What Is a GSM Operating Licence? Guide to Applying for a Non-Sanitary Establishment Permit
How is a GSM licence obtained? Differences between 1st, 2nd and 3rd class GSM, the competent authority, required documents, application process.
A GSM licence is a workplace opening and operating licence issued for workplaces that, during their activity, cause or may cause biological, chemical, physical, mental or social harm to those around them, or that may pollute natural resources. The GSM class of a business, its field of activity and capacity are determined according to their equivalent in the current legislative annexes; the competent authority to which the application is made varies depending on the location of the facility. This guide explains the scope of your business, the correct application authority, the required document groups, the process differences between first, second and third class, and the relationship of the GSM licence with EIA, Temporary Activity Certificate (GFB) and environmental permits, in a way that facilitates decision-making.
What is a GSM licence?
A non-sanitary establishment (GSM) licence is a workplace opening and operating licence issued by the competent authority so that a business can operate at a specific address and within a specific scope of activity. The presence of a potential environmental or societal impact does not automatically mean the business falls into a particular class; the class is determined based on the annexes of the Regulation and concrete activity information. A GSM licence is not merely a matter of "completing paperwork." Zoning and building compliance, layout, fire safety, process, capacity, health protection measures and environmental obligations related to the activity must all be consistent within the same file. A permit or registration obtained from another authority does not automatically eliminate the GSM licence obligation. Important distinction: the consultant carries out application preparation and follow-up with authorities; the final assessment regarding classification and the licence belongs to the competent authority.
Does your business fall within GSM scope?
GSM scope is not determined solely by looking at the NACE code or by whether the business is called a "factory." The actual activity, production method, capacity, materials used, equipment and the definitions in the annexes of the Regulation must be evaluated together. Activities such as manufacturing, metalworking, painting, chemical storage, food production, waste processing and recovery may fall within scope; however, two facilities within the same sector may be evaluated in different classes due to differences in capacity or process. Data to review when determining scope: clear and technical description of the activity and product/service outputs; installed and planned capacity and shift information; machinery, equipment, heat treatment, boilers, chimney and ventilation sources; chemicals, fuels and hazardous substances used; wastewater, waste, emission, noise, odour and vibration sources; parcel, building, zoning function and sensitive uses in the surrounding area.
Differences between 1st, 2nd and 3rd class GSM
The GSM class is not a free consultant interpretation in the form of "high, medium, low risk." The essential classification is made based on the correspondence of the activity and capacity in the annexes of the Regulation on Workplace Opening and Operating Licences. 1st class GSM: activities that must be kept away from residences and places allocated for human habitation; site selection and facility establishment permit, review board, health protection zone and, depending on the activity, trial permit may be required; zoning compliance, site selection, health protection zone, project and process documents must be assessed before the facility is established. 2nd class GSM: establishments that do not necessarily need to be kept away from residences, but whose effects on the health, well-being and rest of nearby residents must be examined before permitting due to their installation or location; the file and facility suitability are reviewed by the competent authority; certain activities involving hazardous substances, fuel, gas or waste processing require pre-permit review and a health protection zone. 3rd class GSM: establishments that may be opened next to residences but are subject to sanitary supervision; the concrete activity is still classified based on the annexes of the Regulation; application and compliance checks may be more limited, but sanitary supervision and general compliance requirements continue. If the activity or capacity is not clearly found in the annexes of the Regulation, obtaining a written opinion from the competent authority is the safest approach, based on an assessment of similar facilities and probable effects. The official basis for this three-way distinction is Article 269 of Public Health Law No. 1593.
When is a health protection zone required for 2nd class GSM?
Automatic health protection zones are not envisaged for every 2nd class GSM. However, for certain works involving combustible, flammable, explosive or hazardous materials — oxygen and LPG filling/storage facilities, their distribution and retail outlets, fuel and gas stations, waste processing industrial facilities and similar places — a pre-permit review must be carried out and a health protection zone determined by the competent authority must be left. This list does not mean the same distance applies to every facility; the exact correspondence of the activity in the Regulation, the location of the facility and the distance to be left are assessed by the competent authority in the concrete application.
How is the competent authority determined for a GSM licence?
The application authority is determined based on the facility's address, municipal status, and whether it is located within a special zone such as an organized industrial zone, industrial zone or technology development zone. Therefore, the assumption that "every application is made to the municipality" is not correct: within municipal boundaries — the relevant municipality, or in metropolitan areas the metropolitan or district municipality depending on the matter; outside municipal boundaries and adjacent areas — the special provincial administration; organized industrial zone — the OIZ legal entity; industrial zone — the relevant unit of the Ministry of Industry and Technology as determined in the relevant legislation; technology development zone — the management company and, for relevant activities, the powers of the provincial directorate of the Ministry may come into play. Precisely determining the competent authority prevents filing with the wrong institution and unnecessary preparation according to the document lists of different institutions.
