Short answer
A facility in Türkiye whose activity appears in Annex-1 or Annex-2 of the Environmental Permit and Licence Regulation (Çevre İzin ve Lisans Yönetmeliği), Official Gazette 10.09.2014 / 29115, must first obtain a Temporary Activity Certificate (Geçici Faaliyet Belgesi, GFB), valid for one year, and then convert it into an environmental permit or an environmental permit and licence within that year (Article 5(2) and 5(3)). The permit document is valid for five years (Article 11(1)(a)). Applications for Annex-1 facilities are made through an environmental consultancy firm or an in-house environmental management unit, electronically with an electronic or mobile signature (Articles 7(1) and 7(2)). The competent authority is the Ministry of Environment, Urbanisation and Climate Change for Annex-1 facilities and the provincial directorate for Annex-2 facilities (Article 6(1)). Enpark holds environmental consultancy competency certificate No. 217503132.2.1, valid until 30 April 2028.
Permit versus licence: an environmental permit covers emission, discharge, noise and deep-sea discharge subjects; an environmental licence covers waste treatment and recovery activities. A facility that needs both holds a single combined environmental permit and licence document. Where Annex-1 and Annex-2 activities coexist at one facility, the application is assessed under Annex-1 (Article 6(2)).
Which facilities need a permit
Scope follows the Annex-1 and Annex-2 lists of the Regulation, which classify facilities by their environmental effects (Article 5(1)). The permit is issued in the name of the operator, and all facilities of that operator at the same address are assessed together in one process (Article 6(2)). Where several operators or legal entities share one address, each takes its own document, or one is taken for the facility as a whole, based on the definition of operator in the Regulation (Article 6(3)).
The statutory timetable
| Stage | Statutory period | Provision |
|---|---|---|
| Provincial directorate conformity letter | Issued within two months of the application at the latest; valid one year | Art. 4(1)(i) |
| Assessment of the temporary activity certificate application | 30 calendar days | Art. 8(1) |
| Closing deficiencies in that application | 60 calendar days, then a further 20 calendar days of assessment | Art. 8(3) |
| Validity of the temporary activity certificate | 1 year | Art. 8(4), Art. 5(3) |
| Application for the environmental permit or permit and licence | Within 180 calendar days of the temporary activity certificate | Art. 9(1) |
| Assessment of that application | 60 calendar days | Art. 9(2) |
| Closing deficiencies, including measurements and analyses | 90 calendar days | Art. 9(3) |
| Validity of the environmental permit and licence document | 5 years | Art. 11(1)(a) |
| Renewal application | At least 180 calendar days before expiry; the provincial conformity letter at least two months before that | Art. 11(1)(b) |
| Renewal after a material change at the facility | Started within 90 calendar days of the change | Art. 11(2)(c) |
| Notification of other changes | Within 30 calendar days of the change, then 90 calendar days to apply for renewal if required | Art. 11(2)(ç) |
| Change of title or tax number | Within 90 calendar days of the registry gazette | Art. 12(1) |
| Assessment of a change of title | 30 calendar days | Art. 12(2) |
| Waste code addition request | Once per year within the document’s validity; assessed within 30 calendar days | Art. 11(4) |
Changes that force a renewal
Independently of the five-year cycle, the renewal process must be started where the facility changes its location, changes its line of activity, changes its fuel or combustion system, increases its total production or waste treatment capacity by at least one third or into the Annex-1 range, or records a change in total combustion or nominal thermal power meeting the conditions in Article 11(2)(a)(5). A change of location, the addition of a new permit or licence subject, or a change in the process or operating conditions of an existing licence subject takes the process back to the temporary activity certificate stage (Article 11(2)(b)).
Where the 30-day notification in Article 11(2)(ç) is missed and the change required a renewal, the existing environmental permit and licence is cancelled (Article 11(2)(d)). Failing to apply within the periods in Article 11(2)(c) and (ç) also results in cancellation (Article 11(2)(e)). For a change of title or tax number, an application made after the 90-day period attracts a document update fee at twice the normal rate (Article 12(4)).
