Türkiye’s Climate Law Proposal submitted to the Turkish Grand National Assembly on February 20, 2025, represents a long-awaited step in Türkiye’s efforts to combat climate change. By conducting a comprehensive analysis of this proposal, appreciating its positive aspects while identifying its shortcomings will help us properly evaluate the progress of our country’s climate policies.

Historical Context and Timeline of Türkiye’s Climate Policy Evolution

Türkiye’s journey toward comprehensive climate legislation has been complex and marked by a shifting perspective on environmental priorities and international commitments. Understanding this historical trajectory helps contextualize the significance of the current Climate Law Proposal.

Türkiye’s engagement with international climate policy began officially when it became a party to the United Nations Framework Convention on Climate Change (UNFCCC) in 2004. Unlike most developed nations, Türkiye joined with a unique status—included in Annex I (industrialized countries) but removed from Annex II (countries with financial obligations to support developing nations). This special positioning reflected Türkiye’s self-identification as a developing economy despite its OECD membership, creating a tension that would shape its climate policy for years to come.

The first significant domestic policy response came in 2010 with the adoption of the National Climate Change Strategy (2010-2023). This document represented Türkiye’s initial attempt to formulate a coherent approach to climate change, though it lacked binding targets or enforcement mechanisms. It was followed in 2011 by the more detailed National Climate Change Lawion Plan, which outlined sectoral measures for both mitigation and adaptation but similarly lacked mandatory implementation provisions.

A critical turning point occurred in 2015 when Türkiye submitted its first Intended Nationally Determined Contribution (INDC) to the UNFCCC ahead of the Paris Agreement negotiations. Türkiye pledged a 21% reduction in greenhouse gas emissions from the business-as-usual scenario by 2030—a target widely criticized by environmental organizations as unambitious given that it actually allowed for significant emissions growth compared to baseline years used by other countries.

Despite participating in the Paris Agreement negotiations, Türkiye remained one of the few countries not to ratify the agreement for several years, citing concerns about access to climate finance and its unique position. This hesitation represented a significant gap in Türkiye’s climate policy framework and limited its international engagement on climate issues.

The 2018-2022 period saw increasing domestic and international pressure for climate action. Extreme weather events, including unprecedented wildfires, floods, and drought, heightened public awareness of climate vulnerabilities. Simultaneously, the European Union’s introduction of the European Green Deal and Carbon Border Adjustment Mechanism (CBAM) in 2019-2021 created economic imperatives for Türkiye to strengthen its climate policies, particularly given the EU’s status as Türkiye’s largest trading partner.

A major shift occurred in October 2021 when Türkiye finally ratified the Paris Agreement and shortly thereafter announced a net-zero emissions target for 2053. This represented a fundamental realignment of Türkiye’s climate policy and signaled a new willingness to engage with global climate governance. The ratification came after Türkiye secured promises of enhanced access to international climate finance, addressing one of its longstanding concerns.

Following this breakthrough, institutional developments accelerated. In 2022, the Climate Change and Environment Ministry was established, elevating environmental governance to cabinet-level priority. This was followed by the creation of the Directorate of Climate Change in 2023, which began the process of developing more ambitious climate policies aligned with Türkiye’s new international commitments.

The introduction of the Eleventh Development Plan (2019-2023) and subsequently the Twelfth Development Plan (2024-2028) began to integrate climate considerations into national economic planning, though critics noted tensions between climate objectives and continued support for carbon-intensive development projects.

Prior to the current Climate Law Proposal, Türkiye’s climate governance remained fragmented across numerous laws and regulations, including the Environmental Law, Energy Efficiency Law, Renewable Energy Law, and various sectoral regulations. This created coordination challenges and policy inconsistencies that hindered effective climate action.

