Communiqué on Administrative Fines to Be Imposed Pursuant to Environmental Law No. 2872 (2025)

The Ministry of Environment, Urbanisation and Climate Change’s “Communiqué on Administrative Fines to Be Imposed Pursuant to Environmental Law No. 2872 (2025/1)” was published in the Official Gazette dated 24 December 2024, No. 32762. It sets the amounts of the administrative fines in Article 20 of the Environmental Law that apply between 1 January 2025 and 31 December 2025. This entry concerns 2025. Because the amounts are revalued every year, the 2026/1 Communiqué, published in the Official Gazette dated 30 December 2025, No. 33123, is the one in force for 2026.

Why do the fines in the Environmental Law change every year?

The amounts in Article 20 of the Environmental Law are increased by the revaluation rate announced under repeated Article 298 of Tax Procedure Law No. 213. For the 2025 amounts, the 2024 revaluation rate of 43.93 percent was used; it was announced by Tax Procedure Law General Communiqué No. 574, published in the Official Gazette dated 27 November 2024, No. 32735.

The 2026 amounts were set by Communiqué 2026/1 using a rate of 25.49 percent, effective from 1 January 2026. The figures on this page therefore cannot be applied directly to an inspection carried out today; they remain a reference only for violations committed during 2025.

Which violations carried which amounts?

In the 2025 table published by the Ministry, each paragraph shows the amount written in the Law next to the amount applicable in 2025. The main paragraphs relevant to waste, destruction and recycling had the following 2025 amounts:

• Article 20(r): collecting, transporting, temporarily or intermediately storing, recovering, recycling, reusing or disposing of waste contrary to the rules: TL 623,242 to TL 2,492,979; TL 2,077,481 for those who import waste.
• Article 20(v): activities concerning hazardous waste contrary to the rules and prohibitions: TL 2,786,491 to TL 27,865,872; the same range applies under paragraph (y) for hazardous chemicals.
• Article 20(t) and (u): bringing hazardous waste into the country, or exporting or transiting it without prior notification: TL 55,731,888 each.
• Article 20(cc): failing to establish a zero waste management system, or to document that one has been established: TL 138,498.
• Article 20(bb): giving plastic bags free of charge: TL 114.55 for each square metre of enclosed sales area; TL 20,771 to TL 207,747 for online sellers.

Paragraph (z), which applies to those who do not pay the recovery contribution fee, contains no fixed amount; the fine equals 20 percent of the unpaid contribution.

How are the fines aggravated, who imposes them and how can they be challenged?

The Law provides that the fines in sub-paragraphs 1 to 4 of paragraph (ı) and in paragraphs (k), (l), (r), (s), (t), (u), (v) and (y) are imposed at three times the amount on institutions, organisations and enterprises. In Special Environmental Protection Areas the fines apply at double. If the same act is repeated within three years, the fine is increased by one times on the first repetition and by two times on the second and later repetitions (Article 23).

Administrative sanction decisions are issued by general directors at the Ministry’s central organisation and by provincial environment and urbanisation directors elsewhere (Article 24). Inspectors draw up a report, the competent authority issues the decision, and it is served under the Notification Law. An action may be brought before the administrative court within thirty days of service; filing the action does not suspend collection of the fine (Article 25). Where the act also constitutes a crime, the provisions of the Turkish Criminal Code and other laws remain applicable.

What does this mean for destruction and recycling?

For a business that generates, transports or has waste destroyed, the most important paragraphs of this communiqué are (r), (v) and (cc). The Law requires those who carry out waste transport and collection, and recovery, recycling and disposal facilities, to hold a licence from the Ministry (Article 11). Handing waste to an unlicensed or non-compliant firm brings the business itself closer to inspection and sanction risk.

For those liable for the recovery contribution fee, an unpaid contribution is penalised under paragraph (z), and non-compliance with plastic bag and contribution rules under paragraph (bb).

What should be checked in practice?

Always check which year’s communiqué an amount comes from. For 2026, Communiqué 2026/1 applies; the 2025 amounts in this entry do not replace it. Because the thirty-day period for challenging a fine starts on service, the date on which the decision was served should be recorded.

Given that repetition increases the fine and that three times the amount may apply to corporate operators, regular review of waste contracts, licence documents and declaration records is the most practical way to reduce sanction risk.