Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

Turkish President Erdoğan signed Presidential Decision No. 11068 on 16 March 2026, published in the Resmî Gazete on 17 March 2026, establishing a mandatory pre-clearance regime for the transit passage and re-export of controlled military items through Türkiye's customs territory. Covered items include military vehicles and defence equipment, weapons and ammunition and their spare parts, military explosives, and dual-use technologies associated with these categories, as defined under Law No. 5201. Any entity seeking to move such goods through Türkiye must obtain a "uygunluk yazısı" (compliance letter) from the Ministry of Trade, which reviews applications in consultation with relevant public institutions. The measure directly operationalises Türkiye's response to sustained US pressure over Iran-related sanctions evasion via Turkish transit corridors and entity-list additions naming Türkiye-based diversion networks.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 32 entities to the Entity List, with the largest bloc — 23 entries — under the destination of China, plus India (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (2). The rule also removed two addresses from one Russian entry (Intertech Rus LLC) and made 27 typographical corrections to existing entries. Several Chinese additions — including Shanghai Fudan Microelectronics, Sino IC Technology, GMC Semiconductor (Wuxi), and Chinese Academy of Sciences units (National Time Service Center; Aerospace Information Research Institute) — were given footnote 4 designations, extending the EAR's foreign-direct-product (FDP) reach to non-US-origin items destined for Russian military end use. Three Turkish entries (Atempo, EB Teknoloji, Dentun Elektronik) and one Indian entry (AR Sales Pvt Ltd) were footnote-3 Russian Procurement Entity designations. The rule is a final rule effective September 12, 2025; all listed parties are subject to a license requirement for all items subject to the EAR with a presumption-of-denial review policy.

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

On 2 May 2024 Türkiye's Ministry of Trade announced that all export, import and transit transactions with Israel, covering all product groups, were halted, as the second phase after the 9 April 2024 restriction on 54 product groups. Customs declarations naming Israel as country of shipment, destination or origin are no longer registered. The ministry stated the halt stays in force until Israel declares a ceasefire in Gaza and allows uninterrupted humanitarian aid access.

On 9 April 2024, Türkiye's Ministry of Trade restricted exports of 1,019 tariff lines across 54 product groups to Israel — including cement, marble, sulphur, aluminium wire, ceramics, varnishes and mineral fertilisers — in response to Israel's conduct of the Gaza war and its refusal of a Turkish request to participate in aid airdrops. The government stated the restriction would remain in force until Israel declared an immediate ceasefire and allowed unimpeded humanitarian aid into Gaza. The measure was superseded three weeks later, on 2 May 2024, when the Ministry halted all exports, imports and transit trade with Israel across every product category.

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).

The Bureau of Industry and Security (BIS) added 49 entities under 52 entries to the Entity List, effective October 11, 2023. The bulk of additions — 42 of 49 — are Chinese entities determined to be acting contrary to US national security or foreign policy interests, predominantly for supplying US-origin integrated circuits to Russian defense-sector consignees after March 1, 2023 in violation of export controls. Remaining entities span Estonia, Finland, Germany, India, Turkey, UAE, and the United Kingdom and were designated on similar Russia-diversion or end-use violation grounds. All listed parties face a license requirement for all EAR-subject items, reviewed under a presumption of denial.