Climate regulation and CBAM — a summary for SMEs

General information only. Assess whether you are in scope and what you must do against the legislation in force and with expert advice.

Türkiye's targets

Türkiye aims for net zero by 2053. Its latest NDC, announced at COP30, targets cutting emissions from the 695 million tonnes projected for 2030 to 643 million tonnes by 2035.¹

1. Climate Law and Emissions Trading System (ETS)

Climate Law No. 7552 was published in the Official Gazette on 9 July 2025 (No. 32951).²³

• ETS: covered installations must hold emission permits and surrender allowances matching verified emissions; links to voluntary carbon markets and a national crediting system are foreseen.³
• Pilot phase: a pilot period precedes full ETS operation, with administrative fines reduced by 80%.³
• MRV: monitoring, reporting and verification of emissions underpins the system.

Who is covered? The ETS targets large emitters above set thresholds; most SMEs will not be covered directly, but covered customers will ask for more energy, material and emissions data.

2. EU Carbon Border Adjustment Mechanism (CBAM)

CBAM entered its definitive regime on 1 January 2026.⁴

• Goods: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen.
• Who is liable? The EU importer. Importers above a 50-tonne annual threshold must become authorised CBAM declarants — a simplification that exempts small importers.⁴⁵
• Cost: declarants surrender certificates for embedded emissions, priced on EU ETS auctions (quarterly average in 2026, weekly from 2027).⁴

For Turkish SMEs: if you sell these goods — or intermediate goods containing them — into the EU, your buyer will ask for verifiable, product-level emissions data. Suppliers with data avoid costlier default values and gain an edge.

3. Sustainability reporting (TSRS)

Türkiye's Sustainability Reporting Standards (TSRS), issued by the Public Oversight Authority, are mandatory for certain companies. For periods beginning on or after 1 January 2025, companies exceeding two of the following for two consecutive periods are in scope:⁶⁷ total assets TRY 1 billion, net revenue TRY 2 billion, 500 employees.

Most SMEs are out of direct scope — but reporting companies ask suppliers for value-chain (Scope 3) data.

Where to start

1. Log energy and fuel use monthly — the basis for Scope 1 and 2.
2. Calculate your carbon footprint with a recognised method (e.g. GHG Protocol, ISO 14064-1).
3. Exporting to the EU? Check your products' CBAM status by customs code.
4. Ask your customers which data they need, in what format and when.
5. When ready, publish a sustainability report on your SME profile.