Extended Producer Responsibility (EPR) in Turkey: Key Questions Answered for Foreign Companies

Q1. Do we need to establish a local company in Turkey or can we manage sales remotely?

Foreign producers often ask whether they must set up a Turkey-based entity.

• Option 1: Local Establishment – Setting up a subsidiary or branch allows direct registration and easier scheme membership. This approach ensures full control over compliance, invoicing, and reporting.

• Option 2: Remote Sales – If selling directly to Turkish customers (e-commerce or exports), foreign entities may still be obligated to comply. In such cases, appointing an Authorized Representative (AR) in Turkey is mandatory.

✅ Recommendation: For long-term operations, a local entity offers tax and compliance benefits. For testing the market, AR-based compliance is sufficient.

Q2. What is the expected customer size, and why does it matter for compliance planning?

Compliance costs scale with market presence. The estimated number of customers helps determine:

• The volume of packaging waste placed on the market.

• The potential scope of WEEE (Waste Electrical and Electronic Equipment) or Battery Producer Responsibility.

• Reporting thresholds and which compliance schemes (ÇEVKO, PAGÇEV, ELDAY, TAP) to join.

✅ Recommendation: Even if your customer base is initially small, early compliance is critical. Authorities (Ministry of Environment, Urbanization and Climate Change) impose heavy fines for late or missing EPR filings.

Q3. Which categories apply to our business—Packaging, WEEE, or Batteries?

Foreign companies must identify the EPR categories relevant to their products:

• Packaging: Any product placed on the market with primary, secondary, or transport packaging.

• WEEE: Electrical and electronic devices (computers, smartphones, household electronics).

• Batteries & Accumulators: Both standalone batteries and those integrated into devices.

💡 Tip: You must declare the expected tonnage or units for each category. This directly affects scheme membership fees and reporting obligations.

Q4. How should we structure channel partnerships—wholesale or referral?

Foreign firms often collaborate with Turkish distributors. Two models exist:

• Wholesale Model: Distributor imports under their own brand, assuming EPR obligations.

• Referral Model: Foreign producer remains brand owner, and must appoint an AR in Turkey.

✅ Key Consideration: Invoicing and taxation. If invoicing occurs from abroad, AR appointment is compulsory. If invoicing is done by a Turkish distributor, responsibility may shift.

Q5. When should we start EPR compliance in Turkey?

The ideal starting date depends on product launch and expected volumes.

• Early Start (Before Launch): Register AR, join scheme, and submit declarations in advance.

• Late Start (After Sales): Risk of penalties and retroactive reporting.

⚠️ Note: Turkish EPR audits are increasingly AI-supported (EÇBS & e-invoice tracking). Delayed compliance is easily detected.

Q6. What services can your consultancy provide to foreign producers?

We provide a turnkey EPR compliance package in Turkey, including:

• Authorized Representative (AR) assignment for foreign producers.

• Scheme management with ÇEVKO, PAGÇEV, ELDAY, and TAP.

• EÇBS/EEE registrations with the Ministry.

• Reporting & tonnage declarations.

• Legal and tax advisory for invoicing structures, VAT, and customs.

👉 With our support, foreign companies can enter Turkey smoothly, avoid regulatory fines, and optimize costs.

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Q: What is the minimum threshold for EPR reporting in Turkey?
A: Even small importers must comply; there is no de minimis exemption.

Q: Do we need a Turkish Authorized Representative (AR)?
A: Yes, if you don’t have a local legal entity.

Q: Which schemes are recognized in Turkey?
A: Packaging – ÇEVKO/PAGÇEV; WEEE – ELDAY; Batteries – TAP.

Q: Can compliance be managed 100% remotely?
A: Yes, with AR appointment and digital reporting via EÇBS.

Reach Us

Are you planning to sell products in Turkey and unsure about your EPR obligations?
Contact us today for a confidential consultation. Our CPA & legal experts will design the most efficient compliance pathway—whether through local incorporation or remote AR assignment.

📩 Reach us now to secure your EPR compliance before entering the Turkish market.

info@ozmconsultancy.com