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EU ETS explained: what it means for non-EU and Turkish exporters

Blog

EU ETS explained: what it means for non-EU and Turkish exporters

EU ETSemissions tradingETS2free allocationCBAMTürkiye ETSEuropean Green Dealmaritime ETS

Publish: 10 Nov 26Reading Time: 7 Min

The EU Emissions Trading System (EU ETS) is the EU's cap-and-trade carbon market: power and heat producers, industrial installations, aviation and, since 2024, maritime transport must hold and surrender allowances for their emissions, under a cap tightened to cut emissions 62% by 2030 compared with 2005. A company producing outside the EU has no EU ETS obligation for its own plant. Since 1 January 2026, however, the EU ETS price reaches its goods through CBAM, the carbon charge on imported iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.

Updated 10 November 2026.

What is the EU ETS and how does cap and trade work?

Set up in 2005, the EU ETS is the world's first international emissions trading system. It operates in all EU countries plus Iceland, Liechtenstein and Norway, is linked to the Swiss ETS, and covers about 40% of the EU's total greenhouse gas emissions.

The mechanism has three parts:

  1. Cap. A ceiling on the total emissions of covered installations and operators. The cap falls each year; after the 2023 revision it is set to bring emissions down 62% by 2030 compared with 2005.
  2. Allowances. Each covered company must surrender enough allowances to cover its verified emissions. Most allowances are sold at auction; companies that emit less than they hold can sell the surplus, and those that emit more must buy.
  3. Free allocation. Some allowances are given free to industry at risk of carbon leakage, meaning production moving to countries with laxer climate rules. Free allocation is calculated from benchmarks and is shrinking.

Which sectors does the EU ETS cover?

  • Electricity and heat generation.
  • Industrial manufacturing, including the energy-intensive sectors that CBAM now mirrors at the border.
  • Aviation. Free allocation for aviation was removed as of 2026.
  • Maritime transport, since 2024. Cargo and passenger ships of 5,000 gross tonnage and above are covered for 100% of emissions on voyages between EU ports and while in EU ports, and 50% of emissions on voyages between an EU and a non-EU port. Shipping companies surrender allowances for 40% of their 2024 emissions, 70% of 2025 emissions and 100% from 2026 emissions onwards.
  • ETS2 (separate system). A second system covers CO2 from fuel combustion in buildings, road transport and additional sectors, mainly small industry. Monitoring and reporting began in 2025; the Commission states that ETS2 becomes fully operational in 2028.

For a Turkish company, shipping is the part that can create a direct EU ETS obligation: the Commission describes the maritime ETS as flag-neutral and route-based, so coverage follows the voyage, not where the operator is based. For manufacturers, the exposure comes through CBAM.

How does free allocation end, and why does that matter outside the EU?

Free allocation exists to protect EU producers from carbon leakage. CBAM replaces that protection in its sectors: as free allowances for iron and steel, aluminium, cement, fertilisers and hydrogen are phased out between 2026 and 2034, CBAM charges importers for a growing share of embedded emissions. In 2026 producers in CBAM sectors keep 97.5% of their benchmark-based free allocation; under current law it reaches zero in 2034.

That timeline may move. On 17 July 2026 the Commission proposed an EU ETS revision that would reintroduce 15% of the phased-out free allocation in CBAM sectors from 2028, stretching the phase-out to 2038. It is a proposal under negotiation, not law.

How does the EU ETS price feed into CBAM?

CBAM is built as the mirror of the EU ETS, and three links connect them:

  1. Price. CBAM certificates are priced from EU ETS auctions. For 2026 the Commission publishes a quarterly average: €75.36 per tonne for Q1, €75.28 for Q2 and €82.32 for Q3. From 2027 the price is calculated weekly.
  2. Free allocation adjustment. The certificates an importer owes are reduced by the free allocation EU producers of the same goods still receive, so CBAM rises as ETS free allocation falls.
  3. Carbon price paid abroad. Article 9 of the CBAM Regulation lets the declarant reduce certificates for a carbon price effectively paid in the country of production, under detailed rules to be set by a Commission implementing act. From 2027 the Commission may also publish default carbon prices for third countries with carbon pricing.

