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MAİD — Marmara Business Platform

The carbon bill has arrived: CBAM’s financial phase and the exporter’s new homework

The EU Carbon Border Adjustment Mechanism entered its financial phase on 1 January 2026. The declarant may be the importer, but the data comes from the producer in Türkiye.

As of 1 January 2026 the EU Carbon Border Adjustment Mechanism (CBAM) entered its financial phase. Reporting-only years are over: CBAM certificates must now be purchased in proportion to the embedded carbon of goods entering the EU.

Who is affected?

The mechanism currently covers six sectors: cement, aluminium, fertiliser, iron and steel, hydrogen and electricity. Textiles, automotive parts and plastics are close behind. The declaration obligation usually sits with the EU importer — but the product, installation and emissions data comes from the producer in Türkiye. From 2026 the importer must also hold Authorised CBAM Declarant status; without it, shipment is not possible.

A practical road map

  1. Confirm whether your products fall in scope at HS-code level.
  2. Calculate a product-level footprint — corporate (ISO 14064-1) is not the same thing.
  3. Keep energy, fuel-mix and output data verifiable at installation level.
  4. Agree in the contract, now, who bears the certificate cost.

Compiled from the Ministry of Trade’s Green Deal and CBAM publications. Commentary is MAİD’s own.

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