If You Fill the Bottle, You Own the Packaging Obligation
In perfumery, everyone talks about the scent. Yet the first line item at the till is glass, cardboard, and the shipping box. And the life of that box does not end in the consumer's bin — legally, it still sits in your ledger. This article clearly separates the two distinct obligations that arise the moment you place a 100 ml bottle on the market: the packaging declaration and the Recovery Participation Contribution (GEKAP).
First, let us settle one concept: the party placing on the market. In regulatory language, this is the business that first offers a product under its own brand or trade name on the Turkish market. That means:
- If you buy a fragrance oil, bottle it under your own brand, and sell it — you are the party placing it on the market.
- If you outsource manufacturing but your brand appears on the box — you are still the party placing it on the market.
- If you import finished perfume from abroad — as the importer, you are the party placing it on the market.
- If you are a boutique or reseller that sells another brand's labelled products off the shelf — the product packaging is not yours; but the bags you give customers and the shipping packaging you use are your responsibility.
That last point is the most commonly overlooked. The phrase "I'm not a manufacturer, I only sell" does not grant you a full exemption. If you are the one sealing the shipping box, that box falls within your declaration.
Let the distinction be clear: there are two separate obligations and neither substitutes for the other. The Packaging Information System (ABS) declaration is an environmental declaration made to the Ministry of Environment. The GEKAP declaration is a financial declaration made to the Revenue Administration (GİB) and results in a payment. Completing one and skipping the other is a common — and costly — mistake.
The regulatory backbone is the Regulation on the Control of Packaging Waste. All packaging placed on the market, and the waste generated from it, is subject to declaration. The legal basis for the financial side is the supplementary article of Environmental Law No. 2872 and the associated schedules. GEKAP is a participation contribution paid not only by those placing bags on the market, but by anyone placing any kind of packaging on the market — including tyres, batteries, accumulators, lubricating oils, and all types of packaging.
Packaging Information System: Registration, Declaration, and the Nil Return
There is no payment here — only data. But if the data is wrong, the payment will be wrong too. The ABS is where you keep the official answer to the question: "How many kilograms of each material did I place on the market last year?"
The system's logic is straightforward: the business registers, enters the previous year's packaging data within the prescribed period, and confirms it. Parties placing goods on the market, suppliers, and packaging manufacturers must declare and confirm their packaging data from the previous year via the Packaging Information System by the end of February each year. Some sources cite the end of March as the deadline; as the calendar can change from year to year, verify the current announcement at the start of each period — make a habit of noting it down.
Tip — "I used no packaging that year" scenario: The obligation does not lapse automatically. If no packaging was used by the business in a given year, the packaging declaration must still be submitted as a nil entry and confirmed. In other words, a nil return is still a return. Submitting zero and submitting nothing are not the same thing.
The second critical point is the supply chain. Your printer, glass/bottle supplier, and contract filling workshop must also be registered in the system. Suppliers that carry out contract manufacturing for parties placing goods on the market are obliged to register with the Packaging Information System, provide requested information and documentation, and conduct all packaging procurement and supply operations exclusively with economic operators registered in the system.
The practical implication is this: when buying bottles and boxes, ask your supplier for their ABS registration. A batch of 5,000 bottles sourced from an unregistered supplier can leave your own declaration indefensible during an audit.
The third point concerns the deposit side, which is sometimes confused with glass beverage packaging. Under the Procedures and Principles on Mandatory Deposit System Applications, parties placing packaging groups subject to mandatory deposit on the market register via the Deposit Information Management System, obtain a code number, and fulfil their financial obligations through that system. A perfume bottle is not a beverage container in the classical sense; however, scope lists can be updated. Check once a year whether your product category appears on that list.
GEKAP: Where Pence Multiplies by Kilogram
GEKAP looks at the packaging's material and weight. Not your scent, your brand, or your selling price. That is why the calculation starts with scales.
