The Climate Law No. 7552 ("Law"), which includes regulations on the procedures and principles related to the reduction of greenhouse gas emissions in the fight against climate change, climate adaptation activities, planning and implementation tools, revenues, permits and inspections, and the legal and institutional framework surrounding these, was published in the Official Gazette dated July 9, 2025, No. 32951, and entered into force. This Law sets out general principles and objectives from a casuistic perspective, preferring to leave detailed and technical regulations to secondary legislation.
Administrative fines ranging from TRY 120,000 to TRY 50,000,000
may be imposed on those who violate the provisions of this Law,
depending on the nature of the violation.
Indeed, in line with the green growth vision and net-zero
emissions target set out in the Law, it is planned that the
objectives of combating climate change will be achieved through
mechanisms such as the Emissions Trading System and the Carbon
Border Adjustment Mechanism.
1. Emissions Trading System
Pursuant to Article 9 of the Law, an Emissions Trading System
("ETS") will be established by the Climate Change
Directorate. This system will be a national and/or international
market-based mechanism that operates on the principle of setting an
upper limit on greenhouse gas emissions in line with the net-zero
emissions target and encourages emission reductions through the
trading of allowances.
Under the ETS, businesses that carry out activities directly
causing greenhouse gas emissions will be required to obtain a
greenhouse gas emission permit from the Climate Change Directorate
in order to conduct such activities. The scope and criteria of
businesses that are considered to cause direct greenhouse gas
emissions will be determined by secondary legislation (a
regulation) at a later stage.
Indeed, businesses included within the scope of the ETS are
obligated to surrender annual allowances corresponding to their
verified annual greenhouse gas emissions. Otherwise, these
businesses will be required to pay the administrative fine set
forth under Article 14, paragraph 4(c) of the Law for each
unsubmitted allowance when submitting their allocation for the
following calendar year, and they must also surrender an equivalent
amount of allowances corresponding to the unsubmitted
emissions.
Additionally, businesses falling under the scope of the ETS must
obtain a greenhouse gas emission permit within three years from the
date the system comes into force. However, during this three-year
transitional period, businesses will be deemed to have such permits
on a one-time basis, allowing them to continue operating under the
ETS.
2. Carbon Border Adjustment Mechanism
Article 8, paragraph 1(ç) of the Law provides that a Carbon Border Adjustment Mechanism ("CBAM") may be established to address the embedded greenhouse gas emissions of goods imported into the Turkish Customs Territory. The CBAM envisioned under this provision essentially corresponds to the European Union's CBAM, which was developed to prevent carbon leakage and is currently in a transitional phase until 2026.
The procedures and principles of the national CBAM to be
established under the Law will be set by secondary legislation, and
it is expected that this legislation will align with the EU CBAM.
In parallel with the EU CBAM, the national CBAM is anticipated to
impose a carbon cost obligation on imports from countries that do
not meet certain environmental or emissions-related criteria. This
means that the carbon emissions resulting from the production of
imported goods will be calculated, and a corresponding carbon cost
will be applied to those goods. In this way, the goal is twofold:
to achieve national targets for greenhouse gas emissions and to
ensure a level playing field between domestic producers subject to
carbon pricing and foreign importers. Since domestic producers will
be charged for their carbon emissions under the Law, charging
importers the same carbon cost for equivalent products is essential
to maintain fair competition in the market.
You can Access Law via link:
https://www.resmigazete.gov.tr/ eskiler/ 2025/
07 /20250709-1.htm
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
