# Extended Producer Responsibility (EPR) in Turkey: Full Guide on Scope, Registration, Reporting & Fees # **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: | Category | Key Regulation | Responsible Entity | | --- | --- | --- | | Packaging | Packaging Waste Control Regulation (2021) | Producers / Importers / E-commerce Sellers | | Electronics (WEEE) | Regulation on WEEE (2023) | Manufacturers / Importers | | Batteries | Battery and Accumulator Regulation | Battery Manufacturers / Importers | | Textiles (expected) | Under preparation (2025–2026) | Producers / Retailers | 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** | Report Type | Frequency | Submitted To | | --- | --- | --- | | GEKAP Declaration | Quarterly | Environmental Agency of Turkey | | EPR Packaging Report | Annual | MoEUCC / E-Devlet System | | WEEE Data Report | Annual | MoEUCC | | Authorized Representative Audit Summary | Annual | Upon request | 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** | Compliance Route | Advantages | Drawbacks | | --- | --- | --- | | **Collective (PRO)** | Shared costs, simplified logistics, lower admin burden | Less control, standardized fees | | **Individual** | Full control, possible fee optimization | Higher operational cost, greater audit exposure | 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** | Cost Element | Description | | --- | --- | | Registration & AR Service | One-time + annual retainer | | PRO Membership Fee | Annual base fee + per-unit charge | | GEKAP Environmental Fee | Quarterly based on kg/unit | | Audit & Reporting | Optional CPA verification or consultancy | --- ## **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