The difference between the two systems, item by item: CBAM vs EU ETS: what is the difference. The CBAM basics in one page: What is CBAM?

What does the EU ETS mean for a Turkish exporter?

  1. No EU ETS permit for your plant, but your data sets your customer's cost. The EU importer owes CBAM certificates for your goods. If you supply verified actual emissions, the importer can use them; if not, it uses EU default values with a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. What a typical request asks for: Answering a CBAM supplier data request.
  2. The first bill is due in 2027. Certificates for 2026 imports go on sale on 1 February 2027, and the first declaration and surrender are due by 30 September 2027.
  3. Türkiye's ETS is a separate obligation. It applies to the installation in Türkiye, whatever its export market (see the table below).
  4. A Türkiye carbon price may reduce CBAM, but only under the EU rules. Whether a cost paid under Türkiye's ETS counts as a carbon price effectively paid depends on the Article 9 implementing rules, not on the existence of the system. See CBAM and carbon prices paid outside the EU.

EU ETS vs CBAM vs Türkiye ETS

Comparison of who is obliged, the instrument and status under the EU ETS, CBAM and Türkiye's ETS
EU ETS CBAM Türkiye ETS
Legal basis Directive 2003/87/EC, as revised Regulation (EU) 2023/956, amended by Regulation (EU) 2025/2083 Climate Law No. 7552 (Resmî Gazete, 9 July 2025, No. 32951), Article 9; Türkiye ETS Regulation (Resmî Gazete, 27 August 2026, No. 33353)
Who is obliged Installations in the EU, Iceland, Liechtenstein and Norway; aircraft and ship operators for covered flights and voyages EU importers (authorised CBAM declarants) above 50 tonnes a year; electricity and hydrogen always Category B (over 50,000 up to 500,000 t CO2e a year) and Category C (over 500,000 t CO2e) installations in Türkiye
What is priced Emissions of covered installations and operators Emissions embedded in imported CBAM goods Emissions of covered installations
Instrument Tradable allowances CBAM certificates, not tradable or transferable Allowances, traded on a market operated by EPİAŞ
Free allocation Yes, phased out in CBAM sectors 2026–2034 Mirrored through the free allocation adjustment Yes, set by the Carbon Market Board using benchmarks
Annual cycle Verified emissions report and surrender each year Declaration and surrender by 30 September of the following year Verified emissions report by 30 April; surrender by the last business day of November
Status In force since 2005 Definitive period since 1 January 2026 Starts with a pilot period whose scope and duration the Carbon Market Board sets

How does the EU ETS relate to the European Green Deal?

The European Climate Law sets the binding targets behind the European Green Deal: a net greenhouse gas reduction of at least 55% by 2030 and 90% by 2040, both against 1990, and climate neutrality by 2050. The 2040 target was added by Regulation (EU) 2026/667. The EU ETS is the EU's main carbon-pricing tool for reaching them, and the Commission's July 2026 revision proposal is designed to align the system with the 2040 target.

What we see in practice

For Turkish industrial groups, the EU ETS mostly arrives as CBAM data work. With Tosyalı Holding, that meant embedded emissions quantified from production-level data and quarterly submission packages prepared for each of about 20 production entities, with every calculation technically reviewed before it reached facility teams. How we run that cycle: CBAM accounting and reporting.

Frequently asked questions

Does the EU ETS apply to companies outside the EU?

Not to their plants. The EU ETS covers installations in the EU, Iceland, Liechtenstein and Norway. Non-EU shipping operators are covered for voyages to, from and between EU ports, and non-EU manufacturers feel the ETS price through CBAM on their exports.

