Import Control of Wastes Subject to Environmental Protection Communiqué on Product Safety and Inspection No: 2026/3 – Türkiye

Scope

The Communiqué applies to:

• All waste materials listed in Annex-1 subject to environmental conformity control,
• Annex-2/A and Annex-2/B wastes, whose importation into Türkiye is strictly prohibited,
• Imports conducted under free zones, inward processing regimes, and other customs procedures,
• Environmental controls performed at the border customs offices prior to release.

Transit movements are generally excluded, subject to Basel Convention obligations.

Mandatory Environmental Approval

Waste imports listed in Annex-1 require a Conformity Letter (Uygunluk Yazısı) issued by the relevant Provincial Directorate of the Ministry of Environment, Urbanization and Climate Change.

Key conditions include:

• The importer must operate a licensed recovery or recycling facility, or qualify under specific exemptions (e.g. inward processing use).
• Wastes must not contain radioactive, explosive, hazardous, or prohibited substances, nor be contaminated with such materials.
• Certain GTIP-specific imports require origin-country analysis certificates, translated and verified.

Application and Review Process

• Applications must be submitted at least three business days before arrival via the Ministry’s electronic Waste Import/Export Permit System.
• Required documents typically include:

Failure to apply within the prescribed timeframe results in automatic rejection.

Customs Value Clarification and Practical Application

From a customs-compliance perspective:

• Environmental conformity control is a mandatory pre-condition for customs clearance.
• Goods found non-compliant are denied entry, and must be re-exported or transited to a third country at the importer’s expense.
• Any attempt to misdeclare waste as “product” shifts the burden of proof entirely to the importer and creates significant post-clearance exposure.

Validity and Legal Effect

• The Conformity Letter is shipment-specific and non-transferable.
• Imported wastes cannot be sold, transferred, or diverted to third parties.
• Non-compliance detected after release triggers retroactive enforcement actions.

Enforcement and Compliance Risk

The Communiqué introduces high enforcement sensitivity, particularly for:

• Plastic, rubber, textile, battery, and electronic waste,
• Imports relying on product vs. waste classification claims,
• Inward Processing Regime imports where environmental permits are waived.

Violations may lead to:

• Administrative fines under Environmental Law No. 2872,
• Customs penalties and seizure procedures,
• Suspension of environmental permits and future import authorizations.

Repealed Regulation and Entry into Force

• Communiqué No. 2025/3 is repealed.
• Communiqué No. 2026/3 entered into force on 1 January 2026.
• A 45-day transitional period applies to shipments dispatched prior to entry into force, subject to favorable provisions.

Compliance Assessment

From a professional customs advisory standpoint:

• Waste imports are now treated as high-risk transactions, even where exemptions exist.
• Importers should conduct pre-shipment compliance mapping covering GTIP, waste code, permit status, and laboratory documentation.
• Any ambiguity between “waste” and “product” classification should be resolved before shipment, not at the border.

Failure to do so exposes the importer to irreversible operational and financial consequences.

See the legislation document.