Türkiye - Sustainability Claims and Greenwashing
What are the top 3 developments in your territory concerning green claims and the associated risk of greenwashing?
As sustainability awareness grows among companies and consumers in Türkiye, businesses are adapting their practices to meet environmental goals while regulators continue to develop and enforce sustainability standards. With consumer preferences increasingly shaped by sustainability considerations, green claims and the associated risk of greenwashing are expected to rise.
The three most significant recent developments in Türkiye relevant to greenwashing are:
1. Türkiye introduces First Statutory Definition of Environmental Claims in Advertising Law
On 1 July 2026, the Ministry of Trade published the Regulation Amending the Regulation on Commercial Advertising and Unfair Commercial Practices in the Official Gazette numbered 33297 (Ticari Reklam ve Haksız Ticari Uygulamalar Yönetmeliğinde değişiklik yapılmasına dair Yönetmelik).
For the first time, the Regulation defines an environmental claim (çevresel beyan) in Turkish advertising law as any statement or visual relating to a good or service’s components, production, placing on the market, presentation, use or disposal that asserts an environmental benefit, or a reduced or absent adverse environmental impact.
The amendment requires that any certificates or approvals referred to in an advertisement containing an environmental claim be substantiated by documents obtained from competent or accredited bodies, relevant university departments, or accredited or independent research, testing and evaluation organisations.
General or vague environmental terms may no longer be used in advertising without explanation, or in a way that creates ambiguity for consumers as to the environmental effects of the product, service or its production processes.
Advertisers must clearly state which part, component or life-cycle stage of the product or service an environmental claim relates to, and must make information on the underlying measurement or evaluation methods easily accessible to consumers, for example through a link, warning sign or pop-up screen.
The same amendment introduces parallel transparency obligations for social media influencer marketing, AI-generated advertising content and consumer reviews, and revises the rules governing discount advertising, reflecting a broader modernisation of Turkish advertising law of which the new environmental claims regime forms a core part.
2. With the amendment entering into force on 1 August 2026, advertisers and brand owners have a narrow window to bring existing environmental marketing claims into line with the new substantiation and disclosure requirements making this the most immediate greenwashing-related development in the Turkish market.Enhancement of potential consumer claims due to greenwashing.
Currently, there are only a few examples of greenwashing-related lawsuits in Türkiye. However, as consumer awareness grows, such litigation is likely to increase significantly.
The main legislation that allows claims based on greenwashing practices are the Consumer Protection Law numbered 6502 (Tüketicinin Korunması Hakkında Kanun, the “Consumer Law”), the Turkish Commercial Code numbered 6102 (Türk Ticaret Kanunu, the “Commercial Code”), the Regulation and the Environmental Law numbered 2872 (Çevre Kanunu, the “Environmental Law”). In addition, several secondary pieces of legislation could also affect greenwashing claims, such as the Corporate Governance Communique and the Framework for Compliance with Sustainability Principles of the Capital Markets Board.
Under the Consumer Law, consumers may claim damages under the concept of “defective goods” where the goods lack the characteristics indicated by the seller or stated on their packaging, advertising or label. In addition, the Consumer Law provides for sanctions and fines for non-compliance with advertising prohibitions, in particular the prohibition of misleading advertising and of misleading practices constituting unfair commercial practices.
The Commercial Code provides that misleading statements about goods, products, activities or business relationships may constitute unfair competition, giving rise to both civil and criminal liability, including damages claims.
Turkish authorities tend to adopt strict measures on sensitive matters such as renewable energy, public health and food safety, areas closely linked to ESG principles and therefore exposed to greenwashing risk. In recent years, food security and nutrition have become major consumer preference criteria, further increasing greenwashing exposure in these fields.
A further statutory basis for greenwashing exposure has since emerged. Since 1 January 2024, companies within scope must prepare sustainability reports under the Turkish Sustainability Reporting Standards (Türkiye Sürdürülebilirlik Raporlama Standartları, “TSRS”) issued by the Public Oversight, Accounting and Auditing Standards Authority (Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu, “KGK”), based on the IFRS Foundation’s ISSB standards (TSRS 1 and TSRS 2). Following the Sustainability Audit Regulation published on 17 January 2025, these reports are subject to mandatory external assurance. As TSRS reports contain climate, emissions and governance disclosures prepared alongside financial statements, misleading or unsubstantiated statements may now be challenged as false financial disclosure, in addition to claims under the Consumer Law, the Commercial Code and the Environmental Law.
3. Türkiye enacts its first Climate Change Law
Türkiye's first Climate Law numbered 7552 (İklim Kanunu, the “Law”) entered into force on publication in the Official Gazette numbered 32951 on 9 July 2025. It is the country's first comprehensive, binding legal framework on climate change, replacing the 2022 draft referred to in earlier editions of this chapter.
The Law is designed to advance Türkiye's green growth vision and its 2053 net-zero emissions target. It establishes the legal and institutional framework for reducing greenhouse gas emissions, for adaptation to climate change, and for related planning, permitting and monitoring instruments.
A new Climate Change Directorate (İklim Değişikliği Başkanlığı) is established as the Law's principal implementing and enforcement authority, empowered to prepare national, sectoral and thematic reports, to develop climate-related incentive mechanisms, and to establish and operate the Türkiye Green Taxonomy. A Carbon Market Board (Karbon Piyasası Kurulu) has also been created to oversee the carbon market.
The Law introduces, for the first time in Turkish legislation, defined concepts directly relevant to green and sustainability claims, including net-zero emissions, just transition, climate justice, carbon credit, Emissions Trading System (“ETS”), allocation, embedded greenhouse gas emissions, primary market, offsetting and voluntary carbon markets. A carbon border adjustment mechanism may also be established for imported goods to address their embedded emissions.
Implementation is phased. The secondary legislation and planning instruments required under the Law must be adopted by 31 December 2027, a deadline the President may extend by up to one year. Key operative details including the scope of the ETS and the Türkiye Green Taxonomy will therefore be determined through secondary legislation over the coming one to two years.
For greenwashing purposes, the Law’s practical significance lies not in any new claims mechanism but in the fact that Türkiye now has an official statutory taxonomy and a defined vocabulary of green and carbon-related terms. Once the taxonomy and its secondary legislation are in place, they will provide a benchmark against which regulators, competitors and consumers can test the accuracy of green claims materially increasing the legal and reputational exposure of unsubstantiated claims in Türkiye.
This policy direction was further reinforced on 4 July 2026 with the publication of Türkiye’s National Green Finance Strategy and Action Plan 2026–2029 (“Ulusal Yeşil Finans Stratejisi ve Eylem Planı (2026–2029)”) through Presidential Circular numbered 2026/8, published in Official Gazette numbered 33300. The Strategy envisages the completion of the Türkiye Green Taxonomy and the operationalisation of the Emissions Trading System within 2026, while positioning the financial sector as a key enabler of the country’s 2053 net-zero emissions objective.
