Navigating The 2026 Carbon Frontier: Preparing Turkish Industry For Simplified CBAM Compliance

1.   Introduction

Following the European Union’s (“EU”) launch of the Green Deal in 2019, the transition into a green economy has been framed not only as an environmental imperative but also as a new growth strategy. The Green Deal seeks to combine the reduction of emissions with the preservation of economic competitiveness. To translate these objectives into practice, the EU has relied on and expanded market-based instruments such as the Emissions Trading System (“ETS”) and the Carbon Border Adjustment Mechanism (“CBAM”), established by Regulation (EU) 2023/956 (the “CBAM Regulation”), which together aim to price carbon, encourage the reduction of emissions and address the risk of carbon leakage. With the initial phase of the CBAM transitional period ending on December 31, 2025, the definitive regime took effect on January 1, 2026. Ahead of that changeover, the EU adopted Regulation (EU) 2025/2083, in force since October 20, 2025, which introduced significant simplifications to the