Plastics and packaging laws in Turkey

1. What is the general legislative framework regulating packaging and plastic waste in your jurisdiction?

The general legal framework for the regulation of packaging and plastic waste is defined by: Environmental Act No. 2872, the Waste Management Ordinance and the Ordinance on the Management of Packaging Waste. In addition, a Draft Regulation on the Management of Packaging Waste ("Draft Regulation") has been published, which is not yet in force.

The above general legal framework aims at protecting natural resources, implementing the use of clean technology to ensure that production is in line with the sustainable environment and sustainable development principles, and promoting the production, design and use of more durable, reusable and recyclable products.

2. Are there any measures, existing or expected, in respect of single-use plastics?

The Ordinance on the Management of Packaging Waste states as a general principle that recyclable packaging is preferable to single-use plastics and further states that it is essential to include single-use packaging in the recycling process. In this context, the Packaging Waste Management Regulation provides for the introduction of a deposit-return system aimed at returning single-use packaging to the seller and achieving certain annual targets based on recycling rates. In addition, the Draft Regulation also emphasises the above principles.

3. Are there any existing or expected producer responsibility schemes in place for packaging or plastics?

Yes, according to the Ordinance on the Management of Packaging Waste, producers are obliged to comply with the Extended Producer Responsibility standards, design and produce packaging in such a way that it is suitable for recycling and ensures minimum potential harm to the environment, provide training for recycling and comply with the general principles of packaging production and release in the market. Extended producer liability has been further specified in the Draft Regulation. 

Accordingly, producers will be responsible for implementing methods to ensure the efficient use of products throughout their life cycle, including repair, reuse and recycling. The draft regulation empowers the Ministry of Environment and Urbanisation to establish the principles and procedures of extended producer liability.

4. Are there any existing or expected deposit return schemes (“DRS”) in place for packaging or plastics?

Yes, according to the additional Article 12 of the Environmental Law, the implementation of deposit return will be mandatory for various types of packaging and products, as determined by the Ministry from 1 January 2022

The parties involved in the process, such as manufacturers, sellers, distributors of products, etc., must fulfil the relevant obligations, such as releasing certain products under the deposit return system in accordance with the principles for sellers to be established by the Ministry and fulfilling the conditions for participation in the deposit-return system, etc. If these obligations are not fulfilled, administrative penalties will be imposed. 

Furthermore, the draft regulation introduces several additional obligations through the deposit-return system for the parties involved, such as registration in the deposit-management system, compliance with the additional criteria set by the deposit-system administrator (i.e. the Turkish Environmental Protection Agency), etc.

5. Are there any existing or expected taxes on packaging or plastics?

Yes, sellers, importers and product importers are required to pay "recycling contribution shares" (geri kazanım katılım payı) for certain goods and products specified in the Environmental Law. Parties that do not comply with this requirement are subject to administrative penalties.

Some examples of recycling contribution shares for 2021 include: TRY 0.19 for each plastic bag, TRY 2.1 for each rubber tyre, TRY 0.43 per kilogram for plastic packaging (except beverage packaging and plastic bags), etc.

6. Are there any measures, existing or expected, regarding micro-plastics or the use of microbeads in products?

There are no measures regarding microplastics or microbeads in Tukey.

7. Are there any existing or expected recycling or waste reduction targets in place for packaging or plastics?

Even though no specific targets have been set for packaging and/or plastic waste, plastics and plastic waste fall within the scope of the Zero Waste Management System, the implementation of which is intended to ensure environmental sustainability. 

Zero Waste Management System is a waste management model applied by local governments, certain structures and institutions (e.g. airports, hospitals, shopping centers, retail chains, etc.) and voluntarily by other institutions and/or organisations, which establishes several objectives, principles and strategies, such as avoiding waste production when avoiding waste disposal is not possible, reducing the amount of waste, storing and separating the waste produced in accordance with the established principles, ensuring that temporary storage is not harmful to the environment and human health, etc. 

Organisations receive Zero Waste certificates to the extent that they comply with the principles of the system.

8. Is the use of recycled materials in food packaging regulated?

The use of recycled materials in food packaging is not regulated in Turkey.

The Draft Regulation on the management of packaging waste was published with the intention of obtaining the opinions of the relevant institutions and experts. After the finalisation and adoption of the draft, we expect a new regulation on this issue.

Portrait of Döne Yalçın
Döne Yalçın
Managing Partner Turkey
Istanbul
Portrait of Alican Babalioglu
Alican Babalioglu
Managing Partner
Istanbul
Portrait of Taner Elmas
Taner Elmas
Naz Ugurlu