Turkey and ESPR — Export Compliance Guide

Why ESPR Matters for Turkey's EU Exports

The European Union is one of the world's largest import markets, and ESPR applies to every product placed on the EU market regardless of where it is manufactured. For Turkey's exporters, this means that ESPR compliance is not optional — it is a market access requirement. Products that do not have a valid Digital Product Passport after the applicable compliance date cannot be placed on the EU market. EU customs authorities and market surveillance authorities will verify DPP compliance at the border and in the market.

Turkey's main EU export categories include textiles, apparel, automotive parts, chemicals, and steel. These sectors will be affected by ESPR at different times, depending on when the relevant delegated acts are adopted. Exporters should monitor the Commission's delegated act timeline and begin preparation well in advance of the compliance deadlines.

Key Sectors Affected

Textiles and Apparel

Turkey is the EU's largest supplier of textiles and apparel, with annual exports exceeding €10 billion. The ESPR textile delegated act is expected in 2026–2027 and will require Digital Product Passports for all textile products placed on the EU market. The DPP must contain fibre composition data, recycled content percentages, chemical treatment data, country of manufacture, and end-of-life instructions. Turkish textile manufacturers must begin collecting this data from their supply chains now.

The EU's Strategy for Sustainable and Circular Textiles (2022) sets the policy framework for ESPR's textile requirements. Key requirements include minimum recycled content thresholds, restrictions on the destruction of unsold textiles, and extended producer responsibility for textile waste. Turkish manufacturers who supply EU fast fashion brands should expect significant compliance requirements as these brands face their own ESPR obligations.

Automotive Parts

Turkey is a major supplier of automotive components to EU vehicle manufacturers. Automotive parts are expected to be covered by ESPR delegated acts, with requirements for recycled content, substance of concern disclosure, and DPPs. Turkish automotive suppliers should monitor the Commission's working plan for automotive sector delegated acts and begin preparation for DPP requirements.

Authorised Representative Requirement

Non-EU manufacturers who place products on the EU market must appoint an EU-based Authorised Representative under ESPR Article 16. The Authorised Representative is a legal entity or natural person established in the EU who is authorised to act on behalf of the manufacturer in relation to ESPR obligations. The Authorised Representative is legally responsible for ensuring that the DPP is accurate, complete, and accessible. They must maintain technical documentation and be available to market surveillance authorities.

The Authorised Representative must be appointed before the product is placed on the EU market. The appointment must be documented in a written mandate that specifies the Authorised Representative's responsibilities. The Authorised Representative's name and address must be included in the DPP and on the product or its packaging.

Digital Product Passport Requirements for Exporters

Every product covered by an ESPR delegated act must have a Digital Product Passport accessible via a QR code or NFC tag on the product or its packaging. The DPP must contain the data specified in ESPR Annex III for the relevant product category. The QR code must comply with GS1 Digital Link standards. The DPP data must be hosted on a system that is accessible 24/7 and must remain accessible for the entire market lifetime of the product.

Exporters from Turkey have two main options for DPP compliance: they can use a third-party DPP registry (such as digitalproductpassports.co.za, which is designed for non-EU manufacturers), or they can build a proprietary DPP system. Third-party registries are typically more cost-effective for manufacturers who do not have the technical resources to build and maintain a compliant DPP system.

Conformity Assessment and CE Marking

Products covered by ESPR delegated acts must undergo conformity assessment before being placed on the EU market. The conformity assessment procedure depends on the product category and the delegated act. For most consumer products, the manufacturer can conduct a self-declaration of conformity (Module A). For higher-risk products, third-party assessment by a notified body may be required. After conformity assessment, the manufacturer issues an EU Declaration of Conformity and affixes the CE marking to the product.

Exporters from Turkey should engage with their EU Authorised Representative early in the compliance process to understand the conformity assessment requirements for their specific product categories and to ensure that the necessary technical documentation is prepared.

Compliance Timeline for Turkey Exporters

Penalties for Non-Compliance

ESPR Article 68 requires EU Member States to lay down penalties for infringements of the regulation. Penalties must be effective, proportionate, and dissuasive. In practice, this means that products without a valid DPP can be refused entry at EU customs, seized by market surveillance authorities, and subject to mandatory recall from the EU market. Importers and Authorised Representatives can face fines that vary by Member State but can be substantial — in some Member States, fines for ecodesign non-compliance have reached hundreds of thousands of euros.