What changed, and what it is
| Instrument | Status | Who it binds |
|---|---|---|
| CBAM (EU Carbon Border Adjustment Mechanism) | Definitive period began 1 January 2026; one CBAM certificate is surrendered per tonne of CO₂e [1]. | The declarant importing covered goods into the EU; the burden passes down the chain to the exporter. |
| Climate Law No. 7552 | In force since 9 July 2025; it sets the legal framework for the national ETS. Secondary regulation is due by 31 December 2027 [2][3]. | Facilities with direct greenhouse gas emissions; it introduces a permit obligation. |
| Turkish ETS Regulation | Published 27 August 2026; it starts with a pilot period [3]. | Facilities emitting 50,000–500,000 tCO₂e (B) and above 500,000 t (C): combustion, refining, steel, cement, glass, ceramics, paper, chemicals [3]. |
This is a summary of the rules, not legal advice. Confirm your own obligation with an adviser, against your activity codes and export structure.
Why the warehouse is out of scope, and what that does not change
The regulation's lowest threshold is 50,000 tonnes of CO₂ equivalent a year [3]. A warehouse — including cold storage — sits far below that, and storage is not among the listed activities. So you will not need an emissions permit or allowances for your warehouse.
What does not change: a customer inside the scope will ask you for data. A manufacturer preparing a CBAM declaration or corporate report has to account for the transport and storage leg too, and can only do so with your figures. If you are a 3PL, that request becomes a contract annex. So the warehouse question is not “am I compliant?” but “can I produce the data being asked for?”.
The data a WMS can genuinely provide
A WMS is not a carbon calculator, and it is worth being cautious about products sold as one. What a WMS does is produce activity data; multiplying it by an emission factor is the job of a calculation tool or an adviser. Keeping that boundary matters, because factors change while activity data endures.
| Activity data | Where it comes from in the WMS | What it feeds |
|---|---|---|
| Shipment weight and volume | Carton and pallet records, volumetric weight | Transport emissions |
| Shipment count and fill rate | Dispatch and loading records | Making empty-running visible |
| Packaging consumption | Pack station and consumables records | Packaging reporting and waste reduction |
| Return rate | Return records and reasons | The burden of reverse logistics |
| Equipment runtime | Forklift and equipment task logs | Estimating energy use |
| Dwell time and area | Stock age and location occupancy reports | The storage leg's share |
Most of this data already exists in the system; what is usually missing is a report that can be exported and filtered by date range. That is the first thing to ask a vendor.
Ask the vendor
- Can I export weight, volume and distance per shipment for a date range?
- Is packaging consumption (cartons, filler, tape) recorded per item or per order?
- Are equipment task durations reportable; can I pull forklift hours?
- Can I feed these to a carbon calculation tool over an API, or is it spreadsheet only?
- Can I produce a customer-specific report containing only that customer's data?
- Are emission factors embedded in the product? (If so, ask which source and which vintage.)
We mark solutions whose sources state these capabilities; see the reporting and integration side in the <a href="/en/analysis/erp-wms-integration-matrix">ERP–WMS integration matrix</a> and on solution profiles. To see which data you already hold, build your site in the <a href="/en/warehouse-model">floor model</a> and read the summary it produces.
Frequently asked questions
Is my warehouse covered by emissions trading (ETS)?
Almost certainly not. The lowest threshold in the Turkish ETS Regulation is 50,000 tonnes of CO₂ equivalent a year, and storage is not among the covered activities. A warehouse, including cold storage, sits far below that.
So why does carbon reach the warehouse at all?
A customer inside the scope will ask you for data. A manufacturer preparing a CBAM declaration or corporate report must account for the transport and storage leg, and can only do so with your figures. If you are a 3PL, that request becomes a contract annex.
Does a WMS calculate carbon?
A WMS is not a carbon calculator. What it does is produce activity data: shipment weight and volume, vehicle fill, packaging consumption, return rate, equipment runtime and dwell time. Multiplying by an emission factor is the job of a calculation tool or an adviser; factors change while activity data endures.
When did CBAM start?
The EU's Carbon Border Adjustment Mechanism entered its definitive, financially binding period on 1 January 2026; one certificate is surrendered per tonne of CO₂ equivalent. In Turkey, Climate Law No. 7552 came into force on 9 July 2025 and the ETS Regulation was published on 27 August 2026.
Sources
- Ankara Chamber of Industry, “CBAM Company Guide” — aso.org.tr (accessed: 2026-09-26)
- Turkish Directorate of Climate Change, “Turkey's first Climate Law enacted” — iklim.gov.tr (accessed: 2026-09-26)
- Erdem & Erdem, “Turkish Emissions Trading System Regulation published” — erdem-erdem.av.tr (accessed: 2026-09-26)
Method and corrections: editorial policy.