Import Inspection of Construction Products

Regulatory Scope – Dual Structure: CE-Marked and Non-CE Construction Products

The Communiqué, published in the Official Gazette dated 31 December 2025, applies to construction products listed in Annex-1 and Annex-2, creating a dual regulatory structure that distinguishes between CE-marked and non-CE-marked products.

Annex-1 covers construction products subject to CE marking under the Construction Products Regulation aligned with EU Regulation 305/2011, while Annex-2 covers products that are not CE-marked but must comply with national or internationally recognized standards such as TS, ISO, or CEN.

This distinction is operationally critical because each category follows a different compliance logic:

• Annex-1 products require AVCP-based documentation aligned with CE marking
• Annex-2 products require standard-based conformity evidence

As a result, classification must be handled not only at the tariff level but also at the regulatory level, ensuring that the product is mapped correctly to the applicable framework, which often requires structured evaluation through HS code classification.

How the System Works – AVCP-Based Compliance Through TAREKS

All construction product imports under this Communiqué are processed through TAREKS, where applications are submitted before customs declaration and evaluated through a risk-based system.

The process includes:

• Submission of product data and documentation
• Uploading of compliance evidence aligned with AVCP system
• Risk analysis based on importer, product, and transaction parameters
• Direct approval or routing to physical inspection

If approved, a TAREKS Reference Number is generated and must be declared in Box 44.

However, it is essential to emphasize that:

• The reference number does not prove compliance
• It does not validate performance characteristics
• It only allows the import transaction to proceed

If the shipment is routed to physical inspection, the importer must upload additional documentation within strict deadlines, typically 20 working days, and any delay results in automatic rejection.

Practical Impact – AVCP System Determines Documentation Requirements

From an operational perspective, the most critical factor in construction product imports is the correct identification of the applicable AVCP system.

Each AVCP level requires a different set of documents:

• AVCP 1 and 1+ require notified body certificates confirming constancy of performance
• AVCP 2+ requires Factory Production Control (FPC) certification
• AVCP 3 requires approved laboratory test reports
• AVCP 4 relies primarily on manufacturer declarations

This means that submitting a technically correct document that does not correspond to the correct AVCP system is treated as a compliance failure.

For example, providing only laboratory test reports for a product that falls under AVCP 1+ will result in rejection, even if the product itself meets all performance criteria.

Risk Areas – AVCP Misalignment and Document Traceability

The most critical risk under this Communiqué is misalignment between the product’s AVCP system and the submitted documentation.

Common failure scenarios include:

• Incorrect identification of AVCP system
• Missing notified body certificates where required
• Incomplete or inconsistent Declaration of Performance
• Lack of traceability between documents and product identity

Another major risk area is document traceability and authenticity.

Authorities assess whether:

• Documents are issued by the relevant notified body or laboratory
• Product identification (model, type, batch) matches across all documents
• Translations accurately reflect original content

If any document is found to be unreliable or inconsistent, the inspection is finalized negatively regardless of other compliance elements.

For a broader understanding of how such inconsistencies can affect compliance outcomes across technical products, see customs valuation of assists.

Compliance and Audit Impact – Post-Clearance Risk Remains Active

A critical feature of this regulation is that compliance responsibility continues after customs clearance.

Even when a product is not selected for physical inspection:

• The importer remains fully responsible for compliance
• Authorities may conduct post-clearance inspections
• Market surveillance may reassess product performance

If a product is later found to be:

• Non-compliant with declared performance
• Incorrectly classified under AVCP
• Supported by invalid documentation

authorities may initiate enforcement actions retroactively.

This reflects Türkiye’s broader enforcement model, where compliance is continuously monitored through customs audit.

Strategic Actions – Building an AVCP-Compliant Documentation System

From a professional customs advisory perspective, construction product imports must be managed through a structured AVCP-compliant documentation system.

Companies should:

• Identify the correct AVCP system for each product
• Ensure DoP aligns with product performance and AVCP requirements
• Verify that all certificates are issued by the appropriate notified body
• Prepare approved Turkish translations of all documents
• Establish internal controls for document consistency and traceability

Additionally, companies should integrate compliance checks into their supply chain processes rather than treating them as a final-stage requirement.

For companies managing complex import operations, aligning documentation and regulatory strategy through customs consulting can significantly reduce operational risk.

Professional Assessment – Performance-Based Compliance Requires Technical Discipline

From a senior customs consultancy standpoint, Communiqué 2026/14 represents a performance-driven compliance regime where technical accuracy and documentation discipline determine import success.

The key differentiator in this regime is that:

• Compliance is linked to performance declarations, not only safety
• Documentation must match regulatory structure, not just product reality
• Risk arises from misalignment, not from lack of documentation

In this environment, companies that rely on generic or incomplete documentation will face repeated delays, while those that build AVCP-aligned compliance systems will achieve predictable import outcomes.

For companies operating across international markets, this reinforces the importance of integrated compliance strategies, as discussed in globalization and consultancy.

Conclusion – Construction Product Imports Are AVCP-Driven Compliance Processes

Communiqué 2026/14 confirms that construction product imports into Türkiye operate under a highly technical, AVCP-driven compliance model where success depends entirely on correct system identification, precise documentation, and disciplined execution.

This transforms construction product imports into performance-based compliance processes where even minor inconsistencies can result in immediate rejection and long-term regulatory exposure.

Official Gazette Reference

The official legal text is only available in Turkish; however, the key regulatory framework and practical implications are fully explained above.

See the legislation document.