The Climate-Policy Chain, Made Simple
Learning objectives
- Explain the global-to-Turkish climate-policy chain in plain terms.
- Describe how Climate Law, TR ETS and EU CBAM interact for manufacturers.
- Distinguish what an SME must do now versus later.
1. SDGs, carbon management and the problem this lesson solves
In practice, begin with a premise you can carry into your own workplace: climate goals rarely reach a factory as abstract ideals. They arrive as questionnaires, verification appointments, allowance prices and — if you export into the European Union — as carbon costs embedded in trade. The United Nations , especially SDG 13 (Climate Action), together with SDG 7 (affordable clean energy), SDG 9 (industry and innovation) and SDG 12 (responsible production), give you a shared language for why that pressure exists. They do not, by themselves, tell you which meter to install or which subcontracted finishing step could weaken a CBAM file.
Carbon management is the organisational craft that sits between goals and instruments. You work through it as a cycle: define what counts; measure activity and emissions; reduce where it matters; report in a form others can trust; and finance the transition without mistaking a brochure for a pathway. When that craft is weak, policy can feel arbitrary and punitive. When it is strong, you can turn the same policy into a constraint your plant can navigate.
Accordingly, this lesson has a more practical purpose than simply asking you to “learn sustainability.” It helps you reconstruct the climate-policy chain that connects global goals to Turkish law and markets, and from there to the factory gate — so that you can argue, cite and sequence action while testing common assumptions carefully (see Figure 1).
1. SDGs
Goals 7, 9, 12 and 13: energy, industry, production and climate.
2. Carbon management
Measure, reduce, report and finance the transition.
3. Climate policy tools
Law, MRV, ETS, border measures and standards.
4. Factory-gate pressure
Buyer data asks, costs and market access.
SDGs set direction; carbon management is the organisational craft; policy instruments turn that direction into enforceable pressure at the plant.
Figure 1. From SDGs and carbon management to binding policy and factory-gate pressure.
2. From global goals to climate policy instruments
From 2015 onward, the locked in a logic of nationally determined pathways (NDCs). The genius — and the frustration — of Paris is that it is polycentric: countries choose their contributions, then must invent domestic instruments capable of delivering them. Carbon pricing (taxes or ), performance standards, industrial policy, fossil-fuel subsidy reform and public procurement all become candidates. argue that carbon pricing is powerful because it is incomplete: it works best alongside technology and innovation policy, not as a lonely purity test. You should watch the short UN explainer video below before you continue.
What is the Paris Agreement?
However, critical scrutiny still matters. ex-post review of carbon-pricing evaluations is uncomfortable reading for slogan-makers: surprisingly few studies rigorously measure emissions reductions (37 in her set, mostly Europe), and results depend heavily on design — caps, allocation, enforcement, complementary measures. Aggregate reductions attributed to pricing are often about 0–2% per year; EU ETS studies in her synthesis cluster around 0–1.5% per year. “We have a carbon price” is not the same claim as “our carbon price is cutting emissions.” Learning to hold that distinction is one of the most useful professional habits this course can give you.
turn the same lesson into a practice checklist across eight jurisdictions: environmental effectiveness, economic efficiency, market management, revenue management and stakeholder engagement.
Meanwhile, the EU’s deepening of its ETS and the European Green Deal (from 2019) raised a second-order problem: if one jurisdiction prices carbon hard while others do not, carbon leakage and competitiveness disputes intensify. That is the doorway through which border carbon adjustments walk into the story (see Table 1).
Table 1. Selected chronology: Paris → CBAM → Türkiye Climate Law.
- 2015Paris Agreement; NDCs begin
- 2015–Türkiye MRV system for covered installations
- 2019European Green Deal
- 2021–23EU CBAM proposal → Regulation
- Oct 2023CBAM transitional reporting begins
- 2024CCMSAP 2024–2030; İDB ETS–SKDM briefings
- Jul 2025Türkiye Climate Law No. 7552
- 2026CBAM definitive regime; TR ETS pilot expectations
3. Why borders entered the story: BCAs and CBAM
summarise the economic rationale of border carbon adjustments (BCAs): when carbon-price disparities are large, a well-designed BCA is among the more coherent domestic tools for addressing leakage and competitiveness — though design details (sector coverage, benchmarks, treatment of exports, recognition of foreign pricing) decide whether the tool is workable diplomacy or a trade fight waiting to happen. , reviewing 97 economic studies with a PRISMA protocol, underline the same core logic: level the playing field and reduce leakage through carbon-content-based border measures — which is why embedded-emissions accounting, not slogans, sits at the centre of the instrument. Their synthesis also warns that there is no one-size-fits-all CBAM design: coverage of trade and sectors, treatment of carbon content, and use of revenues change effectiveness across fair competition, leakage and welfare objectives.
