Will Turkey's emissions trading system reduce CBAM costs for Turkish exporters?
Only to the extent a carbon price is actually paid. Turkey's climate law sets up an emissions trading system that starts with a pilot phase, and allowances in early phases are expected to be largely free. Free allowances give nothing to deduct; paid allowances can count, with proof.
What can be deducted
Under Article 9, the EU declarant can claim the carbon price effectively paid in Turkey for the embedded emissions, net of free allocation and any compensation.
What to do now
- Align the monitoring plan required by the Turkish system with your CBAM monitoring, so one data set serves both.
- Keep allowance purchase and surrender records by installation.
- Arrange an independent certification of the amount attributable to EU exports.
What Senseible does here
Senseible reads coal, coke, gas and electricity invoices and production records into a dated, fingerprinted record per site, so the direct emissions behind each tonne can be traced to the documents. Emissions factors outside India are entered from the official source and labelled.
Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM legislation and guidance, European Commission, price of CBAM certificates
Last reviewed 2026-10-21.