The rates are updated every year by the revaluation rate. The GEKAP amounts applicable from 1 January 2026 were re-determined by the Communiqué published in the Official Gazette dated 30 December 2025, issue 33123, applying a revaluation rate of 25.49%.
| Packaging type | Unit | 2026 participation rate | Perfumery equivalent |
|---|---|---|---|
| Glass packaging (non-beverage) | kr/kg | 330 kr (3.30 TL) | Flacon, tester bottle, glass dropper bottle |
| Plastic packaging (excluding bags) | kr/kg | 700 kr (7.00 TL) | Pump, valve, cap, PET container, shrink wrap, bubble wrap |
| Paper–cardboard packaging | kr/kg | 330 kr (3.30 TL) | Product box, shipping box, coated label carrier |
| Metal packaging (non-beverage) | kr/kg | 800 kr (8.00 TL) | Aluminium cap, metal tin, metal canister |
| Composite packaging (other) | kr/kg | 800 kr (8.00 TL) | Multi-layer tube, paper + foil laminate box |
| Wooden packaging | per unit | 170 kr (1.70 TL) | Gift crate, wooden collector's box |
| Plastic carrier bag | per unit | 107 kr (1.07 TL) | Bag given to customers in-store |
The figures in the table reflect the 2026 unit rates: plastic packaging 700 kr/kg, metal packaging 800 kr/kg, paper-cardboard 330 kr/kg, glass 330 kr/kg, composite 800 kr/kg, and wooden packaging 170 kuruş per unit. The contribution levied per plastic carrier bag stands at 107 kuruş in 2026. The portion of the 1.00 TL bag charge collected from the consumer is not business income — it must be declared and remitted.
The most common mistake — grams or millilitres? GEKAP is calculated on the empty weight of the packaging, not on the weight or volume of the liquid inside. The assumption "100 ml product = 100 g" is wrong here — and in formulation too. The specific gravities of fragrance oils and solvents vary across a wide range (citrus-heavy compositions are around 0.84; heavy resin/synthetic compositions can exceed 1.10). So a 100 ml fill can weigh as little as 84 g or as much as 110 g. For packaging declarations, ignore the liquid entirely — weigh the bottle empty.
Let us now work through a real line item. Here is an example calculation for a single perfume sold in a 100 ml glass flacon with pump, cardboard box, and shipping packaging (weights should be measured from your own supplier):
| Component | Material | Example weight | Unit rate | Per unit |
|---|---|---|---|---|
| Flacon | Glass | 180 g | 3.30 TL/kg | ≈ 0.59 TL |
| Pump + cap + shrink wrap | Plastic | 20 g | 7.00 TL/kg | ≈ 0.14 TL |
| Product box | Cardboard | 35 g | 3.30 TL/kg | ≈ 0.12 TL |
| Shipping box | Cardboard | 150 g | 3.30 TL/kg | ≈ 0.50 TL |
| Filler / air cushion | Plastic | 10 g | 7.00 TL/kg | ≈ 0.07 TL |
| Total | — | 395 g | — | ≈ 1.42 TL |
1.42 TL per bottle sounds modest. Across 2,000 bottles a month that is 2,840 TL; across 24,000 bottles a year it approaches 34,000 TL. If you do not put this figure in your cost table, you will pay it out of your profit margin.
Tip — the heavy-glass decision is no longer purely aesthetic: Switching from a 180 g elegant flacon to a 320 g "heavy-base" bottle takes the glass contribution per unit from roughly 0.59 TL to 1.06 TL. Keep a jeweller's scale on the table at design meetings.
From Declaration to Price Tag: An Eight-Step Process
Knowing the regulations is not enough — you need to embed them into your production workflow. The sequence below is a framework that both a small workshop and a 50-person brand can apply.
- Write down your role
Write it in a single sentence on paper: "In this product I am the party placing it on the market / the supplier / the point of sale." If your brand is on the label, the answer is clear. This sentence determines every step that follows.
- Draw up your packaging inventory
Flacon, pump, inner cap, outer cap, label, box, cellophane, shipping box, tape, filler. List every item line by line. The most commonly forgotten items are tape and filler material.
- Weigh each item and code its material
Weigh 10 samples on a precision scale and take the average. Write the material clearly: glass / plastic / paper-cardboard / metal / composite / wood. Composite classification matters — a tube that combines a paper layer and a foil layer counts as composite, not paper, and carries a higher rate.
