Türkiye – Import Inspection of Solid Fuels Controlled for Environmental Protection (Product Safety and Inspection: 2026/7)

Scope

The Communiqué covers the importation of solid fuels listed in Annex-1 under the Release for Free Circulation regime only.It does not apply to other customs regimes as a general rule; the compliance model is designed around environmental parameters verified by sampling and analysis at or after arrival, prior to release.

Mandatory Surveillance Certificate

Imports within scope are permitted only if the importer holds and presents the required documents:

1) Importer Registration Requirement

• Imports may only be carried out by firms holding a Solid Fuel Importer Registration Certificate issued by the Ministry of Environment, Urbanization and Climate Change.
• Registration is obtained via the Ministry’s Environment Import/Export Permits Application system with corporate documentation (trade registry/association registry, tax certificate, and a ministry-required undertaking).

2) Conformity Documentation at CustomsFor customs declaration registration, one of the following must be available, depending on the pathway:

• Import Solid Fuel Conformity Certificate (issued by the Provincial Directorate after successful analysis), or
• Solid Fuel Exemption Letter (for narrowly defined exempt uses approved by the Ministry).

Without one of these documents, clearance is blocked.

Application and Review Process

The conformity control is analysis-driven and involves multiple parties:

Pre-sampling application (to Provincial Directorate)To initiate sampling for release for free circulation, the importer must submit (via the Ministry application system):

• copy of the Importer Registration Certificate,
• Import Solid Fuel Conformity Certificate form (two copies),
• loading analysis certificate (original + sworn translation) evidencing compliance with the Ministry’s limit values for each parameter,
• exporter invoice copy + sworn translation.

Sampling and laboratory analysis

• Sampling is conducted by an international inspection company under a commission structure involving:
• Samples are analyzed at either:
• Results are transmitted to the Provincial Directorate, which then issues:

Objection / witness sample

• If results are non-compliant, the importer has 7 business days to request witness sample testing (at importer’s cost).
• If witness testing remains non-compliant, the non-conformity decision becomes final, and new sampling cannot be requested except for issues arising from sample handling/storage chain integrity.

Practical Application and Customs Declaration Requirements

Key operational implications for importers:

• Customs release is certificate-driven: the Conformity Certificate (or Exemption Letter) must be available at declaration registration, except for the special “on-vehicle processing” pathway described below.
• Single pile / multiple withdrawals: where a single batch is stored as one pile but withdrawn in multiple parts, the first withdrawal can be supported by an analysis representing the whole pile, and subsequent certificates can be issued based on that same analysis report.
• Industrial vs heating vs thermal power use conversion (risk mitigation):

“On-vehicle processing” pathway (exceptional logistics)

• Where temporary storage/warehouse capacity is not available, and the importer submits the Information Form (Annex-2) before arrival, the fuel may be processed on-vehicle and then stored only at the declared site under strict restrictions:
• If analysis becomes non-compliant and reclassification-to-use is not possible, the fuel must be re-exported to origin/loading country or a third country.

Validity and Legal Effect

• The Communiqué establishes a transaction-specific compliance model: conformity is evidenced through sampling and analysis for the imported batch, and the resulting certificate supports customs release.
• Additional post-clearance obligations apply for certain industrial-use imports:firms that imported solid fuels for industrial use under a Conformity Certificate must submit a delivery receipt proving delivery to factories within 90 days. Failure triggers a 6-month suspension of future Conformity Certificate requests until remedied.

Enforcement and Compliance Risk

This is a high-enforcement regime because it combines customs control with environmental conformity:

• Non-conformity blocks import: fuels receiving a Non-Conformity Letter cannot be released; the goods must be returned to origin/loading country or transited to a third country at importer cost.
• Tight challenge window: only 7 business days to request witness sample testing.
• Strict restrictions under the on-vehicle pathway: any breach (movement, use, sale, processing) before certification can create significant compliance exposure.
• Sanctions may be applied under:

Repealed Regulation and Entry into Force

• The Communiqué repeals Product Safety and Inspection: 2025/7.
• It entered into force on 1 January 2026.
• A 45-day transitional period applies for shipments with transport documents issued before entry into force, subject to the repealed Communiqué, while more favorable provisions of the new Communiqué may apply.

Compliance Assessment

For importers, the most defensible compliance setup is:

• maintain valid Importer Registration Certificate and keep corporate data current (renewals required if core registration data changes),
• align contracts and shipment planning with the sampling/analysis timeline (avoid demurrage risk),
• prepare for two-layer evidence: exporter loading analysis + Türkiye-side laboratory outcome,
• pre-plan fallback usage (industrial/thermal) and the required undertakings in case heating-grade parameters fail,
• treat the “on-vehicle” pathway as a last resort due to its strict movement/usage prohibitions and re-export risk.

See the legislation document.