Quick Read: Competition Law Updates In Türkiye – December 2025

January 2026 – December 2025 served as a high-velocity conclusion of the year for the Turkish Competition Authority (“TCA”). The month was characterised by a wave of new investigations that set a clear enforcement agenda for 2026.

In addition, the TCA's recent releases of reasoned decisions spanned diverse sectors—from jet fuel and hygiene products to cosmetics. Key themes included the robust application of the settlement mechanism, strict scrutiny of resale price maintenance (“RPM”), and a no-tolerance policy towards non-compliance with information requests. This issue of Quick Read provides a concise summary of the most notable competition law developments in Türkiye.

Dive into December Case Updates

1. From negative clearance to concentration: The competition law journey of the THY Opet/Shell case

The Turkish Competition Board (“Board”) recently cleared THY Opet's acquisition of Shell's participation interest and related assets under the Joint Aviation Operations Agreement for airport storage and aircraft refuelling in Bodrum and İzmir Airports (the “Agreement”).¹ What makes this transaction particularly noteworthy is the Board's evolving assessment of the same Agreement across multiple decisions over time.

• Negative clearance (2006):² In 2006, the Board examined the Agreement in the context of BP, Mobil, and Shell jointly operating airport storage facilities. The Board concluded that the jointly operated facility did not qualify as a joint venture, as it lacked independence from its parents. Taking into account that the parties' prices and sales conditions remained unaffected by the joint operation and that prices resulted from competitive tenders, the Board found no restriction of competition and granted a negative clearance on the Agreement.
• Individual exemption (2008):³In 2008, the Board reassessed the Agreement following Opet's inclusion in the joint operation of airport storage facilities. While reiterating its 2006 finding that the transaction did not give rise to a concentration, the Board refrained from granting negative clearance, citing the potential risk of coordination among competitors. Instead, the Board granted an individual exemption, emphasising efficiencies such as economies of scale, cost savings, the efficient use of limited airport space, and enhanced operational safety.
• Qualification as a concentration:⁴In 2014, the Board reviewed THY Opet's acquisition of Mobil's 25% ownership interest in the assets covered by the Agreement and determined that THY Opet's resulting 50% stake amounted to an acquisition. The Board initiated a Phase II review, during which THY Opet submitted commitments to address competition concerns.

Subsequently, in 2023, the Board examined THY Opet's acquisition of BP's participation interest and related assets. The Board again classified the transaction as an acquisition, citing the transfer of rights and obligations arising from the Agreement, as well as BP's airport assets and operating rights.

In its most recent 2025 decision, the Board assessed THY Opet's acquisition of Shell's participation interest and the associated assets. Referring to its earlier acquisition decisions, the Board confirmed that the transaction constituted a concentration and approved it, concluding that it raised no competition concerns.

2. Silence comes at a cost: TCA fines Vindex for non-compliance with information requests

In a stern reminder of the TCA's investigatory powers, the Board fined Vindex 0.1% of its annual turnover for failing to respond to the TCA's information requests.⁵

During the investigation, the TCA sent Vindex three separate requests for information. When Vindex failed to respond within the statutory deadlines, the TCA attempted to contact the chair of the board by phone and explicitly warned—via both email and telephone—of the potential sanctions for non-compliance. Despite these reminders, Vindex repeatedly requested extensions, citing its ongoing concordat (restructuring) proceedings. The case handlers granted these extension requests. Throughout the process, the TCA made multiple attempts to communicate with Vindex. However, Vindex often failed to respond. Even in instances where Vindex indicated that it could submit only part of the requested information, it ultimately failed to provide any of the data.

The Board ruled that administrative hurdles do not exempt an undertaking from its duty to provide accurate and timely data. However, the Board decided not to impose a daily administrative fine, which normally applies in cases of incomplete or non-submission of information, considering that the TCA had been unable to obtain the information for approximately six months and that, due to the ongoing concordat process, Vindex could no longer provide the data in a complete, accurate, and reliable manner.

