Türkiye – Import Inspection of Non-Road Mobile Machinery (Product Safety and Inspection: 2026/2)

Executive Summary:

With the Communiqué on Import Inspection of Non-Road Mobile Machinery (Product Safety and Inspection: 2026/2) published in the Official Gazette dated 31 December 2025 (No. 33124, 4th Repeated), Türkiye has renewed the import-time compliance controls for specific non-road mobile machinery listed in Annex-2, under the regulatory frameworks listed in Annex-1. The Communiqué is built on TAREKS risk-based processing with TSE as the inspection unit, but it introduces a distinctly operational requirement: Import Inspection Pre-Approval (İthalat Denetim Ön İzni) must be obtained for Annex-2 machinery, meaning part of the review is designed to occur before the goods reach the customs area, based on submitted documents.

Scope

• Covers Annex-2 products that fall under the regulations in Annex-1 when placed under the Release for Free Circulation regime.
• Does not cover goods returning under the Outward Processing regime.
• Applies to machinery subject to one or more of these compliance regimes (as per Annex-1):

Mandatory Surveillance Certificate

This Communiqué does not establish a “surveillance certificate” in the classical trade-policy sense. Instead, the binding prerequisite is:

• Mandatory Import Inspection Pre-Approval (Ön İzin) for Annex-2 products, and
• A TAREKS reference number for import clearance steps.

Operationally, for Annex-2 machinery pre-approval is compulsory in all cases, even if the product could otherwise benefit from streamlined routing (e.g., A.TR).

Application and Review Process

Two-step structure is the key practical change vs. many other UGD communiqués:

1) Import Inspection Pre-Approval (Ön İzin) – mandatory

• Application is submitted via TAREKS (E-Services).
• The firm user selects “Pre-Approval / Product Group Based Application” and marks Import Inspection Pre-Approval.
• Certain documents are uploaded at application stage, and some are additionally forwarded to the inspection unit after the goods reach the customs territory (per the Communiqué’s Annex-3 logic).
• If an uploaded EU Declaration of Conformity / Type Approval / test report is determined not to be issued by the genuine competent party, the pre-approval is rejected even if all other conditions appear satisfied.

2) Shipment/batch application (import lot) before customs declaration registration

• Import controls are conducted before customs declaration registration, consistent with the Customs Regulation framework.
• The firm uploads the relevant customs/transport documentation and proceeds through TAREKS tracking.

Customs Value Clarification and Practical Application

• The Communiqué is not a customs valuation mechanism; it is a technical compliance/import safety control mechanism.
• However, operationally it ties compliance to documentary integrity: invoice/proforma and technical documents are core inputs, and any falsification or non-authentic documentation can trigger rejection and enforcement consequences, independent of product quality.

Validity and Legal Effect

• A TAREKS reference number must be declared in Box 44 of the customs declaration.
• The reference number is valid for 1 year from issuance.
• Crucially:

Enforcement and Compliance Risk

This Communiqué is operationally high-impact for importers of construction and industrial machinery because it combines mandatory pre-approval with strict documentary controls.

Key compliance risks:

• Pre-approval is compulsory “in all cases” for Annex-2 goods; import planning must incorporate this lead time and document collection.
• Authenticity controls: the Communiqué explicitly allows rejection if DoC/type approval/test reports are found not to be genuinely issued.
• Risk-based routing remains: even where products are A.TR-declared, risk analysis may route to physical inspection; additionally, the Communiqué states that A.TR cases still require pre-approval.
• Sanctions: misleading statements, falsified documents, or violations trigger application of Law No. 7223, the Customs Law, the Technical Regulations Regime Decision, and other relevant rules.
• User-level consequences: firm users may face 1–12 months suspension and firms may be routed to physical inspection for 1–12 months, depending on severity, frequency, history, and product nature.
• Post-clearance exposure: if the GTIP is later identified as being in Annex-2, the case can be escalated; if the competent authority determines the product is unsafe, it is treated as negatively assessed.

Repealed Regulation and Entry into Force

• Repeals UGD: 2025/2 (published 31/12/2024).
• Enters into force on 1 January 2026.
• Transitional rule: shipments with transport document issued or presented to customs before 1 January 2026 can be processed under the repealed Communiqué until 28 February 2026 (inclusive), provided a TAREKS application is filed and the importer requests that route.

Compliance Assessment

From a practical importer / customs compliance standpoint, 2026/2 requires “front-loading” preparation:

• Product scoping: confirm whether the machinery is within Annex-2 and identify the applicable regime(s): Machinery / Emissions / Noise / EMC.
• Pre-approval planning: set an internal checklist that must be completed before arrival:
• Document legalization workflow: where the Communiqué requires approvals by Trade Counsellor/Attaché in the country of exit, build lead time and document routing into contracts and shipping timelines.
• Do not treat TAREKS outputs as compliance certificates: maintain a separate technical compliance file (CE/DoC/type approval/noise/emissions) for audits, market surveillance, and post-clearance controls.

See the legislation document.