What is the purpose of the Packaging Waste Control Regulation?
The Packaging Waste Control Regulation was published in the Official Gazette dated 26 June 2021, No. 31523, and repealed the regulation of 27 December 2017, No. 30283 (Article 28). It sets out the strategies and procedures for producing packaging that meets environmental criteria, preventing packaging waste, recycling and recovery, the deposit management system, and the duties of the Turkish Environment Agency (Article 1). It is administered by the Ministry of Environment, Urbanisation and Climate Change.
Its scope covers all packaging placed on the market and the waste from that packaging (Article 2).
Who has obligations?
Obligations are shared among packaging producers (including importers), suppliers, those placing products on the market and points of sale; sales through electronic channels are also covered (Articles 4 and 9-11). These parties register with the Packaging Information System, and data on the type, characteristics and quantity of packaging placed on the market in the previous year are reported to the Ministry through that system by the end of March each year (Article 25).
For packaging placed on the market after 1 January 2020, the obligations under the Regulation on the Recovery Contribution Fee are also fulfilled (Article 10).
What are the recycling targets?
Under Article 21, the total recovery rate target is 60 per cent and the total recycling rate target is 55 per cent for each year between 2021 and 2025. The total recycling target is 65 per cent for 2026-2030 and 70 per cent from 2031 onwards. Annual recycling rates by material are also set separately for glass, plastic, metal, paper/cardboard and wood.
For the recovery of packaging waste, material recycling comes first, and use as an energy source is the last option (Articles 5 and 20).
How does the deposit management system work?
The deposit management system is based on taking back products placed on the market with a set fee after use and refunding that fee. The Turkish Environment Agency is the system manager responsible for setting up and operating it (Articles 4 and 8).
Packaged products brought under mandatory deposit, with single-use sales packaging made of glass, PET-type plastic and aluminium used for beverages for human consumption as the priority, cannot be placed on the market without the Agency's approval (Article 17). For products under mandatory deposit, the deposit fee is marked on the packaging and shown as a separate data item on sales documents, and points of sale must accept deposit-bearing empty packaging back (Articles 11 and 16). The Agency sets the procedures and publishes them on its website.
What does it mean for destruction and recycling?
Packaging waste producers comply with the Waste Management Regulation and the Zero Waste Regulation for the accumulation, temporary storage, delivery and transport of waste (Article 19). Facilities where packaging waste is separated, recovered or disposed of are also bound by the obligations in the Waste Management Regulation (Article 20).
Competent authorities must take the necessary measures so that packaging waste is not sent to landfills. Packaging waste other than waste that cannot be recovered may not be sent to disposal facilities (Articles 19 and 20). For the accumulation and transport of empty packaging collected under the deposit system, the permit and licence conditions of waste management legislation are not required; these activities are subject to the Agency's rules (Article 19).
What sanctions apply to non-compliance?
Those who act in breach of the Regulation face the administrative sanctions provided for in Law No. 2872 and other relevant legislation, imposed by the authorities empowered under that legislation (Article 26). The sum of lead, cadmium, mercury and hexavalent chromium concentrations in packaging cannot exceed 100 ppm (Article 13).
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