Import Inspection of Personal Protective Equipment (PPE) – Communiqué (Product Safety and Inspection): 2026/11 (Türkiye)

Scope

• Products covered: PPE falling under the PPE Regulation, as listed by GTIP in Annex-1 (e.g., face shields, various protective gloves, protective clothing, life jackets, FFP-type masks aligned with EN 149, protective footwear with protective toe caps, helmets (only those qualifying as PPE), protective eyewear components, gas masks and parts/accessories).
• Customs regime: Applies to Release for Free Circulation.
• Excluded: Does not cover goods returned under Outward Processing.

Application and Review Process

• Platform: All procedures are performed in TAREKS, based on risk analysis.
• Prerequisite: Importers must be registered in TAREKS and authorize at least one firm user, in line with the general TAREKS framework referenced (UGD: 2025/28).
• Timing: Inspection is carried out before registration of the customs declaration (in line with the structure referencing Customs Regulation Art. 181/4).
• Decision flow (operationally):

Mandatory Documents to Upload in TAREKS (Annex-2)

For PPE imports under this Communiqué, the standard file set is:

1. Relevant customs/transport documents (depending on shipment status): summary declaration, transit/transport documents (B/L, CMR, CIM), free zone forms, prior declarations for warehousing/temporary import, and—if requested—the customs declaration.
2. Invoice or proforma invoice.
3. EU Declaration of Conformity (AB Uygunluk Beyanı)
4. Product photos taken in the customs-controlled area.
5. Turkish product information and user manual (Turkish instructions/guide).

Critical integrity rule: If the uploaded EU Declaration of Conformity, test report, or any other document is determined not to have been issued by the relevant party (or is otherwise unreliable), the inspection is concluded negatively even if other conditions appear acceptable.

Validity and Legal Effect

• The TAREKS reference number must be entered into Box 44 of the customs declaration by the importer.
• The reference number is valid for 1 year from the date it is issued.
• A positive TAREKS result / reference number does not constitute proof that the product is compliant or safe; it is an import-control outcome.

The Communiqué also provides fixed 23-digit TAREKS reference numbers for certain special cases (as specified in Article 11), including imports under the “fifth part” of the Decision implementing certain provisions of Customs Law No. 4458, and returned goods scenarios.

Enforcement and Compliance Risk

• Importer liability remains full: Even where the product is not physically inspected, the importer remains responsible for ensuring the PPE complies with the PPE Regulation and all applicable legislation, under Law No. 7223.
• Post-clearance control risk: If later controls determine the imported product’s GTIP falls under Annex-1, customs notifies the Ministry of Labour and Social Security. If the competent authority finds the product unsafe, the conformity assessment is treated as negative.
• Sanctions: Apply under Law No. 7223, Customs Law No. 4458, the Technical Regulations Regime and other applicable rules.
• TAREKS user/firma risk: Non-compliance may trigger suspension of firm user authorization (1–12 months) and routing the firm’s applications to physical inspection (1–12 months), depending on severity, frequency, and prior history.

Repealed Regulation and Entry into Force

• Communiqué 2025/11 is repealed; references to 2025/11 in other texts are effectively understood as references to 2026/11 in practice (per standard repeal logic in these UGD sets).
• Entry into force: 1 January 2026.
• Transitional period: For shipments dispatched before 1 January 2026 (transport document issued / presented to customs), imports may—upon TAREKS application and importer request—be finalized under the repealed Communiqué until 28 February 2026 (inclusive).

Compliance Assessment

From a clearance-risk and operational perspective, the most practical implications are:

• PPE vs. non-PPE classification is decisive: Several product lines (e.g., helmets/visors, eyewear, gloves) can fall into or out of PPE scope depending on intended use and technical characterization. Misclassification can lead to routing errors, delays, and post-clearance exposure.
• EU Declaration of Conformity is the backbone document: Missing, inconsistent, or unverifiable DoC is a high-probability rejection trigger, particularly for physical inspection cases.
• Turkish documentation readiness matters: The Turkish user manual/instructions are explicitly requested—importers should standardize a compliant Turkish documentation pack per product/brand/model.
• Have a bonded-area photo process: Since product photos from the customs-controlled area are required, an operational workflow with the warehouse/broker avoids avoidable waiting time.
• Don’t treat “TAREKS positive” as “full compliance”: The Communiqué is explicit: permission/reference is not proof of conformity. Firms should retain technical files and ensure labeling/marking consistency to withstand post-market and post-clearance checks.

See the legislation document.