July 2025 – Comprehensive updates have been made to the Turkish EIA Regulation with the regulation published in the Official Gazette dated 26 June 2025. In particular, the project lists (Annex 1 and Annex 2) that determine which projects are subject to the environmental impact process and how they are subject to it have undergone notable changes.
Why are Annex 1 and Annex 2 lists important?
- Projects included in Annex 1 are considered to have high environmental impacts and require the preparation of a detailed "EIA Report." This entails a longer, more detailed, and more costly process for the investor.
- Projects included in Annex 2 are considered to have lower environmental impacts. In such cases, only a "Project Information File" is prepared, and the project is typically subject to a faster evaluation process. If deemed appropriate, the process can be completed more quickly and at a lower cost with a "EIA Not Required" decision.
- Projects not included in either list are not subject to any environmental impact assessment process.
These changes may have direct consequences in terms of timing, budget planning, and permit obligations in investment processes.
Some notable changes:
- In mining projects, facilities with grading, washing, etc., with output at or above 400,000 tons/year are now included in Annex 1.
- Wind energy plants with 15 turbines or more, as well as offshore wind energy plants, have been added to Annex 1, while projects with 1-14 turbines have been added to Annex 2.
- For solar power plants, the Annex 1 threshold has been set at 25 hectares, and the Annex 2 threshold at 7.5 hectares (excluding roof and facade systems).
- For electricity transmission lines, the length limit for Annex 1 has been increased from 15 km to 50 km.
- The threshold value for coal projects has been significantly reduced, from 500 tons/day to 50 tons/day.
- The threshold for marble processing facilities has been reduced from 10,000 m³/year to 5,000 m³/year.
These changes will have a significant impact on investment plans, particularly in the energy, mining, infrastructure, and manufacturing sectors.
The full text of the legislation, along with Annex-1 and Annex-2, is available here (in Turkish only).
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.
