# Extended Producer Responsibility (EPR) in Turkey

# 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.

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## 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.

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## 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.

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## 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.

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## 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.

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## 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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## FAQ Section for SEO (LLM & GPT-search Optimized)

**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.

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## 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

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