The submission of the Climate Law Proposal to parliament in February 2025 thus represents the culmination of a gradual but accelerating evolution in Türkiye’s approach to climate change—from reluctant participant to increasingly active stakeholder in global climate efforts. The proposal’s strengths and weaknesses must be understood within this historical context: as a significant step forward from previous positions, yet shaped by ongoing tensions between economic development priorities and environmental imperatives that have characterized Türkiye’s climate policy from the beginning.

This historical perspective underscores why the current proposal, despite its limitations, represents a milestone in Türkiye’s climate governance. It also highlights why addressing the proposal’s shortcomings—particularly regarding binding targets, independent oversight, and just transition provisions—is essential to overcoming the policy fragmentation and implementation gaps that have historically constrained Türkiye’s climate action.

Analysis of the General Principles and Adaptation Measures in Türkiye’s Climate Law Proposal

The Climate Law Proposal’s Article 3, titled “General Principles,” and Article 6, which addresses “Adaptation to Climate Change,” contain significant provisions that merit closer examination. These articles establish the philosophical foundation and practical approach to climate resilience within the proposed framework.

Article 3 establishes that Türkiye’s climate change efforts will be guided by the principle of “common but differentiated responsibilities and respective capabilities.” This internationally recognized principle acknowledges that while all countries share responsibility for addressing climate change, their historical contributions to the problem and their capacity to respond differ significantly. By explicitly incorporating this principle, Türkiye positions its climate policy within the established international framework while maintaining flexibility regarding its implementation timeline and approach.

The principles of equity, climate justice, precaution, participation, integration, sustainability, transparency, just transition, and progressive approaches mentioned in Article 3(a) align with global best practices. However, the proposal fails to define these principles concretely or establish mechanisms to ensure their application in practice.

For instance, while “just transition” is mentioned, there are no specific provisions for supporting workers and communities dependent on carbon-intensive industries during the transition to a low-carbon economy. In contrast, the EU’s Just Transition Mechanism provides dedicated financial support and technical assistance to ensure the green transition is fair and leaves no one behind.

Article 3(c) references the National Contribution Statement (NDC) and the net-zero emissions target, stating that “the country’s development priorities and special circumstances are taken into consideration.” This language, while acknowledging the need for climate action, potentially creates a loophole that could be used to delay ambitious action. Unlike the EU Climate Law, which establishes legally binding targets and timelines, this provision leaves considerable room for interpretation regarding when and how Türkiye will achieve net-zero emissions.

The adaptation measures outlined in Article 6(5) represent one of the proposal’s stronger elements. This provision recognizes the importance of ecosystem protection, biodiversity conservation, and land degradation neutrality in climate resilience. The emphasis on increasing both the quality and proportion of protected marine and terrestrial areas is particularly significant given Türkiye’s rich biodiversity and vulnerability to climate impacts. The commitment to sustainable management of carbon sinks in non-forest areas for achieving the net-zero emission target also demonstrates an understanding of the importance of nature-based solutions.

However, Article 6 lacks specific targets for protected area expansion or ecosystem restoration, which would provide clearer direction for implementation. It also does not establish a dedicated funding mechanism for these adaptation measures, raising questions about how these ambitious goals will be financed. The absence of provisions for community involvement in adaptation planning is another notable gap, particularly since local knowledge is increasingly recognized as crucial for effective climate adaptation.

When compared to comprehensive frameworks like the EU Adaptation Strategy, Türkiye’s approach in Article 6 appears less systematic. The EU strategy includes requirements for adaptation monitoring and reporting, climate risk assessments across sectors, and integration of adaptation concerns into all policy areas. Türkiye’s proposal would benefit from similar provisions to ensure that adaptation efforts are coordinated, evidence-based, and regularly evaluated.

In summary, while Articles 3 and 6 contain important principles and commitments, they would be significantly strengthened by more concrete definitions, clearer targets, established implementation mechanisms, and dedicated funding streams. These improvements would help transform these well-intentioned principles into effective tools for climate action and resilience building.

