Does a Carbon Price Paid at Home Reduce Your CBAM Bill? The Real Limits of Article 9

One of the questions we hear most often from producers exporting to the EU is: “We already pay a carbon price at home — doesn’t that come off the CBAM bill?” The answer sits in Article 9 of Regulation (EU) 2023/956. But the article works more narrowly than most optimistic retellings, and any plan built without the details is a risky plan.

This article draws the frame from the Commission’s own Q&A, shows the two most-missed traps, and — as a verifier should — says plainly what cannot be known today.

What Article 9 says

The frame rests on three conditions:

• The price must have been effectively paid in the country of origin. Amounts that were rebated, refunded or otherwise compensated do not count. Where payment was made in a foreign currency, it is converted to euro at the yearly average exchange rate.
• Only compliance schemes are considered. Carbon taxes explicitly levied on embedded emissions and allowances under an emissions trading system fall within the definition; credits from voluntary carbon markets do not.
• The evidence and certification rules are set in a separate implementing act — which documents suffice, and how independent certification works, depend on it.

The point to hold on to: the existence of the article does not mean any country’s scheme is automatically taken into account. The assessment is made country by country, scheme by scheme, and it belongs to the European Commission.

Trap one: “a carbon price exists” is not “it applies to my emissions”

A country having an ETS or a carbon tax does not mean your product’s emissions carry a price. For two separate reasons:

Sector scope. Some schemes cover only the power sector — a cement or steel producer in such a country pays nothing for its emissions despite the country “having a carbon price”. The mirror image exists too: schemes that cover industry but not electricity. We keep what applies where, with sources, in our country table.

Thresholds. Most schemes cover installations above an emissions threshold. A plant below the threshold may effectively pay nothing even in a covered sector.

Trap two: free allocation

The least discussed and most decisive detail of Article 9. Where an ETS hands a producer part of its allowances free of charge, the producer has not effectively paid for that share of its emissions. And a price not effectively paid has nothing to deduct.

This matters especially for newly built schemes — because almost all of them start with high rates of free allocation to protect industry.

The Türkiye example: the regulation is out, the questions are just starting

Türkiye’s ETS Regulation was published in the Official Gazette on 27 August 2026 (No 33353). It sets a pilot period for 2026–2027 and a first implementation period for 2028–2035; coverage follows the activities in Annex-1, and free allocation with sub-installation benchmarking is foreseen.

Three things a producer should take from this:

1. A scheme is being built, and that matters in itself. One of CBAM’s highest-volume trading partners is on the way to its own carbon pricing infrastructure.
2. Its CBAM-side effect cannot be computed today. How the scheme is considered under Article 9 depends on the Commission’s assessment, and the free-allocation rate will directly shape what is effectively paid. Any calculation claiming today that “the Turkish ETS cuts CBAM costs by X” is built on data that does not yet exist.
3. The decisive factor is still in the same place: verified actual data. Whatever Article 9 brings, reporting your own emission intensity instead of the default value plus a rising mark-up remains the one cost lever fully in your control — whether that figure lands below or above the default is something only the calculation will tell you.

A verifier’s summary

Article 9 is a real possibility — but a process to watch, not a plan to build on today. Until the implementing act is out and the Commission’s assessments take shape, the soundest move is to build your own emissions data in a verifiable structure. That file serves you against the default value today and under Article 9 tomorrow — the same file in both scenarios.

Sources: Regulation (EU) 2023/956, Article 9; the European Commission’s CBAM Q&A; scheme information in the country table from ICAP, the World Bank, the Energy Community, the OECD, the IEA and the Turkish Official Gazette (27.08.2026/33353). This article is for information and makes no Article 9 eligibility claim for any country’s scheme; the final assessment belongs to the European Commission.