- Calculate the unit cost
Weight (kg) × unit rate (TL/kg) = GEKAP per unit. Items charged per unit (bags, wooden boxes) are simply multiplied by quantity. Keep the result as a separate line in your product formula cost table.
- Set up your ABS registration and annual declaration
Register the business on the Packaging Information System, declare the previous year's data within the period, and confirm it. If you used no packaging, confirm the nil return anyway. Guarantee your suppliers' registration status contractually.
- Schedule your GEKAP declaration in the calendar
The GEKAP declaration is submitted electronically via the Revenue Administration and must be paid within the declaration period. Declaration periods and deadlines are set by communiqué and are subject to change; at the start of each year, write the period calendar with your accountant and set reminders.
- Document the export, return, and stock split
Packaging exported abroad and packaging placed on the domestic market are not treated the same way; return and wastage records are also kept separately. Document this split in real time — trying to reconstruct it retrospectively at year-end is the most expensive approach.
- Build it into the price, not into the margin
Add the per-unit GEKAP to your unit cost, then apply your profit margin on top. If you work in the reverse order, the contribution comes out of your margin. When the annual rate is updated, revise your price list accordingly.
See the cost item in full. GEKAP does not arrive alone. Alongside it sit the packaging unit price, label printing, official fees on the cosmetic product notification side, and safety assessment costs. There is one widespread misconception here: assuming that product notification/registration processes are "free." Firm registration and product notification on the Product Tracking System side are subject to official fees; the cost is not limited to the safety assessment alone. Obtain current fee amounts from official sources at the start of each year.
Packaging also has a safety dimension. Alcohol-based perfume and high-strength ethanol are flammable (low flash point). This affects both packaging selection and transport rules: a leak-tight cap, an impact-resistant outer box, and proper labelling are all required. When filling in the workshop, good ventilation, avoidance of static electricity, gloves and eye protection are mandatory. The same warnings apply to room fragrance solvents (glycol ethers such as DPM and MMB). "Environmental regulations" and "occupational safety" sit at the same table.
Tip — shrink the shipping box and win twice. Reducing box volume lowers both the dimensional weight/freight charge and the GEKAP on cardboard kilograms. Reducing a 150 g box to 110 g saves approximately 0.13 TL per unit; across 20,000 shipments that is 2,600 TL. A small line item grows when you multiply it.
Frequently Asked Questions and Related Regulations
Packaging waste does not stand alone. KKDİK applies when buying fragrance oil, IFRA applies when building a formula, and ÜTS applies before selling the product; GEKAP is the final link in this chain. Below we have collected the most commonly asked questions.
I sell perfume on a small scale from home — do I have to pay GEKAP?
GEKAP or packaging declaration — do I have to do both?
Do I need to file a declaration even in periods when I made no sales?
Do shipping boxes and bubble wrap count as packaging?
Which costs more — glass or plastic?
How much do I pay for the bags I give out in my shop?
I buy fragrance oil in 5-litre containers — do I pay GEKAP on those containers?
Do I pay a contribution on the packaging of products I export?
Do GEKAP rates change every year?
Is ÜTS registration the same as the packaging declaration?
Where do IFRA and KKDİK fit into all this?
Is it mandatory to put a recycling symbol on packaging labels?
I outsource manufacturing — does the filling company file the declaration?
What happens if I get the calculation wrong?
A final word — and a mandatory disclaimer. The figures in this article are based on the unit values published for 2026 and change every year; declaration periods, scope lists, and fees are also updated by communiqué. Nothing you have read here constitutes financial or legal advice. For definitive amounts, deadlines, and procedures, refer to the Official Gazette, the Revenue Administration (GİB), the Ministry of Environment, Urbanisation and Climate Change, and — for the cosmetics side — TİTCK's current sources; set up your compliance processes together with your accountant.
Packaging is not the container of the scent — it is the scent's contract. A brand that knows the weight of its bottle, has coded the material of its box, and has calmly built that line item into its pricing stands on solid ground in an audit and at the negotiating table alike. The rest is your signature.
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