Selling to the EU from Türkiye

It works differently from a free trade agreement, and the difference matters. The EU–Turkey customs union has existed since 1995 and lets industrial goods in free circulation move without customs duty; evidenced by an A.TR movement certificate, not by a statement on origin. Agricultural goods and coal and steel sit outside it and follow the ordinary rules.

No: this is the most expensive misconception in Turkish export. The customs union removes customs duties on goods in free circulation; it does not touch product-safety law. GPSR, CE marking, REACH and the Responsible Person apply to Turkish products exactly as to products from China or the US. The border is free; the rules are not.

Only if that subsidiary is the economic operator that places the products on the EU market. If your German company imports and sells, it is the Responsible Person for those goods; no separate appointment needed. If the Turkish parent sells direct, the Responsible Person must be appointed separately.

No. CE and GPSR are separate frameworks: CE proves conformity with technical directives; GPSR is the general safety net. Many Turkish manufacturers already carry CE for machinery, toys or electronics; that changes nothing about the GPSR Responsible Person and labelling duties on top.

GPSR for the consumer product, the EU textile labelling regulation (fibre composition), and REACH for restricted substances in the fabric; azo dyes, formaldehyde, certain softeners. France adds textile-EPR on top of packaging-EPR. The product is simple; the layers on top are not.

The obligation sits with the authorised CBAM declarant, not with you, but the data has to come from you. That declarant is the importer established in a member state; where the importer is established outside the EU it is his indirect customs representative. The definitive regime applies from 1 January 2026.

Threshold. He is exempt for as long as the net mass he imports in a calendar year, added up over iron and steel, aluminium, cement and fertilisers, does not pass 50 tonnes (Article 2a, with the figure in Annex VII, point 1). Once he passes it in a calendar year, the obligations apply to the embedded emissions of that whole year. The threshold counts per importer, not per shipment and not per supplier. It does not apply to hydrogen or to electricity (Article 2a(4)): for those he is in scope from the first consignment, however small.

Authorisation. The goods may only be released for free circulation by an authorised CBAM declarant, or by his indirect customs representative (Article 4; application under Article 5). Transitional rule: where the application is submitted by 31 March 2026, he may keep importing during 2026 for as long as the competent authority has not decided. If it is refused afterwards, a penalty follows on the emissions imported in the meantime.

Certificates. There are no CBAM certificates on sale in 2026. Sales start on 1 February 2027 (Article 20(1)). For import year 2026 the CBAM declaration is filed and the certificates are surrendered by 30 September 2027 (Article 22). The cost counts in his margin from 2026, but the cash leaves in 2027.

What he will ask you for. Which goods are in scope is decided by the CN code in Annex I: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For those he chooses how the embedded emissions are determined: from the actual emissions of the installation, or from default values (Article 7(2)). He is not required to ask you first, and not required to show that actual data cannot be obtained. It is a cost calculation, not a penalty. Default values are set at the average emission intensity of the exporting country, raised by a mark-up fixed in implementing acts; where reliable data for the exporting country is missing, the average emission intensity of the ten exporting countries with the highest emission intensity is used instead. Against that, only actual emissions have to be checked by an accredited verifier (Article 8(1)), so working from default values saves him that verification. Your figures are worth buying when your installation is cleaner than the country average plus mark-up by more than the verification costs; for an installation dirtier than that average, the default value can be the better deal for him. The customs union does not change any of this: CBAM is not a customs duty and free circulation does not exempt a good from it.

Wood is one of the seven commodities in Regulation (EU) 2023/1115, and furniture and panels are derived wood products, so yes for a large part of the Turkish furniture and panel trade. The point that catches exporters is that the origin of the timber decides the work, not the country you ship from: wood imported into Türkiye, processed and re-exported to the EU still has to be traced back to the plots it was harvested on, with the production period and evidence of no deforestation after 31 December 2020. Which codes are caught is set out in Annex I; check your own code against the current text rather than a summary of it.

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