CBAM does not apply directly to food. Annex I of the Regulation has no food heading, but it does list nitrogen fertilisers, ammonia and nitric acid. The definitive regime began on 1 January 2026. Direct effects fall on those selling fertilisers or steel and aluminium goods into the EU. Any effect on Turkish farm costs is an unmeasured inference.
What is CBAM and when did it start?
The Carbon Border Adjustment Mechanism puts a carbon price on the emissions embedded in certain goods imported into the EU. According to the Commission, the transitional phase ran from 2023 to 2025 and the definitive regime began on 1 January 2026. Türkiye is not among the countries excluded in Annex III of the Regulation.
The obligation sits with the EU importer. The timetable is:
| Item | Rule |
|---|---|
| Threshold | An importer whose total net mass stays within 50 tonnes in a calendar year is exempt (not for electricity or hydrogen) |
| Certificate sales | From 1 February 2027 |
| First declaration and surrender | By 30 September 2027, for 2026 imports |
| 2026 price | Quarterly average: Q1 EUR 75.36, Q2 EUR 75.28, Q3 EUR 82.32 |
Prices are from the Commission’s certificate price page. If a carbon price paid in production can be proved, the corresponding amount can be deducted, which makes the producer’s data valuable to the buyer.
Which fertilisers does CBAM cover?
The fertiliser headings in Annex I are:
| CN code | Product |
|---|---|
| 2808 00 00 | Nitric acid, sulphonitric acids |
| 2814 | Ammonia |
| 2834 21 00 | Potassium nitrate |
| 3102 | Nitrogenous mineral or chemical fertilisers |
| 3105 | Fertilisers with two or three of nitrogen, phosphorus and potassium (except 3105 60 00, phosphorus and potassium) |
So not every fertiliser is covered. The list is built around nitrogen, and headings 3103 and 3104 are not in Annex I. Fertilisers are also absent from Annex II, the list of goods counted on direct emissions only, so indirect emissions count too.
In its Fertiliser Action Plan, the Commission says it applied a flat 1 percent markup to fertiliser default values. For other CBAM goods the markup is 10, 20 and 30 percent in 2026, 2027 and 2028.
Are food products covered?
No. Annex I consists of cement, electricity, fertilisers, iron and steel, aluminium and hydrogen. It has no heading for fruit, vegetables, meat, dairy, olive oil, flour or processed food. A Turkish company selling food to the EU does not trigger a CBAM declaration on those goods.
Which effects are direct and which are inference?
The most common mistake is to mix the two. CBAM applies when goods are imported into the EU customs territory. That single fact shapes the table below.
| Who | Effect | Basis |
|---|---|---|
| Producer selling fertiliser, ammonia or nitric acid to the EU | Direct: the buyer needs emissions data, and actual values require the producer’s verified data | Regulation and Commission guidance |
| Company selling steel structures, steel tanks over 300 litres, aluminium cans or foil to the EU | Direct: these goods are in Annex I | Annex I (7308, 7309, 7607, 7612) |
| EU farmer | Indirect: imported fertiliser may cost more. The Commission has yet to finish measuring this | Action Plan, evaluation due Q1 2027 |
| Turkish company selling food to the EU | No direct effect. Packed food is treated under its food code (inference) | No food code in Annex I |
| Farmer buying fertiliser in Türkiye | CBAM does not apply to this purchase. Any price effect could come only through trade flows (inference, no measured data) | Article 2 of the Regulation |
The last row matters. CBAM is not added to fertiliser a Turkish farmer buys at home. The sentence “fertiliser is covered, so your costs will rise” is not correct as it stands. A producer’s EU export costs and pricing decisions could influence the domestic market, but we have seen no official measure of the direction or size of any such effect.
The Commission itself is still gathering evidence for the EU: the Action Plan commits to evaluating how CBAM and ETS costs pass into fertiliser prices paid by farmers and into food prices, with a Q1 2027 target.
Could CBAM reach farm machinery?
Not today, but there is a proposal. COM(2025) 989 aims to add downstream goods made largely of steel and aluminium. Its list includes soil preparation machinery and parts (8432 80 00, 8432 90 00). This is a proposal, not law, and negotiation can change it. The same proposal contains an Article 27a allowing a good to be removed from Annex I temporarily in serious and unforeseen circumstances.
What should an agri-food company do?
- Check every line you sell to the EU by CN code against Annex I. Even if your main product is food, packaging and equipment sold separately may be covered.
- If you export fertilisers or steel and aluminium goods, prepare for data requests from your EU buyer. Actual emissions data may lead to a lower obligation than default values.
- If you sell farm machinery to the EU, follow COM(2025) 989.
- In your cost model, show CBAM as a scenario, not as a proven cost line.
This guide is general information, not legal or tax advice. For agri-food companies selling to the EU, the closer issue is often the EUDR. For a compliance roadmap, see Green Transition and Sustainability.
Frequently asked questions
Does CBAM tax food exports to the EU?
No. Annex I has no food heading, so a food product sold to the EU does not trigger a CBAM declaration. If the same company also sells a listed good, such as empty aluminium cans, that line is assessed separately.
Will Turkish farmers pay more for fertiliser because of CBAM?
CBAM applies only on import into the EU, not to purchases in Türkiye. An indirect effect on domestic prices is possible, but that is an inference. We found no official measure of its direction or size.
Has the CBAM definitive period started?
Yes, on 1 January 2026. Certificate sales open on 1 February 2027. The first declaration and surrender for 2026 imports are due by 30 September 2027. Prices are quarterly for 2026 and weekly from 2027.
Is every fertiliser covered?
No. Annex I lists nitric acid, ammonia, potassium nitrate, nitrogenous fertilisers under 3102 and mixed fertilisers under 3105. Code 3105 60 00 is excluded, and headings 3103 and 3104 are not listed.
Who does the 50 tonne threshold apply to?
The EU importer. If total net mass of CBAM goods stays within 50 tonnes in a calendar year, the importer is exempt. If the threshold is passed, all that year’s imports fall under the obligations. It does not apply to electricity or hydrogen.
Official sources
- Regulation (EU) 2023/956, konsolide metin, 20.10.2025
- Regulation (EU) 2025/2083 (SKDM sadeleştirme değişikliği)
- European Commission, CBAM definitive regime
- European Commission, Price of CBAM certificates
- European Commission, CBAM legislation and guidance
- Fertiliser Action Plan, COM(2026) 310 final
- Komisyon önerisi COM(2025) 989 (mamul ürünlere genişleme)
This guide is general information, not legal or financial advice. Programme terms can change, so check the current official text before applying.
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