The EU’s Carbon Border Adjustment Mechanism (CBAM) is entering a new operational reality: the definitive period starts on 1 January 2026. The European Commission is explicitly urging importers (or their indirect customs representatives) to apply for authorised CBAM declarant status as soon as possible via the CBAM Registry’s authorisation module.
For companies sourcing from Türkiye into the EU, this is not a “policy watchlist” item anymore. It’s a compliance workflow that must be built into procurement, contracting, supplier qualification, and shipment execution.
This post is written as a news-style brief with a practical checklist you can implement immediately.
What changed for 2026 (the hard dates that matter)
1) The definitive period begins 1 Jan 2026
The Commission’s CBAM guidance states clearly that the definitive period starts on 1 January 2026 and points importers to the Authorisation Management Module (AMM) for applications.
2) Authorised declarant applications run through the CBAM Registry (AMM)
The Commission launched the AMM in the CBAM Registry to enable importers and indirect customs reps to apply for authorised status.
3) Certificate sales timing: sold from 1 Feb 2027 (but obligations are tied to 2026 imports)
The Commission’s December 2025 Q&A notes that CBAM certificates will be sold only from 1 February 2027 for goods imported in 2026, and its CBAM review report also references certificate sales taking place from February 2027 via the central platform.
Interpretation that matters commercially: “Sold later” does not mean “ignored now.” 2026 is the year that creates the embedded-emissions exposure you’ll ultimately reconcile.
4) Enforcement detail is being tightened via late-2025 rulemaking
On 17 December 2025, analysis of Commission actions highlights an implementing/operational package and a proposal to extend CBAM to more downstream products and strengthen anti-circumvention measures.
Why this hits Turkey–EU sourcing lanes especially hard
Türkiye is a major near-market manufacturing base for the EU across metals, construction inputs, components, and many downstream products. The problem is rarely “can Türkiye supply?” The problem is data discipline:
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embedded emissions data availability
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supplier methodology consistency
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contract leverage when data is late or incomplete
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customs + document flow stability
On the document-flow side (separate from CBAM, but operationally important), the Commission also confirmed EU Member States accept electronically issued A.TR movement certificates from Türkiye (with QR code / no wet-ink signature) under EU–Türkiye Customs Cooperation, supported by EU–Türkiye committee decisions.
The 9-step “CBAM-ready Turkey sourcing” checklist (importer-grade)
Step 1) Map CBAM exposure by HS code (not by product name)
CBAM scope is HS-driven. Do not rely on internal product labels. Start from the customs classification list and map all Turkey→EU lanes accordingly.
Step 2) Decide who will be the CBAM actor
Confirm whether you file as:
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the importer, or
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an indirect customs representative acting on your behalf.
Step 3) Apply for authorised CBAM declarant status (now, not in January)
The Commission urges early applications via AMM. Treat this like an “account opening” bottleneck risk: leave it late and you compress everything else.
Step 4) Build a supplier “CBAM data pack” template (minimum viable)
Require suppliers to provide:
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installation/operator identifiers
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emissions calculation approach and values (embedded emissions)
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supporting evidence and retention plan
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verification readiness (when applicable)
Your goal is consistency across suppliers—not perfection on day one.
Step 5) Add a contract clause: data failure has consequences
Most supplier delays are incentive problems. Add commercial triggers such as:
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delayed acceptance / delayed payment
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charge-back of admin costs
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right to switch to default values / terminate supply lane
Step 6) Operationalize the “2026 imports → 2027 certificates” reality
The Commission states certificates are sold from 1 Feb 2027 for 2026 imports. Build internal reporting and budgeting so 2026 shipments are tracked with auditable data from day one.
Step 7) Track national guidance on thresholds (don’t assume one rule fits all)
Some national authorities publish additional operational guidance (e.g., discussion of 50-tonne/year thresholds in certain contexts). Always validate against your Member State competent authority.
Step 8) Reduce customs friction where possible: use electronic A.TR correctly
If your lane uses A.TR within the Customs Union framework, ensure:
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QR code / e-issuance requirements are met
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the verification method is available
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your broker treats A.TR as “free circulation” proof (not origin proof)
Step 9) Build an audit trail before you need it
Store (at minimum):
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purchase contracts + Incoterms
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HS classification rationale
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supplier emissions pack
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shipment docs + declarations
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internal sign-offs (who approved what, when)
A short “what to do this week” action list (Dec 2025)
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Identify all Turkey→EU lanes and classify HS codes.
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Assign ownership: compliance lead + procurement lead + customs rep.
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Start AMM authorisation workflow.
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Send your supplier CBAM data-pack request.
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Add the “data failure clause” to new POs/contracts.
Exportora angle
If your sourcing is multi-supplier/multi-category, the highest ROI is standardizing supplier verification + documentation control + pre-shipment gates so CBAM data doesn’t become a last-minute scramble. (This is exactly where an on-ground Turkey partner adds measurable value.)
