CBAM and Turkey

Turkey stands among the European Union's largest suppliers of iron and steel, and Turkish cement, aluminium and fertilisers travel the same routes into the single market. That position makes Turkey one of the countries most directly touched by the EU's carbon charge at the border — the Carbon Border Adjustment Mechanism (CBAM), which prices the emissions built into imported goods the same way EU factories already pay for theirs now that the definitive phase is live — and one of the countries best placed to turn the mechanism into a commercial advantage.

The Customs Union between the EU and Turkey keeps industrial goods moving free of customs duties, and CBAM operates alongside it as a separate carbon instrument. The importer of record for CBAM goods holds authorised declarant status, and that status lives in an EU Member State. Turkish exporters who control that import position themselves set their own terms at the border.

What the definitive phase requires

Six sectors fall within scope today: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Article 25 of the CBAM Regulation provides that customs authorities allow the importation of CBAM goods by an authorised CBAM declarant, and that declarant purchases its certificates from the competent authority in the EU Member State where it is established. The status applies where cumulative annual imports exceed 50 tonnes of CBAM goods, with electricity and hydrogen counting from the first unit.

The first annual declaration covers calendar year 2026 and falls due by 30 September 2027. Certificate sales open on 1 February 2027 through the common central platform. Since 1 January 2026, EU import declarations carry a CBAM code in the additional reference field.

Turkey's own carbon price strengthens the case

Turkey adopted a national Climate Law in 2025 that establishes a Turkish emissions trading system. The CBAM Regulation allows a carbon price effectively paid in the country of production to be taken into account at the EU border, which means verified Turkish emissions data and domestic carbon costs translate directly into a lower certificate bill. Producers who organise their data pipeline now — installation-level figures, verification, the link to the EU declaration — hold a head start that competitors will spend years assembling.

What Turkish exporters gain from a Dutch entity

A Turkish mill selling through European buyers depends on those buyers holding authorised declarant status and passing carbon costs back through price. A producer importing through its own Dutch BV sets the terms: it purchases certificates directly at the EU carbon price, applies its own verified emissions figures and domestic carbon costs, and invoices European customers as a European supplier under EU VAT rules.

On steel and cement volumes the Article 23 licence carries real weight. Import VAT moves to the periodic VAT return rather than falling due at customs clearance, which releases working capital on every consignment arriving in Rotterdam. The Netherlands also hosts one of the largest Turkish business communities in Europe, which makes the practical side — banking, advisors, logistics partners — well-trodden ground.

Structuring the ownership chain

The Netherlands and Turkey maintain a long-standing double tax treaty, and the Dutch participation exemption keeps dividends and capital gains from qualifying subsidiaries flowing to the parent free of Dutch corporate tax. We map the shareholding chain before the notarial deed is drafted, so profit repatriation and the wider group structure are correct from day one.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce (KvK). Incorporation runs remotely by power of attorney, with the parent company holding the shares. After registration the BV obtains its VAT number and EORI number and applies for the Article 23 licence and the CBAM authorisation. The same entity then serves as your base for European contracts and the wider compliance agenda mapped on EU market entry.

Further reading: an EU entity for CBAM and fiscal representation and Article 23. Starting the entity itself: start from Turkey.

Frequently asked questions

Does the EU-Turkey Customs Union exempt Turkish goods from CBAM?

The Customs Union removes customs duties on industrial goods, and CBAM operates alongside it as a separate carbon instrument. Iron and steel, aluminium, cement and fertilisers from Turkey fall within CBAM scope, and importation runs through an authorised CBAM declarant established in the EU.

How does Turkey's own climate legislation interact with CBAM?

Turkey adopted a national Climate Law in 2025 that establishes a Turkish emissions trading system. Where a carbon price has effectively been paid in the country of production, the CBAM Regulation allows that amount to be taken into account, which makes verified Turkish emissions data increasingly valuable at the EU border.

Can a Turkish company import CBAM goods into the EU directly?

Importation of CBAM goods is reserved for authorised CBAM declarants, and the declarant purchases certificates from the competent authority in its EU Member State of establishment. A Turkish company therefore either sells to an established EU buyer holding that status, or incorporates its own EU entity such as a Dutch BV.

Does the Netherlands have a tax treaty with Turkey?

Yes. The Netherlands and Turkey maintain a long-standing double tax treaty, and the Netherlands hosts one of the largest Turkish business communities in Europe, which makes the practical side of running a Dutch entity from Turkey well-trodden ground.