4/10/2026, 6:34:55 AM

Update on Recycling Contribution Fee (GEKAP) Amounts for 2026 (Türkiye – Environmental Compliance Update)

The Communiqué on Recycling Contribution Fee (GEKAP) amounts issued under Environmental Law No. 2872 was published in the Official Gazette dated 30 December 2025 (No. 33123) as Communiqué No. 2026/1 and entered into force on 1 January 2026. The regulation introduces updated GEKAP unit amounts applicable to products listed in Annex (1) of the Environmental Law, covering both domestically supplied and imported goods.

While the update follows a predictable annual adjustment mechanism, its practical impact on companies trading with Türkiye is far from routine. The increase in GEKAP amounts directly affects cost structures, compliance exposure, and operational planning for both importers and foreign exporters supplying the Turkish market.

Regulatory Framework and Scope

GEKAP is an environmental contribution fee imposed on certain products and packaging types placed on the Turkish market. It applies equally to:

  • manufacturers supplying goods domestically,
  • importers introducing goods into free circulation in Türkiye

The legal basis is Additional Article 11 of Environmental Law No. 2872, which provides for annual updates based on the revaluation rate announced under the Tax Procedure Law.

For 2025, the revaluation rate was determined as 25.49% pursuant to Tax Procedure Law General Communiqué No. 585. Accordingly, all GEKAP unit amounts listed in Annex (1) have been recalculated and increased for application in 2026.

The structure of the system remains unchanged. The update does not introduce new product categories or calculation methodologies. Instead, it increases the monetary burden per unit across all applicable items.

Collection principles also remain consistent:

  • Plastic bags → collected at the point of sale
  • Other products → collected from manufacturers, importers, or entities placing goods on the market

Additionally, fractions not exceeding 5% continue to be disregarded in final calculations.

Structural Impact: GEKAP as a Cost Component

From a business perspective, GEKAP must be treated as a direct cost element rather than a marginal environmental charge.

The 2026 update reinforces this reality. The increase in unit amounts means that for:

  • high-volume imports,
  • packaged consumer goods,
  • fast-moving products

GEKAP may represent a significant portion of total landed cost.

This is particularly relevant for companies operating with tight margins or price-sensitive markets. In such cases, even a relatively moderate percentage increase in GEKAP rates can materially affect profitability.

Companies engaged in Türkiye-bound trade should therefore integrate GEKAP into broader cost modeling frameworks alongside customs-related components such as customs consulting Turkey and customs valuation Turkey.

Impact on Foreign Exporters

Foreign exporters often underestimate the impact of GEKAP, as the obligation formally lies with the Turkish importer. However, in practice, GEKAP costs are frequently reflected in:

  • purchase price negotiations,
  • cost-sharing arrangements,
  • long-term supply agreements

With increased GEKAP amounts, exporters should reassess:

  • whether environmental charges are explicitly defined in contracts,
  • how cost increases will be allocated between parties,
  • whether pricing models remain sustainable

Failure to address these points may result in:

  • unexpected cost pass-through disputes,
  • margin erosion,
  • renegotiation of supply terms

For companies evaluating market entry or expansion strategies, this also ties into broader considerations discussed in trading with Turkiye opportunity or risk .

Importer Perspective: Declaration and Compliance Risk

For importers, the primary risk lies in incorrect declaration and reporting.

GEKAP obligations are not limited to payment. They require accurate:

  • product classification,
  • packaging identification,
  • quantity reporting

Errors in any of these areas may lead to:

  • administrative penalties,
  • retroactive assessments,
  • audit findings

This risk becomes more pronounced in 2026 due to increased unit amounts. Higher amounts amplify the financial consequences of any misdeclaration.

In practice, one of the most common issues is incorrect mapping between GTIP (customs tariff classification) and GEKAP product categories.

Companies should ensure alignment between customs classification and environmental obligations, particularly in complex product structures. For technical support in this area:HS code classification Turkey.

