Regulation on the Recycling Contribution Fee

The Regulation on the Recycling Contribution Fee was published in the Official Gazette dated 31 December 2019, No. 30995 (4th Repeated), and entered into force on 1 January 2020. It is based on Articles 3, 11 and Additional Article 11 of Environmental Law No. 2872 and was amended in the Official Gazettes of 2 June 2021 (No. 31499) and 6 March 2024 (No. 32481). It sets the procedures for determining, declaring, collecting and monitoring the recycling contribution fee (GEKAP) charged when the products in the Law’s annexed List (1) are placed on the market.

Which products and which persons does the Regulation cover?

The Regulation covers listed products placed on the domestic market. The list comprises plastic bags, tyres, accumulators, batteries, mineral oils, vegetable oils, medicines, electrical and electronic equipment, and all packaging including beverage packaging (Article 5(15)). The fee is collected from points of sale for plastic bags and from those placing products on the market or importers for other products; imported products are treated as placed on the domestic market by the importer (Article 5).

Products taken back for reuse, products for own use, customs goods to be liquidated by destruction, and exported products are outside the scope. Products made by public bodies solely for use in their core duties are also outside it (Article 2). Those who operate a nationwide deposit system complying with the Ministry’s rules are exempt from the Regulation’s provisions other than its third part for the quantities sold with a deposit.

When does the obligation arise and how is the fee paid?

The payment obligation begins when the product is placed on the domestic market or imported (Article 11). Unit fees are in the Law’s list and are increased every year at the revaluation rate; fractions not exceeding 5 percent are disregarded (Article 15(3)). Declaration and payment follow the rules set by the Ministry of Treasury and Finance; those placing products on the market must classify them according to the list and record them by number or weight (Article 8).

For some products a declaration is made but no fee is charged. Examples are listed products used as original parts in vehicle and electrical equipment manufacture, and the primary (sales) packaging of packaged products (Article 5(10)–(12)). No fee is charged either on vegetable oil, mineral oil and batteries used as raw material (Article 5(16)).

How do verification, record-keeping and offsetting work?

For businesses that employ a permanent environmental officer or obtain environmental management services, and for businesses whose fee exceeds a set amount, the data behind notifications and declarations must be reviewed and approved by the environmental officer. The 6 March 2024 amendment set that amount at TL 150,000 and provided that it is increased each year at the revaluation rate (Article 10). The Ministry may require declarations to be reviewed by sworn-in certified public accountants or independent audit firms. Data on activities under the Regulation are kept for at least five years.

For returned products, offsetting is made against the current-period declaration using the fee that applied on the date the product was placed on the market; any excess is carried forward. No refund or offsetting applies to plastic bags (Article 12).

What does it mean for destruction and recycling?

GEKAP is linked to the extended producer responsibility approach of the Environmental Law; obligations imposed separately on products under the Waste Management Regulation are fulfilled in addition to GEKAP (Articles 5(9) and 8). For products in liquidation, the fee is charged only where they are sold to be used for their original purpose (Article 5(6)). Customs goods liquidated by destruction are outside the scope.

What should be checked in practice?

In case of breach, the sanctions provided in Law No. 2872 apply (Article 14); Article 20(z) of the Law applies to unpaid fees and other paragraphs to product-specific breaches. Monitoring and inspection are carried out, depending on the subject, by the Ministry of Treasury and Finance and the Ministry of Environment, Urbanisation and Climate Change (Article 13). For current unit fees and the 2026 amounts, Communiqué 2026/1 of 30 December 2025 and the Ministry’s announcements should be followed.