Import Surveillance Requirements for Brushes and Applicators - Communiqué No: 2026/21

Products Covered and Valuation Thresholds

The scope of the regulation covers multiple product groups under heading 9603, reflecting differing commercial realities across the sector.

Hair brushes falling under code 9603.29.30.00.00 are subject to surveillance when declared below USD 11,000 per metric ton (gross weight), while other brushes under 9603.29.80.00.00 fall within scope when declared below USD 6,000 per metric ton.

A unit-based valuation approach applies to art and writing brushes classified under 9603.30.10.00.00. For these goods, surveillance is triggered where the declared value is below USD 0.35 per piece.

Brushes used for the application of cosmetic products under 9603.30.90.00.00 are subject to surveillance when declared below USD 19,000 per metric ton, while paint, varnish, and similar application brushes, including rollers and pads classified under 9603.40, are covered below USD 2,000 per metric ton. The same USD 2,000 per metric ton threshold applies to residual products under 9603.90.

Mandatory Surveillance Certificate Requirement

Where the declared unit value is below the applicable reference level, importation is permitted only upon presentation of a valid Surveillance Certificate issued by the Ministry of Trade. The certificate must be obtained prior to customs declaration and must be correctly referenced in the declaration, including the assigned document number and issue date.

Failure to present a valid certificate results in customs clearance being blocked.

Application and Review Process

Applications are submitted electronically via the national Single Window platform using the designated surveillance document type and selecting Communiqué No: 2026/21 as the legal basis. Submission requires a qualified electronic signature, with an alternative filing option available through the national e-government portal.

In cases where electronic submission is not technically possible, physical applications may be accepted using the prescribed application form, together with corporate registration documentation.

During the review stage, the authority may request original documents, additional explanations, or supplementary information. Any inconsistency, deficiency, or contradiction identified will suspend the process until fully remedied.

Customs Value Considerations and Practical Application

The Communiqué explicitly states, in a separate provision, that the reference values introduced for surveillance purposes do not replace and do not constitute customs value. Standard customs valuation rules remain fully applicable.

In practice, and specifically for value-based surveillance regimes, it is possible to structure the customs value by declaring additional foreign costs—such as freight, insurance, or other overseas charges—in order to increase the declared customs value above the surveillance reference level. This approach is accepted by customs authorities, provided that such costs are legitimate, properly documented, and declared in accordance with valuation rules.

Accordingly, imports may proceed without a Surveillance Certificate where the final declared customs value, including eligible foreign costs, exceeds the applicable surveillance threshold. This practice is limited strictly to value-based surveillance measures and does not apply to quantity-based or non-value surveillance regimes.

Validity and Legal Effect

Surveillance Certificates issued under this Communiqué are valid for six months. The existence of a certificate does not restrict customs authorities from examining or reassessing the declared value under general valuation principles. Conversely, compliance with valuation rules may allow clearance without surveillance certification where thresholds are legitimately exceeded.

Enforcement and Compliance Risk

Where inaccurate, misleading, or incomplete information is identified during application or review, issuance of the Surveillance Certificate will be withheld until corrective action is taken. Failure to meet surveillance requirements may lead to clearance delays, storage costs, and increased scrutiny during post-clearance controls.

Repealed Regulation and Entry into Force

With the entry into force of this Communiqué, Communiqué No: 2004/14 has been fully repealed. The new regime applies to declarations registered from the 30th day following publication, requiring careful transition planning for shipments around the effective date.

Professional Compliance Assessment

From a customs compliance and risk management perspective, this regulation significantly tightens controls over product groups historically associated with low unit values. Importers must reassess pricing structures, declaration strategies, and cost components on a shipment-by-shipment basis.

For value-based surveillance, careful and lawful inclusion of foreign cost elements may offer operational flexibility, provided that documentation is robust and consistent. Advance evaluation of whether surveillance can be avoided through proper valuation—or whether a Surveillance Certificate should be obtained proactively—is critical to ensuring uninterrupted import operations.

See relevant legislative document