July 2025 – Turkish Climate Law No. 7552 (“Law”), which aims to combat climate change in line with the vision of green growth and the net-zero emissions target, entered into force upon its publication in the Official Gazette dated 9 July 2025 and numbered 32951.
The Law sets out provisions regarding the reduction of greenhouse gas emissions, the enhancement of climate change adaptation activities, the establishment of planning and implementation tools in this context, the regulation of revenue mechanisms as well as permitting and supervision processes, and the determination of procedural and substantive rules for the legal and institutional framework governing these matters.
The main regulations introduced by the Law are summarised below.
Combating Climate Change
According to the preamble of the Law, there are two fundamental approaches to combating climate change: the reduction of greenhouse gas emissions and climate change adaptation. These mitigation and adaptation measures are not alternatives to one another but rather complementary and integral components of a holistic strategy.
In this context, the Law obliges institutions and organisations operating in the sectors specified in the Nationally Determined Contribution, including energy, industry, transport, agriculture, construction, waste, as well as land use, land use change, and forestry (LULUCF), to implement various mitigation measures in a manner consistent with the net-zero emissions target and the circular economy approach. These measures include enhancing energy, water, and raw material efficiency; preventing pollution at its source; promoting the use of renewable energy; reducing the carbon footprint of products and operations; opting for alternative clean or low-carbon fuels and raw materials; encouraging electrification; and increasing the development and use of clean technologies. Furthermore, the Law requires relevant institutions and organisations to observe the principle of fair transition in the implementation of these measures and to establish, implement, and monitor a zero-waste system.
In addition, the relevant public institutions and organisations are required to prepare, have prepared, or implement planning tools, vulnerability assessments, and risk analyses related to climate change adaptation at both the national and local levels, and to take such documents into consideration in investment and planning processes.
Emissions Trading System and Carbon Pricing
It is envisaged that an Emissions Trading System (“ETS”) will be established in Türkiye by the Climate Change Directorate (“Directorate”) under the Ministry of Environment, Urbanization and Climate Change. The Carbon Market Board is designated as the competent body responsible for determining the allocations and offsetting transactions under the ETS, as well as the plans, policies, strategies, and actions related to the ETS.
The ETS is defined as a market-based mechanism operating at the national and/or international level, which is based on the principle of imposing a cap on greenhouse gas emissions and encourages emission reductions through the trading of emission allowances.
Within the scope of the ETS, the Energy Markets Operation Joint Stock Company (“EPIAS”) is designated as the market operator responsible for the establishment, operation, and regular functioning of the ETS market. EPIAS is also tasked with establishing a transaction registry system for the issuance, holding, transfer, cancellation, and retirement of allowances; monitoring all rights related to such allowances electronically on a registered basis for each right holder; and maintaining these records in accordance with applicable legislation and confidentiality principles.
According to the provisions governing the ETS, undertakings engaged in activities that directly result in greenhouse gas emissions are required to obtain a greenhouse gas emission permit from the Directorate within three years following the effective date of the Law in order to continue such activities. The Directorate is authorised to extend this deadline by up to two additional years from the end of the initial period.
Undertakings falling within the scope of the ETS are required to surrender an amount of annual allowances equivalent to their verified annual greenhouse gas emissions. Allowances are issued in dematerialised form, are transferable and fungible, and represent the right to emit one metric ton of carbon dioxide equivalent of greenhouse gases for a specified period. The national allocation plan will be prepared by the Directorate, and the distribution of allowances will be carried out accordingly. While the primary method of allocation will be through auctions, certain undertakings may also be granted free allocations based on historical emission data or established benchmarking criteria.
In addition, undertakings falling within the scope of the ETS who are required to surrender allowances equivalent to their verified annual greenhouse gas emissions may partially fulfil this obligation through the offsetting mechanism, by using carbon credits obtained from mitigation and/or removal projects.
Carbon Border Adjustment Mechanism
To monitor the embedded greenhouse gas emissions contained in goods imported into the customs territory, it is envisaged that a national Carbon Border Adjustment Mechanism (“CBAM”) will be established by the Ministry of Trade. The scope, content, and procedures and principles regarding the reporting obligations under the CBAM will be determined by the Ministry of Trade.
The mechanism aims to ensure that the carbon costs reflected in certain product groups produced within the borders of the European Union under the EU Emissions Trading System are equivalently applied to similar products imported into Türkiye. Importers will be granted a reduction in carbon costs to the extent that carbon costs have already been paid during the production phase in third countries. This mechanism is intended both to contribute to environmental sustainability goals and to protect domestic industry and foreign trade in Türkiye.
Administrative Monetary Penalties
The Law stipulates broad administrative monetary penalties in cases of non-compliance with regulations concerning the monitoring, reporting, permitting, and allowance obligations related to greenhouse gas emissions, as well as for violations involving fluorinated greenhouse gases and ozone-depleting substances.
Under the ETS, undertakings that fail to submit a verified greenhouse gas emissions report may be subject to administrative fines of up to TRY 10,000,000 (approximately EUR 213,110). The Law sets the maximum penalty amount at TRY 50,000,000 (approximately EUR 1,065,560) per violation.
However, during the pilot implementation phase, the scope and duration of which are to be determined by the Carbon Market Board, administrative fines for non-compliance will be imposed at a reduced rate of 80%.
Conclusion
The entry into force of the Law, which has long been on the agenda of both the public and experts, is considered an important step in Türkiye’s fight against climate change. The Law outlines the general principles for addressing climate change in accordance with the green growth vision and the goal of achieving net zero emissions. It also aims to enhance the institutional and technical infrastructure needed for activities such as monitoring, reporting, and trading emissions.
The Law is expected to play a transformative role both in terms of achieving environmental targets and adapting industry and trade to a low-carbon economy.