Sustainability messaging has become a defining element of modern brand positioning. Environmental references are no longer confined to niche product lines; they are increasingly embedded in corporate identity, long-term strategies, and competitive differentiation. 

In Türkiye, however, environmental claims are no longer assessed merely as marketing language. Recent enforcement practice demonstrates that they are increasingly treated as verifiable regulatory statements — capable of triggering administrative sanctions and unfair competition exposure. 

While Türkiye does not yet have a standalone Green Claims Act, the combined application of consumer protection law, advertising regulations, and unfair competition rules suggests that a functional anti-greenwashing regime is already taking shape. 

1. From Environmental Messaging to Legal Qualification 

Green claims may be broadly defined as voluntary commercial statements suggesting that a product, service, or undertaking has a positive environmental impact, reduced environmental harm, or superior environmental performance compared to alternatives. 

Typical examples include: 

“Eco-friendly” 

“Carbon neutral” 

“Zero emission” 

“Sustainable packaging” 

“Made from recycled materials” 

“Reduced carbon footprint” 

Legal risk arises where such claims are vague, unqualified, unsupported by scientific evidence, selectively presented or based on unclear comparisons. In these circumstances, environmental positioning may amount to greenwashing — a practice increasingly scrutinised by regulators worldwide. 

2. The European Context: Structured Substantiation as a Regulatory Model 

On 22 March 2023, the European Commission adopted the Proposal for a Directive on substantiation and communication of explicit environmental claims, widely referred to as the Green Claims Directive. 

The proposal introduces a structured regime requiring: 

scientific substantiation of environmental claims, 

independent third-party verification prior to communication, 

governance standards for environmental labelling schemes, 

effective, proportionate and dissuasive sanctions, 

and consumer redress mechanisms. 

Although the Directive has not yet entered into force, it reflects a broader regulatory shift: environmental claims are increasingly treated as evidence-based regulatory representations rather than promotional language. 

3. The Turkish Legal Framework: No Dedicated Act, Multi-Layered Enforcement 

Türkiye regulates environmental claims through a layered legal structure. 

3.1 Law on the Protection of Consumers (Law No. 6502) 

Article 61 prohibits misleading commercial advertisements and unfair commercial practices. Environmental claims that lack objective substantiation or overstate environmental impact may fall within this provision. 

3.2 Regulation on Commercial Advertising and Unfair Commercial Practices 

Two provisions are particularly relevant: 

Article 9 – Burden of Proof 

Advertisers must substantiate factual claims with scientifically valid documentation. Where necessary, documentation must be obtained from universities or accredited independent research, testing or evaluation institutions. 

Article 17 – Environmental Claims 

Advertisements may not exploit environmental sensitivity, misuse environmental symbols or rely on non-recognised scientific findings. 

The burden of proof rests on the advertiser at the time the claim is assessed. 

3.3 Unfair Competition Under the Turkish Commercial Code 

Articles 54 and 55 of the Turkish Commercial Code classify misleading commercial statements and advertising contrary to the principle of good faith as acts of unfair competition, creating potential civil liability exposure alongside administrative sanctions. 

4. Advertising Board Practice: Clear Signals from 2024 Decisions 

Recent 2024 decisions of the Turkish Advertising Board demonstrate a consistent and strict approach to environmental claims. 

Eruslu Sağlık Ürünleri Sanayi ve Ticaret A.Ş. (Advertising Board decision dated 09 July 2024, No. 347, File No. 2024/3317) 

Claims such as “biodegradable in soil,” “dissolves in nature,” and “zero carbon target” were found insufficiently substantiated by accredited documentation. Suspension sanctions were imposed. 

LC Waikiki Mağazacılık Hizmetleri Ticaret A.Ş. (Advertising Board decision dated 09 July 2024, No. 347, File No. 2024/3967) 

Product descriptions including “eco-friendly” and quantified savings claims were deemed vague and unsupported by recognised scientific evidence. The Board emphasised that comparative environmental claims require clearly identified benchmarks and methodological transparency. 

Beymen Perakende ve Tekstil Yatırımları A.Ş. (Advertising Board decision dated 09 January 2024, No. 341, File No. 2023/1026) 

Corporate-level commitments such as “100% sustainable packaging” and “zero waste, zero emission target” were found insufficiently transparent due to unclear scope and absence of verifiable supporting documentation. 

Collectively, these decisions indicate that both product-level and corporate sustainability statements are subject to strict substantiation standards. 

5. Convergence with EU Standards:  

Although Türkiye has not adopted a dedicated Green Claims Directive, recent enforcement practice reveals structural similarities with the EU’s proposed model. 

6. Sustainability as Brand Asset — and Regulatory Exposure 

Environmental positioning is increasingly integrated into brand identity and competitive differentiation. When sustainability narratives form part of brand value, regulatory scrutiny of environmental claims may directly affect brand equity and reputational capital. 

In this context, green claims intersect not only with advertising compliance but also with unfair competition exposure and long-term brand strategy. 

7. Practical Implications 

Companies operating in Türkiye should treat environmental claims as substantiated regulatory representations rather than promotional expressions. 

Particular caution is required for: 

broad or undefined environmental descriptors, 

comparative environmental performance claims, 

forward-looking corporate sustainability commitments. 

Pre-publication documentation, methodological clarity and cross-jurisdictional consistency are becoming central elements of compliance risk management. 

8. Conclusion 

In Türkiye, green claims are no longer reviewed solely as ordinary advertising expressions. They are increasingly evaluated as verifiable regulatory statements capable of triggering administrative sanctions and unfair competition exposure. 

While no standalone Green Claims Act exists, enforcement practice suggests that a de facto anti-greenwashing regime is emerging through the strict application of substantiation and environmental advertising provisions. 

If sustainability becomes a defining element of brand value, environmental claims can no longer be approached as simple marketing language — they are compliance-sensitive commitments requiring legal precision.