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Türkiye's Tenuous Transition & CBAM's Carbon Conundrum

Thursday, May 14, 2026

Synopsis: Based on the Istanbul Policy Center's "Decarbonization of the Turkish Steel Industry" project information session held in May 2026, industry leaders, policymakers, & researchers converged to examine how the European Union's Carbon Border Adjustment Mechanism, emerging green steel classifications, & acute financing pressures are collectively reshaping Türkiye's steel sector transformation agenda.

Türkiye's Tenuous Transition & CBAM's Carbon Conundrum

Decarbonisation's Daunting Dialectic & the Decade-Long Deliberation The Istanbul Policy Center's "Decarbonization of the Turkish Steel Industry" project, now entering its fourth year since its June 2022 inception, convened a landmark information session in May 2026 that brought together an unusually broad coalition of stakeholders, industry executives, public institution representatives, academic researchers, & participants from steel-consuming sectors, to take collective stock of where Türkiye's steel decarbonisation journey stands & where it must urgently accelerate. The meeting, formally titled the "Information Session on the Turkey Steel Industry Network Working Program," served as both a diagnostic forum & a strategic convening, surfacing the full complexity of a transformation that extends far beyond the factory floor into the realms of energy policy, logistics, public finance, & international trade regulation. Project Coordinator Dursun Baş of the Istanbul Policy Center opened proceedings by contextualizing the project's evolution, noting that while its original focus was narrowly trained on crude steel producers, the initiative has progressively expanded its ambit to encompass public institutions, industry associations, financial organizations, & the full spectrum of steel-consuming sectors. Baş articulated a systemic insight that set the tone for the entire session: the decarbonisation of the steel sector is emphatically not the sole responsibility of crude steel producers, but a shared obligation that must be addressed in concert the energy sector, natural gas supply chains, logistics networks, financing institutions, public policy architects, & the downstream industries that consume steel. He further highlighted a dimension often overlooked in mainstream decarbonisation discourse, namely that the Turkish steel industry's emissions burden does not originate exclusively from integrated blast furnace mills, but that electric arc furnace-based plants also generate substantial indirect emissions attributable to their intensive electricity consumption, a reality that complicates the conventional narrative positioning electric arc furnace technology as an unambiguously green alternative. Emissions arising from natural gas usage across steelmaking operations, transportation networks, & logistics chains were also identified as significant contributors to the sector's overall carbon footprint, underscoring the need for a genuinely systemic rather than facility-level approach to decarbonisation. The Istanbul Policy Center is now preparing to launch the fifth phase of the project, covering March 2026 to March 2027, which will organize technical workshops, panels, & a dedicated digital platform consolidating decarbonisation resources, publications, podcasts, & presentations, all timed to maximize impact ahead of the Conference of the Parties 31 climate summit.

Verified Values, Vanishing Verities & CBAM's Verification Vanguard The second major theme to emerge from the information session was the profound shift in the evidentiary basis upon which steel companies' environmental performance will henceforth be assessed, a shift precipitated by the European Union's Carbon Border Adjustment Mechanism & its requirement for verified, third-party-audited emissions data rather than self-reported corporate indicators. Muammer Bilgiç, executive board member of Bilecik Demir A.Ş., articulated this transformation the precision of someone who has navigated both the old & new regulatory regimes: "In the past, companies were evaluated based on indicators they defined themselves, whereas verified emission data will now serve as the basis." This statement encapsulates a regulatory revolution that is quietly but fundamentally altering the competitive landscape of the global steel trade, replacing the self-certification culture that characterized earlier sustainability reporting the rigorous, externally audited verification protocols mandated by the Carbon Border Adjustment Mechanism. Bilgiç stressed that under this new paradigm, companies are considered green only to the precise extent of their verified emissions values, a formulation that strips away the reputational latitude previously enjoyed by companies that could present favorable self-defined metrics. He also challenged a widely held assumption about the relative advantage of electric arc furnace-based facilities under the Carbon Border Adjustment Mechanism, noting that the mechanism evaluates arc furnace-based facilities & basic oxygen furnace-based facilities within their own respective categories rather than applying a single cross-technology comparison, a design feature that may neutralize some of the competitive advantage that electric arc furnace producers had anticipated. Bilgiç further emphasized that sustainability efforts in the steel sector can no longer remain siloed the environmental department but must be integrated across procurement, production, finance, & management processes, a call for organizational transformation that mirrors the systemic thinking articulated by the project coordinator. The Carbon Border Adjustment Mechanism's benchmark & default emission values, once announced by the European Union, mark the beginning of what Bilgiç characterized as a new era, one in which the opacity of self-reported metrics gives way to the transparency of verified data, & in which the consequences of emissions performance are directly monetized through trade costs.

