Environmental Officer Requirement: Which Businesses?
Who is this article for?
The environmental officer requirement is the obligation for businesses carrying out activities with an environmental impact to have their compliance with environmental legislation continuously monitored by a certified individual or an authorised organisation. This article is written for owners and managers who run a production facility, hotel, workshop, healthcare institution or waste facility and are looking for a clear answer to the question 'Does this obligation apply to me?'. We explain step by step how the scope is determined, the ways in which the obligation can be met, and what to watch out for in practice.
What is an environmental officer, and which businesses does it concern?
An environmental officer (çevre görevlisi) is a person who monitors whether a business operates in line with environmental legislation, holds the qualifications set by the Çevre, Şehircilik ve İklim Değişikliği Bakanlığı (Ministry of Environment, Urbanisation and Climate Change) and is certified for this role. Under the environmental inspection legislation currently in force, this monitoring can be carried out in one of three ways: employing an environmental officer in-house, setting up an environmental management unit, or engaging an authorised environmental consultancy firm.
The key factor in determining whether the obligation applies is whether the business's activity is among those listed in the environmental permit and licence legislation. These lists set out activities considered to have a significant environmental impact, together with capacity thresholds. The facility's production capacity, the raw materials it uses, the nature of the waste and wastewater it generates, and emissions from stacks or processes are also decisive in the assessment.
In practice, the following groups of businesses should keep this issue firmly on their agenda:
Industrial and manufacturing facilities in sectors such as food, metal, chemicals, plastics and marble processing
Energy generation businesses with combustion plants
Accommodation facilities that operate their own wastewater treatment plant or fall within the scope of an environmental permit
Hospitals and similar healthcare institutions
Waste collection, sorting, recovery and disposal facilities
Mines and quarries, crushing and screening plants, and ready-mixed concrete plants
This list is not a definitive boundary. A business that appears small may still fall within scope depending on the type and capacity of its activity; the decision should therefore be based on the business's own activity details rather than a general rule.
How is the obligation met, step by step?
The obligation is met by first clarifying whether the business is within scope, then choosing a suitable model and making the appointment, and finally maintaining regular monitoring. The steps below outline the general framework.
1. Identify where your activity sits in the legislation
The first task is to list all of the business's activities and capacities and compare them with the lists in the current environmental permit and licence legislation. The texts of the regulations in force can be accessed via the Mevzuat Bilgi Sistemi (Legislation Information System). This comparison also shows whether an environmental permit is required; the two issues are closely linked. For details of permit procedures, see our article "What Is an Environmental Permit and Licence? An Application Guide for Businesses".
2. Choose how to meet the obligation
A business may employ a certified environmental officer in-house, set up an environmental management unit, or sign a contract with an authorised environmental consultancy firm. The choice should depend on the size of the business, the complexity of its activity and its internal capacity to follow this work on an ongoing basis. For businesses without suitably qualified staff, using an external service makes it easier to stay focused on their core operations.
3. Formalise the appointment
Once the model is decided, the appointment or service contract is put in writing. Appointment and contract details must be kept up to date in UÇBS (Ulusal Çevre Bilgi Sistemi – National Environmental Information System), the Ministry's environmental information system. When the appointed person or firm changes, it is important to update these records without delay.
4. Carry out regular monitoring and internal audits
The environmental officer's work does not end with the appointment; they are expected to monitor the business's environmental performance at regular intervals, carry out internal audits and keep records of the results. Waste declarations, the follow-up of emission and wastewater measurements, permit validity dates and on-site records are all part of this monitoring. Reporting identified shortcomings to management in writing and tracking their resolution is also a significant part of the role.
5. Keep track of changes
An increase in capacity, a new production line, a different raw material or updates to the legislation can change the scope of the obligation. The need for an environmental officer is therefore not something to be determined once and set aside; it should be reassessed as the business changes.
Documents and information to prepare
Having the following information and documents to hand will speed up the process considerably and help it start on the right footing:
The business's field of activity, production or service capacity, and process flow chart
Any environmental permit, environmental licence or temporary operating certificate
The EIA (ÇED) decision or "EIA not required" decision
The business opening and operating licence, together with title deed or lease details
Waste types and quantities, and contracts with the licensed firms to which waste is delivered
Emission, wastewater and noise measurement reports
A list of raw materials, fuels and chemicals used
Registered user and authorised person details in UÇBS
If an in-house appointment is to be made, the staff member's environmental officer certificate
Missing or outdated documents make both the scope assessment and post-appointment monitoring more difficult.
Common mistakes and points to watch
What the typical sticking points have in common is that the environmental officer issue is treated as a one-off formality. Situations frequently encountered in the field include:
Assuming the obligation only applies to large factories and never comparing your own activity with the legislation
Not checking whether the appointed person holds the required certificate and competence
Making the appointment but forgetting to update UÇBS records
Neglecting internal audits and record-keeping; failing to document the work carried out
Not reassessing the obligation when capacity increases or a new activity is added
Postponing the matter until permit renewal or an official inspection
Another point to keep in mind is that the environmental officer's recommendations need to be implemented by management. Even if the officer identifies a shortcoming, the business's responsibility does not disappear if management fails to act.
Notes for businesses in Antalya
In Antalya, the environmental officer issue particularly concerns businesses in tourism, agriculture-based industry, mining and construction materials production. Hotels and holiday resorts that operate their own treatment plant should follow this matter closely because of wastewater and waste management. For seasonal facilities, reviewing records and measurements before the season opens reduces the risk of disruptions during the busy period.
Fruit and vegetable packing houses, cold storage and food processing facilities, as well as marble and stone quarries, crushing and screening plants and ready-mixed concrete plants, may also fall within scope depending on the type and capacity of their activity. Our article "Who Is Required to Use Environmental Consultancy in Antalya?", which looks more broadly at which businesses must obtain consultancy services, can also help guide this assessment. Our environmental consultancy service, which businesses in the region can use to meet the obligation externally, aims to run the process together with you, from scope assessment to regular internal audits.
Frequently Asked Questions
How do I know whether my business needs an environmental officer?
You need to check whether your activity and capacity appear in the lists in the current environmental permit and licence legislation. Businesses on these lists are obliged to have monitoring carried out by an environmental officer, an environmental management unit or an authorised environmental consultancy firm. If you are unsure, the safest course is to have an expert assess your activity details.
Can I work with a consultancy firm instead of an environmental officer?
Yes. The legislation allows the obligation to be met through a contract with an environmental consultancy firm authorised by the Ministry. In this case, monitoring, internal audits and reporting are carried out by the firm; however, remedying any shortcomings identified remains the responsibility of the business.
I run a small business. Does the environmental officer requirement apply to me?
The size of a business is not decisive on its own; the main criterion is the type and capacity of the activity. A small-scale facility may also fall within scope if it carries out an activity on the lists. So rather than assuming 'we're small, it doesn't apply to us', you should compare your activity with the legislation.
What does an environmental officer do?
An environmental officer monitors the business's compliance with environmental legislation, carries out internal audits and keeps records of the results. Their work includes waste management, the follow-up of emission and wastewater measurements, permit and documentation procedures, and notifications in the Ministry's systems. They report any shortcomings identified to management and make recommendations for resolving them.
Contact Us
Get in touch with us to clarify whether your business falls within the scope of the environmental officer obligation and to set up the process correctly; let's assess your situation together.
Written by Selin Sevinç, Environmental Engineer (MSc), Asel Çevre Danışmanlık.
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