Turkey's Position on Digital Product Passports

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Turkey's Strategic Importance in the DPP Landscape

Turkey occupies a uniquely influential position in global trade, serving as a critical manufacturing hub and gateway between European and Asian markets. With a customs union agreement with the European Union that has been in force since 1996, Turkey's industrial and regulatory policies are closely intertwined with those of the EU. As the EU's Ecodesign for Sustainable Products Regulation (ESPR) introduces mandatory Digital Product Passports across a wide range of product categories, Turkey finds itself at a crossroads where regulatory alignment is not merely advantageous but economically essential.

Turkish exports to the EU represent a substantial portion of the country's total trade volume. The automotive, textile, electronics, and construction materials sectors are particularly dependent on European market access. Any failure to align with emerging DPP requirements could result in significant trade barriers, making Turkey's response to the ESPR one of the most consequential regulatory decisions facing the country's industrial policymakers in the coming years.

The Turkish government has signalled awareness of these developments through various policy documents and ministerial statements, though concrete legislative action remains in its early stages. Understanding where Turkey stands today and where it is headed is vital for businesses operating in or trading with the country.

The Customs Union and Regulatory Harmonisation

The EU-Turkey Customs Union covers industrial goods and processed agricultural products, requiring Turkey to adopt the EU's Common External Tariff and align its trade policies accordingly. Historically, this has meant that Turkey adopts a significant proportion of EU product regulations, though the process is neither automatic nor immediate. The customs union does not extend to services, agriculture, or public procurement, and Turkey has no formal seat at the table when EU regulations are drafted.

For DPP requirements under the ESPR (EU Regulation 2024/1781), Turkey faces a familiar challenge: it must align its domestic legislation with EU rules to maintain market access, yet it has limited influence over the shape those rules take. The Turkish Standards Institution (TSE) and the Ministry of Trade have historically managed this process through the adoption of harmonised European standards, and a similar approach is expected for DPP-related requirements.

However, the DPP introduces a layer of digital infrastructure that goes beyond traditional product standards. Requirements for machine-readable data carriers, interoperable data registries, and standardised data formats mean that Turkey must invest not only in regulatory transposition but also in the technological systems that underpin Digital Product Passports.

Current State of Turkey's DPP Readiness

As of September 2026, Turkey has not enacted legislation mandating Digital Product Passports, although the Ministry of Trade tracks the EU rules closely under its Green Deal work, publishing a DPP FAQ for exporters and relaying the Commission's 2025 consultation on DPP service providers. Several parallel initiatives suggest the groundwork is being laid. The Turkish Ministry of Industry and Technology has been developing a national digitalisation strategy that encompasses product traceability, and pilot programmes in the textile and automotive sectors have explored the use of digital identifiers for supply chain transparency.

The Turkish Standards Institution has been actively participating in CEN and CENELEC technical committees working on DPP-related standards, ensuring that Turkish industry has visibility into the evolving requirements. Additionally, several Turkish industry associations, particularly in textiles and automotive components, have begun issuing guidance to their members on preparing for DPP compliance.

• Key indicators of Turkey's DPP readiness include:
• Active participation in European standardisation bodies working on DPP technical specifications
• Pilot traceability programmes in the textile sector aligned with EU sustainability reporting frameworks
• Government digitalisation initiatives that could serve as foundations for DPP infrastructure
• Industry association awareness campaigns and preparatory guidance documents
• Ongoing dialogue between the Ministry of Trade and EU counterparts on regulatory alignment timelines

Sector-Specific Implications for Turkish Manufacturers

Turkey's textile and apparel industry is one of the largest in the world and a major supplier to European fashion brands. Given that textiles are among the first product categories expected to require DPPs under the ESPR, Turkish textile manufacturers face particularly urgent compliance pressures. The ESPR timeline and deadlines indicate that the textiles delegated act is indicatively adopted in 2027 under the ESPR working plan, with compliance required at least 18 months after adoption.

