Türkiye-origin steel declared without verified data is assessed at the Türkiye figures in Implementing Regulation (EU) 2025/2621: 1.85 tCO2e per tonne for pig iron, 2.43 for hot-rolled flat products and 5.47 to 5.54 for stainless flat under CN 7219 11 and 7219 31, plus a 10 percent mark-up in 2026. Direct reduced iron has no Türkiye value, so the fallback applies.
The published Türkiye defaults for steel
Türkiye holds its own set of rows in Annex I of Implementing Regulation (EU) 2025/2621, because every CBAM default value is specific to the country of origin. Iron and steel is an Annex II good, so the figures below price direct embedded emissions only; indirect emissions from electricity are not calculated or counted and add nothing to the certificate obligation. Each base value carries a regulatory mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028.
| Product | Representative CN | Base default (tCO2e/t) | 2026 with mark-up |
|---|---|---|---|
| Pig iron | 7201 | 1.85 | 2.04 |
| Direct reduced iron (DRI) | 7203 | No Türkiye value published | Fallback applies |
| Hot-rolled flat products | 7208 | 2.43 | 2.67 |
| Bars and rods | 7213 | 2.31 | 2.54 |
| Stainless flat, hot-rolled | 7219 11 | 5.47 | 6.02 |
| Stainless flat, cold-rolled | 7219 31 | 5.54 | 6.09 |
Source: Implementing Regulation (EU) 2025/2621, Annex I. Direct emissions only.
Why the Türkiye figures sit below India across the range
Türkiye’s defaults are below India’s for every product in the table that has a Türkiye value. Hot-rolled flat products under CN 7208 carry 2.43 tCO2e per tonne for Türkiye against 4.28 for India. Pig iron repeats the pattern at 1.85 for Türkiye against 2.53 for India, with China at about 1.66 and a 3.48 fallback for origins without a published pig iron value. The full India table appears in the companion answer on Indian steel defaults, and the CN codes in scope are mapped in the answer on covered iron and steel products.
The missing DRI value and what declarants can do
Direct reduced iron under CN 7203 has no published Türkiye default, so DRI consignments declared without verified data fall back to the default for origins without a country value. Low country figures do not remove the case for actual data: a scrap-based EAF installation may measure below even the marked-up Türkiye default, and the mark-up climbs each year until 2028. Declarants importing Turkish steel can size the exposure product by product in the CBAM cost calculator. Installation-level emissions can then be calculated and CBAM reports prepared through a CBAM consulting service, ahead of verification by an accredited verifier.
Sources: Implementing Regulation (EU) 2025/2621 · Regulation (EU) 2023/956