A comparative study of Türkiye's solid waste management legislation during its EU harmonization process

This thesis comparatively examines Turkey's solid waste management legislation within the context of its European Union (EU) accession process, juxtaposing it with relevant legislation and practices in EU member states and the United States (US). The study addresses the environmental, economic, and social dimensions of solid waste management, analyzing legal frameworks, policy instruments, and implementation performance across different geographies. The EU's approach, centered on the waste hierarchy and circular economy, is supported by high recycling and low landfill rates in countries like Germany and Sweden, while Poland's implementation challenges are also assessed. In the US, despite robust federal legislation for hazardous waste management, municipal solid waste management tends to be more fragmented and landfill-dependent. Turkey's solid waste management legislation has made significant strides towards alignment with the EU acquis, adopting circular economy objectives through national initiatives like the "Zero Waste Project." However, substantial disparities and challenges persist in areas such as implementation capacity, infrastructure investments, and the informal sector. The performance comparison of 29 countries presented in Table 2 shows that Türkiye, with its 85% landfill rate, is five times the EU average (17.5%), while its 14% recycling rate remains at the level of Malta and Romania. This comparative analysis provides policy and implementation recommendations necessary for Turkey to achieve EU standards.