The automotive components sector is similarly exposed. Turkey is one of Europe's largest vehicle and parts manufacturers, with major European brands operating production facilities in the country. DPP requirements for batteries are already defined under the EU Battery Regulation, and broader automotive DPP requirements are anticipated under the ESPR's delegated acts. Turkish suppliers must ensure their data collection and sharing capabilities meet the standards expected by European original equipment manufacturers.

Construction materials, electronics, and household appliances are additional sectors where Turkish manufacturers have significant EU market exposure. Each of these sectors is likely to be covered by ESPR delegated acts, meaning that a broad swathe of Turkish industry will eventually need to implement DPP systems. The data requirements for Digital Product Passports will vary by sector, but the underlying need for structured, machine-readable product data is universal.

Challenges Facing Turkish Businesses

The transition to Digital Product Passports presents several challenges specific to the Turkish context. Small and medium-sized enterprises, which form the backbone of Turkish manufacturing, often lack the digital infrastructure and technical expertise needed to implement comprehensive product data management systems. While large manufacturers and those integrated into European supply chains may have the resources to adapt, the broader industrial base faces a significant capability gap.

Data governance presents another challenge. DPPs require accurate, verifiable data on materials composition, environmental impact, and supply chain provenance. Many Turkish manufacturers, particularly those in fragmented supply chains, do not currently collect or maintain this data in the structured formats required. Building the internal systems and processes to generate reliable DPP data will require substantial investment in both technology and workforce skills.

Infrastructure considerations also loom large. Turkey will need to establish or connect to data registries that are interoperable with EU systems, develop verification and auditing mechanisms, and ensure that data carriers on products meet European technical specifications. The costs and complexity of this infrastructure build-out should not be underestimated, particularly given that Turkey must fund these developments without access to EU structural funds.

Opportunities and Strategic Advantages

Despite the challenges, DPP adoption also presents significant opportunities for Turkish businesses. Early compliance can serve as a competitive differentiator, particularly for manufacturers seeking to position themselves as preferred suppliers to sustainability-conscious European brands. Companies that can demonstrate full DPP compliance will be better placed to win contracts as European businesses seek to ensure their supply chains meet regulatory requirements.

Turkey's existing strengths in manufacturing and its geographic proximity to Europe give it a natural advantage over more distant competitors who may face even greater challenges in meeting DPP requirements. By investing early in DPP infrastructure, Turkish manufacturers can strengthen their position in European supply chains at a time when reshoring and nearshoring trends are already favouring closer suppliers.

• Strategic opportunities for Turkish businesses include:
• Differentiation through early DPP compliance in competitive export markets
• Strengthened positioning in European nearshoring and supply chain diversification strategies
• Development of domestic DPP technology and services sector
• Enhanced transparency as a tool for building brand trust with European consumers
• Leveraging DPP data for operational improvements and waste reduction

Government Policy and the Path Forward

The Turkish government's response in the coming months and years will be critical in determining how smoothly the country's industry transitions to DPP compliance. Several policy measures could significantly ease the transition: financial incentives and grants for SMEs investing in digital product data systems; accelerated adoption of EU-harmonised DPP standards through the TSE; investment in shared digital infrastructure that smaller manufacturers can access without building proprietary systems; and bilateral agreements with the EU on mutual recognition of DPP data and verification processes.

Understanding what a Digital Product Passport entails is the essential first step for any Turkish business that exports to Europe. The window for preparation is narrowing, and businesses that begin their compliance journey now will be far better positioned than those that wait for domestic legislation to catch up with EU requirements. Turkey's industrial future in European markets depends, in no small part, on how effectively it navigates the DPP transition.

For Turkish manufacturers and exporters, the message is clear: DPP compliance is not a distant prospect but an imminent commercial reality. Engaging with the requirements now, investing in data infrastructure, and aligning internal processes with European standards will be essential for maintaining competitiveness in the years ahead.