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; electricity-related indirect emissions are monitored and reported but 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
Turkish steelmaking is EAF-heavy, and scrap-based electric arc furnace production is the lowest-emission steel route, so Türkiye’s defaults land materially below India’s for every listed product. 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 gap matters at scale: Türkiye supplied about EUR 3.5 billion of iron and steel to the EU in 2024, placing it among the bloc’s leading suppliers. 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, then have installation-level emissions calculated and CBAM reports prepared through a CBAM consulting service ahead of confirmation by an accredited verifier.
Sources: Implementing Regulation (EU) 2025/2621 · Regulation (EU) 2023/956