In line with this logic, the EU’s is currently the most advanced import carbon-cost mechanism in operation (CITD, 2024). It begins with energy-intensive, trade-exposed goods — iron and steel, aluminium, cement, fertilisers, electricity and hydrogen — precisely because those sectors sit at the intersection of climate ambition and trade politics. The European Parliament Research Service explainer video below walks through how CBAM works at the border; the Commission hub that follows is a useful official landing page for the same instrument.
EU carbon border adjustment mechanism: CBAM
remind us that CBAM is also foreign policy: which “significant others” the EU engages (major emitters, vulnerable exporters, political allies) shapes whether the instrument succeeds or hardens into conflict. IEEP (2025) adds the equity lens: low- and middle-income suppliers face feasibility and fairness stress, even as 2025 simplification debates try to reduce administrative burden.
By contrast, comparative modelling sharpens the caution for exporters. show that CBAM can reduce leakage while still raising the EU ETS price and leaving uncovered downstream and export channels exposed. find leakage reductions on the order of one-third by 2040 under their scenarios, with LDC exemptions able to worsen leakage and revenue recycling into clean energy performing better. None of those results imply that a domestic ETS elsewhere deletes product-data asks. maps the opportunity–challenge pair for non-EU countries specifically: alignment and innovation pressure on one side; administrative burden and trade friction on the other — including tension with Paris “common but differentiated responsibilities” when a uniform carbon-content price is applied at the border. add the accounting foundation: consistent public emissions-accounting systems are a prerequisite if border instruments, linked markets and certification schemes are to be effective and WTO-facing.
4. Mapping the climate-policy chain
Against this backdrop, the workable map for this course has five links:
- Paris / NDC — the political pathway
- — the national sector strategy
- — the legal hinge
- and — measurement and the domestic carbon price
- and buyer questionnaires — border and contract pressure
If you miss one link, the story can slide into a misleading shortcut: that a Turkish ETS will erase CBAM; that MRV is only paperwork; or that SDGs alone are enough. You should keep all five in view. So, we can say that you can brief your board with clarity and confidence (see Figure 2).
Paris & NDCs
CCMSAP 2024–2030
Climate Law 7552
MRV + TR ETS
CBAM / SKDM + buyers
A domestic ETS strengthens data and pricing. It does not automatically switch CBAM off for EU importers (İDB, 2024; Uğurlu).
Figure 2. The climate-policy chain for Turkish manufacturers.
5. Türkiye’s strategic frame: NDC, CCMSAP and 2053
Meanwhile, Türkiye’s long-term narrative includes a 2053 net-zero aspiration. An aspiration without instruments remains only a political statement. The is one of the main bridges from that statement to practice: it organises sector pathways for energy, industry, buildings and related domains under the Paris/NDC frame. For manufacturers, CCMSAP functions as a radar of where public programmes, reporting expectations and investment narratives are likely to concentrate through 2030.
Accordingly, for your strategy team, a workable habit is simple. Maintain a one-page matrix with CCMSAP/NDC milestones on one axis and your products and EU exposure on the other. That matrix helps you recognise each buyer request as part of a predictable policy cascade rather than an unexpected crisis (see Table 2).
Table 2. Sample one-page matrix: CCMSAP/NDC milestones × products and EU exposure (illustrative).
| Product & EU exposure ↓ | NDC / industry pathway | CCMSAP efficiency & fuel-switch | MRV / TR ETS readiness | CBAM & buyer data |
|---|---|---|---|---|
| Hot-rolled steel → EU OEMs | Watch NDC industry intensity language | Map scrap / electrification actions to your line | Keep fuel + process streams verifier-ready | Embedded-emissions pack for each SKU family |
| Cement / clinker → mixed EU & TR | Flag if NDC cement actions tighten | Track kiln / alternative-fuel milestones | Installation MRV plan covers clinker routes | Buyer asks arrive before definitive CBAM |
| Components → domestic only | Low direct NDC hit — still scan annually | Efficiency programmes may unlock finance | Useful practice even if not ETS-covered | Rare CBAM ask; prepare if supply chain shifts |
Illustrative sample only — replace rows with your SKUs and columns with the CCMSAP/NDC milestones your team actually tracks. A filled cell is an early-warning, not a finished compliance file.
