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Our Board Member H. Cahit SOYSAL's article "What is a Non-Tariff Barrier, What is Not?" was published in the newspaper 'Nasıl bir Ekonomi' on 26.02.2024.

Our Board Member H. Cahit SOYSAL's article "What is a Non-Tariff Barrier, What is Not?" was published in the newspaper 'Nasıl bir Ekonomi' on 26.02.2024.

On February 19, an article titled "The cost of inspection in imports has reached the cost of the machine" was published in EKONOMİ Newspaper. In the news article titled "Stating that the range of CE permits required for machinery and equipment in imports has been expanded as of 2024 to include all machinery and equipment for the processing of plastics, rubber, and metal, sector representatives point out that the TSE permit process at customs has been prolonged for this reason", it was stated that the procedures that would be completed in a few days exceeded a month, which was reflected to the importer as warehouse and demurrage fees; these fees sometimes reached an amount close to the cost of the machine. The news article mentioned that if imports are made through TSE inspection, the fee paid starts at 25 thousand TL, which creates an extra cost.

When a person who is not a sector member says, "What's wrong with that? Should Türkiye be flooded with substandard goods without technical inspections?" we would all agree with them in the first instance.

To evaluate the issue objectively, it is first necessary to examine which products are subject to inspection under the "Product Safety and Inspection" communiqués published simultaneously with the Import Regime Decree. With your patience, I would like to list the names of these communiqués without repeating the "2024" in the communiqué sequence numbers, such as 2024/1 at the beginning of each communiqué and the words "Communiqué" at the end:

1- Inspection of Conformity to Standards in Imports
2- Import Inspection of Moving Machinery Used Except for Road
3- Import Control of Wastes Controlled for the Protection of the Environment
4- Import Control of Substances Subject to Special Authorization of the Ministry of Health
5- Import Inspection of Products Subject to the Control of the Ministry of Agriculture and Forestry
6- Import Control of Chemicals Controlled for the Protection of the Environment
7- Import Control of Solid Fuels Controlled for Environmental Protection
8- Import Control of Radio Equipment
9- Import Inspection of Certain Products Required to Carry CE Marking
10- Import Control of Toys
11- Import Control of Personal Protective Equipment
12- Import Inspection of Consumer Products
13- Communiqué on the Announcement of the New Values of Administrative Fines Regulated by the Product Safety and Technical Regulations Law No. 7223
14- Import Control of Building Materials
15- Import Control of Batteries and Accumulators
16- Import Control of Medical Devices
17- Import Control of Mother and Baby Products
18- Inspection of Certain Textile, Apparel and Leather Products
19- Import Control of Tobacco, Tobacco Products, Alcohol and Alcoholic Beverages
20- Import Inspection of Certain Products Inspected by the Ministry of Health
21- Commercial Quality Control in the Export and Import of Certain Agricultural Products
22- ...
23- Import Control of Metal Scrap Controlled for Environmental Protection
24- ...
25- Import Control of Vehicle Parts
26- Communiqué on the Basic Criteria for Conformity Assessment Bodies and Notified Body Notifications.

When looked at one by one, it seems that there is not a single communiqué that can say, "This is not necessary." Besides, when one sees the existence of so many control mechanisms, one feels safer among the arms of the state.

The first reference point is GATT (General Agreement on Tariffs and Trade) when approaching the issue from the official newspaper perspective. VIII of the Agreement to which Türkiye is also a party. In the article, "The Contracting Parties acknowledge that the fees and obligations that the Government or administrative authorities receive from imports or exports, other than customs duties, or collect in connection with imports or exports, must be limited to the approximate cost of the services performed and that any assistance provided to domestic goods or in imports or exports, They accept that it should not be considered a painting for financial purposes." It is said. In today's Turkish, it is meant to say "the service fees you will collect should be at a level that will not turn into an additional cost to support your domestic producer other than the customs tariff, and not higher."
In our age, all these barriers, which take the form of "quantitative restrictions," "financial barriers," and "administrative and technical barriers," are defined as "non-tariff barriers."
So, do the 24 "Communiqués on Product Safety and Inspection" in force in Türkiye fall within this scope? Communiqué No. 2024/13 has already been published, not for product safety, but for updating fines according to revaluation rates. This means that thousands of items are subject to inspection during the import phase within the scope of 23 product safety communiqués.

The internationally accepted non-compliance rate for product safety inspections on non-tariff barriers is 5%. In other words, if a total of up to 5% non-conformity is detected in the import inspections of a product for a year, these inspections should continue. Another indicator is whether import product safety inspections are carried out on domestic products in the domestic market.

As far as is known, the rate of significant nonconformities detected in import product safety inspections in Türkiye is around 3 per 10 thousand. The loss of time for these inspections and the costs of tests and examinations impose significant additional costs on producers and consumers. It is also a fact that these extra costs in machinery and goods imported as product inputs are also reflected in export costs.

On the other hand, the extent to which the product groups covered by the communiqués mentioned above are subject to product safety inspections during their production, distribution, and sale to consumers in Türkiye can be easily determined by every Turkish citizen in their daily lives. In essence, there is no doubt that the current practice serves the "policy of curtailing imports" by increasing import costs through product safety inspections on imports.