Climate Law Enacted 09 July 2025

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