Customs Interaction and Audit Exposure

Although GEKAP is primarily an environmental regulation, it is closely linked to customs processes.

During import operations:

  • product descriptions,
  • packaging details,
  • tariff classifications

are declared to customs authorities.

These data points may later be used by environmental authorities to verify GEKAP compliance.

This creates a cross-functional risk area where inconsistencies between customs declarations and GEKAP reporting may trigger:

  • compliance reviews,
  • joint audits,
  • financial reassessments

Companies subject to regular audits or operating in regulated sectors should consider integrating GEKAP controls into broader compliance frameworks such as:Customs Audit Turkey

and product safety/environmental compliance processes:TAREKS product safety surveillance Turkey

Packaging Strategy and Supply Chain Implications

The increase in GEKAP amounts is not only a compliance issue—it is also a strategic supply chain factor.

Higher environmental costs may influence:

  • packaging material selection,
  • product design decisions,
  • supplier selection

For example:

  • switching to alternative packaging materials may reduce GEKAP exposure,
  • optimizing packaging volume may lower total payable amounts,
  • sourcing from suppliers with compliant packaging standards may reduce risk

These decisions require coordination between:

  • procurement teams,
  • compliance departments,
  • logistics operations

Companies that fail to integrate GEKAP considerations into supply chain planning may face cumulative cost disadvantages over time.

Contractual and Commercial Alignment

A recurring issue in practice is the absence of clear contractual provisions regarding environmental charges.

With increased GEKAP amounts, this becomes a critical risk area.

Companies should review contracts to ensure:

  • GEKAP costs are explicitly defined,
  • responsibility for payment is clearly allocated,
  • mechanisms for cost adjustments are included

This is particularly important in long-term agreements where pricing structures were established before the 2026 update.

Where disputes arise, they may evolve into broader customs or financial claims, requiring structured resolution processes such as:Dispute objection settlement Turkey

Strategic Actions for Companies

Given the scope of the 2026 update, companies should take a proactive approach.

Key actions include:

  • Updating cost models to reflect new GEKAP amounts
  • Reviewing product classification and packaging assumptions
  • Aligning customs and environmental reporting processes
  • Revising contracts with suppliers and customers
  • Implementing internal controls for declaration accuracy

For companies seeking to build a structured compliance framework, integrating GEKAP into broader systems such as AEO consulting Turkey may provide long-term operational advantages.

Professional Compliance Perspective

From a professional standpoint, GEKAP should not be treated as a secondary compliance obligation.

The 2026 update reinforces that:

Environmental charges in Türkiye are an integral part of import cost and compliance management.

Companies that approach GEKAP as an isolated requirement risk:

  • underestimating total landed cost,
  • creating inconsistencies between departments,
  • increasing audit exposure

On the other hand, companies that integrate GEKAP into their customs, financial, and operational processes will achieve:

  • better cost predictability,
  • improved compliance outcomes,
  • reduced risk of penalties

Conclusion

The 2026 update to GEKAP amounts introduces a measurable increase in environmental compliance costs for goods placed on the Turkish market. While the regulatory mechanism remains unchanged, the financial and operational implications are significant.

For foreign exporters and Turkish importers, this is not merely a routine annual adjustment. It is a change that requires alignment across pricing, contracts, supply chain design, and compliance systems.

Failure to address these implications may result in cost overruns, disputes, and regulatory exposure. Proactive adaptation, on the other hand, enables companies to maintain control over both costs and compliance in Türkiye’s evolving regulatory environment.

The official legal text is only available in Turkish; however, the key regulatory changes and practical implications are fully explained above.

See relevant legislative document

Related legislation updates

These related legislation updates reflect ongoing developments in Turkish customs and trade compliance. They may directly affect risk exposure, costs, and compliance strategies for foreign exporters and importers engaging with Türkiye.
Türkiye GEKAP Update 2026 – Revised Recycling Contribution Fees Explained