3. RPM investigation against Ceel Cosmetics concluded through settlement

The TCA concluded its resale price maintenance investigation against the Ceel Cosmetics economic unity, comprising Vitaceel Kozmetik Gıda İth. İhr. San. ve Tic. AŞ, The Ceel Kozmetik İç ve Dış Ticaret AŞ, and Ceel Kozmetik ve Gıda AŞ (“Ceel Cosmetics”), through settlement.⁶

The investigation focused on allegations that Ceel Cosmetics fixed the resale prices applied by its distributors. RPM remains one of the types of infringement that the TCA has closely monitored for years and has consistently prioritised in enforcement actions, frequently resulting in the imposition of administrative fines. In line with this enforcement trend, Board decisions show that undertakings subject to RPM investigations increasingly opt for the settlement mechanism. By choosing to settle, Ceel Cosmetics agreed to bring the investigation to an end at an early stage. Following the settlement process, the Board imposed an administrative fine of TRY 2.5 million (approx. EUR 51,318) on Ceel Cosmetics, which reflects a 25% settlement reduction.

Looking Forward: A Wave of New Investigations

As 2025 drew to a close, the TCA signalled a busy year ahead by initiating several high-profile probes across critical sectors:

• Document solutions market under investigation:⁷  The TCA launched an investigation into the economic unity comprising Kyocera Bilgitaş Turkey Doküman Çözümleri AŞ and Kyocera Document Solutions Europe Management B.V. (“Kyocera”), which operate in the importation, assembly, maintenance, repair, and sale of office supplies, information technology products, document solutions, IT equipment and software, as well as related components, spare parts, stationery, and consumables, and Kyocera's distributor, Geskopikit Dijital Kopyalama AŞ. The TCA will examine allegations that the parties restricted parallel imports, imposed customer and territorial sales restrictions on resellers without distinguishing between active and passive sales, and fixed resale prices. The investigation will also closely scrutinise non-compete clauses and single-brand purchasing obligations included in Kyocera's dealership agreements.
• Investigation into Orzaks İlaç:⁸The TCA initiated an investigation into Orzaks İlaç, which operates under the Orzax brand in the food supplements and consumer health products sector. The investigation focuses on allegations that Orzaks İlaç abused its dominant position by imposing purchasing obligations on pharmacies, requiring the joint stocking of certain product groups, and applying various discount schemes. The TCA will also assess claims that contractual provisions unlawfully restricted resellers' online sales.
• Dominance investigation against Mettler-Toledo:⁹The TCA opened an investigation into Mettler-Toledo, which operates in the market for after-sales services for measurement and control equipment. The TCA will assess allegations that Mettler-Toledo abused its dominant position by restricting the supply of spare parts to competitors and by refusing to share the passwords necessary to perform certain technical operations on devices.
• Scope of the seed sector investigation expanded:¹⁰The TCA expanded the scope of its ongoing investigation into seven undertakings active in the field crops seed market,¹¹ which initially targeted allegations of customer and territorial allocation and the exchange of competitively sensitive information. The TCA has now included four additional undertakings in the investigation. In parallel, the related investigation into the markets for hybrid industrial gherkin seeds and hybrid vegetable and fruit seeds continues.
• Seedling sector under scrutiny:¹²  The TCA launched an investigation into 18 undertakings active in the vegetable seedling sector, as well as the Seedling Producers Sub-Union. The allegations include the exchange of forward-looking prices, sales conditions, costs, profit expectations, and supply volumes; warnings issued to competitors applying lower prices to induce price increases; and the joint determination of prices and sales conditions through decisions taken at sector association meetings.

Stay tuned for our next issue of Quick Read, where we will continue to bring you the latest in competition law developments in Türkiye.

Footnotes

1. THY Opet/Shell (03.07.2025, 25-24/602-377).

2. BP/Mobil/Shell (28.12.2006, 06-95/1202-365).

3. BP/Mobil/Shell/Opet (09.07.2008, 08-44/606-231).

4. THY Opet/Mobil (16.07.2014, 14-24/482-213), THY Opet/BP (14.12.2023, 23-58/1131-405).

5. Vindex (28.08.2025, 25-32/750-445).

6. Ceel Kozmetik (04.09.2025, 25-33/777-459).

7. Kyocera - Geskopikit (06.11.2025, 25-41/991-M).

8. Orzaks İlaç (11.11.2025, 25-42/1021-M).

9. Mettler-Toledo (11.11.2025, 25-42/1020-M).

10. Seed Sector – II (20.11.2025, 25-43/1055-M).

11. Seed Sector – I (22.05.2025, 25-20/478-M).

12. Seedling Sector (20.11.2025, 25-43/1053-M).

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