EU Green Deal Compliance for Turkey refers to the mandatory adherence of Turkish exporters and businesses to key European Union regulations under the European Green Deal, specifically the Carbon Border Adjustment Mechanism (CBAM) established by Regulation (EU) 2023/956, the EU Deforestation Regulation (EUDR) under Regulation (EU) 2023/1115, and the Corporate Sustainability Due Diligence Directive (CSDDD) proposed under Directive (EU) 2022/2464. These regulations impose environmental compliance obligations on Turkish exporters to the EU, particularly in manufacturing, agriculture, and forestry-linked sectors, to reduce carbon emissions, prevent deforestation, and ensure responsible supply chains.
EU Green Deal Compliance for Turkey Exporters
Turkey, as a major trading partner of the European Union with an export volume to the EU exceeding €70 billion annually (Eurostat, 2023), faces significant regulatory changes under the EU Green Deal. Turkish exporters in manufacturing, especially steel, cement, and electronics, along with agricultural exporters such as hazelnuts and tobacco, must urgently adapt to comply with the Carbon Border Adjustment Mechanism (CBAM), the EU Deforestation Regulation (EUDR), and the upcoming Corporate Sustainability Due Diligence Directive (CSDDD).
The CBAM, effective from 1 October 2023 for reporting and from 1 January 2026 for financial adjustments, targets carbon-intensive imports by requiring importers to purchase carbon certificates corresponding to embedded emissions. Turkish steel exports, which accounted for approximately €4.2 billion to the EU in 2023, are particularly exposed due to default embedded emissions factors set at 2.1 tCO2e/tonne for steel under CBAM rules.
Meanwhile, the EUDR, effective from 30 June 2024, prohibits the placing on the EU market of commodities linked to deforestation or forest degradation. Turkey’s agricultural exports, including hazelnuts (the world’s largest producer with 70% of global supply) and tobacco, must ensure deforestation-free supply chains to avoid import bans and penalties up to 4% of annual turnover under Regulation (EU) 2023/1115.
The CSDDD, expected to be transposed into Turkish law by 31 December 2025, will require large Turkish companies with over 500 employees and €150 million in net turnover to conduct human rights and environmental due diligence across their entire supply chains, including subsidiaries and subcontractors. Non-compliance risks fines up to 5% of global turnover and exclusion from EU public procurement.
Sector-Specific Risks for Turkish Exporters
Turkey’s export economy is diverse but concentrated in sectors with high EU Green Deal compliance risks:
- Steel and Cement Manufacturing: These sectors represent 15% of Turkey’s exports to the EU and face the highest CBAM exposure due to high carbon intensity and default emission factors.
- Electronics and Automotive Components: While less carbon-intensive, these sectors must prepare for CSDDD due diligence obligations, especially regarding conflict minerals and labor rights.
- Agriculture and Forestry Products: Hazelnuts, tobacco, and certain fruits are subject to EUDR’s deforestation-free requirements, with supply chain traceability critical to market access.