Where liability sits
From the application until it is concluded, the operator is responsible for the accuracy and legal conformity of the information, documents and reports submitted, and — where the work is bought in as a service — so is the authorised environmental consultancy firm (Article 7(4)). Notifications made electronically by the competent authority through the e-permit system are deemed served on the facility without a separate written notice (Article 7(5)). For a foreign-owned facility this matters in two ways: service is electronic, so somebody must be watching the system; and the consultancy is a co-addressee of liability, not a filing agent.
Relationship with the EIA decision
The decision taken under the Environmental Impact Assessment Regulation (ÇED Yönetmeliği), Official Gazette 29.07.2022 / 31907, is one of the documents submitted with a renewal application, together with the provincial directorate conformity letter, the process flow diagram and summary and the capacity report (Article 11(1)(b)). The EIA decision and the environmental permit are therefore sequential, not alternative: the EIA decision precedes construction, the permit precedes lawful operation.
What Enpark does
Enpark is an environmental and energy consultancy founded in 2012 in Ankara, holding environmental consultancy competency certificate No. 217503132.2.1 (valid until 30 April 2028) and EIA competency certificate No. 222 (issued 09.05.2025, four years). Scope determination, the provincial conformity letter, the temporary activity certificate and the environmental permit and licence applications are prepared and filed by Enpark through the e-permit system under electronic authorisation or a power of attorney, together with the five-year compliance calendar that follows from the document. Laboratory measurements are arranged project by project, either coordinated by Enpark or contracted directly by the operator. Correspondence is in English and Turkish.
Turkish-language counterpart of this page: Çevre İzin ve Lisans Danışmanlığı. Related: Environmental Impact Assessment Regulation — full English translation · Statutory period calculator (in Turkish) · About Enpark.
Other services in English: Environmental Impact Assessment (EIA) in Türkiye · Solar project permitting and management in Türkiye.
Frequently asked questions
What is the difference between a temporary activity certificate and an environmental permit?
The temporary activity certificate is a one-year document that allows the facility to operate while the permit file is completed; facilities in the Annex-1 and Annex-2 lists must obtain it before they may operate (Article 5(2)). Within that year the facility must obtain the environmental permit or the environmental permit and licence, which is valid for five years (Articles 5(3) and 11(1)(a)).
What happens if the 180-day application window is missed?
The temporary activity certificate is cancelled where no application is made within the periods in Article 9(1) and 9(3), where the deficiencies are not completed, or where the application is found unsuitable (Article 13(1)).
Who may file the application?
For Annex-1 facilities, an environmental consultancy firm or an in-house environmental management unit. For Annex-2 facilities, an environmental consultancy firm, an environmental management unit, or an environmental officer employed at the facility (Article 7(1)). Filing is electronic, with an electronic or mobile signature (Article 7(2)).
Does a change in ownership require a new permit?
A change in the title or the tax number of the operator requires an application within 90 calendar days of the registry gazette (Article 12(1)). Where only the owner or the shareholding structure changes, or the facility is leased, and the title and tax number are unchanged, the documents are kept at the facility to be produced on request, and the new owner or lessee is bound by the operating conditions annexed to the existing document (Article 12(3)).
Can a new licence subject be added to an existing document?
Yes. The facility may either apply to renew the temporary activity certificate covering all its permit and licence subjects, or add individual subjects while keeping the validity period of the existing document. For the subjects to be added the process starts at the temporary activity certificate stage, and permit subjects are assessed across the facility as a whole (Article 11(3)).
Official sources
- Environmental Permit and Licence Regulation (Çevre İzin ve Lisans Yönetmeliği), Official Gazette 10.09.2014 / 29115; amendments include Official Gazette 16.10.2021 / 31630 and 23.02.2023 / 32113 — mevzuat.gov.tr
- Environment Law No. 2872 (Çevre Kanunu) of 9/8/1983 — mevzuat.gov.tr
- Environmental Impact Assessment Regulation (ÇED Yönetmeliği), Official Gazette 29.07.2022 / 31907 — mevzuat.gov.tr
- Zero Waste Regulation (Sıfır Atık Yönetmeliği), Official Gazette 12.07.2019 / 30829, referred to in the definition of the provincial conformity letter — mevzuat.gov.tr
Unofficial English rendering of the Turkish provisions cited. Only the Turkish text published in the Official Gazette is legally binding. Author: Can Cihan Yılmaz, Managing Partner.