Rekabet Kurumu Closes Coca-Cola Investigation with Binding Commitments

Rekabet Kurumu (the Turkish Competition Authority) has concluded its investigation into Coca-Cola Satış ve Dağıtım AŞ (CCSD) regarding potential violations of Articles 4 and 6 of Law No. 4054 on the Protection of Competition (Law No. 4054). To address concerns regarding the exclusion of competitors through exclusivity and discount practices, the Rekabet Kurulu (the Competition Board) accepted a series of commitments submitted by CCSD. Consequently, the investigation was closed by Decision No. 26-20/614-243 dated 04.06.2026. These commitments will be re-evaluated by the Board after three years.

Expansion of the Cooler Access Rule

The decision expands the scope of the cooler access rule previously implemented under the 2021 Commitment Decision. Under the new framework, 35% of the capacity of CCSD coolers located in traditional and on-premise sales channels must be opened to competitor products. The presence of a point of sale's own cooler, which is dedicated to non-alcoholic commercial beverages and directly accessible by consumers, does not prevent the application of this access rule. To ensure effective implementation, additional information will be provided to points of sale. Detailed information texts will be prepared and shared, and access to this information will be facilitated via QR codes placed on the coolers.

Cooler Positioning and Planogram Modifications

Significant changes have been introduced regarding the positioning and planogram standards inside the coolers. The 35% space subject to competitor access must be vertically divided within the cooler using a physical separator, and this section must be allocated exclusively to competitor products. Labels must be placed on each shelf of this separated vertical space, explicitly stating that the area is reserved for competitor products and that CCSD products must not be placed there. In points of sale with multiple CCSD coolers, the 35% access rate will be calculated individually for each cooler.

To demonstrate the practical impact of the cooler access rule and ensure its monitoring, CCSD will obtain measurement reports prepared by an independent third party. These reports will be submitted to Rekabet Kurumu upon request. Enforcement mechanisms have also been established to ensure compliance by points of sale. If CCSD or dealer sales representatives detect during their visits that the cooler access rule is not fully implemented, the point of sale will be warned upon the first detection. If the non-compliance persists during subsequent visits, the point of sale's orders will be gradually reduced by 10% for each detected instance of non-compliance. CCSD is not permitted to track which products points of sale place in the space allocated to competitor products.

Furthermore, CCSD is prohibited from placing labels, coatings, or similar materials on the glass surfaces of its coolers that would block or restrict the visibility of competitor products in the designated section. Competitor undertakings are also free to use their own price tags inside the cooler for their products placed in the open section.

Restructuring of the Cooler Supply Model

The cooler supply model has been restructured. CCSD will terminate its cooler efficiency practice, which was based on a minimum annual case purchase volume expected from points of sale. Consequently, the practice of issuing "completion invoices" (tamamlama faturası) to dealers due to a failure to meet these efficiency conditions has been abolished.

Changes to Target and Bonus Schemes

The target and bonus systems within CCSD have been modified to support a competitive market structure. The bonus scheme for Area Sales Managers has been completely removed. For Field Sales Managers and Sales Representatives, the base salary ratio has been increased to 80%, and the share of variable pay within total compensation has been capped at 20%. Employee-based financial support and performance reporting practices provided to dealers have been terminated.

Information dissemination regarding the CCINext application, which allows points of sale to place independent orders, will be increased. Additionally, the competition law compliance obligations of dealers will be strengthened. The minimum order quantity required for penetration to be deemed realized per product in the ASA system will be maintained at 1 (one) case per product.

New Principles for Investment Support

Investment support provided by CCSD to points of sale in the form of awnings, signage, and shelving must now be provided independently of product purchase agreements. These supports must be based on objective criteria and cannot be tied to product purchases. Investment support contracts must clearly regulate the scope, terms of use, duration, ownership, repossession conditions, and the rights and obligations of the points of sale.

These investment supports cannot be made conditional on the removal or absence of competitor products or coolers belonging to competitor firms. Points of sale must be regularly informed of their rights in this regard. Furthermore, the annual budget allocated for awning, signage, and shelf investments will be capped at a specific ratio of CCSD's net sales turnover from the previous fiscal year.

New Rules on Discount and Support Policies

The discount and support policies applied by CCSD to its dealers have undergone fundamental changes. Discounts provided to dealers must be determined independently for each product category and based on objective criteria. A discount in one category cannot be tied to the purchase, sale, or display of products in another category. Free product support in the water and soda categories has been abolished. In other product categories, free product support will be restricted exclusively to points of sale whose annual purchase volume exceeds a specified threshold.