MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert –December 16, 202 5 1 DECEMBER 16, 2025 ENVIRONMENTAL POLLUTION FINES IN TURKEY: AN UPDATE A revised pollution fine tariff schedule has come into effect as of January 1, 2026 for Turkey. In the event of sea pollution, fines may be levied by the Turkish Environmental Protection Agency (EPA) or by local Harbor Masters. For 2026, these fines will increase by 25.5% over those which applied in 2025. Pollution fines levied by the EPA The 2026 fine schedule has been separated into four categories as summarized below in Turkish Lira (TRY). Tonnage Fine Category 1: Petrol/petroleum products discharged to sea by tankers Up to 1,000 GT 5,752.33 TRY/GT 1,001 to 5,000 GT An additional 1,438.13 TRY/GT More than 5,000 GT An additional 143.75 TRY/GT Category 2: Dirty ballast discharged to sea by tankers Up to 1,000 GT 1,048.03 TRY/GT 1,001 to 5,000 GT An additional 209.08 TRY/GT More than 5,000 GT An additional 33.18 TRY/GT Category 3: Petrol/petroleum products and dirty ballast discharged to sea by vessels or any other sea vehicles Up to 1,000 GT 2,876.15 TRY/GT 1,001 to 5,000 GT An additional 575.25 TRY/GT More than 5,000 GT An additional 143.75 TRY/GT Category 4: Garbage and sewage discharged to sea by vessels and any other sea vehicles including domestic wastewater, water with detergent, foam scrubber system wash water and similar washing waters and solid wastes, etc. Up to 18 GT 31,898.30 TRY 18 to 50 GT 63,802.88 TRY 50 to 100 GT 127,605.76 TRY 100 to 150 GT 191,411.15 TRY 150 to 1,000 GT 1,438.13 TRY/GT 1,001 to 5,000 GT An additional 287.63 TRY/GT More than 5,000 GT An additional 33.18 TRY/GT Fines for sulfur discharges Vessels using fuels with sulfur content beyond the limits allowed by IMO regulations that entered into force on January 1, 2020 will be subject to a fine as per the schedule below: MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert –December 16, 202 5 2 Up to 1,000 GT 1,276.08 TRY/GT 1,001 to 5,000 GT An additional 159.50 TRY/GT More than 5,000 GT An additional 31.91 TRY/GT The above fines will be doubled for the Marmara Sea including the Istanbul Strait, Canakkale Strait and Izmit Bay. Fine adjustments The fines, as noted above, will be adjusted considering the following: • Repetition of the same act by a vessel within three (3) years of the date of the first fine will result in the doubling of the fine and tripling of the fine for any repetition of the act thereafter. • The fine will be tripled if the owner of the vessel that caused the pollution is a legal entity that is registered in Turkey. • If hazardous waste or material of a similar nature is released or dumped in Turkish waters, the fine imposed will be 10 times the fine as set forth in Category 1 above. • If the owner of an offending vessel cleans up the pollution itself, by using its own means and efforts, the administrative fine shall be levied at 1/3 of the total amount. • Owners are entitled to lodge an appeal to any fines before an administrative court within 30 days of the fine’s notification date. However, appealing the fine will not result in lifting of a fined vessel’s arrest order and appeals have a