The importation of electric and externally chargeable hybrid vehicles in Türkiye has been subject to significant regulations throughout 2024 and has been updated through various communiqué amendments implemented by the Ministry of Trade of the Republic of Türkiye.
The relevant regulations aim to control the importation of these vehicles into Türkiye and enhance the local service infrastructure. In this article, we will examine the Communiqué on the Importation of Certain Electric Vehicles, which entered into force on January 1, 2024, as well as the amendments made on September 20, 2024, and December 31, 2024.
Repealed Communiqué Regulation:
The Communiqué on the Importation of Certain Electric Vehicles (the "Repealed Communiqué"), which entered into force on January 1, 2024, constituted the first legal regulation in Türkiye concerning the importation of electric vehicles. The Repealed Communiqué specified the customs tariff statistical positions ("GTIP") of imported electric vehicles and defined the relevant goods. Accordingly, it was stipulated that for vehicles originating from countries other than the European Union and countries with which a Free Trade Agreement has been concluded, a permit issued by the Ministry of Industry and Technology of the Republic of Türkiye or authorized institutions ("Permit") would be required for the registration of the customs declaration under the Inward Processing Regime.
Pursuant to the Repealed Communiqué, in order to qualify for an exemption from the Permit requirement, an A.TR Movement Certificate used for the exportation of industrial and processed agricultural products to European Community countries under the Free Trade Agreement between the European Community and Türkiye, or a certificate of origin under the relevant Free Trade Agreement, had to be submitted. An A.TR Movement Certificate is issued only when a good is entirely produced in Türkiye or the EU, or when the good, in whole or in part, originates from third countries but has completed the necessary importation procedures in Türkiye or the EU.
The Repealed Communiqué listed several cumulative conditions that importers were required to meet in order to obtain a Permit. These conditions included:
- Establishing an authorized service network and setting up at least 20 authorized service stations in compliance with specific Turkish Standards Institution ("TSE") standards,
- Ensuring that electric vehicle maintenance personnel possess a qualification certificate issued by TSE or the Vocational Qualification Authority,
- Establishing a Turkish-language call center with at least 40 personnel for each imported brand
- Ensuring that the manufacturer has an authorized representative in Türkiye,
- Submitting a written commitment regarding the monitoring and control of battery systems by the importer.
Amendment Communiqué Regulation:
On September 20, 2024, the Communiqué on the Amendment of the Communiqué on the Importation of Certain Electric Vehicles (the "Amendment Communiqué") introduced changes to the Repealed Communiqué, including renaming it as the Communiqué on the Importation of Certain Electric and Externally Chargeable Hybrid Vehicles. Additionally, the scope of regulated goods was expanded to include externally chargeable hybrid vehicles.
The Amendment Communiqué not only expanded the scope of goods covered by the Repealed Communiqué but also introduced additional conditions for obtaining a Permit. The TSE standards required for the authorized service network were modified, and the requirement for qualification certificates for electric vehicle maintenance and repair was extended to include personnel responsible for hybrid vehicle maintenance and repair. Furthermore, the Amendment Communiqué introduced a provision requiring customs administrations to request an exemption/non-coverage letter issued by TSE for the importation of electric or externally chargeable hybrid vehicles that are not subject to type approval.
Current Communiqué Regulation:
The current regulation in force, the Communiqué on the Importation of Certain Electric and Externally Chargeable Hybrid Vehicles (the "Current Communiqué"), published on December 31, 2024, expanded the definition of goods subject to the importation regulation compared to previous regulations.
Under the Current Communiqué, the definition of goods categorized under GTIP in the Repealed Communiqué was updated to refer to customs tariff positions ("GTP"). The scope of regulated goods was further clarified to redefine the framework for importation. Accordingly, the goods requiring a Permit under the Current Communiqué include:
- Tractors for semi-trailers,
- Wheeled agricultural and forestry tractors,
- Motor vehicles designed for the transport of ten or more persons,
- Passenger cars and other motor vehicles designed for the transport of people (excluding go-karts and search and rescue vehicles),
- Motor vehicles designed for the transport of goods,
- Special-purpose motor vehicles (such as cranes, fire trucks, and concrete mixers),
- Motorcycles, mopeds, and other wheeled vehicles with auxiliary motors,
- Trailers and semi-trailers.
Additionally, the Current Communiqué introduced variations in mandatory conditions for obtaining a Permit based on the classification of goods and vehicles, specifying that new TSE standards would apply to authorized service networks.
The Current Communiqué is set to enter into force on January 1, 2025, for passenger cars and motor vehicles designed for the transport of goods, whereas it will come into effect 60 days after its publication date for other specified goods.
These amendments impose new obligations on importers while aiming to establish a more regulated importation process that encourages the use of electric and hybrid vehicles in Türkiye. It is anticipated that the impact of these regulations on industry will become more evident in the coming years.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
