HOW SHOULD THE 2026-2028 MTP BE INTERPRETED FROM A FOREIGN TRADE PERSPECTIVE?

The Medium-Term Program (MTP) is the 3-year roadmap of the economy. Put into effect each year by Presidential Decree, the MTP is the main policy document that includes macro policies, principles, targets and key economic indicators, total revenue and expenditure estimates, budget balance and borrowing status, as well as the expenditure ceilings of public administrations, and it initiates the central government budget preparation process.

The aim of the MTP is to strengthen predictability for the public and private sectors by presenting the macroeconomic targets determined in light of global, regional, and national economic developments, together with the economic and social policies to be pursued.

The MTP covering the three-year period of 2025-2027 was published in the Official Gazette on September 5, 2024, while the MTP covering the 2026-2028 period was published on September 7, 2025. The program, which aims to strengthen macroeconomic and financial stability, maintain fiscal discipline, and reduce inflation to single digits in the medium term to ensure price stability, also emphasizes sustainable growth targets through increasing productivity, developing R&D and innovation capacity, accelerating technological transformation in the green and digital economy transition, strengthening human capital, making the labor market more effective, improving the business and investment environment, and reducing informality in the economy. We wanted to examine in what ways the 2026-2028 MTP, which highlights these goals, differs from the previous MTP in terms of customs and foreign trade.

In both MTPs, evaluations of the current period as well as policies and targets regarding foreign trade are included under the heading “balance of payments.” In addition, the annex no. 3 of the document, which constitutes the “table of regulations for priority reform areas,” organizes the content of the areas where regulations are planned. By examining the contents of these sections of the previous and subsequent MTPs, it is possible to identify the developments and targets in terms of foreign trade and customs.

In the 2025-2027 MTP, policies and measures were outlined under 7 headings from a macro perspective to improve the balance of payments, while in the 2026-2028 MTP, these were listed in a more specific manner under 6 sub-headings. These sub-headings are as follows:

Increasing product and market diversity in exports

Supporting the financing of exports

Accelerating green and digital transformation in exports

Strengthening trade diplomacy and strategic partnerships

Reducing import dependency and supporting supply security

Developing service exports

The sub-heading “Trade Facilitation,” which was included in the 2025-2027 MTP, was removed from the “balance of payments” section of the 2026-2028 MTP. However, the target text under this heading was transferred without any changes to the “Improving business and investment processes” sub-heading of the “Business and Investment Environment” section. This target states: “In order to facilitate business processes in foreign trade and export transactions, the processing capacity of customs administrations and border gates will be increased, and their physical and technological infrastructure will be renewed in line with needs, taking into account the possibility of domestic use.”

Considering the way the target is worded and the section it was transferred to, it appears that the purpose of facilitating customs procedures is seen merely as improving the physical and technological infrastructure of customs gates. The fact that this facilitation is envisaged only in terms of exports, while facilitation of imports is not foreseen, reflects the perspective of “reducing import dependency” generally emphasized in the MTP. However, we believe that reducing customs facilitation merely to physical and technological infrastructure raises questions about the validity of this perspective.

Leaving aside the way policies and measures are worded, in general, the targets of both MTPs are observed to overlap with each other.

When viewed from the perspective of harmonizing customs legislation with the Customs Union and EU customs legislation, it would not be wrong to say that we are regressing each year.

Article 54 of Decision No. 1/95 of the Association Council, which sets out the principles of the Customs Union established between Turkey and the European Union, stipulates that Turkish legislation in areas directly related to the functioning of the Customs Union should be harmonized as much as possible with Community legislation. In the second paragraph of this article, the areas directly related to the functioning of the Customs Union are listed as follows:

Community trade policy and preferential trade agreements with third countries,

Legislation on the removal of technical barriers to trade in industrial products,

Competition policy,

Legislation on intellectual and industrial property rights,

Customs legislation.

Therefore, harmonizing customs legislation with the EU Customs Code is an obligation imposed by Decision No. 1/95 of the Association Council. In accordance with this obligation, the current Customs Law No. 4458 was enacted in harmony with the EU Customs Code on February 5, 2000, and the amendments made to the EU Customs Code in 2009 and 2013 were incorporated into this Law. However, the EU Customs Code introduced a new Customs Code based on the requirement that all transactions be carried out electronically. Its implementation was postponed due to member states not being able to complete their technical infrastructure, but it started once the technical infrastructure was completed. The most important component of implementing the EU Customs Code, which contains significant differences in customs regimes, is the execution of all transactions in electronic form. Therefore, it is not sufficient to amend only the Customs Law for harmonization; it is also necessary to establish technical infrastructure compatible with EU information systems for the law to be implemented. Naturally, this will take time.

The work on the New Customs Law, which started in 2016 and was opened for consultation in 2019, was removed from the 2025-2027 MTP, and accordingly, it is not included in the 2026-2028 MTP either. Of course, although it is not included in the MTP, this regulation can still be enacted, or the matter may take shape according to the decision to be taken as a result of updating the Customs Union. However, it would not be wrong to conclude that a target included in the previous two MTPs but excluded from the subsequent one is no longer considered a target.

In addition, the target “The EU acquis harmonization program will be updated,” which was included in the 2025-2027 MTP, has this time been removed from the 2026-2028 MTP. Naturally, this removal is a concrete indicator that we are moving further away not only from harmonization of customs legislation but also from harmonization with the EU acquis in general.

The only target in the MTP regarding our relations with the EU in terms of customs and foreign trade is the following: “Studies will be carried out before EU institutions and member states regarding the updating of the Customs Union.” However, this target does not inspire any concrete expectations.

In conclusion, when we evaluate the last three MTPs together; on the one hand, the removal of harmonization with the EU acquis and customs legislation from the text, and on the other hand, the inclusion of the target of “reducing import dependency” in the texts, shows that protectionism has been substituted for the EU and global trade.

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