Trade Nationalism's Tenacious Tide & Financing's Formidable Frontier The geopolitical & financial dimensions of Türkiye's steel decarbonisation challenge were brought into sharp relief by Hasan Akbulut, representative of the Turkish Steel Producers' Association, who situated the sector's transformation within a rapidly evolving global trade environment characterized by what he described as the progressive replacement of globalization by trade nationalism. Akbulut observed that pressure on the sector has intensified during the European Union's emissions trading system revision process, & he was direct about the structural asymmetry that defines the current situation: "This transformation is being carried out in the EU substantial state support. Without resolving the financing issue, it will not be easy to move this process forward." This observation cuts to the heart of a fundamental inequity in the global green transition, namely that European steel producers undertaking decarbonisation investments benefit from substantial public subsidies, state aid mechanisms, & concessional financing instruments that are simply not available at comparable scale to Turkish producers operating in a different fiscal & regulatory environment. Akbulut acknowledged that the Turkish steel industry continues to invest in energy efficiency, material efficiency, & renewable energy integration, but noted that companies are compelled to prioritize among these investments due to the prohibitive scale of capital requirements relative to available financing. The Turkish steel industry is one of the world's most significant, producing approximately 35 to 40 million metric tons of crude steel annually, making it the eighth-largest steel-producing nation globally & the second-largest in Europe, a scale that amplifies both the challenge & the strategic importance of its decarbonisation trajectory. Akbulut also noted that the European Union is actively developing new mechanisms to protect its own steel industry from lower-cost imports, a development that creates a dual pressure on Turkish producers: they must simultaneously decarbonise to meet Carbon Border Adjustment Mechanism requirements & compete against European producers who benefit from state support for that very decarbonisation. He emphasized that despite these structural headwinds, Türkiye must not lose access to the European Union market, which absorbs a substantial share of Turkish steel exports & represents a commercial relationship of existential importance to the sector's economic viability.

CBAM's Calculation Conundrums & the Verification Vexation The operational complexities of implementing the Carbon Border Adjustment Mechanism in practice were examined in granular detail by Barış Bora, environmental manager at İçdaş, one of Turkey's major integrated steel producers, who identified a cascade of practical uncertainties that are already complicating trade flows & investment planning. Bora highlighted a fundamental temporal asymmetry in the Carbon Border Adjustment Mechanism's cost recognition timeline: the costs arising from sales to the European Union in 2026 will only become quantifiable in 2027, creating a significant planning horizon gap that forces producers & importers to make commercial decisions under conditions of material financial uncertainty. This lag between cost incurrence & cost clarity is not merely an accounting inconvenience but a genuine commercial risk that affects pricing strategies, contract structures, & capital allocation decisions across the Turkish steel supply chain. Bora also identified methodological uncertainties in the European Union's published Carbon Border Adjustment Mechanism verification frameworks, noting that differences may emerge between the verification systems currently operating in Türkiye & the practices mandated by the European Union, creating a potential compliance gap that could expose Turkish exporters to unexpected cost liabilities. The complications are further compounded by the role of imported raw materials in Turkish steel production, particularly the use of Russia-origin billet, which creates additional layers of complexity in Carbon Border Adjustment Mechanism calculations given the European Union's sanctions regime against Russia. Bora noted that under the current system, producers utilizing certain imported inputs may in some cases effectively appear as though they are using Russian steel, even when the actual production chain is more complex, a classification anomaly that could result in inflated carbon cost assessments that do not accurately reflect the true emissions profile of the finished product. These verification & methodology challenges underscore the urgent need for bilateral regulatory dialogue between Türkiye & the European Union to establish harmonized verification frameworks that provide Turkish producers the clarity & predictability needed to make long-term decarbonisation investment decisions.

