The CE Marking in Turkey
1. My importer informed me that products being exported to Turkey require CE marking - is that true?
On April 2004, The Government of Turkey's Undersecretariat for Foreign Trade announced the implementation of twenty-three European Union industrial directives, which would affect an estimated 70% of the manufactured products imported into Turkey. The Undersecretariat for Foreign Trade has adopted the EU's Low Voltage Directive, the Simple Pressure Vessels Directive, the Gas Appliances Directive, the Hot Water Boilers Directive, the EMC, the Machinery Directive, the Civil Explosives Directive, the Weighing Instruments Directive, the Equipment and Protective Systems Intended in Explosive Atmospheres Directive, the Lifts Directive (elevators), the Household Refrigerator/Freezer Directive, the Pressure Equipment Directive, the Noise Emission Directive, the Energy Efficiency for Ballast for Fluorescent Lighting Directive, the Active Implantable Medical Device Directive, the Medical Device Directive, the In Vitro Diagnostics Device Directive, the Toy Directive, the Recreational Water Craft Directive, the Construction Equipment Directive, the Personal Protective Equipment Directive, the Radio and Telecommunications Terminal Equipment Directive and the Cableway Directive (ski lifts and gondolas). All products that are deemed to fall within the European Union (EU) directives would need to conform to the directives in order to be sold in Turkey.
2. My importer informed me that I need a Certificate of Conformity issued by a Notified Body/Laboratory, is this true?
Equipment meeting the directive definition of products needing to conform to EU technical regulations must have evidence of meeting the requirements either through verified laboratory testing conducted by an EU approved notified body or by manufacturer's self-declaration if the directive dictates. Companies selling to the Turkish market must submit evidence of conformity compliance (CE Marking) either by providing a notarized/consularized conformity certificate from a notified body or a corporate issued certificate of conformity, which declares compliance of all relevant standards and directive annexes. If the EU directives allow for company or self-declaration of conformity, then this would need to be accepted by the Republic of Turkey as well. For companies having difficulty in having its corporate declaration approved by the Government of Turkey, please contact Commercial Assistant Ms. Ozge Cirika at Ozge.Cirika@mail.doc.gov.
3. I supplied a corporate certificate of conformity with my shipping documents, why are my goods still detained at Turkish Customs?
As Turkey has adopted the European Union New Approach Directives, it is still undergoing a learning process as to what are the Directives and what is CE marking. Exporters and importers are often asked for Certificates of Conformity prepared by EU recognized Notified Bodies. If a customs detainment takes place for companies that are allowed to self certify conformity based on the EU directives (i.e. low voltage, electromagnetic compatibility, portions of the machinery directive etc.), you would only need to contact Ms. Ozge Cirika at Ozge.Cirika@mail.doc.gov, and the Undersecretariat for Foreign Trade will be notified and a request to have the shipment released would be made.
4. Why does the Turkish Customs Authority not accept my Notified Body issued Certificate(s) of Conformity?
Companies selling to the Turkish market must submit evidence of conformity compliance (CE Marking) either by providing a notarized/consularized conformity certificate from a notified body or a corporate issued certificate of conformity, which declares compliance of all relevant standards and directive annexes. Turkish Customs may on occasion question if the certificates are original. In such cases, the company may wish to have the Notified Body Certificate of Conformity or the corporate issued Certificate of Conformity notarized/consularized to confirm document authenticity. For U.S. companies having difficulty in having documents recognized for authenticity, the Commercial Attaché can assist in having a consular stamp affixed to your Certificate of Conformity that would be accepted by the Turkish Customs service.
5. I have been selling to the European Union without CE marking, why am I required to have CE marking for Turkey?
As Turkey implemented the New Approach (CE marking) directives, it is still undergoing a learning process. Given that there is a full range of products not falling under the CE marking regulations, not all products are required to be CE marked or need to conform to EU standards. If companies find that the Government of Turkey asks for CE marking when none is required, please contact Ms. Cirika at Ozge.Cirika@mail.doc.gov immediately. The Commercial Section will request that the Undersecretariat for Foreign Trade inform both Turkish Customs and the appropriate ministries to have the shipment released.
6. My importer informs me that my CE marked product would need to be inspected by the Turkish Standards Institute-is this true?
When Turkey adopted the European New Approach Directive, products that are deemed to conform to the directives would not need to be inspected by the Turkish Standards Institute. As is the case in the EU, if Customs officers or the Government of Turkey believe that a product bearing CE marking may not be in conformity with the EU regulations, Turkish testing could be authorized. For U.S. companies being asked to have its products undergo additional Turkish Standards Institute testing despite evidence of directives conformity, please contact the Commercial Service in Ankara immediately.
7. Despite my CE marking why does my importer ask for an A.TR-1 Certificate? What is the A.TR-1-Certificate?
In the early stages of EU directives implementation, the Government of Turkey exhibited a bias towards CE marked products originating in Europe. The Government was suspicious of certificates of conformity originating outside of the European Union. The A.TR-1 Certificate is a document that establishes that goods are freely allowed to be sold to Turkey within the scope of Turkey's Customs Union with the European Union. Initially, companies were able to clear Turkish Customs easily by providing the Certificate of Conformity and the A.TR-1. Companies asked to ship via the European Union or are asked to acquire an A.TR-1 Certificate should contact the U.S. Embassy's Commercial Section for resolution of this matter. Any U.S. company providing evidence of directives conformity should be allowed access to the Turkish market without having to transship via the European continent.
8. Do Turkish manufacturers need to confirm conformity of the EU New Approach (CE) Directives?
In April 2004, the Government of Turkey announced the adoption of the CE marking for imported products only. The Government of Turkey (Ministry of Industry, the Ministry of Labor and Social Security and the Ministry of Health) will need to promulgate regulations and legislation to have local companies also produce in compliance to the CE marking. At this time, the European Commission has not approved a Notified Body in Turkey. Therefore, Turkish companies requiring Notified Body conformity assessments must have products tested outside of Republic of Turkey.
9. Who can I call on if I have a standards problem in Turkey?
The United States Embassy's Commercial Section has been assisting U.S. companies, which meet EU directives conformity, in having products clear Turkish Customs as expeditiously as possible. The Commercial Section is also working to have the Government of Turkey accept CE conformity certification from U.S. corporations or Notified Bodies, without having U.S. companies face additional bureaucratic delays at customs and additional testing at the Turkish Standards Institute. For additional assistance in navigating the CE Marking regulations in Turkey, please contact our Commercial Assistant at Ozge.Cirika@mail.doc.gov.
10. Where can I find information on the CE Marking on the Internet?
For additional information on the European Union Directives and European standards, please check the websites listed below:
http://ts.nist.gov/Standards/Conformity/export-eu.cfm
http://europa.eu.int/comm/enterprise/index_en.htm