2025 Transition Exemptions and Flexibilities for Sustainable Development
Transition Exemptions for Sustainability Reporting in 2025 Announced
The decision (“Decision”) of the Board of the Public Oversight, Accounting and Auditing Standards Authority (“POA”), dated 25 December 2025 and numbered 75935942-050-01.04-[01/38488], was published in the Official Gazette, dated 30 December 2025 and numbered 33123. Accordingly, the existing exemptions regarding the reporting date of sustainability-related financial disclosures, and the reporting content for the first two reporting periods for entities that reported in compliance with the Turkish Sustainability Reporting Standards (“TSRS”) for the first time in 2024, have been extended for one year. These exemptions can be utilized in the preparation of sustainability reports for the 2025 fiscal year.
You can access the Decision here (in Turkish), and for more detailed information regarding sustainability reporting, you can access our legal alert here (in English).
What changes does the Decision bring?
Pursuant to the Decision, the following transitional provisions will also apply for the 2025 reporting period to entities that reported in compliance with the TSRS for the first time in 2024:
- In the first annual reporting period, entities may report their sustainability-related financial disclosures after publishing their financial statements, as follows:
- If the entity is required to submit the next second-quarter or semi-annual interim general purpose financial report, they may report at the same time as this interim financial report.
- If the entity voluntarily submits the next second-quarter or semi-annual interim general purpose financial report, they may simultaneously report such interim financial report, provided that it is within nine months following the end of the annual reporting period.
- If the entity is not required to submit an interim general purpose financial report and chooses not to submit one voluntarily, they may report within nine months following the end of the annual reporting period.
- In the first reporting period, it is sufficient to disclose information only on climate-related risks and opportunities, and disclosure of comparative information on climate-related risks and opportunities is not mandatory.
- For entities that only disclose climate-related risks and opportunities in the first year, disclosure of comparative information on sustainability-related risks and opportunities (other than climate-related risks and opportunities) will not be mandatory in the second annual reporting period.
The Draft Regulation on Batteries and Waste Batteries?
The Draft Regulation on Batteries and Waste Batteries (“Draft Regulation”), prepared by the Ministry of Environment, Urbanization and Climate Change, has been published on the website of the General Directorate of Environmental Management of the Ministry of Environment, Urbanization and Climate Change and opened for public consultation.
The Draft Regulation sets forth detailed provisions regarding importation and production processes, placement on the market, and the collection, reuse and recycling stages after the end of their life cycle. The aim is to minimize the environmental impacts of batteries throughout their entire life cycle, ensure their sustainability and establish a safe and circular structure.
The Draft Regulation’s entry into force intends to repeal the currently applicable Regulation on the Control of Waste Batteries and Accumulators.
You can access the Draft Regulation here (in Turkish).
Scope and Application
I. Classification of Batteries
The Draft Regulation envisages expanding the scope of battery legislation. Accordingly, all battery categories, such as portable batteries, starting-lighting-ignition (SLI) batteries, light means of transport (LMT) batteries, electric vehicle batteries and industrial batteries, as well as batteries incorporated into or added to products, or designed to be incorporated into or added to products, are covered under the Draft Regulation.
However, (i) equipment related to the protection of essential security interests, such as military products, weapons, ammunition and war materials, (ii) equipment designed to be sent into space, and (iii) equipment specifically designed for the safety of nuclear facilities, are excluded from the scope of the Draft Regulation.
II. Market Placement of Batteries
The Draft Regulation stipulates that batteries compliant with its provisions cannot be prohibited or restricted from being placed on the market or made available due to sustainability, safety, labeling, or information requirements.
Noncompliant batteries may be displayed at trade fairs, exhibitions, demonstrations or similar events, provided they bear a visible mark clearly indicating that they are noncompliant and cannot be placed on the market until they are brought into compliance.
III. Safety and Sustainability
The Draft Regulation introduces comprehensive obligations for calculating and declaring the carbon footprint of certain battery types based on a life cycle approach. Accordingly, for electric vehicle batteries, rechargeable industrial batteries with a capacity above 2 kilowatt hours and LMT batteries, a carbon footprint declaration must be prepared for each battery model and each production facility.
