Amendment to the Communiqué on Import Surveillance (Communiqué No: 2020/9)

1. What has changed compared to the previous regulation?

1.1 Extension of exporter registration validity

• In Annex-2 (Documents to be Attached to the Registration Certificate Application), item (3), the validity period of the Exporter Registry Form (Ek-2B) has been extended:
• This applies to exporter registry forms that are duly approved by the competent foreign authority and authenticated by the Turkish Consulate (or equivalent authority where no Turkish Consulate exists).

Technical meaning:The Ministry now expects exporters’ structural and financial data to be assessed over a longer continuity period, reducing annual repetition but increasing the importance of the initial submission’s accuracy and completeness.

1.2 Introduction of a new discretionary document: EK-2E “Import-Related Questionnaire”

• A new explanatory item (6) has been added to Annex-2.
• Accordingly, the “Import-Related Questionnaire (EK-2E)” may be requested only if the imported goods are considered risk-bearing after examination by the General Directorate, on a country-specific basis, considering:

This is a conditional, risk-triggered requirement, not an automatic attachment.

1.3 Addition of Annex EK-2E as a formal, structured questionnaire

• Annex EK-2E has been formally incorporated into the Communiqué.
• The form is extensive and four-part, covering:

Key characteristics of EK-2E:

• Must be:
• Tables must be filled for all products within the relevant 4-digit GTP scope, not only the specific GTİP line imported.

2. Substantive scope and depth of the new EK-2E form

The newly introduced EK-2E represents a significant escalation in information depth compared to standard registration documentation.

2.1 Importer-level disclosures

The importer must provide:

• GTİP and 4-digit GTP scope mapping,
• Product descriptions and origin,
• Full commercial documentation set (invoice/proforma, payment proofs, transport documents, origin evidence),
• Corporate identity and contact details,
• Promotional and descriptive materials for both exporter and producer.

This ensures commercial traceability and aligns registration review with customs valuation, origin and policy control logic.

2.2 Producer-level disclosures (core risk analysis layer)

If the exporter and producer differ, or if the Ministry requires deeper verification, the producer must disclose:

• Production capacity, output and sales data for the last three years, split by:
• Factory locations, production flow charts, subcontracting details.
• Official proof of producer status (capacity reports, activity certificates).
• Input traceability:
• Workforce data supported by social security records.
• Machinery inventory used in production.

Practical implication:This effectively allows the administration to reconstruct the full cost and supply chain structure of the goods subject to surveillance.

2.3 Exporter-level disclosures

Where the exporter is not the producer:

• Sales volumes and values must be declared by 4-digit GTP scope, for the last three years, with geographic segmentation.

2.4 Declarations and legal accountability

• Separate declarations and undertakings must be signed by:
• Each party confirms:

This establishes direct legal accountability across the entire supply chain, not only at importer level.

3. Practical meaning for companies and required actions

3.1 Shift from “formal registration” to “substantive risk examination”

With EK-2E, the surveillance regime under Communiqué No: 2020/9 evolves from a document-driven registration system into a risk-based analytical mechanism.

Companies should assume that:

• Registration is no longer assessed solely on formal completeness,
• Economic reality, production capability and pricing structure may be scrutinized.

3.2 Increased preparation burden for sensitive sectors

Given the scope of Annex I (textiles, plastics, leather, footwear, accessories, household articles, etc.), firms operating in these sectors should:

• Maintain ready-to-submit producer and exporter data packs,
• Ensure long-term consistency between:

3.3 Risk of delays and indirect enforcement

While EK-2E is discretionary:

• Once requested, incomplete or inconsistent submissions will effectively block registration,
• This may delay customs clearance indirectly, even without a formal rejection.

3.4 Compliance strategy recommendations

From a professional customs consultancy perspective, firms should:

• Treat EK-2E readiness as a preventive compliance tool, not an exception,
• Align internal pricing, sourcing and documentation practices with possible backward-looking scrutiny (2–3 years),
• Review exporter and producer data before first registration submission, especially for:

See related legislation document.