Trump Towers, Ofis Kule:2 Kat:18, No:12, Sisli, Istanbul, Turkey

International Trade Compliance

Since 1 January 2026 the EU’s Carbon Border Adjustment Mechanism has been in its definitive period, and the first certificates for 2026 imports are surrendered in 2027. The legal obligation sits with the authorised CBAM declarant in the EU, but the Turkish producer is the only source of the emissions data that decides the cost. Without verified actual data, the default values apply, and Türkiye’s default table assumes blast furnace steel and primary aluminium. HERDEM helps Turkish exporters and their EU buyers work through the rules, the data and the contracts.

How we help

  • Assessing which of your goods fall within CBAM and what the default values would cost your EU customer
  • Planning the switch from default values to verified actual emissions, including mixing actual data for your own process with defaults for bought-in precursors
  • Preparing for third-party verification and the operator’s emissions report, which must be submitted in English
  • Contract terms with EU importers on data delivery, verification costs and price adjustment
  • Advising on how Türkiye’s Emission Trading System interacts with the CBAM deduction for carbon prices paid

Questions clients bring to us

  • Our EU buyer is asking for emissions data. What exactly do we owe them, and in what form?
  • We produce steel by electric arc furnace. Why are we being treated as a blast furnace producer?
  • Does Türkiye’s new Emission Trading System reduce our customer’s CBAM bill?
  • Who pays for verification, and how do we put that in the contract?

Related industries

Related analysis

Speak to us

Simge Kılıç, Managing Partner, leads HERDEM’s CBAM work. Send us a message below or contact our Istanbul office.


Kustepe Mahallesi, Mecidiyekoy Yolu Caddesi, Trump Towers, Ofis Kule:2 Kat:18, No:12, Sisli Mecidiyekoy, Istanbul, Turkey

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