Environmental Assessment


The Turkish government enacted its restrictions of hazardous substances (Turkey RoHS) rules on electrical and electronic equipment in June 2019.

Comparing Europe and Turkey RoHS

European Union Flag RoHS

Six hazardous substances (lead, mercury, hexavalent chromium, PBBs, and PBDEs) are targeted and the same 10 first EU RoHS product categories are in the scope.

Therefore, assessments, testing, and declarations of electronic devices exported to Turkey must be performed accordingly.

Turkish flag RoHS

Table 1: Restricted Substances and Concentration Limits for Europe and Turkey RoHS

Restricted Substances

EU RoHS (by weight)

Turkey RoHS (by weight)







Hexavalent chromium






Polybrominated biphenyls (PBBs)



Polybrominated diphenyl ethers (PBDEs)



Butyl benzyl phthalate (BBP)



Di-n-butyl phthalate (DBP)



Di(2-ethylhexyl) phthalate (DEHP)



Diisobutyl phthalate (DIBP)



Table 2: Categories of Electrical and Electronic Goods


Applicable Products

Large household items

Large cooling devices; refrigerators, freezers; other large appliances used for cooling, preservation, and storage of food; washing machines; laundry dryers; dishwashers; cooking appliances; electric cookers; electric sheets; microwave ovens; other large appliances for cooking and preparing food; electric heaters; electric radiators; other large appliances used for heating rooms, beds, and sitting groups; electric fans/extractors; air-conditioning devices; other fans, ventilation, and air conditioning equipment; other large household goods within the scope of the definition of electrical and electronic goods

Small appliances

Vacuum cleaners; carpet washing machines; other cleaning machines; knitting, weaving, sewing machines, and other fabric processing machines; ironing machines, ironing and other garment care tools; toasters; frying machines; grinders, coffee machines, packaging devices; electric knives; haircut, hairdryer, tooth brushing, shaving, massage, and other body care tools; wall and wrist clocks and other devices used for measuring and displaying or recording time; scales; other small household appliances within the scope of the definition of electrical and electronic goods

IT and telecommunications equipment

Centralized data processing (mainframes, minicomputers, and printer units); personal computer equipment (personal computers – including a central processing unit, mouse, screen and keyboard – laptop computers – including a central processing unit, mouse, display and keyboard – notebook, laptop and so on); handheld computers (Notepad and similar); printers; copy equipment; electric and electronic typewriters; pocket and desk calculators and electronic information collection, storage, processing, and other products and equipment used for presenting or transmitting; user terminals and systems; fax machines; telex; phones; payphones; cordless phones; cell phones; audio, video and other information via answering machines and telecommunications, and other products and equipment used to transmit; other informatics and telecommunication within the scope of the definition of electrical and electronic equipment

Consumer equipment

Radio receivers; television receivers; video cameras; video recorders; Hi-fi recorders; audio amplifiers; musical instruments; signals and other signals that provide the distribution of image and sound outside of telecommunication, and other products and equipment used for image and sound recording or reproduction, including technologies; other consumer equipment within the scope of the definition of electrical and electronic goods

Lighting equipment

Lamps with fluorescent bulbs, except for domestic use; flat fluorescent lights; compact fluorescent lights; high power discharge, including pressurized sodium lights and metal halide lights; low-pressure sodium lights; other equipment used for lighting or light control, excluding incandescent lights; other lighting equipment within the scope of the definition of electrical and electronic goods

Electrical and electronic equipment

(excluding large and fixed industrial appliances)

Drills; saws; sewing machines; lathes, mills used in the processing of wood, metal or other materials, sandblasting, sanding, cutting, shredding, drilling, drilling, forging, folding, bending and other machining tools; riveting, nailing, screwing; tools used for removing rivets, nails and screws and similar operations; welding, soldering and similar machines; equipment used to spray, disperse, smear or otherwise apply liquid or gaseous substances; tools used for mowing and other gardening work; other electrical and electronic equipment within the scope of the definition of electrical and electronic goods

Toys, leisure, and sports equipment

Electric train and racing car sets; handheld video game consoles; video games; cycling, running, rowing, etc. computers used for sports d) Electrical or electronic sports equipment; coin-operated machines; other toys, entertainment, and sports equipment within the scope of the definition of electrical and electronic goods

Medical devices (excluding implantation products and products with infectious contacts)

Radiotherapy equipment; cardiology equipment; dialysis; artificial respiration equipment; nuclear medicine equipment; laboratory equipment required for tube diagnostics; analysis equipment; deep freezers; reproduction tests; detection, prevention, monitoring of diseases, wounds, and disabilities, and other devices and tools used for healing, alleviating; other medical devices within the scope of the definition of electrical and electronic goods

Monitoring and control instruments

Smoke detector; heat regulators; thermostats; measuring, weighing and adjustment devices and instruments used in domestic or laboratory environment; other control and monitoring instruments used in industrial facilities (for example, control panels); monitoring and control instruments within the scope of the definition of electrical and electronic goods

Vending machines

Hot drink vending machines; hot or cold bottle or box vending machines; vending machines for solid products; money vending machines; all devices that automatically deliver all kinds of products; other vending machines within the scope of the definition of electrical and electronic goods

Exclusions from the Turkey RoHS Scope

  • Equipment requiring more than 1000 V (AC) or 1500 V (DC).
  • Parts used as replacements for products manufactured before June 2009.
  • Equipment produced to be integrated within another piece of equipment.
  • Equipment designed for military purposes such as weapons and ammunition.
  • Batteries
Military RoHS Exclusions

Responsibilities of Producers of Electronics

The Turkey RoHS regulation is similar to Europe RoHS. Manufacturers must comply with the concentration thresholds detailed above for the 6 restricted substances. They must also document and file information proving their products are compliant with the legislation; and this, for 5 years after the date the product was introduced into the market. Additionally, there’s an obligation to fill out a Conformity Declaration Form and submit it every year to the Turkish Ministry of Environment and Forestry.

The original RoHS and WEEE regulation number 28300, Atık elektrikli ve elektronik eşyalar (AEEE) was drafted in 2012, in Turkish.

Turkey RoHS

Should you have any questions about Turkey RoHS, comments or needs, don’t hesitate to contact Enviropass.