CBAM already applies to steel and aluminium parts from Turkey when the CN code of the finished part is listed in Annex I of Regulation (EU) 2023/956, for example 7318 (screws, bolts, nuts, washers and similar articles), 7326 (other articles of iron or steel) or 7616 (other articles of aluminium). The proposed extension to 180 further downstream products from 1 January 2028 is a Commission proposal, not law, as of 30 October 2026.
Does CBAM apply to steel and aluminium parts from Turkey today?
CBAM entered its definitive phase on 1 January 2026. It applies by CN code, whatever the country of origin. The Commission names one group of exceptions: goods originating in Iceland, Liechtenstein and Norway (EU ETS participants) and in Switzerland (linked emissions trading system). Turkey is not on that list.
The customs union sets the duty on industrial goods and does not appear among those exceptions. The Commission also states that a tariff suspension has no effect on CBAM obligations. The duty side is covered in EU–Turkey customs union and machined parts.
An importer that brings in less than 50 tonnes of CBAM goods per year needs no authorisation and has no CBAM obligations. Above that, it must be an authorised CBAM declarant, and customs authorities do not allow import by anyone else.
Table 1. CBAM dates relevant to buyers, status as of 30 October 2026
| Date | Event | Status |
|---|---|---|
| 1 Jan 2026 | Definitive period starts | In force |
| 17 Dec 2025 | Commission proposes the downstream extension, COM(2025) 989 | Proposal |
| 1 Feb 2027 | Sale of CBAM certificates starts on the common central platform | Scheduled |
| 30 Sep 2027 | First annual declaration, for 2026 imports, with certificates surrendered | Scheduled |
| 1 Jan 2028 | Proposed start of the downstream extension | Proposed, not law |
Source: European Commission, CBAM Questions and Answers (15 October 2026), questions 1.1, 1.2 and 3.2; press release IP/25/3088.
Which CN codes are in scope now, and which are only proposed?
The finished good decides, not its material. The Commission's answer to question 4.30 is that a final good classified under a CN code listed in Annex I falls under CBAM, and its net mass counts toward the 50-tonne threshold. A turned or milled part is therefore in scope when customs classify it under a listed heading such as 7318 or 7326, and outside today's Annex I when it is classified as a part of a machine in chapters 84 to 87. Which heading applies is a classification decision for the importer and its customs broker, see HS codes for machined parts.
Table 2. Part-type CN codes in Annex I today and in the Commission proposal of 17 December 2025
| CN code and description | Annex I today | Commission proposal |
|---|---|---|
| 7307, tube or pipe fittings of iron or steel | Listed | Listed |
| 7318, screws, bolts, nuts, rivets, washers and similar articles of iron or steel | Listed | Listed |
| 7326, other articles of iron or steel | Listed | Listed |
| 7616, other articles of aluminium | Listed | Not amended |
| 8431 49, other parts of cranes and lifting machinery of headings 8426, 8429, 8430 | Not listed | Proposed |
| 8432 90 00, parts of soil preparation and cultivation machinery | Not listed | Proposed |
| 8708 40, gear boxes and parts, of motor vehicles of headings 8701 to 8705 | Not listed | Proposed |
| 8412 (cylinders), 8481 (valves), 8482 (bearings), 8483 (shafts, gears) | Not listed | Not in the list |
Source: Commission default values for the transitional period (22 December 2023), iron and steel and aluminium tables; COM(2025) 989 final, Annex I (Council document 16973/25 ADD 1). Several further codes are proposed with the qualifier "containing steel or aluminium", for example ex-8431 10 00 and ex-8419 90 85.
The proposal adds a table called "Combined metal products". It contains codes from chapters 73, 74, 83, 84, 85, 87, 90 and 94 and a few machine part headings. The Council and Parliament both want a different list. The Council's Presidency note applies criteria that add CN codes to the Commission's list and remove some. Parliament's committee report would expand the scope to 457 products. For a part that is not listed today, the final Annex I decides.
What is the status of the downstream extension to 2028?
The Commission published the proposal on 17 December 2025 with a start date of 1 January 2028. It lists 180 products with an average steel and aluminium content of 79%. Of these, 94% are industrial supply chain products, for example base metal mountings, cylinders, industrial radiators and machines for casting, and 6% are household goods. The Commission puts the selected goods at about 15% of the volume and about 53% of the value of the CBAM goods already in scope.
The file is still open as of 30 October 2026:
- The Council reached its general approach on 12 June 2026.
- Parliament decided its first-reading position on 15 September 2026 and referred the file back to its committee for negotiations with the Council (Legislative Observatory, procedure 2025/0419(COD)).
- No agreed text exists yet, so the product list, the start date and the rules for default values can all still change.
Who pays CBAM on parts imported from Turkey?