Additionally, the Draft Regulation introduces further restrictions regarding the chemical substances that batteries may contain, aiming to protect human health and the environment. If the use of a substance at any stage of the battery life cycle, such as production, placement on the market, repurposing or end-of-life processing, poses an unacceptable risk to human health or the environment, restrictions on the use of that substance will be updated or expanded. In this context, if a new regulation is adopted at the European Union level to amend relevant restrictions, national legislation will be amended to align with this new regulation.
Additionally, scientific research and development activities related to batteries are excluded from the additional restrictions set out in the Draft Regulation. For activities aimed at improving the product or production process, the Draft Regulation stipulates the maximum quantities of substances that may be used under this exemption.
IV. Labeling, Marking, and Information
The Draft Regulation stipulates that all batteries must bear a standard label, indicating their basic characteristics and intended use. For rechargeable portable batteries, LMT batteries and SLI batteries, the label must include capacity information. For non-rechargeable portable batteries, the label must indicate the average service life and include a warning that the battery cannot be recharged.
In addition, batteries must bear a visible, legible and indelible QR code, either printed or engraved. Through these QR codes, access will be provided to the battery passport, declarations of conformity, information on recovered materials and instructions on how to manage waste batteries. If it is not possible to affix the QR code directly on the battery, it may be placed on the packaging or accompanying documentation.
V. Digital Battery Passport and Information Systems
The Draft Regulation introduces a mandatory requirement for a digital battery passport for electric vehicle batteries, LMT batteries, and industrial batteries with a capacity exceeding 2 kilowatt hours. In this regard, it is envisaged that a digital battery passport database will be established, along with an online portal enabling the search and comparison of information contained in battery passports.
Economic operators placing batteries on the market will be responsible for ensuring that the information in the battery passport is accurate, complete and up to date. In cases where the battery is prepared for reuse, repurposed or subjected to production processes, the responsibility for updating battery information will be transferred to the economic operator placing or making the battery available on the market. Conversely, when the battery becomes waste, the responsibility for fulfilling obligations related to the battery passport will rest with the producer.
VI. Obligations of Economic Operators
The Draft Regulation sets out separate obligations for producers, suppliers, authorized representatives, importers, distributors and service providers, which are as follows:
- Producers must ensure that batteries are designed and produced in compliance with technical requirements, provided with instructions and safety information in Turkish, and comply with marking and labeling rules.
- Authorized representatives, importers and distributors must verify compliance, provide necessary information and documents, take corrective measures in the case of any risk and cooperate with the Ministry of Industry and Technology.
- Economic operators placing batteries on the market that have been prepared for reuse, repurposing or reproduction must ensure compliance with quality control, performance testing and safety instructions.
- All economic operators must retain the identity and product information of other actors in the supply chain for 10 years and share it with the Ministry of Industry and Technology upon request.
- Economic operators placing batteries on the market or making them available and meeting the turnover threshold determined by the competent authorities must fulfill due diligence requirements.
VII. Extended Producer Responsibility
Extended producer responsibility (EPR) refers to measures requiring producers to assume financial or organizational responsibility for the management of waste generated throughout the life cycle of batteries.
Producers may appoint a producer responsibility organization to fulfill their obligations under EPR on their behalf. Persons or entities designated as producer responsibility organizations will carry out these activities under the authorization granted by the Ministry of Environment, Urbanization and Climate Change. Failure to fulfill these obligations despite authorization will result in the revocation of such authorization.
Producers located outside Türkiye that sell batteries (including those integrated into devices, light mobility vehicles or other vehicles) to end users in Türkiye through distance contracts must appoint an authorized representative based in Türkiye for EPR purposes.
Producers will be responsible under EPR for batteries they place on the market for the first time. Economic operators that first place batteries on the market subject to reuse, repurpose or reproduction will also be considered producers.
Producers’ financial contributions under EPR will cover the costs of: (i) separate collection, transportation and processing of waste batteries; (ii) characterization of mixed municipal waste; (iii) information activities; and (iv) data collection and reporting.
VIII. Battery Producers Registry
To ensure the registration of producers and monitor their compliance with legislation, the Ministry of Environment, Urbanization and Climate Change plans to establish a Battery Producers Registry. In this context, producers placing a battery on the market for the first time will be required to register with the Battery Producers Registry.
