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EPR Services Turkey: Complete Guide for Foreign Companies

EPR Services Turkey: Complete Guide for Foreign Companies

Published
6 min read
EPR Services Turkey: Complete Guide for Foreign Companies
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I’m Evren ozmen, a CPA based in Istanbul, advising remote workers, freelancers, and international founders on Turkish tax and cross-border structuring. I focus on practical tax strategies around: 100% service export income deduction Tax residency in Turkey Company formation for foreigners Remote work and international income I break down complex tax rules into clear, actionable guidance — without losing the legal and compliance reality behind them. info@ozmconsultancy.com 🇹🇷 Türkiye genelinde; yazılım ve dijital ürün geliştiren şirketler, yurt dışına uzaktan hizmet sunan profesyoneller, Teknopark firmaları, oyun stüdyoları ve mobil uygulama şirketlerine Türkçe ve İngilizce mali ve vergisel danışmanlık hizmetleri sunuyoruz. 📘 Insights & Publications: https://medium.com/@evrenozmen 📩 For Online Tax Advisory & Accounting Services/Danışmanlık-Mali Müşavirlik Hizmetleri: info@ozmconsultancy.com

EPR Services Turkey: Complete Guide for Foreign Companies

Introduction: Why EPR Compliance in Turkey Matters

Environmental compliance is no longer a regional option but a global requirement. As sustainability regulations expand, countries are tightening controls over how businesses manage packaging waste, electronics, and batteries after their products reach consumers. Turkey, strategically located between the European Union and Asia, has taken significant steps to align its waste management and environmental rules with EU directives.

For any foreign company exporting goods to Turkey, whether through traditional trade channels or digital platforms such as Amazon, Etsy, or eBay, Extended Producer Responsibility (EPR) obligations apply. Non-compliance is not a theoretical risk—it can result in financial penalties, import restrictions, and reputational damage.

This guide provides a comprehensive overview of EPR services in Turkey:

  • What EPR means globally and locally

  • Which categories (packaging, WEEE, batteries) are covered

  • How the Authorized Representative (AR) model works for foreign companies

  • Step-by-step compliance processes

  • Risks of non-compliance

  • Practical examples for e-commerce sellers

  • Why partnering with a local compliance provider is critical

By the end of this article, you will know exactly how to structure your company’s compliance roadmap for the Turkish market.


What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a regulatory approach that shifts the responsibility for post-consumer waste management from governments and municipalities to the producers and importers of products.

In practice, companies must:

  1. Register with environmental authorities and Producer Responsibility Organizations (PROs)

  2. Report the quantities and types of packaging, electronics, or batteries they place on the market

  3. Finance the collection, recycling, and safe disposal of these products

  4. Ensure transparency through annual audits and compliance certificates

The rationale behind EPR is simple: companies that profit from selling products should also bear the costs of managing the waste generated by those products.

Globally, EPR covers:

  • Packaging: plastic, cardboard, glass, and metal packaging

  • WEEE: Waste Electrical and Electronic Equipment

  • Batteries and accumulators

  • In some jurisdictions: tires, oils, textiles, furniture, and other product categories

Turkey has implemented these frameworks in alignment with EU standards.


Turkey has taken significant steps to harmonize its waste management regulations with the EU Waste Framework Directive. The key regulations governing EPR obligations in Turkey include:

  • Regulation on Packaging Waste Control

  • Regulation on Waste Electrical and Electronic Equipment (WEEE)

  • Regulation on Waste Batteries and Accumulators

These regulations impose specific obligations on companies placing products on the Turkish market, including foreign entities without a local subsidiary. In such cases, an Authorized Representative (AR) is mandatory.

Failure to comply can lead to:

  • Administrative fines

  • Sales and import restrictions

  • Customs clearance delays

  • Reputational damage in an increasingly sustainability-conscious market


EPR Categories in Turkey

Foreign companies selling to Turkey must assess which categories of EPR apply to their business model.

EPR CategoryExamples of ProductsObligation
PackagingPlastic bottles, cardboard boxes, metal cans, glass jarsRegistration, volume reporting, recycling contribution
WEEEComputers, phones, household electronics, lighting equipmentTake-back schemes, recycling targets, reporting
Batteries & AccumulatorsHousehold batteries, rechargeable lithium-ion, industrial batteriesCollection, recycling, safe disposal
Emerging CategoriesTires, textiles, oils, furnitureSector-specific schemes, future compliance obligations

Even companies with low volumes of sales may still face reporting obligations.


Do Foreign Companies Need an Authorized Representative in Turkey?

