Used or Refurbished Goods Import Communiqué (Import: 2026/9) – Türkiye Regulatory Update

Regulatory Scope and System Structure

The Communiqué applies to used or refurbished goods placed under the Release for Free Circulation regime, regardless of sector. It covers:

• Annex-1 listed goods (0970 TPS list)
• Civil aviation goods
• Marine vessels and equipment
• Non-listed goods (case-by-case assessment)
• Temporary import to definitive import conversions

This broad scope means that the regulation is not limited to specific industries. Any company importing second-hand or refurbished goods into Türkiye falls within its framework.

From a compliance perspective, the system is built on two pillars:

1. Mandatory pre-import permit requirement
2. Independent customs control and valuation authority

These two layers operate separately—and misunderstanding this separation is one of the most common causes of audit exposure.

Mandatory Import Permit: Non-Negotiable Requirement

All used or refurbished goods imported under free circulation are subject to prior authorization via TPS (Trade Policy Surveillance System).

Two permit codes apply:

• 0970 → Listed goods (Annex-1)
• 0962 → Non-listed goods

Without a valid TPS reference, customs declarations cannot be registered. This is not a procedural formality—it is a hard system control.

In practice, this means:

• No permit → no customs clearance
• Incorrect permit → blocked declaration
• Mismatch between permit and goods → high audit risk

For companies managing complex imports, integrating this process into broader compliance structures such as customs consulting Turkey is essential.

Annex-1 Listed Goods (0970): Structured Authorization Logic

For goods listed under Annex-1, the Communiqué introduces a structured evaluation based on group classification and intended use.

Group 1 – Standard Listed Goods

Authorization depends on:

• Whether the goods are covered by an investment incentive certificate
• Whether minimum unit customs value thresholds apply
• Compliance with age limits, where defined

If covered by an investment incentive certificate, imports may proceed without unit value thresholds. Otherwise, minimum value conditions become binding.

This creates a dual-layer system where both technical classification and investment structure affect import feasibility.

Group 2 – Aviation and Marine Goods

For civil aviation and marine equipment:

• Authorization requires a Suitability Letter from the Ministry of Transport
• If approved → no minimum unit value requirement applies

However, misclassification is a critical risk:

• If goods are declared under Group 2 but do not qualify technically → authorization is rejected
• If they also fail Group 1 criteria → import becomes impossible

This is a typical example where incorrect classification leads not only to delays but complete transaction failure.

For classification accuracy:→ HS code classification Turkey

Non-Listed Goods (0962): Discretionary Approval Risk

For goods outside Annex-1, authorization is fully discretionary.

The Import General Directorate evaluates:

• Importer profile
• Economic necessity
• Domestic availability
• Technical condition and productivity

This introduces a subjective assessment layer where:

• weak documentation → rejection
• unclear justification → delays
• inconsistent data → permit denial

Unlike listed goods, there is no predictable threshold logic. Approval depends heavily on how well the application is prepared.

This is where early-stage advisory becomes critical, particularly for high-value machinery or specialized equipment.

Temporary Import → Definitive Import Conversion

The Communiqué clarifies three scenarios:

1. Goods new at entry → definitive import allowed without permit
2. Goods new at entry but used later → allowed without permit
3. Goods already used at entry → full permit requirement applies

This distinction is frequently misunderstood.

Companies often assume that temporary import status provides flexibility. In reality, if the goods were already used at entry, full compliance obligations remain.

This becomes a common trigger in post-clearance audits.

Customs Valuation: The Critical Separation

One of the most important clarifications in the Communiqué is the explicit separation between:

• permit values, and
• customs valuation

Declared values in permit applications do not replace customs valuation under Customs Law No. 4458.

Customs authorities retain full power to:

• reassess value
• adjust quantities
• initiate post-clearance audits

A tolerance of up to 5% between permit data and customs data is allowed. However, this is a technical tolerance—not a protection mechanism.

For companies dealing with valuation complexity:→ Customs valuation Turkey

and related valuation risks:→ Customs valuation of assists engineering and development costs

Post-Clearance Risk: The Real Exposure Area

The Communiqué clearly reinforces that:

Permit approval does not eliminate audit risk.

In practice, most issues arise after clearance:

• incorrect age declaration
• mismatch between permit and actual goods
• unrealistic valuation assumptions
• weak technical documentation

These issues may lead to:

• administrative penalties
• reassessment of customs duties
• future permit refusals

For companies regularly importing used goods, integrating audit preparedness into operations is critical:→ Customs audit Turkey

Operational and Commercial Implications

From a business standpoint, this regulation impacts:

1. Investment Planning

Used machinery imports are often linked to investment projects. Any delay or rejection in permits directly affects project timelines.

2. Supplier Selection

Not all suppliers provide sufficient technical documentation. This becomes a critical factor in Türkiye-bound transactions.

3. Contract Structuring

Contracts must reflect:

• permit dependency
• approval risks
• possible delays

4. Cost Predictability

Unexpected valuation adjustments or permit rejections can significantly impact total project cost.

Strategic Actions for Importers

Companies importing used or refurbished goods into Türkiye should implement the following:

• Perform GTIP and group classification before contracting
• Verify age, capacity, and technical specifications
• Align permit application data with customs declaration data
• Treat permit values as indicative—not final
• Prepare full documentation for potential audits

For broader compliance structuring:→ AEO consulting Turkey

And for dispute management if issues arise:→ Dispute objection settlement Turkey

Professional Compliance Perspective

From a professional customs advisory perspective, this Communiqué confirms a key principle:

Used goods imports in Türkiye are not simplified—they are controlled.

Companies that treat permit approval as final clearance authorization expose themselves to:

• valuation risk
• audit findings
• operational disruption

On the other hand, companies that:

• align technical data early,
• structure applications properly,
• integrate customs and regulatory compliance

can significantly reduce long-term risk.

Conclusion

The Used or Refurbished Goods Import Communiqué (2026/9) does not introduce a new regime but reinforces an existing one: a controlled, permit-driven import system supported by strong customs oversight.

For importers, the main challenge is not regulatory change—but execution accuracy.

In this environment, early-stage technical and regulatory alignment is not optional. It is the primary tool for avoiding post-clearance exposure and ensuring predictable import operations in Türkiye.

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

→ (Official Gazette publication – Import Communiqué 2026/9 – Turkish text) →https://www.resmigazete.gov.tr/eskiler/2025/12/20251231M3-14.pdf