Draft Turkish Emissions Trading System Regulation opened for comment

What happened

On 22 July 2025, about two weeks after the Climate Law entered into force, Türkiye's Climate Change Presidency published the draft Turkish Emissions Trading System (TR ETS) Regulation and opened it for comment until 4 August 2025. The draft was the first detailed implementing framework for the system established by Climate Law No. 7552.

According to the Presidency's announcement, the main points of the draft were:

• Coverage threshold: Installations with an annual emission capacity above 50,000 tonnes of CO₂.
• Pilot period (2026-2027): Sectors covered by the EU's Carbon Border Adjustment Mechanism (CBAM); 100 percent free allocation based on benchmark values; coverage of about 41 percent of emissions.
• First implementation period (2028-2035): Installations carrying out the activities in Annex 1 of the regulation; two sub-periods, 2028-2030 and 2031-2035; coverage of about 47 percent of emissions.

The final regulation was published in the Official Gazette on 27 August 2026; see our separate news item for details.

Who is affected

The draft set out, for the first time in Türkiye, a timeline for putting a price on an installation's carbon. Large installations in CBAM sectors such as power generation, cement, iron and steel, aluminium and fertilisers were natural candidates for the pilot period. For companies in these sectors exporting to the EU, the issue cuts both ways: CBAM on the EU side, the ETS on the Turkish side. Because the EU has built a structure that takes into account the carbon price paid in countries with carbon pricing when calculating CBAM (from 2027 the Commission may set default carbon prices for these countries), a domestic ETS matters especially for exporters.

Installations carrying out Annex 1 activities outside the pilot period also began to see their preparation timeline in this draft, since they will come into scope from 2028.

What companies should do

• Assess annual emissions for each installation against installed capacity and determine where you stand relative to the 50,000-tonne threshold.
• Because free allocation will be based on benchmarks, calculate your product-level emission intensity; if you are above the sector average, you may face an allocation shortfall.
• Collect emissions-per-product data in a single data infrastructure for both the ETS and CBAM.
• Compare the final regulation and pilot period decisions with the draft and update your plan accordingly.

Alalëa supports installation threshold checks, benchmark comparisons and allocation impact analysis: ETS readiness.