Furthermore, for producers to place batteries on the market, including those integrated into devices, LMT vehicles, or other vehicles, they must hold a Battery Producers Registry registration number. This requirement must be fulfilled either by the producer itself or, if authorized, by its representative appointed for EPR purposes.
IX. Administrative Sanctions
Currently, under the Regulation on the Control of Waste Batteries and Accumulators, necessary actions are taken and relevant penalties are imposed in accordance with the provisions of the Environmental Law No. 2872 for violations of applicable rules. In the case of noncompliance with the obligations under the Draft Regulation, administrative sanctions are envisaged not only under the Environmental Law No. 2872 but also under the Product Safety and Technical Regulations Law No. 7223. In this regard, the following administrative fines may be imposed for violations of the provisions of the Draft Regulation:
Under Environmental Law No. 2872, companies that:
- Collect, separate, temporarily or intermediately store, recover, reuse, transport, package, label, dispose of hazardous waste or fail to properly close hazardous waste disposal facilities, and produce, process, import, export, transport, store, use, package, label, sell or offer for sale hazardous chemicals or goods containing such chemicals in violation of legislation will be subject to a fine ranging from TRY 3,496,767 to TRY 34,968,882 (approximately USD 80,995 to USD 810,449) per violation
- Violate regulations related to product sales and distribution will be subject to a fine of TRY 43,447 (approximately USD 1,007) per violation
Under the Product Safety and Technical Regulations Law No. 7223, companies that:
- Violate technical regulations or general product safety provisions will be subject to a fine ranging from TRY 434,505 to TRY 4,345,058 (approximately USD 10,070 to USD 100,702) per violation
- Violate technical regulations other than those related to product safety and fail to comply with certification, conformity assessment, product liability and notification obligations will be subject to a fine ranging from TRY 173,801 to TRY 1,738,022 (approximately USD 4,028 to 40,281) per violation
- Fail to comply with obligations related to information provision, labeling or product recall will be subject to a fine ranging from TRY 86,900 to TRY 869,010 (approximately USD 2,014 to USD 20,140) per violation
- Fail to comply with obligations related to traceability, packaging, user instructions, technical documentation or notifications will be subject to a fine ranging from TRY 60,830 to TRY 608,307 (approximately USD 1,410 to 14,098) per violation
- Commit repeated violations will be subject to an administrative fine equal to twice the previous penalty
X. Transitional Provisions and Repeal of Existing Legislation
Upon entry into force of the Draft Regulation, the Regulation on the Control of Waste Batteries and Accumulators will be repealed. In this respect, the Draft Regulation introduces transitional provisions regarding existing authorized organizations, environmental permits and licensed facilities, temporary storage areas, and other practices.
Accordingly, organizations holding an authorization certificate under the Regulation on the Control of Waste Batteries and Accumulators will continue their activities in compliance with the provisions of the Draft Regulation for the duration of their authorization, while facilities with ongoing licensing processes will be assessed under the provisions of the current regulation. Existing permits for the temporary storage of waste accumulators and accumulator deposit practices will remain valid for their respective durations.
Provisions regarding the digital battery passport will not apply until Türkiye joins the system established by the European Commission. Furthermore, obligations related to registration and data sharing will be deferred until the Battery Producers Registry is established, with the implementation date to be announced on the official website at least 30 calendar days in advance. Similarly, provisions on battery due diligence will not apply until the relevant procedures and principles are determined.
Conclusion
The extension of TSRS transition exemptions provides companies with additional time to align with sustainability reporting obligations, whereas the Draft Regulation aims to strengthen environmental compliance through innovative provisions such as a life cycle approach to battery management, digital traceability and EPR. Although still at the draft stage and expected to enter into force at a later date, stakeholders are encouraged to submit their comments and suggestions on the published draft to the Ministry of Environment, Urbanization and Climate Change through the feedback form available here (in Turkish). While the two regulations have different scopes and objectives, they reflect Türkiye’s commitment to environmental regulation and indicate that a more consistent and auditable compliance framework is taking shape for businesses.
