Extended Producer Responsibility (EPR) in Turkey: Full Guide on Scope, Registration, Reporting & Fees

Introduction

Sustainability regulations are no longer aspirational—they are binding business obligations.
In Turkey, the Extended Producer Responsibility (EPR) framework is reshaping how manufacturers, importers, and online sellers handle waste, packaging, and post-consumer materials.
Whether you are an EU-based manufacturer exporting to Turkey or a local distributor, this guide explains the scope, registration steps, timelines, reporting cadence, PRO options, and cost implications of Turkey’s EPR system.

1. What Is EPR and Why It Matters

EPR (Extended Producer Responsibility) is an environmental policy approach under which producers bear responsibility for the entire life cycle of their products — from design and distribution to collection, recycling, and final disposal.
The principle is simple: “the polluter pays.”

Implemented across the EU and increasingly aligned in Turkey, EPR ensures that companies internalize environmental costs rather than shifting them to society.

2. Legal Framework and Scope in Turkey

2.1 Core Regulations

Turkey’s EPR regime is primarily regulated through:

• Packaging Waste Control Regulation (June 26 2021) — superseding prior packaging directives.

• Regulation on Waste Electrical and Electronic Equipment (WEEE, 2023 revision) — aligning with EU Directive 2012/19/EU.

• Battery and Accumulator Waste Management Regulation.

• Future plans for textile EPR under the EU Green Deal adaptation process.

Authorities:

• Ministry of Environment, Urbanization, and Climate Change (MoEUCC)

• Environmental Agency of Turkey (Çevre Ajansı) for data, audits, and fee collection.

2.2 Product Categories Covered

EPR applies to anyone placing goods on the Turkish market, including importers and foreign manufacturers selling online.
Main categories include:

If you sell packaged products, electronic goods, or batteries in Turkey, you are legally required to register and report under EPR.

3. Registration Process: Step by Step

3.1 Who Must Register

• Any company that produces, imports, or sells products within the scope of the regulations.

• Foreign manufacturers must appoint an Authorized Representative (AR) established in Turkey.

• E-commerce platforms may be jointly liable when representing foreign sellers.

3.2 Role of the Authorized Representative (AR)

Foreign entities cannot directly register.
They must appoint a locally based AR, who:

• Acts as official contact with Turkish authorities.

• Manages registrations, filings, and audits.

• Pays environmental participation fees (GEKAP).

• Maintains product and packaging data records.

AR services are typically offered by professional compliance or CPA firms — such as OZM Consultancy — ensuring seamless communication and local legal coverage.

3.3 Registration Steps

1. Determine scope: Identify which of your products are under EPR.

2. Sign AR mandate (if foreign manufacturer).

3. Register on the Packaging Information System (Ambalaj Bilgi Sistemi) or MoEUCC E-Devlet platform.

4. Submit product and material declarations.

5. Receive registration confirmation.

6. Start quarterly or annual reporting.

3.4 Timelines

• Regulations become effective upon publication (e.g., Packaging Regulation on 26 June 2021, WEEE revision 1 February 2023).

• New market entrants must register before the first sale in Turkey.

• Reporting cycles: Quarterly (GEKAP) and Annual (EPR declarations).

4. Reporting and Compliance Obligations

4.1 Reporting Cadence

Data includes quantities of materials placed on market, collected, recycled, and recovered.
Digital reporting is mandatory, and misreporting may trigger penalties or license suspension.

4.2 Audit & Recordkeeping

• All producers and ARs must maintain supporting documents (sales invoices, recycling certificates, contracts) for minimum 10 years.

• Authorities may conduct on-site inspections or request electronic data uploads.

• Non-compliance can lead to fines, sales bans, or deregistration.

5. PRO (Producer Responsibility Organization) Options

5.1 Definition

A Producer Responsibility Organization (PRO) allows companies to collectively fulfill their EPR duties — pooling logistics, recycling, and reporting functions.

5.2 Collective vs. Individual Compliance

Most international producers join a PRO for efficiency, especially when managing multiple product lines (e.g., electronics, batteries, packaging).

6. Fees and Financial Obligations

6.1 How Fees Are Calculated

EPR fees depend on:

• Material type and weight (plastic, glass, metal, paper).

• Product quantity placed on market.

• Eco-design attributes (e.g., recyclability, reusable packaging).

• Administrative and collection costs.

Turkey applies eco-modulation principles similar to the EU: environmentally friendly designs pay less.

6.2 GEKAP (Environmental Contribution Fee)

Manufacturers and importers must pay GEKAP quarterly through the Ministry’s portal.
Fees are based on product type and unit weight (₺/kg).
ARs or PROs usually manage GEKAP filings and payments on behalf of foreign entities.

6.3 Typical Cost Structure

7. Challenges & Practical Risks

• Data accuracy – ensure internal ERP systems track packaging and product volumes precisely.

• Regulatory volatility – EPR rules evolve annually; follow MoEUCC updates.

• Cross-border consistency – harmonize Turkish filings with EU EPR data where possible.

• Supplier coordination – collect data from subcontractors and recyclers for traceability.

• Penalties – non-compliance can trigger both administrative fines and customs restrictions.

8. Practical Roadmap for Companies

1. Conduct an EPR gap analysis – map your product portfolio and volumes.

2. Appoint an Authorized Representative (if foreign entity).

3. Choose a PRO or individual compliance route.

4. Set up internal data collection systems (ERP, SKU tracking, packaging specs).

5. Integrate EPR costs into pricing models.

6. Train staff on reporting and documentation requirements.

7. Review compliance annually — ensure timely filings and payment of GEKAP fees.

09. Reach us

If your company places products or packaging on the Turkish market, you are likely already subject to EPR.
Proper registration and reporting are essential not only for compliance but also for maintaining import/export licenses and brand reputation.

At OZM Consultancy, we provide:

• End-to-end EPR registration and reporting services,

• Authorized Representative (AR) mandate setup,

• PRO coordination and GEKAP filings, and

• Environmental compliance audits for electronics, packaging, and battery producers.

👉 Contact us to assess your EPR exposure in Turkey and establish full compliance before the next reporting cycle.

info@ozmconsultancy.com