SKDM is the European Union's Borderline Carbon Regulatory Mechanism, which applies a carbon cost to the embodied emissions generated during production on imports of certain carbon-intensive products. The definitive period began on January 1, 2026. However, not every export to the EU automatically falls within the scope of SKDM; The GTIP/CN code of the product, its origin, import method and current legislation should be checked together.
To organize commercial records that will be the source of SKDM evaluation import and export program You can review the page. Emission accounting, verification and legal reporting scope should be evaluated separately.
Turkish producer prepares data, EU importer manages financial liability
SKDM declaration and certificate delivery mainly takes place through the authorized EU importer or the appropriate indirect customs representative. Reliable data may be requested from the manufacturer in Türkiye for the production process of the product and embedded emission calculation.
Check by product code
The industry name alone is not enough; The CN/GTİP equivalent of the product in the legislation annex is examined.
Embedded emission
Direct emissions from production and related indirect emissions data are prepared according to product group.
SKDM certificate
The EU importer manages the certification obligation according to the declared emissions and applicable rules.
Saying “I export to the EU” alone does not mean that you are within the scope of SKDM
The European Commission applies SKDM to certain iron and steel, aluminium, cement, fertiliser, electricity and hydrogen products. Not every product code in the same industry may be covered. Before receiving a customer request, verify your product codes with your customs broker and current legislation annexes.
How to Check SKDM Scope?
Verify product code
Proceed from the current GTIP and EU CN code equivalent used in export, not from the commercial product name.
Check the legislative annex
Check whether the code is included in the list of products covered by the SKDM Regulation.
Identify the importer
From the buyer in the EU, request in writing the declaration responsibility, data format, reporting period and verification expectations.
Review exemptions
Verify current threshold, origin and special conditions with authorized expert on a shipment basis; Don't rely on old transitional rules.
How Does the SKDM Process Work in 2026?
Emission data is generated
Records of fuel, electricity, raw materials, intermediate products and production quantities are kept at the facility level.
Distribution is made to the product
The emission in the relevant production process is tied to the product quantity using the method in the legislation.
forwarded to EU customer
The manufacturer shares the required emission and facility information in the appropriate format for the importer's declaration.
Importer liability
The authorized declarant manages the annual declaration, verification and amount of certificates to be delivered.
According to the information of the Ministry of Commerce checked on 20 August 2026, declarations for 2026 imports are expected to be delivered by 30 September 2027 at the latest. The certificate price is based on the quarterly average of EU Emissions Trading System prices for 2026. Since dates and implementation details may change, the current official source should be taken as basis before processing.
What Data Should the Manufacturer Prepare?
Facility and production process
Which product is produced on which line, through which production steps, and how the plant boundaries are defined.
Fuel and direct emissions
Periodic consumption records of natural gas, coal, LPG and process emission-generating inputs.
electricity consumption
The source of the emission factor used with electricity consumption based on meter, invoice and, if possible, production line.
Semi‑finished product and raw material
The quantity, origin and supplier‑provided emission information of intermediate inputs covered by the scope used in production.
Production and shipment quantity
Recording of intact product, wastage, rework and net quantities shipped to the EU during the period using a common unit of measurement.
Account and verification trail
Method used, source documents, custodians, corrections, and chain of records that can be submitted to the verifier.
Difference Between Actual Value and Default Value
Based on actual data of the facility
It is calculated with measurable fuel, energy, production and intermediate product data. Data quality, methodology and necessary validation conditions must be met.
It is the value determined by the commission
When actual data is not available, it may come into play within the framework of the relevant rules. According to the Ministry of Commerce, an additional margin of 10 percent is applied to the 2026 default values for products other than electricity.
Emissions data can now be part of the quote and customer relationship
Even if the certificate obligation lies with the EU importer, missing, late, or information based on high default values can affect the customer's import cost and supplier preference. Therefore, sales, export, production, energy, purchasing, and finance records must be prepared in a common data structure.
Common Mistakes Made in SKDM Preparation
Make a scope decision based on industry name
It is not enough to say “we produce metal” or “we are the automotive sub-industry”. The product code and scope supplement should be checked.
Distribute the total invoice to the product
Distributing the total energy consumption of the facility equally without establishing a connection between production line, product and period may not produce reliable results.
Bypass supplier data
Embedded emissions of covered intermediate products may affect the final product calculation. The purchase contract and data request must be drawn up accordingly.
Using transitional information
The threshold, verification and liability rules for the reporting period 2023‑2025 and the definitive period starting in 2026 are not the same
What Does ERP Provide and What Does It Not Provide in the SKDM Process?
Traceable business data
It forms the basis for associating bill of materials, production order, material consumption, wastage, energy and shipment records with product and period.
Guarantee of compliance with regulations
The decision on product scope, emission method, accreditation and verification requires evaluation of competent experts and current legislation.
Joint management of foreign currency, exchange rate difference, cost and customs records in export orders in the export and foreign exchange management article; difference between circulation and origin documents Comparing A.TR and EUR.1 and review it.
Frequently Asked Questions
Is SKDM a customs tax?
SKDM is a separate mechanism that applies a carbon cost linked to the EU ETS price to the embodied emissions of certain imported products. Application detail should be evaluated according to the product and import condition.
Does the exporter in Türkiye receive SKDM certificate?
The main liability lies with the authorized EU importer or appropriate indirect representative. The main role of the Turkish manufacturer is to provide accurate production and emissions data.
Are every iron and steel product covered?
No. Scope is determined by product codes. The GTIP/CN code of the product should be compared with the current legislation annex.
How is the carbon cost reflected in the product price?
Effect; depends on variables such as verified embodied emissions, free allowance adjustment, applicable certificate price and any accepted carbon price reduction. It cannot be calculated with a single fixed ratio.
Last check date: 20 August 2026
- European Commission: SKDM final term rules
- Ministry of Trade of the Republic of Turkey: General information and application regulations for AB SKDM
- T.R. Ministry of Commerce: Default emission values
This content is for general information purposes only; It is not a substitute for legal advice, emissions verification service or customs consultancy. Verify current legislation and product code with authorized experts before shipment.
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