Import Surveillance Requirements for Plastic Household and Infant Care Articles - Communiqué No: 2026/24
Why this matters for exporters to Türkiye and brand owners:
This Communiqué replaces a surveillance regime that had been in force since 2006, signalling a policy reset for plastic household and infant care products.
The inclusion of baby bottles, training cups and bottle nipples places infant-related imports under heightened compliance sensitivity, where documentation quality matters as much as price.
Differentiated thresholds across HS 3924 and 3926 significantly increase classification risk, particularly for mixed consignments containing both household and childcare items.
The regulation primarily targets high-volume, low-margin consumer goods, where pricing strategies often operate close to surveillance thresholds.
Importers relying on OEM/private-label sourcing should anticipate closer scrutiny of valuation consistency and supply-chain cost structures.
Executive Summary
Import Surveillance Communiqué (No: 2026/24) introduces a value-based import surveillance regime for a broad range of plastic household articles and infant care products, primarily classified under HS headings 3924 and 3926. The regulation establishes minimum unit customs value thresholds calculated on a gross weight basis (USD per metric ton). Imports declared below these thresholds are subject to a mandatory Surveillance Certificate requirement. The Communiqué repeals Communiqué No: 2006/7 and enters into force 30 days after its publication on 31 December 2025.
Scope of the Regulation
The surveillance regime applies to various plastic articles commonly used in daily life and childcare, including feeding and household products.
Under HS 3924.10, plastic baby bottles and training cups are subject to surveillance when declared below USD 3,900 per metric ton, while other plastic tableware and kitchenware under the same heading fall within scope at thresholds ranging from USD 5,000 to USD 6,600 per metric ton, depending on the specific sub-classification.
Additional plastic articles under HS 3924.90 are also covered. Bottle nipples and related components fall under surveillance when declared below USD 2,500 per metric ton, plastic waste bins are covered below USD 3,000 per metric ton, and other residual plastic household articles are subject to surveillance below USD 4,000 per metric ton.
The regulation further extends surveillance to certain decorative or miscellaneous plastic articles classified under HS 3926.40, which are covered when declared below USD 7,000 per metric ton.
Only shipments declared at or above the applicable reference values may be released without surveillance certification.
Mandatory Surveillance Certificate
Where the declared unit value falls below the relevant reference threshold, importation is permitted only upon presentation of a valid Surveillance Certificate issued by the Ministry of Trade. The certificate must be obtained before registration of the customs declaration and must be properly referenced in the declaration using the assigned document number and issue date.
Absence of a valid certificate will result in customs clearance being blocked, irrespective of the commercial nature or end use of the goods.
Application and Review Process
Applications for Surveillance Certificates are submitted electronically through the national Single Window system using the designated industrial surveillance document type and selecting Communiqué No: 2026/24 as the legal basis. Submission requires a qualified electronic signature, with an alternative filing option available via the national e-government portal.
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 issuance process until fully remedied.
Customs Value Clarification 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. General customs valuation rules remain fully applicable.
In practice, and specifically for value-based surveillance regimes, it is possible to structure the declared customs value by including legitimate foreign cost elements, such as international freight, insurance, and other overseas charges, thereby increasing the final customs value above the surveillance reference threshold. This approach is accepted by customs authorities, provided that all cost elements are genuine, properly documented, and declared in full compliance with valuation rules.
Accordingly, imports may proceed without a Surveillance Certificate where the final declared customs value, inclusive of eligible foreign costs, exceeds the applicable reference level. This approach applies only to value-based surveillance measures and does not extend 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 prevent customs authorities from examining or reassessing the declared value under general valuation principles. Conversely, accurate and well-documented valuation may allow clearance without surveillance certification where thresholds are legitimately exceeded.
Enforcement and Compliance Risk
If inaccurate, misleading, or incomplete information is identified during the application or review stages, issuance of the Surveillance Certificate will be withheld until corrective action is taken. Non-compliance may lead to clearance delays, additional storage costs, and increased scrutiny during post-clearance audits.
Repealed Regulation and Entry into Force
With the entry into force of this Communiqué, Communiqué No: 2006/7 has been fully repealed. The new surveillance regime applies to customs declarations registered from the 30th day following publication, requiring careful transition planning for shipments scheduled around the effective date.
Compliance Assessment
From a customs compliance and risk management perspective, this regulation targets product groups characterized by high-volume, price-sensitive imports, particularly in the infant care and household goods sectors. Importers should reassess supplier pricing, declaration strategies, and cost allocation well in advance of shipment.
For value-based surveillance, lawful inclusion of foreign cost components can provide operational flexibility, provided documentation is robust and internally consistent. Importers should evaluate, on a shipment-by-shipment basis, whether surveillance can be avoided through correct valuation or whether proactive application for a Surveillance Certificate offers greater predictability and risk control.
Other legislation updates
- Türkiye – Amendment to Customs General Communiqué No. 16: Clarification on Simplified Procedure for OKSB Holders
- Türkiye – Anti-Dumping Measures Expiring in 2026: Official Notice under Communiqué No. 2026/4
- Türkiye – Amendment to the Free Zones Implementation Regulation: Licensing, Accounting Separation and Superstructure Regime
- Amendment to the Minimum Fee Tariff for Customs Brokers and Authorized Customs Brokers (Türkiye – Regulatory Update)
- Imposition of Definitive Anti-Dumping Measures on Tin-Coated Flat-Rolled Steel Products Originating in Germany, China, Korea, Japan and Serbia