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Turkey's Emissions Trading System Has Been Published. So What Happens Now?

10/21/2026

The Turkish Emissions Trading System Regulation was published on 27 August 2026.
Approximately one month has passed since then.

In the first phase, we all tried to understand the regulation, Annex-1, and its scope. However, I believe we now need to focus on a more important question:
"How will our companies prepare for this new era?"

Because this issue is not merely about environmental legislation.
We are talking about a new compliance process that spans from production to energy, from foreign trade to customs, and from exports to financial costs.

According to data from the February 2026 CBAM presentation by the Export General Directorate of the Republic of Türkiye Ministry of Trade, Türkiye's exports to the EU in CBAM-covered products reached USD 11.8 billion in 2025. Therefore, this topic is no longer just about "carbon." It is a matter of foreign trade and competitiveness.

I believe a new area of practice is emerging particularly for customs brokers:
HS Code + CBAM + ETS + NACE + PRODCOM + Emissions

Customs brokerage will no longer be limited to the correct preparation of declarations; providing clients with early warnings and pre-compliance perspectives based on product, HS code, and export data will become increasingly important.

For exporting companies, the questions that need to be asked today are quite clear:
🔹 Are our products within the scope of CBAM?
🔹 Is our production facility within the scope of the Turkish ETS?
🔹 Are our actual emissions data ready?
🔹 Are we able to maintain our energy and production data on a regular basis?
🔹 Is our HS Code–NACE–PRODCOM linkage correct?
🔹 Can we already see the carbon cost of our exports to the EU today?

The regulation was published on 27 August. Now it is no longer enough to simply read the regulation — it must be integrated into business operations. For this reason, in the assessment I have prepared, I have tried to address where customs brokers and exporting industrialists can begin one month after the regulation's publication.
I believe the contribution of everyone working in this field is important — first and foremost our public institutions, professional associations, exporters, and customs brokers.