The Most Significant Achievements of the Proposal

The Climate Law Proposal is of great importance primarily because it provides a legal framework for Türkiye’s fight against climate change. The consolidation of climate efforts, previously conducted through scattered legislation and institutional structures, under a single umbrella represents a critical development in terms of policy coherence. Additionally, strengthening the legal status of the Directorate of Climate Change can be considered a positive step toward increasing institutional capacity.

One of the most notable aspects of the proposal is the establishment of an Emissions Trading System (ETS). This mechanism stands out as a market-based tool that will encourage businesses to adopt emission reduction measures by putting a price on carbon emissions. Furthermore, the steps toward establishing sustainable finance infrastructure, such as the creation of the Turkish Green Taxonomy and green bond regulations, are important developments for mobilizing the financial resources necessary for the green transformation.

Comparative Analysis with the EU ETS: Lessons to be Learned

When we compare Türkiye’s planned ETS system with the European Union’s ETS system (EU ETS), which has been in operation since 2005 and is the world’s largest carbon market, significant differences and potential areas for improvement emerge.

The EU ETS was initially criticized for free allocations and loose emission caps, with low carbon prices limiting the system’s effectiveness. However, following reforms implemented particularly in 2018, the system was strengthened, and carbon prices reached more meaningful levels with mechanisms such as the Market Stability Reserve (MSR). For Türkiye’s ETS design to benefit from these EU experiences would ensure that the system operates effectively from the very beginning.

Another important feature of the EU ETS is its transparency and independent oversight mechanisms. The EU has established a strong institutional structure in areas such as emissions data verification, allocation distribution, and market surveillance. In Türkiye’s ETS proposal, however, these areas are not sufficiently detailed, particularly the independent verification mechanisms which are not clearly defined.

Furthermore, the EU mandates that at least 50% of the revenues generated from the ETS must be allocated to climate and energy projects, ensuring that resources collected through the “polluter pays” principle are channeled into green transformation. The Turkish proposal lacks a clear framework for revenue utilization. This ambiguity poses a risk in terms of the system’s legitimacy and acceptability.

Shortcomings of the Proposal

One of the major deficiencies of the Türkiye’s Climate Law Proposal is the absence of binding medium and long-term emission reduction targets. The EU’s goals of reducing emissions by 55% by 2030 and becoming carbon-neutral by 2050 guide all policy and investment decisions. In Türkiye’s proposal, only general principles are stated, without concrete and measurable targets. This situation makes it difficult to measure the effectiveness of climate policies and ensure accountability.

The lack of a clear timeline and planning for the decarbonization of the energy sector, particularly for phasing out coal, is another critical shortcoming of the proposal. Considering that approximately 70% of Türkiye’s greenhouse gas emissions originate from the energy sector, the transformation in this area needs to be clearly planned. Given that the EU has detailed its roadmap for exiting coal within the framework of the Green Deal, Türkiye is expected to take more proactive steps in this regard.

Another significant deficiency in the proposal is the absence of an independent scientific advisory board that would ensure climate policies are based on scientific foundations. Structures such as the UK’s Climate Change Committee or the EU’s Scientific Advisory Mechanism ensure that policies align with scientific realities and hold the government accountable. The lack of institutionalization of scientific guidance in Türkiye’s climate policies increases the risk that decisions will be shaped according to political and economic priorities.

Finally, the insufficient detailing of public participation, access to information, and accountability mechanisms in the development and implementation of climate policies is concerning from the perspective of democratic governance. While the EU’s Climate Law ensures regular public opinion polls, citizens’ consultation assemblies, and participatory processes, these issues are addressed superficially in the Turkish proposal.

Forward-Looking Perspective and Recommendations

Türkiye’s Climate Law Proposal can be strengthened and its deficiencies addressed during the parliamentary process. In this process, it is primarily necessary to add science-based emission reduction targets to the law and clearly define medium and long-term roadmaps. Creating sectoral plans for energy transformation and clarifying the timeline for phasing out coal will increase the effectiveness of the law.