So, we should read CCMSAP as a radar, not as a plant SOP (standard operating procedure). It tells you where public programmes, reporting expectations and investment narratives are likely to concentrate. It does not replace installation monitoring plans, product-intensity worksheets or buyer-specific templates. If you treat a strategy document as if it were a meter, you may overclaim; if you ignore it, you may be surprised by the direction of policy.
6. Climate Law 7552 — the domestic legal hinge
, published in the Official Gazette on 9 July 2025, is the hinge of the Turkish chain. It establishes the legal and institutional frame for greenhouse-gas mitigation and climate adaptation — including planning tools, climate-related revenues, permits and supervision. Critically for this course, it authorises a national ETS, sets expectations around carbon credits / offsetting, and situates Türkiye’s approach in relation to EU CBAM.
In practice, day-to-day climate administration sits with the Directorate of Climate Change. Market and registry functions are associated with . A Carbon Market Board provides governance oversight. Professional bulletins emphasise that the Law hardens enforcement: late or missing verified emission reports can attract substantial administrative fines (; ). Local government relays, such as announcing the Law, show how quickly the message travels from Official Gazette to municipal and industrial ecosystems.
That said, assessment of Türkiye’s ETS draft regulation makes a point that managers need: environmental effectiveness depends on the quality of the cap, the allocation method, market-stability design, MRV capacity and fiscal integrity against abuse — not on the mere existence of a law titled “climate.” CBAM pressure, Hondur notes, is one reason ETS design cannot be treated as a slow academic exercise.
7. MRV since 2015 — the market sits on measurement
Meanwhile, Türkiye did not invent monitoring when it wrote Climate Law. The created an MRV architecture that has operated since the mid-2010s for . Covered operators prepare an approved monitoring plan, monitor accordingly, obtain verification from accredited verifiers, and submit annual emission reports (classically by 30 April). Approximately 800 installations have been covered, representing on the order of half of national GHG emissions.
Accordingly, the Climate Change Directorate’s 2025 verification work assignment via MEDAS (Central Electronic Verifier Assignment System) for hundreds of facilities underscores that verified reports are treated as the data backbone for national ETS preparations. The arithmetic is deliberately boring — activity data × emission factor — and deliberately powerful when it is verified, timestamped and comparable across years.
8. Building a Turkish ETS under CBAM pressure
You should treat this section as a design conversation, not a shopping list. It is where domestic market design meets border pressure — and where comparative evidence should make you appropriately cautious.
An caps emissions allowances and allows trade so that abatement occurs where marginal costs are lowest. , reviewing systems including the EU ETS, California, Québec, RGGI, New Zealand, Korea and Chinese pilots, argue that successful carbon markets depend on institutional learning, administrative prudence, revenue management and stakeholder engagement. Caps that tighten on a published schedule, transparent registries, and revenue recycling into transition support are not optional decorations; they are how markets survive political stress. supplies the ex-post caution that sits beside that checklist: average annual reductions under many pricing schemes remain limited unless design and complementary policy are serious. You should watch the EU ETS explainer video below, then skim the draft TR ETS materials that follow for how Türkiye is translating the same market logic.
The EU Emissions Trading System explained
Türkiye’s pathway draws on earlier Partnership for Market Readiness (PMR) materials and on the Türkiye ETS Regulation governing MRV-linked market rules. A pilot phase has been widely expected from 2026 as the system moves from readiness into operation under Climate Law. Exact thresholds and obligation lists will continue to evolve — which is precisely why scenario literacy beats rumour literacy.