Is Türkiye part of the EU ETS?

No. Türkiye has its own emissions trading system, based on Climate Law No. 7552 and the Türkiye ETS Regulation published on 27 August 2026. It covers Category B and C installations and starts with a pilot period.

When does ETS2 start?

Emissions monitoring and reporting for ETS2 started in 2025. The Commission states that the system becomes fully operational in 2028, covering fuel combustion in buildings, road transport and additional sectors.

Is a CBAM certificate the same as an EU ETS allowance?

No. CBAM certificates are priced from EU ETS auction prices, but they can only be used by the authorised declarant that bought them, cannot be traded or transferred, and are either surrendered, repurchased or cancelled.

Will EU ETS free allocation for steel and cement end in 2034?

Under current law, yes: free allocation in CBAM sectors falls from 2026 and reaches zero in 2034. A Commission proposal of 17 July 2026 would stretch this to 2038; it is still under negotiation.

Book a scoping call and get a carbon-price exposure map for your sites: which installations fall into Türkiye ETS Category B or C, which CN codes reach EU customers under CBAM, and where verified data would replace default values → CBAM accounting and reporting.

Sources

  • European Commission – About the EU ETS – https://climate.ec.europa.eu/areas-action/carbon-markets/about-eu-ets_en (checked 2026-11-10)
  • European Commission – EU ETS emissions cap – https://climate.ec.europa.eu/areas-action/carbon-markets/eu-emissions-trading-system-eu-ets/eu-ets-emissions-cap_en (checked 2026-11-10)
  • European Commission – FAQ: maritime transport in the EU ETS – https://climate.ec.europa.eu/areas-action/transport-decarbonisation/reducing-emissions-shipping-sector/faq-maritime-transport-eu-emissions-trading-system-ets_en (checked 2026-11-10)
  • European Commission – ETS2: buildings, road transport and additional sectors (updated 2 September 2026) – https://climate.ec.europa.eu/areas-action/carbon-markets/ets2-buildings-road-transport-and-additional-sectors_en (checked 2026-11-10)
  • European Commission – European Climate Law – https://climate.ec.europa.eu/areas-action/european-climate-law_en (checked 2026-11-10)
  • European Commission – EU Emissions Trading System (July 2026 revision proposal) – https://climate.ec.europa.eu/eu-action/carbon-markets/eu-emissions-trading-system-eu-ets_en (checked 2026-11-10)
  • European Commission – CBAM Questions and Answers (15 October 2026) – https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en (checked 2026-11-10)
  • European Commission – Price of CBAM certificates – https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en (checked 2026-11-10)
  • European Commission – Officially published simplifications to CBAM, 20 October 2025 – https://taxation-customs.ec.europa.eu/news/officially-published-simplifications-carbon-border-adjustment-mechanism-cbam-2025-10-20_en (checked 2026-11-10)
  • ICAP – EU Commission publishes EU ETS review proposal (17 July 2026) – https://icapcarbonaction.com/en/news/eu-commission-publishes-eu-ets-review-proposal (checked 2026-11-10)
  • ICAP – EU CBAM enters compliance phase (19 January 2026) – https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead (checked 2026-11-10)
  • Resmî Gazete – İklim Kanunu No. 7552 (9 July 2025, No. 32951) – https://www.resmigazete.gov.tr/eskiler/2025/07/20250709-1.htm (checked 2026-11-10)
  • Resmî Gazete – Türkiye Emisyon Ticaret Sistemi Yönetmeliği (27 August 2026, No. 33353) – https://www.resmigazete.gov.tr/eskiler/2026/08/20260827-7.htm (checked 2026-11-10)
  • Resmî Gazete – Türkiye Emisyon Ticaret Sistemi Piyasasının İşletilmesine İlişkin Yönetmelik (21 October 2026, No. 33407) – https://www.resmigazete.gov.tr/eskiler/2026/10/20261021.htm (checked 2026-10-21)

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