Battery Compliance in Türkiye: Step-by-Step Guide for Lithium-Ion Batteries (2025 Update)

Lithium-ion batteries are no longer just an R&D or engineering topic. In Türkiye, they sit at the intersection of product safety, chemicals regulation, waste & EPR obligations, and dangerous goods transport rules.

If you manufacture, import or sell batteries or battery-powered products in Türkiye, you now need a structured battery compliance strategy — not a "we'll deal with it later" approach.

In this article, we explain:

• The key regulations affecting batteries in Türkiye,
• How they link to EU rules and the Green Deal,
• A practical, 10-step battery compliance roadmap you can start using today.

Why battery compliance matters in Türkiye

Türkiye is rapidly expanding its:

• Electric vehicle (EV) ecosystem,
• Energy storage (ESS) projects,
• and battery-powered consumer products.

With this growth comes increased regulatory scrutiny. Authorities are focusing on:

• Product safety and fire risk,
• Environmental performance and waste management,
• Chemicals and hazard communication,
• Safe transport and storage.

Companies that treat battery compliance as a "box-ticking exercise" risk:

• Customs delays and blocked shipments,
• Fines and product recalls,
• Loss of trust with customers and partners.

Those that build a proactive, documented compliance framework gain:

• Faster market access,
• Stronger positioning with EU partners,
• A clear advantage as new rules (like the EU Batteries Regulation) arrive.

1. Key battery regulations in Türkiye

1.1 Product safety – Law No. 7223

Law No. 7223 on Product Safety and Technical Regulations is the main umbrella legislation.

For lithium-ion batteries, it requires that:

• Products placed on the market are safe under normal and reasonably foreseeable conditions,
• Manufacturers and importers perform suitable conformity assessment and keep a technical file,
• Traceability and recall processes are in place.

In practice, this means you need:

• A clear technical description of your battery or battery-powered product,
• Test reports according to relevant standards (e.g. IEC-type safety tests),
• Documented risk assessments (thermal runaway, fire scenarios, misuse),
• Clear user instructions in Turkish and other relevant languages.

1.2 Waste & EPR – Waste Batteries and Accumulators Regulation

Türkiye's Regulation on the Control of Waste Batteries and Accumulators defines how:

• Portable batteries,
• Automotive batteries,
• Industrial batteries

must be managed at end-of-life.

If you are the producer or importer (i.e. the first entity placing batteries on the Turkish market), you are typically responsible for:

• Declaring the quantities you place on the market,
• Meeting collection and recovery targets,
• Financing collection and recovery via authorised schemes and licensed operators.

This is Türkiye's version of Extended Producer Responsibility (EPR) for batteries. Ignoring it can create serious compliance gaps, even if your product is technically "safe".

1.3 Import controls – Product Safety and Inspection Communiqués (TAREKS)

Batteries and accumulators are subject to periodic Product Safety and Inspection Communiqués. These:

• Require risk-based inspections via TAREKS,
• Allow authorities to check documentation, labelling, markings and, where needed, perform physical tests,
• Explicitly confirm that compliance with the Waste Batteries Regulation is mandatory, irrespective of inspection frequency.

For importers, this means:

• You must prepare your technical and compliance documentation before import,
• You should assume that any shipment might be inspected,
• A single non-compliance can trigger wider scrutiny of your product range.

1.4 Chemicals – KKDİK, SEA and Safety Data Sheets (SDS / GBF)

Lithium-ion batteries sit on top of complex chemistry. The most relevant Turkish chemicals regulations are:

• KKDİK – Türkiye's REACH-like regulation, covering manufacture and import of substances at ≥ 1 tonne/year,
• SEA – Türkiye's CLP-like regulation on classification, labelling and packaging.

Within a battery, substances such as:

• Electrolyte components,
• Certain salts and additives,
• Binder materials

may be subject to KKDİK registration if tonnage thresholds are met and you are in the role of manufacturer or importer in Türkiye.

At the same time, SEA drives:

• Correct classification and labelling,
• Provision of Safety Data Sheets (GBF) in Turkish for relevant mixtures.

If you are a non-Turkish manufacturer exporting to Türkiye, you can appoint a Turkish Only Representative (OR) to take over KKDİK obligations from your local importers. This is a strategic decision and should be backed by strong contractual arrangements.

1.5 Dangerous goods transport – high-level ADR framework

Lithium-ion batteries are treated as dangerous goods in transport. For companies, this translates into requirements for:

• Proper packaging and handling,
• Correct marking and labelling of outer packaging,
• Appropriate transport documents,
• Adequate training for warehouse and logistics staff.

You do not need to turn your organisation into a transport academy, but you must have:

• At least basic dangerous goods competence inside the company,
• Written procedures for shipping, storage and incident response,
• A clear understanding of which products are subject to which rules.

1.6 EU Batteries Regulation & Türkiye's Green Deal alignment

The new EU Batteries and Waste Batteries Regulation (EU) 2023/1542 is changing the game in Europe by introducing:

• Battery carbon footprint declarations,
• Recycled content targets,
• More detailed labelling and information requirements,
• And soon, digital battery passports.

Türkiye is actively working on Green Deal alignment, so similar concepts are expected to influence the Turkish market as well.

If you export batteries or battery-powered products to the EU, or work with EU OEMs, you should start aligning now to avoid being locked out later.

2. Roles in the Turkish battery market: who is responsible for what?

Understanding your legal role is critical for battery compliance in Türkiye:

Manufacturer (in the legal sense):

• Established in Türkiye, placing batteries or battery-powered products on the market under your own name or brand.

Importer:

• Established in Türkiye, placing products from outside Türkiye onto the Turkish market.