Green Transition's Geopolitical Gravitas & Diplomatic Deliberations The diplomatic & geopolitical dimensions of the green steel transition were addressed by Bahar Güçlü, deputy permanent representative at the Permanent Delegation of Turkey to the European Union, who offered a perspective shaped by direct engagement the European Union's policy machinery & an acute awareness of the strategic currents reshaping the global trade environment. Güçlü characterized the current moment as the dawn of a new era of trade wars centered on technology & the green transition, a framing that positions decarbonisation not merely as an environmental imperative but as a competitive battleground on which industrial supremacy will be contested. She noted that the European Union's ambitions extend beyond protecting its own industrial base to actively supporting low-emission manufacturing, a dual objective that creates a complex dynamic: "While the EU protects its own industry, it is also placing green transition pressure on its producers." Güçlü informed the session that efforts to expand the scope of the Carbon Border Adjustment Mechanism within the European Union are ongoing, the inclusion of sectors such as automotive & white goods in the system under active discussion, a development that would significantly amplify the mechanism's impact on Turkish manufacturing given the country's substantial exports in both sectors. She highlighted the European Union's multi-pronged strategy for stimulating demand for green steel, encompassing public procurement mandates, dedicated funding mechanisms, & new regulatory instruments, & drew an explicit policy lesson for Türkiye: the country should establish analogous domestic mechanisms to stimulate demand for green products in its own market, creating the demand-side pull that would complement the supply-side push of decarbonisation investment. This call for domestic green procurement policy reflects a sophisticated understanding that the transition to green steel requires not only the technological capability to produce lower-carbon material but also the market architecture to ensure that lower-carbon material commands a price premium sufficient to justify the investment required to produce it.

Classification Criteria's Contentious Calculus & the Greenwashing Gambit The second part of the information session featured a presentation by Daniel Pietikäinen, steel policy manager at Bellona Europa, the Belgium-based environmental non-governmental organization, who delivered a forensic examination of the European Union's emerging low-emission steel classification system & its potentially counterintuitive implications for the global steel industry's decarbonisation trajectory. Pietikäinen explained that the European Union's classification framework covers a broad range of steel products, including hot rolled coil, wire rod, galvanized steel, stainless steel, & electrical steel, & that the Industrial Accelerator Act is intended to create "lead markets" for low-carbon steel & other industrial products. The Ecodesign for Sustainable Products Regulation will establish the definition of low-carbon steel for intermediate products, while the Construction Products Regulation will subsequently define low-carbon steel specifically for construction applications, particularly long products. The draft classification system applies a sliding-scale approach based on scrap content, Class A & Class B corresponding to categories eligible for green public procurement, a framework that Pietikäinen described as relatively lenient in its current form. The methodology incorporates Scope 1, Scope 2, & Scope 3 emissions data, drawing on European Union Emissions Trading System data for European Union-based facilities, Carbon Border Adjustment Mechanism default values for non-European Union plants, & modeled life-cycle emissions for production outside the European Union. Pietikäinen argued that the methodology's reliance on global production data rather than European Union market-specific data, combined its application of inflated Carbon Border Adjustment Mechanism default values, has the effect of shifting a disproportionately large number of plants & products into greener classification categories than their actual emissions performance would warrant. He characterized this as a framework that is overly permissive, one that risks sending misleading signals to the global steel industry about what genuine low-carbon production actually requires.

Emission Thresholds' Elastic Elasticity & the Permissive Paradox The specific numerical parameters of the European Union's proposed green steel classification system were examined by Pietikäinen in a level of detail that revealed the practical implications of what might otherwise appear to be abstract regulatory architecture. For wire rod products, Class A, the highest green classification eligible for preferential public procurement treatment, covers emissions ranging from zero to 0.87 metric tons of CO₂ per metric ton of steel, while Class B ranges from 0.87 metric tons to 2.43 metric tons of CO₂ per metric ton. For hot rolled coil, the proposed thresholds are similarly calibrated, meaning that under the current draft framework, nearly all electric arc furnace-based products & a significant proportion of European Union blast furnace-basic oxygen furnace products would qualify under green public procurement criteria. This is a finding of considerable significance: it implies that the European Union's green steel classification system, as currently drafted, would confer a "green" label on a substantial portion of existing European steel production without requiring any material change in production methods or emissions performance. The European Union has set a target of 25% of the steel used in public procurement consisting of low-emission steel by 2030, a target that Pietikäinen suggested may be achievable under the current draft thresholds without any meaningful decarbonisation effort by European producers, given how broadly the classification criteria are drawn. He noted that the classification methodology prepared by the European Commission using global production data & Carbon Border Adjustment Mechanism default values has sparked significant debate within the industry & among environmental advocates, precisely because it appears to prioritize the commercial interests of existing European producers over the environmental integrity of the green steel label. The risk, as Pietikäinen articulated it, is that a classification system designed to accelerate decarbonisation may instead entrench the status quo by allowing high-emission facilities to claim green credentials they have not genuinely earned, undermining the market signals needed to drive genuine investment in lower-carbon production technologies.