Nevertheless, firm-level evidence deserves a closer look. , studying China’s ETS pilots, find that the “weak” Porter hypothesis was not realised in their sample: the share of green patents fell by about 9.26%, with stronger inhibition among small-scale, manufacturing and non-state-owned firms. Many companies met targets by cutting output and R&D cash flow rather than by innovating. If you advise a mid-sized manufacturer, you should pause over that result. It does not mean “never price carbon.” It means: design and firm capabilities decide whether pricing induces innovation or attrition — the same accuracy habit Lesson 2 will formalise as a four-question claim test.
Türkiye ETS (domestic)
- Cap-and-trade for covered installations
- Built on MRV-verified data
- Prices domestic emissions
- Climate Law / ETS Regulation
EU CBAM / SKDM (border)
- Targets embedded emissions in imports
- Obligation sits with EU importers
- Needs product / installation data
- Definitive regime from 2026
Common misconception: “Once we have a Turkish ETS, CBAM disappears.” Reality: the instruments interact through data quality and relative carbon costs — they are not an automatic exemption.
Figure 3. Domestic ETS and EU CBAM interact — they are not the same instrument.
In line with this, official Turkish communications (Climate Change Directorate ETS–CBAM presentation, 23 February 2024) state the linkage clearly: a credible domestic ETS and verified monitoring strengthen exporters; they do not automatically remove CBAM obligations for EU importers. and make the same structural point from the modelling side: leakage can fall without product-data obligations disappearing. That is the hinge connecting Section 8 to Section 9.
9. CBAM in practice: chronology, politics and Turkish exporters
Implementation timeline
The EU’s Fit for 55 package and the CBAM Regulation (2023) established the legal basis for the mechanism. A transitional reporting phase ran from 1 October 2023 to the end of 2025. From 2026, the definitive regime begins to phase in certificate obligations for EU importers. Policy debates in 2025 about administrative simplification (IEEP, 2025; Ministry of Trade updates) matter for smaller trade flows, but they do not remove the underlying requirement for credible product and installation data.
In practice, for Turkish exporters, CBAM often arrives first as a buyer questionnaire, not as a fine from Brussels. Default values and estimates exist in the EU methodology, yet buyers and intermediaries increasingly prefer measured data because defaults can raise commercial costs (CITD, 2024). quoting Ankara Chamber of Industry leadership is direct: firms unable to provide verifiable emission data risk serious EU market losses. Chamber guides such as ASO’s CBAM firm guide translate that warning into checklists. You should treat them as grey literature with operational value, then verify claims against Ministry of Trade guidance and primary EU texts before signing a supplier declaration.
The Turkish press and ministry pages below show how SKDM and data readiness are already discussed as export competitiveness issues — not distant Brussels theory. The forum video that follows adds a practitioner walk-through of the same border instrument.
Understanding the EU’s CBAM
That said, Smith et al. (2023) and IEEP (2025) also situate CBAM in political context: it is a contested externalisation of EU climate policy, not a neutral accounting spreadsheet. Russia’s WTO complaint (noted in IEEP’s 2025 brief) is a reminder that border carbon measures live in diplomacy as much as in customs forms. For a Turkish manufacturer, the practical implication is straightforward: a credible data trail is part of trade readiness.
10. What the chain implies for sequencing (now → later)
If Sections 1–9 felt like moving parts, this section is the consequence, not a sudden checklist from nowhere.
You now know that SDGs and Paris set direction; CCMSAP organises national sector pathways; Climate Law authorises markets and enforcement; MRV supplies verified numbers; ETS prices domestic carbon (with design risks that can hurt small firms if support is weak); CBAM prices embedded carbon at the EU border and hits exporters through buyers long before anyone “feels ready.” Zhao et al. (2024) — the empirical case that follows — show that border pressure alone can punish exporters commercially while delivering limited industry-wide carbon cuts unless domestic abatement policy is serious. Chen et al. (2021) show that poorly supported firms may shrink rather than innovate under ETS pilots.
Accordingly, sequencing is not a slogan. For you, it is risk management under uncertainty:
Near term (this quarter / this year) grows out of CBAM buyer clocks + MRV enforcement under Climate Law: you should map whether your products (or your customers’ products) sit in CBAM-exposed sectors; organise installation- and product-level activity data; replace opaque “plant averages” with traceable product data; track Climate Change Directorate / ETS calendars if you are or may become covered; answer buyer questionnaires with documented methods; and put data clauses into subcontractor purchase orders before the next EU reporting cycle.
