CORPORATE COMPLIANCE OBLIGATIONS UNDER THE CUSTOMS TAREKS SYSTEM UNTIL END OF DECEMBER 2025

The Risk-Based Trade Control System (“TAREKS”) constitutes an electronic oversight mechanism designed to monitor the conformity of goods subject to import and export with applicable technical regulations, standards, and relevant legislation. Developed within a risk-based architecture, the system aims to ensure a faster, more reliable, and more efficient foreign trade environment.

Effective management of applications submitted through TAREKS is of particular importance, especially with respect to products subject to heightened quality and safety requirements, in order to prevent administrative delays or operational blockages in import procedures.

TAREKS operates as an electronic risk-analysis tool established to prevent the entry of non-compliant products into the domestic market.

The primary objectives of the system include:
•    Conducting risk-based electronic pre-screening in lieu of physical inspection of each product;
•    Directing inspection activities toward high-risk goods;
•    Reducing processing times and associated costs;
•    Ensuring consistent, expeditious, and accurate foreign trade supervision;
•    Preventing delays arising from discrepancies in declarations or supporting documentation.

This structure ensures that products with a high level of compliance are not subject to unnecessary procedural impediments.

Under the applicable legislation, a broad array of product groups fall within the scope of TAREKS supervision, including:

•    Consumer goods (e.g. watches, lighters, sunglasses);
•    Textiles, apparel, and footwear;
•    Personal protective equipment;
•    Toys;
•    Batteries and accumulators;
•    Telecommunications equipment (e.g., telephones, wireless devices, robotic appliances).

As of November 2025, applications must be submitted through the electronic platforms of the Ministry of Trade using a qualified electronic signature. 

In this respect:
•    The company must first be registered within the system;
•    At least one user must be duly authorized;
•    The authorized individual must access the system via the e-Government portal using an e-signature.

While customs brokers frequently act as system users, company personnel or corporate representatives may likewise be authorized. Multiple user authorizations may be granted simultaneously.

Upon submission, the system conducts a risk analysis, following which the product may either:
•    Receive direct approval, or
•    Be referred for physical inspection.

For approved applications, a 23-digit TAREKS reference number is generated, which must be entered in Box 44 of the customs declaration. The reference number remains valid for one year from the date of issuance, after which renewal of the undertaking is required.

Recent amendments introduced by the Ministry of Trade have fully digitalized the renewal procedure, thereby eliminating the requirement for notarized physical documentation.

Renewal applications are now processed:
•    Through an online platform integrated with the Central Registration System (MERSİS);
•    Exclusively by a company representative vested with unlimited signatory authority;
•    Via identity verification and electronic signing through the e-Government portal.

Accordingly, the applicant must possess either:
•    A Turkish Republic Identification Number, or
•    A Foreign Identification Number (“FIN”), an 11-digit identification number starting with 99, which is available solely to foreign nationals residing in Türkiye with a valid work permit. 

This requirement is of particular significance for foreign-capital Turkish companies, as a FIN is not automatically available for foreign board members or group representatives unless they hold a work permit.

Where the company’s sole or principal representative with unlimited signatory powers is a foreign national without a work permit (e.g., non-resident board members), the individual cannot legally authenticate into the TAREKS platform and therefore cannot complete the renewal process.

Consequently, companies must either:

•    Obtain a work permit (and residence permit) in Türkiye for the foreign board member with unlimited signatory powers, enabling issuance of a FIN and e-signature; or

•    Appoint a Turkish national as a board member/ manager vested with unlimited signatory powers, thereby enabling direct access to the system. In practice, such an appointment may be structured as temporary, limited to the duration of the renewal process. However, it must be noted that the appointed manager will remain liable before the customs authority until officially replaced.

Consequently, the TAREKS framework imposes significant procedural obligations with respect to identity verification and signatory authority for corporate representatives.

Accordingly, we strongly recommend that companies, particularly foreign-capital Turkish companies, consult their customs brokers and urgently verify, before the end of December, whether the company’s current authorized signatory can carry out transactions on the new TAREKS online system, in order to avoid any import issues as of January 2026.

Our Law Firm remains at your disposal for any further clarifications you may need.

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