The importer pays. Where the importer is established in an EU Member State, it must hold authorised declarant status unless an indirect customs representative acts as declarant for the goods. Where the importer is not established in the EU, an indirect customs representative must act as declarant. A declarant may hand the technical submission to a service provider but stays legally responsible. Who is the importer in your case depends on the Incoterm and the customs set-up, see Incoterms 2020 for Turkey to EU shipments.
The cost is set by the number of certificates surrendered. For 2026 imports the declaration is due on 30 September 2027, and certificates are sold from 1 February 2027. The 2026 certificate price is the quarterly average of EU ETS auction clearing prices: EUR 75.36 for the first quarter, EUR 75.28 for the second and EUR 82.32 for the third, published on 5 October 2026. The obligation covers only the share of emissions not covered by free allowances under the EU ETS, which are phased out until 2034. Add it as a line to your landed cost model.
How are the embedded emissions of a machined part determined?
Under the rules in force, the emissions that count for a part such as a 7318 article come from the steel or aluminium it is made of. The Commission lists cutting, welding and finishing of iron, steel and aluminium products as outside the system boundaries (question 4.31). The proposal keeps this logic for the new downstream goods. The Commission's example is a car door from a third country, which would carry CBAM only for the steel plate used and not for fabricating or assembling it.
Four rules shape the number:
- For iron and steel, aluminium and hydrogen, only direct emissions are in scope (question 4.16).
- Emissions data must come from the installation that produced the steel or aluminium and be verified by an accredited verifier. Without verified data the importer uses default values (question 4.25 and the Commission Q&A of 17 December 2025).
- Default values carry a mark-up of 10% in 2026, 20% in 2027 and 30% in 2028 (Commission Q&A of 17 December 2025). The proposal sets no mark-up for the new downstream goods.
- If the precursor was produced in the EU, its embedded emissions count as zero in the calculation. The quantity used must still be reported (question 4.18).
The last rule makes the origin of the bar stock part of the compliance file. The data come from the producer of the metal, and the machining shop only holds the traceability.
What should buyers do before the 2028 decision?
- Classify every part number to an 8-digit CN code and compare it with Annex I. Check the headings in Table 2 first.
- Add up the net mass of in-scope parts imported per importer and per calendar year, and compare the total with 50 tonnes.
- If you may exceed it, apply for authorised declarant status through the CBAM Registry. The national competent authority of your Member State of establishment decides.
- Put the steel or aluminium grade, the mill and the country of production of the bar on the RFQ and the bill of materials, and ask which installation produced it. CNC turning and milling quotes depend on the same data.
- Re-check the list when Council and Parliament agree a text, since a code that is outside Annex I today can be added.
Frequently asked questions
- Does CBAM apply to machined parts from Turkey?
- Only if the CN code of the finished part is listed in Annex I of Regulation (EU) 2023/956, for example 7318, 7326 or 7616. A part classified as a machine part in chapters 84 to 87 is not in today's Annex I, but several such codes are in the Commission's 2025 proposal.
- Does the EU–Turkey customs union exempt parts from CBAM?
- No exemption is listed. The Commission names only goods originating in Iceland, Liechtenstein, Norway and Switzerland as exceptions, and states that a tariff suspension has no effect on CBAM obligations.
- When would downstream products enter CBAM?
- The Commission proposed 1 January 2028 for 180 steel and aluminium-intensive products. As of 30 October 2026 this is not law: the Council agreed its position on 12 June 2026, Parliament adopted its position on 15 September 2026, and negotiations follow.
- What is the 50-tonne threshold?
- Importers that bring in less than 50 tonnes of CBAM goods per year are exempt from CBAM obligations and need no authorisation. Above it, the importer must be an authorised CBAM declarant.
- Who pays CBAM, the Turkish supplier or the EU buyer?
- The obligation sits with the importer, or with an indirect customs representative acting as authorised declarant if the importer is not established in the EU. The exporter has no CBAM liability, but the importer needs emissions data from the steel or aluminium producer.
Sources
- European Commission, CBAM Questions and Answers (last updated 15 October 2026)
- European Commission, press release IP/25/3088, 17 December 2025
- European Commission, Q&A on the CBAM proposal QANDA/25/3089, 17 December 2025
- COM(2025) 989 final, Annexes 1 to 3, as transmitted to the Council (ST 16973/25 ADD 1)
- European Commission, Default values for the transitional period of the CBAM (22 December 2023), CN code tables
- Council of the EU, general approach of 12 June 2026 (ST 10423/26)
- Council of the EU, Presidency note on the general approach (ST 10208/26, 9 June 2026)
- European Parliament, Legislative Observatory, procedure 2025/0419(COD)
- EPRS, Extension of CBAM scope to downstream goods and anti-circumvention measures (September 2026)
- European Commission, Price of CBAM certificates 2026
- European Commission, CBAM simplifications officially published (20 October 2025)
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