CBAM part 2: what default values would cost Türkiye's steel and aluminium exporters

Türkiye was the second-largest supplier of goods covered by the EU's carbon border adjustment mechanism (CBAM) between the end of 2023 and mid-2025, with about 12 per cent of imports by mass after Ukraine's 14 per cent, the Commission's December 2025 report found. Part 1 of this series set out the rules. Part 2 puts numbers on Türkiye's exposure: what it sold to the EU in 2025, and what an EU importer would owe per tonne in 2026 if it had no verified emissions data from the Turkish plant and had to use the Commission's default values.

What Türkiye sells

EU imports from Türkiye in 2025, according to Eurostat's Comext data, included 2.10 million tonnes of hot-rolled flat steel (CN heading 7208), worth €1.15 billion and 18.3 per cent of EU imports of that heading by mass, up from 1.41 million tonnes in 2024. They also included 0.80 million tonnes of welded tubes and pipes (7306), 44.6 per cent of the EU total; 0.58 million tonnes of reinforcing and other bars (7214), 25.1 per cent; and 0.47 million tonnes of wire rod (7213). In aluminium, Türkiye supplied 0.21 million tonnes of bars and profiles (7604), worth €955 million and 54.3 per cent of EU imports by mass, and 0.22 million tonnes of plate and sheet (7606). Its 6.12 million tonnes of cement (2523), up from 4.43 million, were 43.0 per cent of the EU total.

The default arithmetic

Default values are set country by country in the Commission's default values workbook, which reflects Implementing Regulation (EU) 2026/1740. For 2026 they carry a 10 per cent mark-up. The importer then deducts a free allocation adjustment of 97.5 per cent of the product's benchmark, multiplied by a cross-sectoral correction factor that the Commission fixed at 100 per cent for 2026 to 2030. Where defaults are used, the benchmark is the one in Column B of the benchmarks workbook, which covers precursors, according to the Commission's Guidance No. 4. On our calculation, at the third-quarter certificate price of €82.32:

• Hot-rolled coil (7208 39 00): a Türkiye default of 2.428 tonnes of CO2 equivalent per tonne against a benchmark of 1.370 leaves 1.34 certificates, or about €110 a tonne, roughly 20 per cent of the €549 a tonne average 2025 import value of hot-rolled flat products.
• Rebar and wire rod (7214 20 00, 7213): a default of 2.310 against 1.364 leaves 1.21 certificates, about €100 a tonne, or 18 per cent of value.
• Welded tubes (7306 30 77): 2.244 against 1.491 leaves 1.01 certificates, about €84 a tonne, 11 per cent of value.
• Aluminium profiles (7604 29 90): 3.741 against 1.493 leaves 2.66 certificates, about €219 a tonne, 4.8 per cent of an average value of €4,530 a tonne.
• Aluminium sheet (7606): 2.714 against 1.485 leaves 1.54 certificates, about €127 a tonne.

Applied to 2025 volumes, the hot-rolled flat figure alone would come to roughly €231 million a year, and the bars and wire rod to about €105 million. These are illustrations: actual volumes, product mix and the quarterly price will differ, and verified installation data below the defaults would lower them.

Where Türkiye's defaults diverge

The workbook treats Turkish steel more leniently than the fallback. For bars and rods the Türkiye default of 2.310 compares with 3.996 for countries without their own table, and for hot-rolled flat 2.428 compares with 4.049. Aluminium runs the other way for profiles: the Türkiye default of 3.741 is above the fallback of 3.233, while for sheet it is 2.714 against 3.717. Both Turkish steel and aluminium defaults are tied to primary routes, the blast furnace (C) and electrolysis (K), so a producer whose own process emits less can lower its bill only with verified data.

Cement is the gap. The workbook shows a dash rather than a value for Turkish grey clinker and grey Portland cement, so the largest Turkish CBAM flow by mass cannot be priced from it, and we have not estimated it. By 2028 the mark-up rises to 30 per cent and the free allocation factor falls to 90 per cent, which on the same defaults would lift the rebar figure from 1.21 to 1.78 certificates a tonne, on our calculation. Part 3 turns to Kazakhstan.