Turkey – Import Inspection of Toys (Product Safety and Inspection: 2026/10)
Executive Summary:
Communiqué 2026/10 renews Türkiye’s import control framework for toys subject to the Toy Safety Regulation (published 4 October 2016, Official Gazette No. 29847). Controls are carried out through TAREKS on a risk-based model, typically before customs declaration registration, and clearance requires declaring a TAREKS Reference Number in Box 44. The Communiqué preserves key pathways (e.g., A.TR-based direct reference generation, special handling for returned goods and certain goods under the Customs Law implementing decision) while reinforcing strict positions on document authenticity, deadlines, and importer liability under Law No. 7223.
Scope
- Covers toys listed in Annex-1 that fall under the Toy Safety Regulation, for imports under Release for Free Circulation.
- Excludes goods re-imported under Outward Processing (returned after export under that regime).
- “Out of scope” is defined for items listed by GTIP in Annex-1 but not actually within the Toy Safety Regulation or not targeted for control under this Communiqué.
Mandatory Surveillance Certificate
- Import permission is evidenced operationally by a TAREKS Reference Number (“product may be imported”), which must be declared in customs declaration Box 44.
- Validity: 1 year from issuance.
- Important: The reference number does not prove the toy is safe/compliant; it only enables completion of the import transaction under the risk-based control model.
Special fixed reference numbers apply (no standard TAREKS application):
- For certain imports under the 5th part of the implementing decision to the Customs Law (Communiqué provides a fixed 23-digit number), and
- For returned goods (another fixed 23-digit number), to be entered in Box 44.
Application and Review Process
1) Firm setup
- Importers must be defined in TAREKS and authorize at least one firm user.
2) Timing
- Controls are conducted prior to customs declaration registration, aligned with the referenced customs procedure.
3) Submission
- The firm user applies via TAREKS (Ministry e-Transactions or e-Devlet), uploading the required information and documents as per Annex-2.
4) Risk analysis
- TAREKS risk scoring considers firm/product/transaction indicators (e.g., past controls and market surveillance results, manufacturer/importer identity, entry customs office, product type/brand/model/price/quantity, origin/shipping country).
5) Physical inspection (fiili denetim)
- May include document control, marking control, physical examination, and/or laboratory testing.
- Annex-2 documents (certain items) must be uploaded within 20 business days (with possible system-granted extension); late uploads result in a negative outcome.
- If any uploaded EU Declaration of Conformity, test report, or other requested document is found not issued by the stated source, the outcome is negative even if other conditions are met.
Practical Application and Customs Declaration Requirements
- Box 44 is critical: the importer must enter the correct TAREKS reference number (or the applicable fixed reference number for special cases).
- A.TR pathway: where the product is declared as supported by an A.TR Movement Certificate, TAREKS can generate the reference number directly—however, items may still be routed to physical inspection based on risk.
- “Out of scope” claims: must be submitted during the TAREKS process to the inspection unit; weak or inconsistent “scope-out” positioning is a common compliance risk.
- GTIP change / later detection: if post-clearance controls determine the imported product’s GTIP is actually within Annex-1, the customs administration notifies the Ministry’s relevant unit; if the toy is determined unsafe, it is treated as negative conformity outcome for enforcement purposes.
Validity and Legal Effect
- TAREKS permission/reference generation does not relieve the importer from:
- The TAREKS reference number cannot be used as a general compliance certificate or for purposes beyond the specific import transaction.
Enforcement and Compliance Risk
Key risk points for importers:
- Incomplete or late Annex-2 uploads in physical inspection cases (automatic negative outcome).
- Document authenticity issues (especially test reports/DoC) triggering negative results.
- Non-conformity found during inspection (marking, documentation, sampling/testing).
- Post-clearance identification that the goods should have been controlled under this Communiqué.
Sanctions may be applied under Law No. 7223, Customs Law No. 4458, the Technical Regulations Regime Decision, and related legislation. Additionally, TAREKS-related violations may lead to firm-user authorization suspension (1–12 months) and/or routing the firm’s applications to physical inspection for 1–12 months depending on severity and history.
Repealed Regulation and Entry into Force
- Repeals the previous Product Safety and Inspection: 2025/10 Toys Communiqué.
- Enters into force on 1 January 2026.
Transitional rule
- Shipments with transport documents issued (or goods presented to customs) before 1 January 2026 may, upon importer request and TAREKS application, be finalized under the repealed Communiqué until 28 February 2026 (inclusive).
Professional Compliance Assessment
For importers and supply chains dealing with toys, the operational priority is to build a “TAREKS-ready toy compliance pack” before shipment, including:
- robust internal verification that the product is genuinely a toy under the Toy Safety Regulation scope (classification and intended use),
- complete and consistent technical documentation set (DoC, test evidence where applicable, labeling/traceability elements),
- process discipline for TAREKS data quality (brand/model/price/quantity consistency),
- a contingency plan for sampling/testing timelines to avoid demurrage and storage cost escalation,
- controlled handling of any labeling/marking rectification requests (given heightened scrutiny and related guidance practice).
Other legislation updates
- Türkiye – Import Inspection of Certain Products Required to Bear the CE Marking (Product Safety and Inspection: 2026/9)
- Türkiye – Import Inspection of Solid Fuels Controlled for Environmental Protection (Product Safety and Inspection: 2026/7)
- Türkiye – Import Inspection of Environmentally Controlled Chemicals (Product Safety and Inspection: 2026/6)
- Türkiye – Import Inspection of Products Subject to the Control of the Ministry of Agriculture and Forestry (Product Safety and Inspection: 2026/5)
- Türkiye – Import Inspection of Substances Subject to Special Authorization of the Ministry of Health (Product Safety and Inspection: 2026/4)