

For companies operating in the Turkish B2B market, the issue is no longer theoretical. Legally, CBAM does not concern only European importers; in practice, it affects the entire value chain. European clients are now asking their Turkish suppliers for more reliable data on embedded emissions, product carbon reporting elements, as well as a credible industrial decarbonisation trajectory. Put simply: the cost is legally borne by the EU importer, but the commercial and competitive pressure rises directly up to the Turkish exporter.

CBAM is already changing the trade relationship between Europe and Turkey

In practice, the carbon border adjustment mechanism introduces a new competitiveness requirement. Yesterday, the discussion was mainly about price, quality, lead times, and logistical proximity. Tomorrow, it will also be about the ability to measure, document, and reduce the carbon intensity of a product exported to the European Union. This development is particularly important for Turkey, because its industry is deeply integrated into European value chains. The EU accounts for more than 40% of Turkish exports, and several of the country’s key industrial sectors fall directly within the CBAM scope.

Turkey therefore appears as one of the countries most exposed to the mechanism. The World Bank highlights that Turkish exports of iron and steel to the EU covered by CBAM amount to around USD 7.5 billion, and that 58% of the relevant Turkish aluminium exports are destined for the European market. The same analysis also stresses one essential point: if Turkey decarbonises its industrial base more quickly, it can not only limit the shock but also gain market share at the expense of more carbon-intensive competitors.

Why Turkey is particularly concerned

The issue is critical for Turkey for three reasons.

First, several of its industrial sectors most exposed to Europe are directly within the scope of CBAM. Second, Turkey already plays the role of an industrial platform close to Europe, which makes it essential for sectors such as metals, materials, certain processing industries, and part of export subcontracting. Finally, Turkey’s geographic and logistical proximity alone will no longer be enough to protect its competitiveness if the carbon footprint of products remains poorly measured or too high. CBAM is not just a regulatory constraint; it is also an accelerator of industrial transformation.

The case of Turkish cement is revealing. According to Cement Europe, Turkey accounted for 42.9% of EU cement and clinker imports in 2025. The case of steel is also strategic: Turkey remains a major supplier to the European market, in a context where the steel and aluminium sectors remain at the heart of the Union’s industrial, commercial, and climate-related trade-offs.

According to EBRD and Climate Focus modelling (2023), the potential annual cost for Turkish industry varies very significantly depending on the assumptions used:

• → €138 million/year from 2027 onwards – CBAM price at €75/tCO₂
  EBRD & Climate Focus, March 2023
• → €2.5 billion/year by 2032 – CBAM price at €150/tCO₂
  EBRD & Climate Focus, March 2023
• → €1.08 billion if the Turkish ETS is at €50/tCO₂ (vs €2.5 billion)
  EBRD & Climate Focus, March 2023

However, a notable IPC-Mercator analysis (February 2026), based on a general equilibrium model, provides an important nuance: the overall macroeconomic impacts are ultimately moderate (GDP variation close to zero) and concentrated in a few energy-intensive sectors.

Turkish steel, which relies heavily on electric arc furnaces and recycled steel, even enjoys a short-term competitive advantage over more carbon-intensive Asian or Russian competitors.

By contrast, upstream energy sectors (coal, gas) suffer real income losses of up to 2% for households in those sectors in the absence of labour mobility.

What CBAM specifically implies for Turkish exporters

For Turkish exporters, the immediate priority is CBAM compliance. This means being able to produce emissions data that is credible, traceable, and usable by the client or European importer. It also means better understanding the logic used to calculate embedded emissions, ensuring the quality of carbon reporting, and anticipating growing demands from European clients regarding MRV (Monitoring, Reporting, and Verification), verification, and carbon transparency. The European Commission’s CBAM materials specifically stress this growing need for data and reporting tools.

But the issue does not stop there. In the medium term, Turkish industrial players will also have to act on the production tool itself: energy efficiency, electrification of processes, integration of renewable energy, heat recovery, consumption management, and low-carbon industrial investment. This is where CBAM Turkey becomes not only a regulatory issue, but also an industrial and commercial one. Compliance is the immediate need; decarbonisation is the medium-term market.

Turkey is not only affected by CBAM: it is adapting to it

Another important point for the strategic reading of the issue is the evolution of the Turkish framework. In 2025, Turkey adopted its first climate law, and the Directorate of Climate Change subsequently published a draft regulation on the Turkish emissions trading system (ETS). In other words, the Turkish regulatory environment is also beginning to structure itself around carbon pricing tools, climate governance, and preparation for a more decarbonised industry.

For Turkish industrial companies, this may be seen as an additional constraint. But for European companies active in low-carbon solutions in Turkey, it is also a market signal. The country is gradually preparing for a more demanding framework in terms of carbon, compliance, and environmental performance. This creates demand for expertise, tools, and equipment capable of helping Turkish exporters remain competitive in the European market. CBAM is becoming a catalyst for economic and industrial transformation in Turkey.

Climate Law and National ETS

In July 2025, the Grand National Assembly of Türkiye adopted the country’s first Climate Law (Law No. 7552). It establishes the legal framework for an emissions trading system (Turkish ETS, with a pilot phase planned for 2026–2027) and a CBAM mirror mechanism (SKDM) for imports. Business key point: a Turkish ETS would make it possible to deduct the domestic carbon price from the CBAM certificate, thereby reducing exporters’ overall cost exposure. With an ETS at €50/tCO₂, the CBAM cost would fall from €2.5 billion to €1.08 billion per year by 2032, while ETS revenues would remain in Türkiye to finance the transition.

What opportunities for European SMEs and mid-sized companies?

Seen from France, or more broadly from Europe, CBAM in Turkey opens up several concrete opportunities.

The first is in consulting and carbon compliance: product-level emissions measurement, reporting structuring, data auditing, support for exporters and subcontractors, preparation for customer or customs requirements, traceability tools, and carbon management software.

The second is in industrial decarbonisation technologies: energy efficiency, automation, instrumentation, heat recovery, process optimisation, electrification, or integration of renewable energy.

The third is more strategic: industrial partnerships, know-how transfer, local establishment, or the development of an ecosystem of low-carbon solutions around the Turkish sectors most exposed.

In this context, Turkey is not just a country “affected” by CBAM. It is also becoming an industrial transition market, where European players can position themselves upstream, before competitive and regulatory pressure intensifies further. This is a key point for European SMEs and mid-sized companies that have technical, software, regulatory, or industrial know-how related to decarbonisation, MRV, industrial ESG, or process optimisation.

Commercial constraint or industrial opportunity?

The right answer is probably: both.

Yes, CBAM adds a commercial, administrative, and financial constraint for export chains between Turkey and the EU. Yes, the most carbon-intensive sectors will face increased pressure on their margins, their carbon documentation, and their competitiveness. But, at the same time, the mechanism is creating a real market for all solutions that make it possible to better measure, better prove, and better reduce industrial emissions. This is why CBAM Turkey should be understood not as a simple compliance issue, but as a change in the framework for industry, subcontracting, and supplier relationships between Europe and Turkey.

For European companies, the real question then becomes: how can they position themselves now on the concrete industrial transformation needs of Turkish exporters? That is precisely where on-the-ground support, sector knowledge, and a fine understanding of the Turkish market make the difference.

Do you want to assess the impact of CBAM on your sector, your suppliers, or your development strategy in Turkey?
Advantis supports European companies in reading the Turkish market, identifying opportunities, carrying out regulatory analysis, qualifying partners, and developing industrial projects in Turkey.