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Omnibus Bill Including Amendments to the EU SKDM Regulation

The European Commission is working on several policy areas, including the Border Carbon Adjustment Mechanism (BCDM). simplification proposals He announced this in February 2025. These proposals were accepted by EU institutions. Published in the EU Official Gazette on October 17, 2025. It was published.

In order for the processes to be implemented under the SKDM during the financial obligation period starting in 2026, there are still some requirements. secondary legislation It needs to be published. This includes issues such as emission calculation and verification, verifyer accreditation, reduction of carbon fees paid in third countries, and adaptation of free allowances under the EU Emissions Trading System (ETS) to the SKDM.

SKDM Exemption and Declaration

  • Exemption: Within the scope of SKDM, the annual total Under 50 tons Companies importing iron and steel, aluminum, cement, and fertilizers (especially SMEs) exempted. If this limit is exceeded, all imports become subject to SKDM (Special Consumption Tax) obligations.

  • Declaration Process: The SKDM Declaration is submitted annually for the previous year. Until September 30th The declaration period is for the year 2026. September 30, 2027’Until.

  • Declaration Content: The declaration includes the tonnage of imported goods, emission values, corresponding emission SKDM certificates, and verification reports, all of which are electronically uploaded to the system.

  • Authorized Declarant: Verified emission data and SKDM certificates for each product must be readily available in the system by the declaration period. Additionally, crude emissions calculated by the third-country exporter must also be provided to the declarant; this information can be directly transferred to the SKDM Registration System.

SKDM Certificate Purchase

  • Obligation to Possess Certificates: The Authorized Declarant shall declare, at the end of each quarter of the year in which the import takes place, that the emissions calculated based on the assumed emission values are at least... %50’sine karşılık gelen SKDM sertifikasını They must have it readily available in the system.

  • Default Emission Value: It is determined by averaging reliable data from the top 10 exporting countries.

  • Certificate Sales: First sale February 1, 2027 Transactions will commence on [date] and will be conducted through the Commission's platform. Sales prices will be determined based on the ETS closing collection fee or the quarterly average.

  • Retrieval of Excess Certificates: After the SKDM notification process is completed, every year Until October 31st Excess certificates can be retrieved and the purchase price will be refunded.

  • Validity Period: Certificates obtained in the previous calendar year and for which no application for retrieval has been submitted. It expires on November 1st..

Certification Obligation:

    • The embodied emissions of each SKDM product are calculated according to the EU ETS limit values adapted with a free allocation factor.

    • For emissions exceeding the upper limit, an SKDM certificate is required; one certificate corresponds to 1 ton of CO₂ equivalent emissions.

    • If carbon taxes have been paid in third countries, this will be deducted from the number of certificates.

Free allocations will be gradually reduced to zero in 2034.

Emission Calculation:

  • For simple products, only the inputs in the production process are considered; for complex products, the embodied emissions of the inputs are also added.

  • Cement and fertilizer production includes indirect emissions from electricity generation.

In cases where emissions cannot be calculated, default values are used; the average of the top 10 exporting countries is taken as the basis.

Verification and Accreditation:

  • Emissions calculated by third-country exporters are verified by accredited verifiers and transferred to the SKDM Registration System.

  • Validators are authorized by the accreditation bodies of the member states; in Türkiye, accreditation will be possible through TÜRKAK.

SKDM Registration System and Declaration:

    • Emission data is transmitted electronically to the Authorized Declarant.

    • The declaration is made annually by September 30th; certificates and verification reports are added to the system.

Importer and Authorized Declarant:

    • SKDM products can only be imported into the EU by an Authorized Declarant.

    • Companies importing less than 50 tons annually are exempt.

    • The applicant must be established in the EU, and the application will be processed within a maximum of 120 days.

Responsibilities of Our Country's Exporters:

    • SKDM involves calculating embodied emissions in products.

    • Verifying the calculated emissions through accredited verifiers.

For detailed information; https://ticaret.gov.tr/dis-iliskiler/yesil-mutabakat/ab-sinirda-karbon-duzenleme-mekanizmasi/ab-skdm-tuzuk-degisikligini-iceren-torba-yasa

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