Türkiye’s new Green Deal Action Plan sets a timetable for a national CBAM. Published by the Ministry of Trade on 10 November, the plan schedules a sectoral impact assessment and the legislative framework for 2027, with data collection and a registry-style mechanism planned for 2027–2028. The national CBAM is to be compatible with Türkiye’s ETS.
What Türkiye has scheduled
The 2027 work covers the impact assessment and the legislation needed to establish the mechanism. Parallel data work in 2027–2028 will examine product emissions and the cost increases associated with carbon pricing, helping identify potential product groups for coverage. The plan leaves the start of charging and the final product list open.
Türkiye already has the legal basis for an ETS, and its operating regulation entered into force in August 2026. A border mechanism would apply carbon pricing to imports competing with Turkish production covered by the ETS. The national CBAM work sits alongside efforts to align verification requirements with EU CBAM and improve access to verified emissions data.
The same plan seeks EU recognition for Turkish renewable-electricity arrangements in emissions calculations. Electricity recognised as renewable under Turkish rules may be treated differently when emissions are calculated for exports, because the destination applies its own electricity-accounting rules.
The calculation can change with the destination
For Türkiye, the data work scheduled for 2027–2028 will help define which products and emissions enter its own calculation. A manufacturer supplying several markets could face different carbon costs for the same production, because the destination determines which emissions count and which foreign payments qualify for relief.
For covered cement products, EU CBAM includes both direct emissions and emissions from the electricity used in production. The UK’s initial charge is based on direct emissions. A cement plant’s electricity supply can therefore affect the emissions charged on EU sales while remaining outside the initial UK calculation.
Under the EU’s actual-emissions route, eligible carbon prices effectively paid abroad can reduce the number of certificates an importer must surrender, after taking rebates and compensation into account.
Several systems, at different stages
The EU’s definitive CBAM regime began in January 2026. The UK’s starts on 1 January 2027 under its own legislation and carbon-pricing framework. Norway is taking the EU model into the European Economic Area (EEA), with full application targeted for 2027; the EEA Joint Committee approved incorporation in September, and further legal steps are still needed for implementation.
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asset1_cbam_frameworks_comparison_article.png. Comparison of the EU, UK, Norwegian and Turkish frameworks, distinguishing implementation milestones from preparatory work.]
Canada launched formal consultations in August 2021. Australia’s completed Carbon Leakage Review recommends a border adjustment initially covering cement and clinker, with the recommendations to be considered in the 2026–2027 Safeguard Mechanism review. In the US, the Foreign Pollution Fee Act has been introduced in Congress and referred to the Senate Finance Committee.