Yes. Non-resident companies cannot register directly with Turkish authorities for EPR obligations. Instead, they must appoint an Authorized Representative (AR).

The AR acts as the legal entity responsible for:

  • Registering the foreign company with Turkish environmental authorities

  • Submitting regular compliance reports in Turkish

  • Coordinating with waste management and recycling schemes

  • Serving as the official contact point during audits or inspections

This model is similar to the EU Authorized Representative concept, but with distinct Turkish regulatory nuances.

Companies that typically require an AR in Turkey include:

  • Amazon, Etsy, and eBay sellers shipping directly into Turkey

  • E-commerce platforms offering cross-border sales

  • Electronics manufacturers exporting WEEE-covered products

  • Food and beverage companies with packaged goods


The EPR Compliance Process in Turkey

EPR services in Turkey usually follow a structured, multi-step process:

Step 1: Initial Assessment

  • Identify applicable product categories (packaging, WEEE, batteries)

  • Calculate annual sales volumes and packaging weights

Step 2: Registration

  • Register with the Ministry of Environment, Urbanization, and Climate Change

  • Obtain necessary permits and compliance accounts

Step 3: Data Reporting

  • Report volumes and categories of products placed on the market

  • Submit quarterly or annual declarations depending on product type

Step 4: Contracting with Recycling Schemes

  • Engage with licensed Producer Responsibility Organizations (PROs)

  • Pay recycling and waste management fees

Step 5: Annual Compliance and Audits

  • Provide documentation for inspections

  • Receive compliance certificates to maintain market access


Penalties for Non-Compliance

Turkey imposes strict sanctions for companies that ignore EPR obligations.

ViolationPossible Sanction
Failure to registerAdministrative fines
Failure to report volumesMonetary penalties, additional audits
Non-payment of recycling contributionsSuspension of sales, customs block
Fraudulent reportingHigher fines, reputational damage

In practice, penalties are not only financial. A company facing customs clearance issues or shipment holds may incur significant operational losses.


Case Study: E-Commerce Sellers and Marketplaces

Consider a German company selling smartphone accessories through Amazon to Turkish customers:

  • Packaging: Plastic retail packaging triggers packaging EPR obligations.

  • Electronics: If accessories contain electronic components, WEEE obligations apply.

  • Batteries: Products with rechargeable batteries must comply with battery regulations.

Since the company has no Turkish legal entity, it must appoint an Authorized Representative who will handle registration and reporting. Without AR compliance, customs may block shipments or apply fines.

Similarly, an Etsy seller exporting handmade candles must comply with packaging waste regulations if the products are shipped with plastic or cardboard packaging.


Why Partner with a Local EPR Compliance Provider?

While some companies attempt to manage compliance remotely, this approach is rarely successful due to:

  • Language barriers (all reporting is in Turkish)

  • Bureaucratic complexity (different portals, agencies, and deadlines)

  • Cultural and legal differences (interpretation of EU-aligned rules in a Turkish context)

By working with a local EPR services provider in Turkey, foreign companies benefit from:

  • End-to-end compliance management

  • Transparent reporting and recordkeeping

  • Direct communication with authorities

  • Cost optimization through efficient recycling scheme contracts

  • Reduced compliance risks and uninterrupted market access


Frequently Asked Questions (FAQ)

1. What is EPR in Turkey?
EPR (Extended Producer Responsibility) in Turkey requires producers and importers to take responsibility for the collection, recycling, and disposal of packaging, WEEE, and batteries.

2. Do foreign companies need an Authorized Representative?
Yes. Non-resident companies cannot register directly and must appoint a local AR.

3. Which product categories are covered?
Packaging, electronics (WEEE), and batteries are the main categories, with tires, oils, and textiles emerging.

4. Are small sellers exempt?
Thresholds may apply, but even small-volume sellers must evaluate compliance obligations.

5. What are the penalties for non-compliance?
Fines, customs clearance issues, and potential bans on placing products on the Turkish market.


Conclusion: Secure Your Market Access with Proper EPR Services

Turkey’s alignment with EU environmental directives means that EPR compliance is no longer optional for foreign companies. Whether you sell packaged goods, electronics, or batteries, you must ensure compliance with Turkish regulations.

The key to success lies in appointing a trusted Authorized Representative who can handle registration, reporting, and ongoing compliance.

👉 If your company is planning to sell in Turkey, now is the time to establish your EPR compliance strategy. Contact us today to discuss tailored EPR services in Turkey and secure your market access without risk.

info@ozmconsultancy.com