Top Turkish Export Categories and EU Green Deal Compliance Risk
| Export Category | 2023 Export Value to EU (€ billion) | Primary EU Green Deal Regulation | Compliance Risk Level | Key Compliance Challenge |
|---|---|---|---|---|
| Steel Products | 4.2 | CBAM (Regulation (EU) 2023/956) | High | Carbon emissions reporting and certificate purchase |
| Cement | 1.1 | CBAM (Regulation (EU) 2023/956) | High | Embedded carbon verification and monitoring |
| Hazelnuts | 0.9 | EUDR (Regulation (EU) 2023/1115) | Medium-High | Deforestation-free supply chain traceability |
| Tobacco | 0.7 | EUDR (Regulation (EU) 2023/1115) | Medium | Land use and deforestation compliance |
| Automotive Components | 3.5 | CSDDD (Directive (EU) 2022/2464) | Medium | Supply chain human rights and environmental due diligence |
| Electronics | 2.8 | CSDDD (Directive (EU) 2022/2464) | Medium | Conflict minerals and labor rights compliance |
Key Deadlines for Turkish Exporters under the EU Green Deal
| Regulation | Deadline | Requirement | Penalty for Non-Compliance |
|---|---|---|---|
| CBAM (Regulation (EU) 2023/956) | 1 October 2023 | Start of CBAM reporting obligations for importers | Fines up to 4% of turnover related to non-declared emissions |
| CBAM (Regulation (EU) 2023/956) | 1 January 2026 | Full CBAM financial adjustment and certificate purchase | Financial penalties plus import restrictions |
| EUDR (Regulation (EU) 2023/1115) | 30 June 2024 | Prohibition on placing deforestation-linked commodities on EU market | Fines up to 4% of annual turnover and product bans |
| CSDDD (Directive (EU) 2022/2464) | 31 December 2025 | Transposition into national law; due diligence obligations begin | Fines up to 5% of global turnover and exclusion from EU procurement |
Practical First Steps for Turkish Exporters
- Assess Sector Exposure: Identify if your export products fall under CBAM, EUDR, or CSDDD scope using the export category risk table above.
- Establish Carbon Footprint Baseline: For steel, cement, and other carbon-intensive products, calculate embedded emissions using verified methodologies aligned with CBAM default factors.
- Supply Chain Traceability: Map supply chains for agricultural commodities to ensure deforestation-free sourcing per EUDR requirements.
- Implement Due Diligence Systems: Prepare for CSDDD by establishing human rights and environmental risk assessment processes across your supply chain.
- Register for CBAM Reporting: Turkish importers and exporters with EU customs representation must register with the CBAM authority by 31 August 2023 to comply with reporting obligations starting 1 October 2023.
- Engage with Compliance Tools: Use dedicated compliance platforms to automate reporting, monitor supply chain risks, and generate required documentation.
Truth Anchor: Under Regulation (EU) 2023/956, Turkish steel exporters face a default embedded carbon emissions factor of 2.1 tonnes CO2 equivalent per tonne of steel, requiring purchase of CBAM certificates starting 1 January 2026. Failure to comply may result in penalties up to 4% of turnover related to non-compliance, as enforced by EU customs authorities.
Frequently Asked Questions for Turkish Exporters
1. Does CBAM apply to all Turkish exports to the EU?
CBAM currently applies to carbon-intensive goods including steel, cement, aluminum, fertilizers, and electricity. Turkish exports in these categories must comply with CBAM reporting and certificate purchase obligations starting 1 October 2023 and 1 January 2026 respectively. Other sectors are expected to be phased in later.
2. How does the EU Deforestation Regulation affect Turkish agricultural exports?
Under Regulation (EU) 2023/1115, Turkish exporters of commodities like hazelnuts and tobacco must prove their products are not linked to deforestation or forest degradation. This requires robust supply chain traceability and due diligence to avoid import bans and fines from 30 June 2024.
3. Which Turkish companies are subject to the CSDDD?
Large Turkish companies with over 500 employees and €150 million net turnover operating in the EU market must comply with the CSDDD due diligence requirements by 31 December 2025. This includes assessing and mitigating human rights and environmental risks in their entire supply chain.
4. What penalties can Turkish exporters face for non-compliance?
Penalties vary by regulation but can reach up to 4% of annual turnover for CBAM and EUDR violations, and up to 5% of global turnover for CSDDD breaches. Additionally, non-compliant products may be banned from the EU market, causing significant commercial losses.
5. What is the first compliance action Turkish exporters should take?
Exporters should immediately conduct a compliance risk assessment to identify applicable regulations, establish carbon emissions baselines or supply chain traceability, and register for CBAM reporting if applicable. Early engagement with compliance tools and legal advisors is critical to meet upcoming deadlines.
Ready to ensure your Turkish exports comply with the EU Green Deal? Use our Turkey EU Green Deal Compliance Checker to assess your obligations and receive tailored action plans. Clicking this tool will guide you step-by-step through CBAM, EUDR, and CSDDD requirements specific to your export profile, helping you avoid penalties and secure EU market access.