Executive summary
Turkey’s Regulation on Recycling Contribution Fee (the Regulation) was published on 31 December 2019 and came into force on 1 January 2020.
The purpose of the Regulation is to determine the procedures and principles on application, declaration, collection and monitoring of the recycling contribution fee to be collected from suppliers/importers and stores.
Detailed discussion
Scope
The recycling contribution fee (RCF) was introduced on 10 December 2018 via Law no. 7153 amending the Environmental Law.
The scope of the RCF consists of goods stated in list (1) attached to the Environmental Law which are supplied to the market or imported, including those that are recycled and those that are in the liquidation process and sold in relation to their original purpose.
Goods produced by state institutions to be used exclusively for their main purpose and not to be supplied to the market with commercial purposes, dutiable goods which are to be liquidated through disposal, goods subject to exportation, goods for personal use and reused products are outside the scope of RCF.
Deposit system
In the context of procedures and principles determined by the Ministry of Environment, the amount subject to deposit for the goods that are supplied to the market as “returnable product” is not within the scope of the RCF.
Responsible parties
The entities who are required to pay the RCF are stores for plastic bags and the supplier or importer of the good for all the other products within the scope of RCF.
RCF amount
Amounts of RCF to be collected are stated in the list (1) attached to the Environmental Law.
| Product | Unit | RCF |
Plastic bags |
Piece | 15 kr |
| Mineral oil | Kg | 50 kr |
| Vegetable oil | Kg | 10 kr |
| Tires (for passenger car) | Piece | 2 TRY |
| Tires (for bus, trucks, vans, loaders, excavators and others) | Piece | 4 TRY |
| Tires (for heavy construction equipment) | Piece | 10 TRY |
| Solid tires | Piece | 5 TRY |
| Accumulator (lead-acid type) | Kg | 20 kr |
| Accumulator (nickel-cadmium type) | Kg | 50 kr |
| Zinc-carbon batteries | Kg | 5 kr |
| Alkali cylindrical batteries | Kg | 2 TRY |
| Alkali button batteries | Kg | 2 TRY |
| Button batteries (zinc-air and silver oxide) | Kg | 10 TRY |
| Lithium button batteries | Kg | 10 TRY |
| Lithium cylindrical chargeable and primer batteries (excluding car batteries) | Kg | 5 TRY |
| Car batteries (excluding those containing lead) | Kg | 15 TRY |
| Car batteries (containing lithium) | Kg | 15 TRY |
| Other chargeable batteries | Kg | 5 TRY |
| Electronic goods: Televisions and monitors | Kg | 20 kr |
| Electronic goods: Telecommunication equipment (excluding televisions and monitors) | Kg | 20 kr |
| Electronic goods: Lighting equipment | Piece | 10 kr |
| Electronic goods: Small home appliances and others | Kg | 20 kr |
| Electronic goods: White appliances (excluding refrigerators, coolers and air conditioners) | Kg | 25 kr |
| Electronic goods: Refrigerators, coolers and air conditioners | Kg | 30 kr |
| Drugs | Box/Bottle | 1 kr |
| Plastic beverage packages (up to 0.33 ltr) | Piece | 1 kr |
| Plastic beverage packages (0.3301-0.75 ltr) | Piece | 2 kr |
| Plastic beverage packages (0.7501-1.5 ltr) | Piece | 3 kr |
| Plastic beverage packages (above 1.501 ltr) | Piece | 4 kr |
| Other plastic packages (excluding plastic bags) | Kg | 40 kr |
| Metal beverage packages | Piece | 3 kr |
| Other metal packages | Kg | 50 kr |
| Paper-board based composite beverage packages (up to 0.25 ltr) | Piece | 1 kr |
| Paper-board based composite beverage packages (0.2501-0.5 ltr) | Piece | 2 kr |
| Paper-board based composite beverage packages (above 0.501 ltr) | Piece | 4 kr |
| Paper-board based composite other packages | Kg | 50 kr |
| Paper-board packages | Kg | 20 kr |
| Glass beverage packages (up to 0.25 ltr) | Piece | 1 kr |
| Glass beverage packages (0.2501-0.5 ltr) | Piece | 2 kr |
| Glass beverage packages (0.501-1 ltr) | Piece | 3 kr |
| Glass beverage packages (1.01-5 ltr) | Piece | 5 kr |
| Glass beverage packages (5.01 ltr) | Piece | 10 kr |
| Other glass packages | Kg | 20 kr |
| Wooden packages | Piece | 10 kr |
Deduction
The RCF paid on goods that are later returned can be deducted from future RCF liabilities. Deduction of RCF shall be done in line with the procedures and principles determined by the Ministry of Treasury and Finance.
Notification and declaration
Suppliers/importers and stores are required to comply with the principles determined by the Ministry of Treasury and Finance for their declarations regarding the goods supplied to the market.
Suppliers/importers and stores are required to comply with the principles determined by the Ministry of Environment for their notifications regarding the goods supplied to the market.
Penalties
Penalty provisions stated in the Environmental Law shall be applicable for those who do not comply with the provisions of the Regulation on Recycling Contribution Fee.
As per the article 20/z of the Environmental Law, an administrative penalty of 20% more of (120% of) the unpaid RCF shall be levied on those who had not paid RCF.
Additional notes
Further legislation regarding the RCF has not been published yet as of this Alert. Additional legislative information is expected to be published to determine the further details on application of the RCF, such as notifications and declarations.