Medium term (1–3 years), meanwhile, grows out of ETS design evolution + abatement economics: full ETS compliance if obligated; deeper fuel-switch and process capex guided by hotspot maps; green-finance cases that rest on verified pathways; board scenarios that price both domestic carbon costs and border exposure.
A concise board-level statement of the same logic is: this is not sustainability theatre; it is aligning measurement, domestic pricing readiness and export-data credibility because the policy chain has already reached the factory gate.
We WILL Fix Climate Change!
−32%
Export volume to the EU
−58%
Export profits for exporters
Limited
Industry-wide carbon cut if trade exposure is low
Commercial pain at the border is not the same as deep domestic decarbonisation. Pairing CBAM pressure with a comprehensive domestic abatement package improves carbon-reduction efficiency and softens trade impacts.
Figure 4. Modelled CBAM impacts on China’s steel exports (Zhao et al., 2024).
References
Anadolu Agency. (2025). Industry focuses on the EU CBAM’s next phase. https://www.aa.com.tr/
Ankara Chamber of Industry. (n.d.). CBAM firm guide. https://www.aso.org.tr/
Baranzini, A., van den Bergh, J. C. J. M., Carattini, S., Howarth, R. B., Padilla, E., & Roca, J. (2017). Carbon pricing in climate policy: Seven reasons, complementary instruments, and political economy considerations. WIREs Climate Change.
Chen, Z., Zhang, X., & Chen, F. (2021). Do carbon emission trading schemes stimulate green innovation in enterprises? Evidence from China. Technological Forecasting & Social Change, 168, 120744.
CITD (Butscher, E., & Camiña, M. A.). (2024). European Union’s Carbon Border Adjustment Mechanism: A Primer. Centre for International Trade and Development.
Directorate of Climate Change (Türkiye). (2024, 23 February). ETS–CBAM relationship [Presentation].
Directorate of Climate Change. (2025). Verification work assignment news (MEDAS / MRV). https://iklim.gov.tr/
European Parliament Research Service. (2022). CBAM “at a glance” (EPRS).
Green, J. F. (2021). Does carbon pricing reduce emissions? A review of ex-post analyses. Environmental Research Letters, 16, 043004.
Hondur, A. (2025). Emissions trading system and Türkiye: assessment of the draft ETS regulation. SÜAMYOD, 8(2), 85–108. https://dergipark.org.tr/en/pub/suamyod/article/1846112
Istanbul metropolitan climate pages. (2025). Climate Law announcement. https://cevre.ibb.istanbul/iklim-degisikligi-sube-mudurlugu/iklim-kanunu-yayimlandi/
IEEP (Oger, A., & Leturcq, P.). (2025). The EU CBAM’s reform and remaining implementation challenges for low- and middle-income countries.
Kabine Law. (2025). Analysis of emissions trading systems and Türkiye’s Climate Law. https://www.kabinelaw.com/tr/emisyon-ticareti-sistemleri-ve-turk-iklim-kanununun-analizi/
Keen, M., Parry, I., & Roaf, J. (2022). Border carbon adjustments: Rationale, design and impact. Fiscal Studies.
KPMG Vergi. (2025, 9 July). Climate Law of 9 July 2025 [Bulletin]. https://kpmgvergi.com/yayinlar/mali-bultenler/gumruk/09072025-tarihli-iklim-kanunu/3151
Narassimhan, E., Gallagher, K. S., Koester, S., & Rivera Alejo, J. (2018). Carbon pricing in practice: A review of existing emissions trading systems. Climate Policy, 18(8).
Republic of Türkiye. (2024). Climate Change Mitigation Strategy and Action Plan 2024–2030 (EN). https://iklim.gov.tr/db/turkce/icerikler/files/CLIMATE%20CHANGE%20MITIGATION%20STRATEGY%20AND%20ACTION%20PLAN%20_EN%281%29.pdf
Republic of Türkiye. (2025). Climate Law No. 7552. Official Gazette, 9 July 2025. https://mevzuat.gov.tr/mevzuat?MevzuatNo=7552&MevzuatTur=1&MevzuatTertip=5
Republic of Türkiye. Türkiye Emissions Trading System Regulation; Regulation on Monitoring of Greenhouse Gas Emissions (MRV; Official Gazette 17 May 2014, No. 29003). https://mevzuat.gov.tr/mevzuat?MevzuatNo=19678&MevzuatTur=7&MevzuatTertip=5
Smith, I. D., Overland, I., & Szulecki, K. (2023). The EU’s CBAM and its ‘significant others’: Three perspectives on the political fallout from Europe’s unilateral climate policy initiative. Journal of Common Market Studies.
