We are sharing for information and assessment the press statement prepared by the Plastiksiz Türkiye Platformu regarding the current draft regulation on the environmental impacts and management of single-use plastics.
As the Plastiksiz Türkiye Platformu — a coalition of civil society organisations working in nature and environmental protection — we consider the “Draft Regulation on Single-Use Plastics”, opened for public consultation by the Ministry of Environment, Urbanisation and Climate Change, as an important step towards preventing plastic pollution.
Plastic pollution can no longer be addressed solely through waste management. Today, plastic pollution constitutes a global crisis that threatens all living beings and habitats — ecologically through the degradation of marine and terrestrial ecosystems, through risks to human and environmental health, and economically through the increasing cleaning costs borne by local authorities, as well as through unsustainable consumption patterns and its links to the climate crisis. Single-use plastics are among the most visible components of this crisis, as they may remain in nature for hundreds of years despite being used for only a few minutes. Approximately 40% of all plastics produced globally consist of single-use products, which also make up a large share of marine litter.
However, the crisis is not limited to oceans. Research shows that plastic accumulation in agricultural soils, freshwater resources and wetlands may exceed that found in marine environments. Microplastics entering soil and water become part of the food chain, directly threatening the right to life of all living beings. Scientific studies demonstrating that microplastics can be found in nearly all human organs — and that plastics and associated chemicals are linked to Alzheimer’s disease, Parkinson’s disease, behavioural disorders, infertility and various types of cancer — are increasing every day.
For this reason, policies that combine bans, consumption reduction, reuse systems and extended producer responsibility mechanisms are rapidly expanding worldwide in the fight against plastic pollution. Many countries are now restricting not only plastic bags but also items such as straws, single-use cutlery, plates, stirrers and polystyrene food containers.
In Türkiye, recent steps such as the Zero Waste policy, the introduction of fees for plastic bags and the deposit-return system have contributed to progress in tackling plastic pollution. In this context, the Draft Regulation on Single-Use Plastics represents an important starting point, as it envisages banning certain problematic products and reducing consumption of specific items. However, several critical gaps need to be addressed in order to strengthen its societal and environmental impact.
A Regulation Without Targets Is Destined to Fail
First, the draft lacks measurable consumption reduction targets. In particular, the absence of gradual and measurable targets for transitioning to reuse systems in the HORECA sector (Hotels, Restaurants and Cafés) constitutes a significant gap. The general statement in Article 6 of the draft — “reduction is essential” — falls short of providing a concrete basis for tackling pollution. Therefore, binding, measurable and annually increasing numerical reduction targets — especially for beverage cups and food containers — should be explicitly included.
To avoid enforcement ambiguity and legal loopholes, technical criteria that clearly distinguish whether a product is a “food container” or a “beverage container” — such as “single-portion serving” and “mode of consumption” (eaten or drunk) — should also be clarified in the definitions.
Those Who Produce Plastic Also Produce Waste
Second, the Extended Producer Responsibility (EPR) mechanism should be strengthened. Instead of municipalities and society alone bearing the costs of collecting, cleaning and managing waste generated by single-use plastics, producers must also contribute to these costs. In the draft, producer obligations are largely limited to administrative measures such as labelling and information provision. However, to address the true cost of pollution, a financial mechanism requiring producers to directly cover municipal and street cleaning costs associated with plastic waste should be placed at the core of the regulation. Otherwise, leaving the economic burden of waste management solely to local authorities and the public does not incentivise ecological product design.
A Narrowly Scoped Regulation Cannot Prevent Leakage
Third, the exclusion of certain widely used packaging types from the regulation may limit its effectiveness. Products such as tetra pack packages with attached plastic straws, expanded polystyrene (EPS) foam meal trays and food containers, as well as plastic stretch films, constitute a significant share of plastic pollution. Additionally, single-use beverage packaging below 500 ml and paper-like cups smaller than 7 oz are widely consumed. Therefore, these materials should also be included in the scope of bans.
Furthermore, the “up to 3 litres” threshold applied to beverage bottles should be consistently defined as an upper limit across all major pollutant product groups, including snack packaging, wrappers and other food containers that are commonly found in marine litter.
Without Data, There Is No Effective Management
Establishing a transparent data collection and reporting system is essential for the effective implementation of the regulation. Without regular data on plastic production, consumption and waste generation, the effectiveness of policy tools cannot be assessed.
Consumption Cannot Be Reduced Without Limiting Production
Finally, one of the most significant shortcomings of the draft is that it focuses only on reducing consumption and restricting market supply. The provision should be expanded to include “limiting the production of targeted products intended for placement on the domestic market.” Addressing pollution solely from a waste management perspective is insufficient; in order to prevent pollution at its source, the regulation must explicitly include restrictions on production. Limiting only domestic market placement while allowing continued production risks perpetuating environmental impacts. This change would strengthen the preventive nature of the regulation.
As the Plastiksiz Türkiye Platformu, we believe that strengthening the draft regulation would enable Türkiye to make significant progress in combating plastic pollution. Clearly articulating production restrictions, expanding reuse systems, reinforcing producer responsibility and setting measurable reduction targets would help reduce plastic pollution at its source and accelerate the transition towards a circular model.
Implementing strong and effective policies that reduce dependency on single-use plastics — including production restrictions — is crucial for protecting nature, seas and our living spaces.
Respectfully submitted to the public,
Plastiksiz Türkiye Platformu