Import Inspection of Batteries and Accumulators – Communiqué (Product Safety and Inspection): 2026/15 (Türkiye)

Scope

• Products: Batteries and accumulators listed in Annex-1 (e.g., primary cells and batteries under heading 8506, lead-acid accumulators under 8507.10 / 8507.20, NiMH under 8507.50, lithium-ion and other accumulators under 8507.60 and related subheadings, etc., as detailed by GTIP).
• Customs regime: Applies to imports under Release for Free Circulation.
• Exclusion: Does not cover goods returning under the Outward Processing regime.

Environmental Compliance Permit (Çevre Uyum İzni)

A distinctive and high-impact requirement under this Communiqué is that importers must hold a Çevre Uyum İzni under the Waste Batteries & Accumulators framework.

• The permit application is initiated through TAREKS (via “E-Transactions” → TAREKS → “Inspection Application” → “Pre-Permit” → “New Application” → “Application by Product Group”, selecting Çevre Uyum İzni).
• However, the supporting documents required by the Ministry of Environment, Urbanization and Climate Change are sent separately in writing to that Ministry, and the permit decision is made by that Ministry.

Operationally, this means import readiness depends not only on TAREKS steps, but also on the external permit workflow of the environmental authority.

TAREKS Process and Risk-Based Model

• All inspections and approvals are performed via TAREKS, based on risk analysis.
• Firms must be registered in TAREKS and must have at least one authorized firm user.
• Inspection is conducted before customs declaration registration (Customs Regulation approach).

Risk analysis can take into account typical risk indicators (firm history, past inspection outcomes, product type/brand/model, price/quantity, origin/shipping country, entry customs, etc.) and may still route “normally exempt” cases to physical inspection.

Exemptions and Special Regimes

• If the importer holds a Çevre Uyum İzni and the goods are supported by an A.TR Movement Certificate, TAREKS may generate the “may be imported” reference number directly (but this can still be overridden by risk-based routing to inspection).
• AQAP certificate holders (defense-industry quality assurance): once the AQAP certificate is defined in TAREKS, the TAREKS reference number generated for a specific product may be reused for subsequent imports of the same product until the end of the calendar year.
• Certain installed/embedded or specialized-use batteries are explicitly treated as out of scope of the Waste Batteries & Accumulators Regulation and must be declared as “out of scope” (e.g., pacemaker batteries, batteries embedded in life-critical medical devices, permanently installed industrial batteries in equipment, certain professional/scientific uses, and batteries that must only be removed by professionals to ensure continuous operation).

Application and Inspection Steps

• Application is made in TAREKS by uploading the initial documents listed in Annex-2 (items 1 and 2).
• If routed to physical inspection, the additional documents in Annex-2 (items 3 and 4) must be uploaded within 20 working days (including the application day). Failure to upload within the deadline results in a negative outcome.
• A strict integrity rule applies: if test reports or other requested documents are found not to be issued by the relevant party, the inspection is concluded negatively even if other conditions appear compliant.

Documents Required in TAREKS (Annex-2)

1. Relevant customs/transport documents based on the shipment’s status (summary declaration, transit/transport docs such as B/L–CMR–CIM, free zone forms, prior declarations, etc.).
2. Invoice or proforma invoice.
3. Accredited laboratory test report demonstrating the imported batteries comply with the harmful substance limits and thresholds defined by the Waste Batteries & Accumulators Regulation (original or laboratory-certified copy).
4. Product photos taken in the customs-controlled area.

Customs Declaration Practice (Box 44)

• Once cleared, a TAREKS reference number must be entered into Box 44 of the customs declaration by the importer.
• Validity of the reference number is 1 year from issuance.

Fixed reference numbers (special cases)

• For imports under the postal/express cargo framework referenced (Decision No. 2009/15481 – “Fifth Part”), no TAREKS application is made; the fixed 23-digit TAREKS reference number 18150099115115014436576 is entered into Box 44.
• For returned goods (Customs Regulation Art. 446 scenarios), no TAREKS application is made; the fixed 23-digit TAREKS reference number 24150099915801771102479 is entered into Box 44.

Enforcement and Compliance Risk

• Importers remain responsible for compliance with the Waste Batteries & Accumulators Regulation and related obligations whether inspected or not, under Law No. 7223.
• Non-compliance, false declarations, or document tampering may trigger enforcement under:
• Additional TAREKS governance sanctions may apply:
• If batteries/accumulators are denied import and left to customs, the Communiqué provides for disposal/transfer to authorized collection points and/or licensed waste battery recovery facilities (paid or free of charge) for recovery or disposal.

Repealed Regulation and Entry into Force

• Communiqué 2025/15 is repealed.
• Entry into force: 1 January 2026.
• Transitional provision: Shipments dispatched for export to Türkiye before 1 January 2026 (transport document issued or goods presented to customs) may—upon TAREKS application and importer request—be processed under the repealed Communiqué until 28 February 2026 (inclusive).

Compliance Assessment

In practice, this Communiqué is “permit + evidence” driven. The main operational risk points for importers are:

1. Permit readiness: Ensure the Çevre Uyum İzni is secured before import planning; delays are typically outside the importer’s control because the final decision sits with the environmental authority.
2. Test report quality: Use a truly accredited lab and verify that the report explicitly covers the relevant harmful substances and thresholds. “Generic” reports that do not map to regulatory limits are a common failure point.
3. Product identity consistency: Ensure that the product identity (type, model, chemistry, packaging) matches the test report and invoice—especially for mixed lots (button cells, pouch cells, prismatic cells, accumulators).
4. Customs-site photo workflow: Have a practical process to obtain compliant photos in the bonded area without blocking clearance.

See the legislation document.