The ETS system should be designed more robustly by leveraging EU experiences, with more detailed regulations especially on issues such as transparency, the amount of free allocation, and the risk of carbon leakage. Legal assurance should be provided for channeling ETS revenues into green transformation and climate adaptation projects.

The establishment of an independent scientific advisory board will ensure that policies are based on scientific foundations and implemented consistently. Additionally, establishing stronger mechanisms for public participation and access to information will increase social ownership of climate policies.

In conclusion, while the Climate Law Proposal represents an important step in Türkiye’s fight against climate change, it contains shortcomings in its current form. Addressing these deficiencies during the parliamentary process with the contributions of civil society, academia, and the business world is critical for Türkiye to achieve its Paris Agreement goals and realize its green transformation. As part of the international community and in fulfillment of our responsibility to future generations, implementing an effective and inclusive climate law based on scientific realities should be our country’s priority.

 

KEY CONCEPTS AND DEFINITIONS

Climate Change: A long-term shift in global or regional climate patterns, primarily attributed to increased levels of atmospheric carbon dioxide produced by the use of fossil fuels.

Paris Agreement: An international treaty on climate change, adopted in 2015, aiming to limit global warming to well below 2°C, preferably to 1.5°C, compared to pre-industrial levels. Türkiye ratified the Paris Agreement in 2021.

Net-Zero Emissions: A state in which the greenhouse gases going into the atmosphere are balanced by their removal. This balance – net-zero – will happen when the amount of greenhouse gases we add is no more than the amount taken away.

Emissions Trading System (ETS): A market-based approach to controlling pollution by providing economic incentives for reducing emissions. A central authority allocates or sells a limited number of permits that allow emissions up to a certain level. Entities that need to increase their emission permits must buy them from others willing to sell them.

Carbon Leakage: The situation that may occur when businesses transfer production to countries with less stringent emission constraints due to costs related to climate policies, potentially leading to an increase in their total emissions.

Green Taxonomy: A classification system that establishes a list of environmentally sustainable economic activities. It provides companies, investors, and policymakers with definitions for which economic activities can be considered environmentally sustainable.

Just Transition: An approach to environmental policy-making that aims to minimize hardships for workers and communities in industries transitioning away from fossil fuels, ensuring the benefits and burdens of the transition to a low-carbon economy are fairly distributed.

Climate Adaptation: The process of adjustment to actual or expected climate and its effects. In human systems, adaptation seeks to moderate harm or exploit beneficial opportunities. In natural systems, human intervention may facilitate adjustment to expected climate and its effects.

Climate Mitigation: Lawions that aim to reduce or prevent greenhouse gas emissions, such as using new technologies and renewable energies, making older equipment more energy efficient, or changing management practices or consumer behavior.

Land Degradation Neutrality: A state whereby the amount and quality of land resources necessary to support ecosystem functions and services and enhance food security remain stable or increase within specified temporal and spatial scales and ecosystems.

Market Stability Reserve (MSR): A mechanism introduced in the EU ETS to reduce the surplus of emission allowances in the carbon market and improve the system’s resilience to future shocks by adjusting the supply of allowances to be auctioned.

Common but Differentiated Responsibilities: A principle within the United Nations Framework Convention on Climate Change (UNFCCC) that acknowledges all states have a shared obligation to address global environmental destruction but denies equal responsibility of all states with respect to environmental protection.

Carbon Sinks: Natural or artificial reservoirs that accumulate and store carbon-containing compounds for an indefinite period, thereby reducing the concentration of CO₂ in the atmosphere. The main natural carbon sinks are forests, soil, and oceans.

Nationally Determined Contributions (NDCs): Non-binding national plans highlighting climate actions, including climate-related targets for greenhouse gas emission reductions, policies and measures governments aim to implement in response to climate change and as a contribution to achieve the global targets set out in the Paris Agreement.