What obligations apply when exporting to Turkey

With the introduction of Decrees No. 2026/32 and 2026/09 issued by the Turkish Ministry of Trade, a new challenge has begun for exports of machinery and spare parts

Stefano Nicolussi

Turkey should be regarded as a significant trading partner, but it also represents a context that requires increasing attention from a regulatory, customs and documentary perspective. What were previously sporadic customs checks are now becoming systematic, thanks to the introduction of the new digital platform TAREKS, and they extend to a wide range of customs codes covering both machinery and spare parts.

Before outlining the new approach, it is important to point out that all activities relating to the registration of machinery on the TAREKS portal and the uploading of the required documentation fall under the responsibility of the Turkish importer.

In particular, Decree 2026/32 encompasses a wide range of customs codes covering the vast majority of machinery intended for export. These codes are divided into two separate annexes, which regulate the procedures for registration and customs clearance of goods.

The annexes are:

• 2/A, relating to so-called “dangerous” machinery, which includes all codes requiring pre-shipment registration (all documents certifying the safety of the machinery must be uploaded before shipment);
• 2/B, relating to codes requiring registration only, without the need for prior approval.

In the registration process, it is essential that all accompanying documents for the machinery are consistent with one another and, in the case of technical documentation, that they have been issued prior to shipment; otherwise, there is a high likelihood of inspection or rejection by customs.

The mandatory documents for the registration of machinery falling under Annex 2/A are:

• invoice/proforma invoice;
• EC Declaration of Conformity;
• noise emission test reports;
• photographic documentation of the machinery (from all angles);
• machine nameplate;
• instruction manual (translated into Turkish; a sworn translation is not required).

With regard to technical documentation:

• checklist in accordance with ISO 12100*;
• electrical test reports in accordance with EN 60204-1, carried out by an ISO 17025 accredited laboratory;
• electromagnetic compatibility (EMC) test reports*.

* These do not need to be issued by an accredited laboratory.

Only in the event of documentary inconsistencies, doubts regarding actual compliance, or risk indicators may the Administration request additional test reports or subject the machinery to technical verification. In such cases, the test reports should be dated prior to shipment, as they must certify product compliance before release for free circulation. For this reason, it is advisable for both manufacturer and importer to hold such reports in advance, even if not expressly mandatory.

For machinery falling under Annex 2/B as well, attention must be paid to the fact that, should customs require additional checks, the documentation must be readily available and dated prior to shipment in order to allow the goods to be placed on the market.

Further considerations must also be given to:

• used machinery, which falls under Decree 2026/09;
• partly completed machinery;
• partially assembled machinery;
• assemblies of machinery/complete lines;
• temporary exports for exhibition, demonstration or testing purposes.

With regard to the latter, no specific decree appears to apply: the goods will only be subject to the above-mentioned obligations if they are subsequently placed on the market.

For customs support and documentation relating to exports, the Association Secretariat remains available: [email protected].