TGSD (Turkish Apparel Manufacturers Association) posted a written statement briefly summarizing the Climate Law, which came into effect on July 9, 2025, specifically for the apparel and garment industry. In the information note, it also shared a practical roadmap for manufacturers in this regard.
The system will become mandatory at the end of a 3-year transition period
The statement explains legal obligations under two headings: Greenhouse Gas Emission Permits (Articles 11-12) and the Emissions Trading System (ETS) (Articles 13-17).
Accordingly, all facilities that generate emissions are required to obtain a permit from the Climate Change Presidency prior to commencing operations. If there is a change in the production line or capacity, the permit must be updated.
All facilities that will be covered by the ETS are required to operate based on carbon allowances. At the end of the three-year transition period, the system will become mandatory, and if emissions cannot be covered by allowances, it will be mandatory to purchase carbon credits or offset them.
Penalties will be imposed for violations of the rules specified in the law. Accordingly;
- For operating without an emissions permit, up to 5 million TL,
- For violations of MRV obligations, between 500,000 TL and 5 million TL,
- For entities operating under the ETS without a greenhouse gas emissions permit, or continuing operations with an expired or revoked greenhouse gas emissions permit; for businesses with a verified annual greenhouse gas emissions report, 5 TL per ton of CO₂ equivalent,
- For failure to provide information or documents, between 120,000 TL and 1 million TL,
- In cases of misleading information or obstruction of inspection, between 2 million TL and 5 million TL,
- Businesses using ozone-depleting substances will be subject to a fine of 2.5 million TL,
- Businesses using fluorinated gases without a permit will be subject to a fine of up to 2.5 million TL.
Along with this, for the first 3 years, an 80% discount on penalties is expected.
Companies should start the transformation process now under the Climate Law
The statement draws attention to the fact that the Climate Law is no longer just an environmental regulation for apparel and textile exporters, but a strategic legal requirement that directly affects international market access, financial eligibility, and operational sustainability. It highlights the points that companies should focus on. Accordingly, it is emphasized that companies should address carbon management not only at the reporting level but also in conjunction with financial and managerial strategies, and that they should initiate transformation processes today by anticipating ETS obligations.
For industrialists, in the practical roadmap, it is recommended that, in the first phase, processes that generate emissions (such as dyeing, printing, steam, energy consumption, etc.) be identified. Secondly, it recommends establishing a measurement, monitoring, reporting, and verification infrastructure, followed by permit applications and preparation for the ETS system.
In the fourth phase, it advises preparing climate adaptation and risk management plans, and finally, planning green transformation investments (renewable energy, energy efficiency, waste management).