What documents are required for a GSM licence?
There is no single document list valid for every business. The document set must be finalized according to the business's class, type of activity, capacity, condition of the building, and the current practice of the competent authority. Common basic documents: application/declaration form as appropriate; documents regarding address, title deed or right of use; description of activity and capacity information; layout/site plan and process flow plans; company and representation documents. Class-dependent documents: site selection and facility establishment file; plan showing the health protection zone; projects forming the basis of the review board's assessment; records relating to the trial permit where required. Activity-dependent documents: fire safety/fire department compliance; documents regarding zoning and building compliance; chimney, ventilation or technical system reports; decisions relating to EIA, environmental permit or other special permits. Application note: capacity, machinery list, process flow and data in environmental permit documents in the application file must not conflict with each other.
How does the GSM licence application process proceed?
A sound application begins with scope and class determination, continues with confirmation of the competent authority and parcel/building compliance. Filing the dossier is not the final but the initial stage of the process; institutional review, site inspection and possible revisions follow. Steps: define the activity: combine product, process, capacity, machinery and environmental impact sources into a single technical description. Verify the class: compare the activity and capacity with the annexes of the Regulation; if uncertain, obtain the opinion of the competent authority. Determine the competent authority: verify municipal, special provincial administration, OIZ or special zone authority via the address. Review site and building compliance: check zoning function, building usage status, layout and health protection requirements. Build the document matrix: separate common documents from class- and activity-dependent documents; record those responsible and validity status. Submit the application: ensure that the activity/capacity information in the form, plan and technical documents is identical. Manage review and site inspection: record and respond in a traceable manner to the institution's requests for additional information or correction. Verify the licence scope: check that the address, title, activity and capacity information on the issued licence matches the actual situation. For 1st class GSM facilities, the site selection and facility establishment permit ensures that the site, project and documents are assessed for suitability before the facility is built; the review board examines site selection, facility establishment, trial or opening permit. The health protection zone is determined taking into account the facility's effects on environmental and public health; it cannot extend beyond property boundaries, and residential or human-habitation construction is not permitted within this zone.
2025 Regulation amendment: what happens if the licence is not issued within two months?
Article 45/A, added on 11 December 2025, grants the business operator the opportunity to apply to the provincial directorate of the Ministry of Environment, Urbanisation and Climate Change if the competent authority fails to issue the licence within two months despite an application made in compliance with the Regulation. The lapse of two months does not automatically create a licence and does not mean the Ministry will necessarily grant it. The operator must first have submitted a licence application to the competent authority in compliance with the Regulation. If no licence is granted within two months of the application date, an ex officio licence request may be submitted to the provincial directorate against payment of the fee listed in the Ministry's relevant year unit price list. The provincial directorate requests the opinion of the competent authority regarding the file. The competent authority must communicate its opinion, explaining the reason for inaction, within 15 days at the latest; if no opinion is given in time, a favourable opinion is deemed to have been given. After the competent authority's opinion, the file is reviewed by the provincial directorate within 15 days at the latest. If the request complies with the Regulation, the provincial directorate may issue the licence ex officio. If a discrepancy or deficiency is identified, it is notified to the applicant within the same period. After deficiencies are remedied, the provincial directorate may carry out a new assessment upon a further application. The provincial directorate cannot carry out a finalizing site inspection for the licence; inspection under the Regulation remains subject to the applicable provisions.
Statutory processing times by class
For 2nd and 3rd class GSM, if the workplace is arranged in compliance with the envisaged criteria and the application form is submitted appropriately, the Regulation stipulates that the licence be issued within 5 days; subsequent inspection of the licensed workplace must occur within 1 month of the licence date; if a violation is identified during post-licence inspection, it must be remedied within 15 days on a one-time basis, otherwise revocation of the licence and closure of the workplace may follow. For 1st class GSM, post-licence inspection must occur within 1 month of the licence date. The Article 45/A application threshold is 2 months from the application date if the licence is not issued despite compliant application; the operator may apply to the provincial directorate, but no automatic licence is created. The 5-day period is not a guarantee of outcome for any incomplete or non-compliant application.
How do GSM licence, EIA, GFB and environmental permit differ?
