In today’s world, both globally and in Türkiye, increasing mechanization and the decreasing reliance on human labor have led to the widespread use of machinery across almost all sectors. In order to extend the service life of such machinery and minimize friction and wear, mineral oils are commonly used. However, oils used in machinery gradually lose their original properties over time and must be replaced. Oils generated as a result of this replacement process are classified as waste oils.
Waste oils include, but are not limited to, used automotive oils (such as gasoline engine oil, diesel engine oil, transmission and differential oils, hydraulic brake fluids, antifreeze, greases, and other specialty vehicle oils), industrial oils (including hydraulic system oils, turbine and compressor oils, cutting and processing oils, heat transfer oils, insulation and protective oils, transformer oils, pneumatic system oils, and industrial greases), special preparations (such as thickeners, protectants, and cleaners), as well as contaminated oil products.
Waste oil is defined as any petroleum-based or synthetic oil that has been refined from crude oil and subsequently contaminated by chemical or physical impurities through industrial or non-industrial use, primarily for lubrication purposes, resulting in the loss of its original characteristics. Although such oils lose their original properties, valuable components may be recovered through refining processes. Therefore, the recycling and recovery of waste oils is of significant importance in terms of preventing environmental pollution and contributing to the national economy.
Regulatory Oversight and the Mobile Waste Tracking System (MoTAT)
The technical and administrative procedures related to the temporary storage, collection, transportation, refining, energy recovery, and disposal of waste oils are regulated and supervised by the Ministry of Environment, Urbanization and Climate Change. Inspections and controls are conducted through the Mobile Waste Tracking System (MoTAT).
As of January 2018, printed Waste Transport Forms (UATF) have been abolished, and MoTAT has become a mandatory system for hazardous waste transportation. Within the scope of MoTAT:
Waste generators and licensed transport companies approve waste loading by entering the relevant TKN–TDN numbers via mobile devices,
Waste processing facilities confirm receipt of the waste by generating a Discharge Number (BON), thereby completing the transportation process,
All stages of waste generation, loading, transportation, and unloading are digitally recorded with location and time data.
Prohibition of Improper Disposal and Legislative Background
The disposal of waste oils into soil, sewage systems, seas, lakes, rivers, or similar environments; mixing waste oils with fuel; using them as fuel; or recovering or disposing of them through improper methods is strictly prohibited.
The Regulation on the Management of Waste Oils was published in the Official Gazette dated 21 December 2019 and entered into force on 1 January 2020. Subsequently, two amendments were introduced:
The first amendment was published on 23 December 2020 (Official Gazette No. 31343),
The second amendment was published on 12 January 2023 (Official Gazette No. 32071).
Purpose of the Regulation
Pursuant to Article 1 of the Regulation, its purpose is to establish the technical and administrative principles governing the temporary storage, collection, transportation, refining, energy recovery, and disposal of waste oils, with the aim of protecting human health and the environment while ensuring the efficient use of natural resources.
General Principles Governing Waste Oil Management
Article 5 of the Regulation sets out the fundamental principles applicable to waste oil management. Accordingly:
The release of waste oils into the environment, their use as fuel, improper recovery, incineration, or disposal is prohibited.
The addition of water, solvents, toxic, hazardous, or other substances to waste oils is strictly forbidden.
The MoTAT system ensures that waste oils are monitored from their point of generation to their delivery to refining facilities, preventing unregistered transactions. Any attempt to artificially increase waste oil quantities by adding prohibited substances is subject to administrative fines imposed by the Ministry.
Authorization for Waste Oil Collection
With the amendment published on 23 December 2020, waste oils may be collected not only by authorized organizations but also by licensed refining facilities, provided that such facilities obtain collection authorization from the Ministry.
Waste oil producers are required to deliver their waste oils exclusively to authorized entities or refining facilities holding collection authorization. The collection, transportation, refining, energy recovery, or disposal of waste oils by unauthorized third parties is strictly prohibited. Violations are subject to sanctions under the Environmental Law No. 2872 and, where applicable, the Anti-Smuggling Law No. 5607.
Obligations of Oil Producers
Under the amended regulation, oil producers are required to use base oils derived from domestic waste oils in mineral oil production at the following minimum rates:
2023: 2%
2024: 4%
2025: 6%
2026: 8%
Higher rates may be determined by the Ministry in subsequent years. Imported base oils derived from waste oils are excluded from these mandatory ratios, and the obligation does not apply to base oil groups for which waste-derived production is not feasible.
Obligations of Waste Oil Refining Facilities
Refining facilities authorized by the Ministry are subject to additional obligations, including:
Ensuring nationwide collection and transportation of waste oils in compliance with the Regulation,
Transferring non-refinable waste oils to co-incineration or incineration facilities,
Submitting a guarantee letter of an amount determined by the Ministry,
Obtaining licenses for transfer points where applicable,
Subjecting their activities and financial records to independent audits and submitting audit reports to the Ministry.
Environmental License for Waste Oil Refining
Companies intending to engage in waste oil refining must submit a trial production plan to the Ministry. Existing facilities must apply for an Environmental License for Waste Oil Refining within three months following the approval of their trial production results, provided that the conditions set out in Articles 12 and 13 of the Regulation are met. Failure to apply within the prescribed period or unsuccessful trial production results will result in the termination of the facility’s environmental license.
Conclusion
Within the scope of the Regulation on the Management of Waste Oils dated 21 December 2019, the procedures governing the collection, storage, transportation, and refining of waste oils circulating within Türkiye have been comprehensively regulated. Subsequent amendments further aim to integrate waste oils—whose importation is prohibited—into the economy through environmentally responsible practices.
Natural and legal persons involved at any stage of waste oil management are required to comply strictly with the applicable regulations. Failure to do so may result in significant administrative and criminal sanctions.