Distributor:

• Only storing and placing products on the market without changing them, often downstream in the chain.

Most obligations concentrate on manufacturers and importers. Distributors still have duties (e.g. not to sell clearly non-compliant products), but are usually not the primary registrants or producers for EPR.

3. 10-Step lithium-ion battery compliance roadmap for Türkiye

Below is a practical checklist you can use internally and with your partners.

Step 1 – Define your battery product and applications

Start with a product mapping exercise:

• Cell, module or full pack?
• Chemistry: LFP, NCM, LCO or others?
• Applications: EV, ESS, consumer electronics, industrial tools?

This will determine:

• Which technical standards apply,
• How the product falls under the Waste Batteries Regulation (portable / automotive / industrial),
• The complexity of your EPR and logistics setup.

Step 2 – Create a regulatory matrix per product family

Build a table for each product line including:

• Product safety requirements (Law 7223, applicable standards),
• KKDİK and SEA obligations (substances, tonnages, OR vs. importer roles),
• Waste & EPR responsibilities (producer/importer, collection targets, schemes),
• Dangerous goods transport obligations (per mode: road, sea, air).

This regulatory matrix becomes your internal reference and helps you avoid "forgotten" obligations.

Step 3 – Prepare a product safety file and risk assessment

For each battery or battery-powered product, prepare a technical file containing:

• Design and technical specifications,
• Relevant test reports (mechanical, electrical, environmental),
• A structured risk assessment (including misuse and foreseeable abuse),
• User instructions and warnings in Turkish,
• Traceability elements (serial/lot numbers, date and place of manufacture).

This is your main defence in product safety inspections and incident investigations.

Step 4 – Perform a KKDİK / SEA assessment

Work with your supplier and internal teams to:

• Identify all substances in your battery systems (CAS/EC, concentration),
• Calculate annual tonnages relevant for Türkiye,
• Decide who will take the role of registrant (importer vs. Only Representative),
• Plan and implement:
  • SEA classification and labelling,
  • Required notifications,
  • SDS / GBF provision in Turkish.

For many companies, it is more efficient to:

• Appoint a specialised Only Representative in Türkiye,
• Centralise KKDİK responsibilities,
• And protect the supply chain from fragmented or inconsistent registrations.

Step 5 – Review battery labelling and information

Check that your labels and documents cover:

Product safety + SEA content:

• Responsible economic operator in Türkiye,
• Hazard and precautionary statements (where applicable),
• Any relevant symbols and safety warnings.

Waste Batteries Regulation:

• Crossed-out wheeled bin symbol,
• Heavy metal symbols (Pb, Cd, Hg) if present,
• Capacity and type (where required).

Instructions for use:

• Charging and discharging conditions,
• Storage and temperature limits,
• What to do in case of damage, leakage or fire.

Step 6 – Design your EPR & waste strategy

Treat EPR as a project, not just a formality:

• Choose your collection and recovery partners (authorised schemes, municipalities, licensed recyclers),
• Design a take-back process for damaged and end-of-life batteries,
• Plan the logistics for return flows,
• Clearly allocate EPR costs internally and in your contracts.

This approach will position you well when future recycled content and carbon footprint trends hit the Turkish market more concretely.

Step 7 – Get ready for TAREKS and customs inspections

Before importing batteries or battery-powered products:

• Make sure your technical file, test reports, SDS and EPR evidence are ready,
• Verify that labels and markings on shipping units match the legal requirements,
• Ensure your customs broker understands your product and compliance status.

Think of TAREKS as a gatekeeper: once you pass with a clean compliance record, your life becomes easier; repeated issues create an institutional memory against your company.

Step 8 – Strengthen your logistics and storage procedures

Dangerous goods rules should be reflected in your internal procedures:

• Incoming and outgoing goods checks (damaged batteries, swollen packs, etc.),
• Storage conditions (SOC control, temperature, fire separation),
• Documented handling instructions for warehouse staff,
• Emergency response plans for smoke, fire or leak events.

Even if you outsource logistics, authorities may still hold you responsible as the producer/importer; make sure your contracts and audits cover these topics.

Step 9 – Fix the legal framework with partners

Battery compliance has an important contractual dimension:

With non-Turkish manufacturers:

• Who is responsible for KKDİK registrations?
• Who pays for data and dossier updates?
• How will you handle inspections or information requests?

With distributors and large customers in Türkiye:

• Who bears the EPR costs?
• How do you coordinate recalls or incident communication?
• What information and documentation must be shared?

Strong contracts reduce disputes when something goes wrong and make your compliance model scalable.

Step 10 – Monitor changes and treat compliance as a strategic asset

Finally, set up a simple but robust monitoring system:

Annual review of:

• EU Batteries Regulation developments,
• Turkish legislation (environment, product safety, energy, customs),
• Dangerous goods and fire safety guidance.

Internal actions:

• Update procedures, templates and training materials,
• Review supplier contracts and technical files,
• Integrate compliance requirements into product development and sourcing.

Companies that treat battery compliance as a strategic capability will be the ones that can grow sustainably in Türkiye and the EU.

Key takeaways for battery compliance in Türkiye

• Lithium-ion batteries are covered by a bundle of regulations, not a single law.
• You must address product safety, chemicals, EPR and transport together, not in separate silos.
• A simple 10-step roadmap (product mapping, regulatory matrix, technical file, KKDİK/SEA, EPR, TAREKS, logistics, contracts, monitoring) can transform your approach from reactive to proactive.
• Early alignment with the EU Batteries Regulation and Türkiye's Green Deal agenda will protect market access and create competitive advantage.