A GSM licence, EIA decision, Temporary Activity Certificate (GFB) and environmental permit/environmental permit and licence certificate serve different legislative purposes. Obtaining one document does not automatically remove the other obligations; furthermore, not every GSM facility is automatically subject to a GFB or environmental permit. The GSM licence concerns opening and operating the workplace at the relevant activity and address, and is required if the activity is classified as a non-sanitary establishment under the Regulation; it does not replace the EIA process. The EIA process concerns assessing the project's environmental impacts at the project stage, and comes into play if the project falls within the scope and thresholds of EIA legislation; it does not replace the GSM licence. The GFB is the temporary activity stage within the environmental permit/environmental permit and licence process, relevant if the business falls within the scope of the annexes of the Environmental Permit and Licence Regulation; it does not replace the GSM licence. The environmental permit/licence covers environmental obligations regarding emission, discharge, noise or licence matters, relevant if the business falls within the scope of the relevant Regulation; it does not replace the GSM licence.
Is the licence updated if capacity, process or address changes?
The legal consequence of changes is not the same. Under Article 28 of the Regulation, if the business's field of activity changes, obtaining a new licence is mandatory. An address change brings up the licensing process for the new address; changes in capacity, process, machinery, layout or hazardous materials must be assessed with the competent authority according to their concrete impact. During inspection, not only the existence of the licence document but also the consistency between the activity written on the licence and the actual situation at the facility matters. Four questions to ask before a change: does the new activity or capacity change the class under the annexes of the Regulation? Does the new machinery or process affect the layout plan and fire measures? Should the EIA or environmental permit scope be reassessed? Does the competent authority request a new licence, update, or additional document?
Pre-application GSM licence checklist
The following checks can be used to catch fundamental contradictions between activity, location, building and documents before the application file is submitted to the authority: has the activity description and capacity been clarified in a single technical text? Has the activity and capacity been compared with the annexes of the Regulation? Has the competent authority been confirmed based on address and special zone status? Is the zoning function compatible with the planned activity? Are the building's usage status and projects compatible with the actual layout? Do the machinery list, process flow and site plan show the same situation? Have fire, escape, storage and emergency measures been reviewed? Have chimney, emission, wastewater, noise, odour and waste sources been identified? Have EIA, GFB, environmental permit and other special permit scopes been separately checked? Have the currency, signatures and title/address information in the file been verified? Common mistake: using different production capacities in the application form, capacity report and environmental permit file can create disputes over revision and scope.
Our GSM licence consultancy service scope
EUROPECARBON carries out application preparation, document coordination and follow-up of institutional requests based on the facility and activity information provided by the business. The final decision on granting the licence belongs to the competent authority. Commercial transparency: EUROPECARBON provides GSM licence application consultancy. This content is for general informational purposes and does not replace the competent authority's classification, facility suitability and licensing decision. Our services include: application file — existing documents are converted into a matrix in terms of class, activity and competent authority expectations; deficiencies and responsible parties are identified. Scope and class pre-review — activity, capacity, process and annexes of the Regulation are compared; uncertain areas are prepared for institutional confirmation. Competent authority check — the application channel is clarified based on facility address, municipal status and OIZ/special zone status. Technical document coordination — the consistency of layout, process, fire, building and activity-specific technical documents is checked. Revision follow-up — the competent authority's requests for additional information and correction are recorded; responses of relevant parties are coordinated. Final scope check — address, activity, title and scope information on the issued document is compared with the business's current status.
Legal basis and official sources
The fundamental framework for the GSM licence process is Law No. 3572 and the Regulation on Workplace Opening and Operating Licences. Depending on the nature of the activity, Public Health Law No. 1593, zoning, fire, environmental and sectoral regulations are also considered together. The Regulation on Workplace Opening and Operating Licences was amended by the regulation published in the Official Gazette dated 11 December 2025 and numbered 33104. Therefore, instead of old checklists, the current consolidated text, the amendment text and the current practice of the competent authority must be relied upon together. Primary and institutional sources: Official Gazette — Regulation amendment of 11 December 2025; Union of Municipalities of Turkey — table of previous and post-amendment Regulation text; Ministry of Environment, Urbanisation and Climate Change — text of the Regulation on Workplace Opening and Operating Licences; Ministry's Local Administrations General Directorate — health protection zone opinion dated 22 September 2025; Ministry — environmental permit and licence process.
How we work
- 1Define the activity: combine product, process, capacity, machinery and environmental impact sources into a single technical description.
- 2Verify the class: compare the activity and capacity with the annexes of the Regulation; if uncertain, obtain the opinion of the competent authority.
- 3Determine the competent authority: verify municipal, special provincial administration, OIZ or special zone authority via the address.
- 4Review site and building compliance: check zoning function, building usage status, layout and health protection requirements.
- 5Build the document matrix: separate common documents from class- and activity-dependent documents; record those responsible and validity status.
- 6Submit the application: ensure that the activity/capacity information in the form, plan and technical documents is identical.
- 7Manage review and site inspection: record and respond in a traceable manner to the institution's requests for additional information or correction.
- 8Verify the licence scope: check that the address, title, activity and capacity information on the issued licence matches the actual situation.