Mineral Oils & Lubricants Legislation
Packaging and Marketing of Mineral Oils
Mineral Oil Legislation in Türkiye
Packaging and Placing on the Market of Lubricating Oils
In Türkiye, lubricating oils (madeni yağlar) are regulated by the Energy Market Regulatory Authority (EPDK). The key mineral oil legislation is the Communiqué on the Packaging and Placing on the Market of Lubricating Oils, published in Official Gazette No. 27844 of 12 February 2011 and last amended by the communiqué published in Official Gazette No. 32087 of 28 January 2023. Lubricant production is carried out under an EPDK lubricant licence.
Safety Data Sheets and Reporting Obligations
Under Turkish mineral oil legislation, lubricant manufacturers and importers have the following documentation and reporting obligations:
- Safety data sheets (Article 8): Lubricant manufacturers and importers must prepare safety data sheets (SDS) for the lubricants they place on the market and keep them available for inspections.
- Quarterly reporting: Manufacturers must prepare manufacturing, sales, stock and import information forms, and importers must prepare import, sales and stock information forms. These forms are submitted electronically to the Revenue Administration every quarter, by 24:00 on the 35th day after the end of each period.
- Lubricants for which these forms and safety data sheets have not been prepared cannot be placed on the market.
Under Annex II of KKDİK, safety data sheets must be prepared by certified chemical assessment specialists (KDU).
TSE Certification and Licensed Production Facilities
- TSE certification (Article 9): Manufacturers may only produce lubricants whose TSE and/or TSEK Certificate of Conformity standard number is recorded in their licence. When a standard is revised or a new one is published, manufacturers have eighteen months to renew the certificate.
- Base oils: Manufacturers may not place base oils on the market as base oil, either directly or mixed with additives, outside their lubricant production activity.
- Use as fuel prohibited (Article 11): Lubricants, base oils, solvents and similar petroleum products, as well as waste oils, may not be sold or used as fuel. Manufacturers and importers must notify EPDK if they find that their products are used for other purposes.
- Licensed facilities: Lubricants may only be sold or stored at sites with the required permits, and production, filling and packaging take place at licensed facilities, within the quantity recorded in the licence.
- Facility standards (Article 12): Facilities must be designed, built, operated and maintained in line with TS or EN standards or, where these do not exist, other standards accepted by TSE.
The Council of State’s 13th Chamber annulled the licensed-facility provision in 2014 (E.2012/287, K.2014/383), but this decision was reversed by the Board of Administrative Case Chambers on 22 March 2017 (E.2014/4208, K.2017/1306).
Advertising Claims, Responsible Manager and Insurance
- Advertising claims (Article 13): Concrete claims on packaging and in advertisements must be supported by scientific evidence and presented to EPDK inspectors on request. Lubricants must also comply with the classification, labelling and packaging legislation.
- Safety (Article 14): Lubricants must not harm human health or the environment when used under normal and foreseeable conditions.
- Responsible manager (Article 15): Production facilities must employ a full-time responsible manager with a degree in chemistry or in chemical, petroleum, environmental, mechanical or industrial engineering.
- Insurance (Article 16): Companies producing, storing, transporting or selling lubricants must take out hazardous substances financial liability insurance.
How Doruksistem can help
Doruksistem helps lubricant manufacturers comply with Turkish mineral oil legislation: TSE certification, the selection of environmentally friendly chemicals, product performance testing, production site licensing, and labels and safety data sheets prepared by certified experts.
Call 0 850 532 35 97, email info@doruksistem.com.tr or contact us online.
Read the communiqué on the EPDK website (in Turkish).