With the "Decree Amending the Decree on Export Subsidies" numbered 8191 published in the Official Gazette dated February 23, the definition of "Green consensus compliance project" was added to the "Decree on Export Subsidies" numbered 5973: Refers to the project for the needs analysis of companies for compliance with the European Green Deal..." definition was added. With the same Decree, Article 14 of the Decree No. 5973 was amended as follows. 

"Green deal harmonization project support

  Article 14- (1) Consultancy service expenses incurred by companies within the scope of the green consensus compliance project are supported at a rate of 50% for five years and up to 10.000.000 TL in total."

With the publication of the decision, exporters were caught in a severe storm of excitement—businesses needing help finding resources sought how they could access this export support.

It would be helpful to examine the extent to which this regulation is "fit for purpose."

The purpose of Decree 5973 is defined in Article 1 as follows: "This Decree has been prepared to regulate the expenses related to strengthening the design and institutional capacities of companies to prepare them for export and to give them a competitive advantage in international markets, to support the promotion, marketing, promotion and branding of their products abroad and the expenses related to other activities necessary to ensure the sustainable increase of our exports will be covered from the Support and Price Stabilization Fund (DFIF)."

Six circulars have also been issued stating that the Ministry of Trade's General Directorate of Export is authorized to grant all supports under the Decree on Export Supports and to evaluate exceptional circumstances or force majeure.

The Green Deal, which was put into effect in the European Union, consists of a bundle of projects with the following sub-strands: new industrial strategy, circular economy action plan, farm-to-table agriculture strategy, biodiversity strategy, clean energy, sustainable smart transportation, carbon regulation at the border, green financing and diplomacy. Under the heading of "diplomacy," the goal of "leading international efforts" in this field was announced by creating a green day for the western Balkans, developing a climate and environment partnership with China, and developing a comprehensive strategy with Africa.

The Green Financing sub-heading includes the relevant funds and who can benefit from them. Within the European Green Deal scope, it is stated that EUR 1 trillion will be provided to support sustainable investments in the EU. EUR 100 billion will be allocated under the Fair Transition Fund to help those most affected economically and socially by the green transition. Turkish entrepreneurs cannot benefit from these two funds for their investments in our country. However, it is understood that Turkish entrepreneurs can benefit from smaller-scale study and research programs such as InvestEU Union Program, Green R&D, and LIVE Union Program.

We will face the Green Deal for the first time in 22 months. Because within the scope of CBAM Regulation (EU) No 2023/956, the carbon footprint of products exported to the EU after January 1, 2026, will be monitored, and carbon tax collection will start from these products. However, data collection has already begun as of January 1, 2024, for the CBAM Certificate for tons/CO² to be allocated to importers called "Authorized CBAM Declarant" on that date.

As a country, our character is very prone to accept that "22 months is a long time; let January 1, 2026, come, and we will figure it out". We can also define this as "sweeping the problem under the carpet until the egg is stuck in the door."

Or someone else might say, "Why are we so alarmed? Let countries like China, which exports the most to the EU, figure out what to do first".

Let us tell you: China has established a pilot ETS (Emissions Trading System) in 2021. It has already developed a market worth EUR 400 million. Let's leave aside developed economies such as Japan and South Korea. Indonesia established a pilot ETS system in 2021. Chile introduced "green car criteria" in 2014 and decided to close all coal plants by mutual agreement in 2040. Mexico established a pilot ETS system in 2020. Argentina established the ETS market with all its mechanisms in 2021. In the market, ton/CO² prices are traded at USD 10.

We are still in the period of "allocation of consultancy service expenses" at the level of "raising awareness" and "preparation of seminars or training programs to carry out awareness-raising activities."

Interestingly, we do this from the resources allocated for export promotion. "What does the source matter? Isn't the important thing to provide consultancy on the Green Deal?"

However, the picture will look different for outsiders. When we look at the issue at the business level, should it be vital to make investments that reduce carbon emissions by reviewing production processes or to train your marketing department on the Green Deal? If you are training your marketing department staff without changing your production processes, you will be perceived to be preparing for an eyewash.

When the issue is approached at the country level rather than the enterprise level, one would expect these funds to be allocated by the Ministry of Industry and Technology under Law No. 5084 on the Promotion of Investments and Employment. Green Deal funds provided by the Ministry of Trade (General Directorate of Export) can be considered a "marketing activity."

No matter how pure the intentions of the Ministry of Trade, this is how the European Union will take the picture.