Turkey is preparing a draft framework regulation on ecodesign requirements for sustainable products, explicitly inspired by the EU ESPR Regulation (Regulation (EU) 2024/1781). The aim is to establish a regulatory framework to progressively make products more sustainable by improving their environmental performance and reducing both their carbon footprint and overall environmental footprint throughout their entire life cycle.
The scope of application is particularly broad. In general, the draft applies to all physical products placed on the Turkish market or put into service, including components and intermediate products. Specific exclusions are provided for (including, by way of example, food, feed, medicinal products, and vehicles), but the overall scope remains wide enough to cover most consumer goods as well as many categories of industrial products.
Ecodesign requirements: from “declared” sustainability to “demonstrable” sustainability
The core of the regulation is the introduction of ecodesign requirements as a condition for placing products on the market. These requirements are designed to improve product characteristics with a direct impact on sustainability, including—among others—durability and reliability, reusability, upgradability, repairability, the possibility of maintenance and refurbishment, as well as aspects related to the use of resources and materials, recycled content, recyclability, and the recovery of materials. The draft also explicitly refers to the assessment of environmental impacts, including carbon footprint and environmental footprint, and to the reduction of expected waste generation.
From a systematic perspective, the ecodesign requirements are divided into two main categories. On one hand, performance requirements, understood as quantitative or non-quantitative levels based on specific product parameters set out in the annexes, which may concern, for example, durability, emissions, or recycled content. On the other hand, information requirements, namely mandatory information that must accompany the product and which, at a minimum, includes the Digital Product Passport (DPP) and information concerning the presence of substances of very high concern (SVHC). This mandatory information must be made available through the indicated channels (the product itself, packaging, label, user manual/documentation, or freely accessible platforms).
Digital Product Passport: traceability and compliance verification across the value chain
The Digital Product Passport is a key element of the draft. The related provisions aim to facilitate access to information, support compliance verification, and enhance traceability throughout the value chain. The DPP must be linked, via a data carrier (for example, a barcode), to a persistent unique product identifier; the data carrier must be physically present on the product, on its packaging, or in the accompanying documentation. As for content, the DPP may include—depending on the provisions and annexes—information such as product identifiers, operator and facility identifiers, conformity elements/documents, instructions and safety information, as well as additional data supporting traceability and compliance management.
Unsold goods: destruction ban for selected categories
Of particular relevance for certain sectors (including fashion, apparel, and footwear) is the chapter addressing the destruction of unsold consumer products. The draft introduces a principle of prevention, requiring economic operators to adopt reasonable measures so that destruction does not become necessary. In parallel, it establishes an obligation to disclose specific information, including quantities (number and weight) by category, reasons for disposal, destinations (reuse, recycling, recovery, etc.), and measures adopted or planned to prevent destruction.
In addition, the draft sets an explicit destruction ban for certain categories of unsold consumer products, including clothing and accessories as well as footwear, with specific references to customs/HS codes (for example, for footwear, headings 6401–6405). It is also provided that the competent authority may expand the list of products subject to the ban over time.
Obligations of economic operators: responsibilities across the supply chain
The draft sets out specific obligations for several economic operators (including manufacturers, importers, distributors, and online marketplace providers). In this context, compliance-oriented requirements emerge, such as carrying out or verifying conformity assessments, preparing declarations of conformity, ensuring the availability and management of the DPP, and retaining technical documentation and declarations for extended periods (generally 10 years). Distribution operators are also subject to preliminary verification obligations, depending on their role within the supply chain.
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