Ministry of Trade (Türkiye). (n.d./2026 updates). EU Carbon Border Adjustment Mechanism. https://ticaret.gov.tr/
United Nations. (2015). Transforming our world: The 2030 Agenda for Sustainable Development (SDGs).
Zhao, L.-T., Chen, Z.-Y., Duan, Y.-X., & Qiu, R.-X. (2024). How will CBAM affect the decarbonisation of steel industry in China? A system dynamics approach. International Journal of Production Research, 62(18), 6859–6880. https://doi.org/10.1080/00207543.2023.2285397
Zhong, J., & Pei, J. (2024). Carbon border adjustment mechanism: a systematic literature review of the latest developments. Climate Policy, 24(2), 228–242.
Erdogdu, E. (2025). The Carbon Border Adjustment Mechanism: opportunities and challenges for non-EU countries. WIREs Energy and Environment.
Reeve, A., & Aisbett, E. (2022). National accounting systems as a foundation for embedded emissions accounting in trade-related climate policies. Journal of Cleaner Production, 371, 133678.
Case Study
CBAM and China’s steel industry (Zhao et al., 2024)
It is early 2026. You advise the commercial director of a mid-sized Turkish steel exporter with material EU sales. A board member has just argued that “CBAM is mainly politics” and that “once Türkiye’s ETS is running, European buyers will stop asking for our data.” Your brief must use evidence, not slogans.
The evidence pack. Zhao, Chen, Duan and Qiu (2024) model China’s steel supply chain under CBAM using system dynamics. For the scenarios they report, the authors find approximately:
- a 32% decrease in steel export volume to the EU;
- a 58% loss in export profits for those exporters;
- limited industry-wide carbon reduction when EU trade exposure is low;
- a clearer climate and commercial outcome when CBAM pressure is paired with a comprehensive package of domestic emission-reduction measures.
Steel sits in CBAM’s first wave for Turkish exporters as well. Process mixes and trade shares differ from China, but the mechanism travels: border carbon costs can punish exporters commercially without automatically forcing deep domestic abatement. That is one reason Türkiye is building Climate Law / ETS capacity under CBAM pressure (Climate Change Directorate, 2024; Hondur, 2025). Parallel firm-level evidence from China’s ETS pilots also cautions that smaller and non-state firms may cut output or R&D rather than innovate when pricing arrives without support (Chen, Zhang & Chen, 2021).
Discussions
Please consider the case study you have worked on above. Answer the questions below, post your response, and discuss with your peers by replying to their posts.
Q1. Zhao et al. report large modelled losses in export volume (~32%) and export profits (~58%), yet limited industry-wide carbon reduction when EU trade exposure is low. Why can CBAM hurt exporters commercially without forcing deep domestic decarbonisation — and what does that imply for a Turkish steel or cement exporter with material EU sales?
Q2. The authors argue that a comprehensive domestic abatement package improves carbon-reduction efficiency and softens CBAM’s trade impact. You should name two Turkish instruments or processes from Sections 6–8 that could play that role, and one risk if they are poorly designed for SMEs.
Q3. After this case, which boardroom myth is more dangerous — “CBAM is only politics” or “a Turkish ETS will switch CBAM off”? Defend your choice in one clear paragraph.
Posts are visible to your peers on this course. Inappropriate content is reviewed by the programme team.
End-of-session quiz (5 questions)
Score starts at 100. Each incorrect answer reduces your score by 5 points. Your accuracy is saved with lesson completion.
1. What is the primary purpose of Türkiye's national ETS under Climate Law 7552?
2. Which goods are in CBAM’s first wave for Turkish exporters?
3. Does a live Türkiye ETS automatically eliminate CBAM for EU-bound goods?
4. In the case, CBAM alone on China’s steel exports mainly showed:
5. What has been the data backbone for Türkiye’s ETS pathway since the mid-2010s?