Turkey 2026 Import Regime — Cumhurbaşkanı Kararı No. 10790 (cross-sectoral surveillance + additional duties up to 48% on non-EU)

Mechanism

Decree 10790 is the annual cross-sectoral import-policy instrument of the Republic of Türkiye — the architectural counterpart to (and legally distinct from) the sector-specific 2024-06-08-turkey-decree-8639-chinese-vehicle-tariff. Where Decree 8639 added a single 40%/50% additional layer on Chapter 8703 Chinese vehicles, Decree 10790 rebuilds the entire import-tariff schedule across 21 chapters and 4,344 product lines for the 2026 tariff year.

Stated authority: Customs Law No. 4458, Law No. 1567 on the Protection of the Value of Turkish Currency, Law No. 474 (customs tariff schedule), Law No. 3283 (WTO valuation), Law No. 2976 (additional financial obligations), and the Import Regime Decree framework (originally Cumhurbaşkanı Kararı No. 3350 of 31 December 2020). The decree was prepared in line with WTO commitments, the EU-Türkiye Customs Union (1995/1 Decision), free trade agreements, the EU's autonomous-regime preferences, and the Generalized System of Preferences.

Three protective levers, layered:

1. Ek Mali Yükümlülük (Additional Financial Obligation) / İlave Gümrük Vergisi (Additional Customs Duty) — 5%–48% on non-EU imports across 21 chapters, with the highest rates concentrated on iron and non-alloy steel articles, copper, aluminium, and base-metal household goods (saucepans, cookware, white-goods inputs). Reference-price floors apply: e.g., USD 3.5/kg on HS heading 7314 (steel woven cloth/grill/netting) — even if declared CIF is below that, the duty is calculated against the reference floor, neutralising under-invoicing. 2. Surveillance regime — 172 products newly subject to import-surveillance certificates (24 with updated unit prices, 23 entirely new lines) requiring pre-arrival approval. Surveillance is a Turkish-administrative-trade-remedy precursor that builds the evidence base for subsequent safeguard or anti-dumping action. 3. Tariff-quota allocations — duty-free imports up to volume caps for 35 industrial-product categories where domestic capacity does not meet industry demand, channelling priority inputs (lithium cells, technical textiles, organic chemicals) free of the tariff wall.

Severity 4 (mixed basis): cross-sectoral coverage (~USD 50bn+ in-scope import flow), structural EU-Customs-Union complementarity asymmetry vs non-EU partners, indefinite duration (annual instrument refreshed yearly), and quantitative scale (4,344 lines × 5%–48% rates) place this above narrow sector-specific tariff actions but below the highest-severity emergency-power instruments (US Section 232 globals, US reciprocal-tariff regime).

Downstream implications

• Steel-pipeline impact — Türkiye is a net steel exporter but a steel-

product net importer for downstream finished goods. The 5%–48% Ek Mali Yükümlülük on non-EU iron/steel/copper/aluminium tightens China-origin finished-product import compression already initiated by the EU's 2025-03-24 steel safeguard tightening (Reg 2025/612) — Türkiye is closing the EU customs union's southeastern flank.

• Capex pull into Türkiye — same mechanism as Decree 8639's Yatırım Teşvik

Belgesi carve-out, but at the annual-cross-sectoral level: non-EU OEMs facing 5%–48% additional duty have a pricing incentive to assemble in Türkiye for the EU/Türkiye market. Watch white-goods (Arçelik competitive shield), small kitchen-appliances, base-metal cookware, and downstream steel-finishing capex for relocation announcements through H2 2026.

• Surveillance precursor to safeguards — 172 surveillance products is a

large pipeline. Surveillance certificates create administrative-cost friction even before any duty rate changes; Türkiye historically converts ~20–30% of new surveillance lines to safeguard or anti-dumping action within 18–24 months.

• Current-account narrative — Ministry of Trade explicitly cites the

current-account deficit as rationale. Türkiye's CA deficit hit -USD 45bn in 2023 and improved to -USD 10bn in 2024 on tighter monetary policy. Decree 10790 is the structural-policy lever paired with the central bank's ongoing tight stance.

• Lira / inflation feedback loop — Ek Mali Yükümlülük on non-EU

intermediate inputs and consumer goods is a pass-through inflationary shock for the 2026 CPI print, partially offsetting the disinflation track the CBRT has been engineering. Watch April–June 2026 manufactured-goods CPI series.

Open questions

• How does the EU-Türkiye Joint Committee respond to the 5%–48% asymmetry on

base metals — does the EU treat the structure as Customs-Union-compatible given that non-EU origins are taxed and EU origins are not?

• Will Türkiye convert any of the 172 surveillance lines to formal safeguard

measures before mid-2026, and on what countries?

• What share of the 4,344 lines maps to China-origin trade flow specifically

vs. broader non-EU (Korea, Japan, India, Vietnam)? The decree is origin- neutral on its face but China is the modal counterparty across iron/steel/ copper/aluminium/household goods.

• Does the 31 March 2026 A.TR Pan-Euro-Mediterranean transitional carve-out

get extended, and on what terms — particularly for goods that originate outside the EU but are in free circulation?