Systemic Sovereignty, Structural Solidarity & Türkiye's Strategic Sine Qua Non The cumulative weight of the information session's deliberations points toward a set of structural imperatives that Türkiye's steel sector must address if it is to navigate the Carbon Border Adjustment Mechanism era successfully & maintain its competitive position in European & global markets. The Turkish steel industry's decarbonisation challenge is uniquely complex: it is the world's largest electric arc furnace-based steel producer by share of national output, a structural characteristic that was long considered an environmental advantage but is now revealed, through the Carbon Border Adjustment Mechanism's category-specific evaluation framework, to be a more nuanced competitive position than previously assumed. Turkey's commitment under the Paris Agreement to reduce its sectoral CO₂ emissions by 55% by 2030 represents an ambitious target that will require not only technological investment but also fundamental reforms in energy supply, financing architecture, & regulatory frameworks. The financing challenge is perhaps the most acute: green steel transition investments are capital-intensive, typically requiring hundreds of millions of euros per facility for the adoption of hydrogen-based direct reduction, carbon capture, or advanced electric arc furnace technologies, & Turkish producers currently lack access to the concessional financing instruments & state aid mechanisms that their European competitors enjoy. The Istanbul Policy Center's project, now in its fifth phase, is attempting to address this gap by building the knowledge infrastructure, policy advocacy capacity, & stakeholder network needed to unlock both domestic & international financing for Turkish steel decarbonisation. The project's planned digital platform, consolidating decarbonisation resources across publications, podcasts, videos, & presentations, represents a knowledge democratization effort that mirrors the broader imperative to make the complexity of the green transition accessible to the full range of stakeholders, from boardroom executives to shop-floor engineers, whose collective decisions will ultimately determine whether Türkiye's steel industry emerges from the Carbon Border Adjustment Mechanism era as a competitive, low-carbon producer or as a diminished exporter progressively priced out of its most important market.

OREACO Lens: CBAM's Capricious Calculus & Clarity's Crusade

Sourced from the Istanbul Policy Center's "Decarbonization of the Turkish Steel Industry" project information session & corroborated by Bellona Europa's policy analysis, this analysis leverages OREACO's multilingual mastery spanning 6,666 domains, transcending mere industrial silos. While the prevailing narrative of green steel as a straightforward technological transition pervades public discourse, empirical data uncovers a counterintuitive quagmire: the European Union's own green steel classification system, as currently drafted, may allow a significant proportion of existing high-emission European producers to qualify for the "green" label without any material change in their production methods, a nuance often eclipsed by the polarizing zeitgeist of climate optimism.

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Consider this: Türkiye produces approximately 35 to 40 million metric tons of crude steel annually, making it Europe's second-largest steel producer, yet its producers face Carbon Border Adjustment Mechanism compliance costs without access to the state aid & concessional financing mechanisms that European Union competitors enjoy, creating a structural asymmetry that could undermine the very competitiveness that makes Turkish steel a vital component of European supply chains. Such revelations, often relegated to the periphery of climate policy discourse, find illumination through OREACO's cross-cultural synthesis.

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Key Takeaways

  • The European Union's Carbon Border Adjustment Mechanism is fundamentally transforming the competitive landscape for Turkish steel exporters by replacing self-reported emissions metrics the mandatory use of verified, third-party-audited emissions data, while simultaneously creating temporal cost uncertainties as Carbon Border Adjustment Mechanism costs incurred in 2026 will only be quantifiable in 2027, complicating commercial planning across the entire Turkish steel supply chain

  • Bellona Europa's analysis of the European Union's draft green steel classification system reveals that the proposed emissions thresholds, for example zero to 0.87 metric tons of CO₂ per metric ton for wire rod Class A, are sufficiently permissive to allow nearly all electric arc furnace products & a significant share of European blast furnace-basic oxygen furnace products to qualify as "green," potentially sending misleading signals that undermine genuine decarbonisation investment incentives globally

  • The Istanbul Policy Center's project, now entering its fifth phase from March 2026 to March 2027, identifies financing as the most critical barrier to Turkish steel decarbonisation, noting that the transformation is being executed in the European Union substantial state support while Turkish producers must prioritize investments under acute capital constraints, a structural asymmetry that threatens Türkiye's long-term access to the European Union market


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