Türkiye's carbon market is in force, but you cannot deduct yet

Türkiye's emissions trading system now has operating rules, but an EU importer of Turkish CBAM goods has nothing to deduct yet. On 27 August 2026 Türkiye published the Türkiye Emisyon Ticaret Sistemi Yönetmeliği in the Official Gazette, issue 33353. The Yönetmelik entered into force on publication.

Türkiye is one of the largest suppliers of CBAM goods to the EU. If you import Turkish steel, aluminium, cement or fertiliser, the question is not whether Türkiye has a carbon price. The question is whether you can deduct anything yet. The short answer is no, and the reason matters, because the answer will change.

What the regulation does

The Yönetmelik sets the operating rules for Türkiye's national emissions trading system. It is made under the Climate Law (İklim Kanunu) no. 7552 of 2 July 2025 and Presidential Decree no. 4, article 792/D. It sets the procedures for monitoring, reporting and verifying greenhouse gasgreenhouse gasA gas covered by the applicable greenhouse-gas accounting or CBAM rules. emissions from the activities in its Annex 1. It also sets who operates the trading system, and with what authority.

The design is comparable with the EU ETS. The regulation provides for:

• verification bodies and their accreditation;
• a central electronic system that assigns verifiers to installations;
• free allocation, calculated on the emissions intensityemissions intensityEmbodied emissions per applicable functional unit for a UK CBAM good. of each sub-installation;
• an auction market that distributes allowances;
• a market stability mechanism that aims to keep allowance prices stable.

Article 40 repeals the 2014 regulation on monitoring greenhouse gas emissions. Every reference to that instrument now points to this regulation.

Three categories fall outside the regulation:

• facilities used for research and development, or for testing new products and processes;
• facilities that burn exclusively biomass;
• military assets.

The pilot period is still undecided

One provision decides the answer for an importer. It is Provisional Article 1:

"The Emissions Trading System begins with a pilot implementation period. Pursuant to article 1(1) of the provisional provisions of Law no. 7552, the scope, duration and procedures of the pilot implementation period shall be determined by the Carbon Market Board, having taken the opinion of the relevant institutions, organisations and civil society organisations."

The system therefore starts as a pilot. The regulation does not say which installations take part, how long the pilot runs, or how much free allocation they receive. The Carbon Market Board, the Karbon Piyasası Kurulu, must decide these points. It has not decided them yet.

The regulation also sets no first allowance price. It builds the market in which a price will form, but it names no price.

Why the pilot decides the deduction

Article 9 of the CBAM Regulation lets an authorised CBAM declarantAuthorised CBAM declarantThe only person permitted to import CBAM goods from 1 Jan 2026: the EU-established importer or the indirect customs representative holding the CBAM account number in the customs declaration. An importer whose relevant annual mass does not e claim a reduction for a carbon price effectively paid in the country of origin. The reduction covers the emissions embedded in the imported goods. Those two words, effectively paid, decide the question.

A price that is only legally applicable, announced or in force does not qualify. A price that a producer did not pay is not deductible. A producer that receives free allocation has not paid for the allowances it received for free.

Türkiye's published rules therefore leave this position today:

• The system is in force, but it starts as a pilot with an undetermined scope.
• The Carbon Market Board has not yet decided whether a given Turkish installation takes part in the pilot.
• The free allocation an installation would receive belongs to the same undecided package.
• No allowance price exists yet from which to compute an amount paid.

There is therefore nothing to deduct today. The deduction is not unavailable in principle. None of the quantities that it needs exist yet.

Why Türkiye prices its own carbon

This section is our reading, not a rule. CBAM charges the gap between the EU carbon price and the price already paid at origin. If nothing was paid at origin, the whole gap leaves the country as certificates bought in the EU. If Türkiye prices its own carbon, the Turkish state collects that money instead. The money then stays in Türkiye, where it can fund the decarbonisation that would shrink the bill.

The exporter's cost is similar either way. What differs is who keeps the money. This matters more for Türkiye than for most countries, because it is one of the EU's largest suppliers of steel, aluminium and cement. In our reading, a domestic carbon price is the cheapest response available to it. It is also the behaviour that CBAM was built to encourage. You may read that as the mechanism working as designed, or as pressure on a trading partner. Your reading depends largely on which side of the border you sit.

What to watch

Watch for one event: a Carbon Market Board decision that sets the pilot's scope, duration and allocation. That decision, and not the regulation published in August, makes a Turkish carbon price relevant to a CBAM declaration. We will report it when it is published.

What it means for importers

If you import from Türkiye, nothing changes in your 2026 declaration. A 2027 cost model cannot rest on this regulation either, because the number a deduction needs has not been published.

When a price does arrive, the deduction needs proof of the price that that installation actually paid for those emissions, verified. The existence of a Turkish carbon price is only the precondition. It is not the evidence.

What to do

• Leave any deduction for Turkish goods out of your declaration and your cost model.
• Ask your Turkish suppliers one question now: do you expect to be inside the pilot phase, and have you been told anything about your free allocation? Most will answer that they do not know yet. The asking is what matters. When the Board decides, suppliers that know what to look for will produce evidence months before the others.
• Keep a place in your supplier file for the verified price that each installation paid, once one exists.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article explains a regulation and a rule. It is not legal, tax or customs advice.