Turkey Steel Products: 2026 List, İGV and EMY

Which steel products are on the January 2026 list?

The January list concerns additional customs duty (İGV), a separate instrument from an additional financial obligation (EMY); steel can also carry EMY, because footnote (8) to the chapter 72 table of List II to the Import Regime Decision, as replaced by Decision No. 10790 from 1 January 2026, sets USD 200 per tonne for non-WTO countries, except Azerbaijan, on the lines marked with it. Decision No. 10791 replaces the annexes of Decision No. 3351. It was published in the Official Gazette on 31 December 2025, No. 33124, third repeated issue, and Article 2 sets entry into force at 1 January 2026.

The headings below group the listed lines in chapters 72 and 73; they do not cover every product within each heading. Check the exact GTİP, origin, country column and footnotes in the annex before using a rate.

Read the Official Gazette decision and complete annex or the Ministry of Trade notice and annex files. The summary describes the January list, not a tariff ruling for a later shipment.

The remaining sections explain how additional financial obligations are created, collected and challenged. For the January steel list, use the product groups above and the separate İGV explanation below.

The charge is imposed on the import of specified goods by a Presidential Decision issued under Law No. 2976 on the Regulation of Foreign Trade. Article 1 of that Law allows such obligations to be imposed on import, export and other foreign trade transactions outside taxes and similar obligations, so an EMY is not a tax, not a customs duty, and not a trade remedy, even though the customs administration collects it at the border alongside everything else. If your goods are caught, the charge is challenged in two steps: a written objection to the higher customs authority within fifteen days of notification under article 242 of Law No. 4458 (the Customs Law), and then an action before the tax court within the period set by article 7 of Law No. 2577.

For a corporate importer, the practical difficulty is not the concept but the moving target. There is no single consolidated EMY tariff. Each measure lives in its own Presidential Decision, published in the Official Gazette with its own list of twelve-digit tariff codes (GTİP), its own origin conditions and its own rate, and Decisions are added, amended and repealed on a rolling basis.

What is an additional financial obligation, and what is it not?

The starting point is the wording of article 1 of Law No. 2976: the imposition and removal of additional financial obligations “outside taxes and similar obligations”, the determination of the principles governing them, and the use of any funds created, are all carried out under that Law. The instrument was designed as a flexible trade-policy lever, deliberately placed outside the tax code so that it could be created and withdrawn by executive decision rather than by legislation.

That legal character explains three things importers often get wrong. First, an EMY is not a variant of ordinary customs duty and does not follow the tariff preferences that duty follows; a free-trade agreement that zeroes the duty on a line does not automatically neutralise an EMY, because the Decision itself defines which origins escape. Second, it is not a trade remedy: anti-dumping duties may be imposed under Law No. 3577 only where an investigation establishes that dumped or subsidised imports cause material injury to a domestic industry, threaten such injury, or physically retard its establishment (article 3), and the duty is then set at the dumping margin found in that investigation or at a lower rate sufficient to remove the injury (article 13). An EMY is created directly by Presidential Decision and applies to whole tariff lines, with no investigation stage at all. Third, it is a separate line item in the landed cost, sitting on top of the ordinary charges that arise when importing goods into Türkiye rather than inside them.

Türkiye also operates a distinct instrument called additional customs duty (ilave gümrük vergisi), which is amended through its own Presidential Decisions, the framework Decision on additional customs duty was last revised for 2026 by Decision No. 10791, published in the Official Gazette of 31 December 2025 No. 33124 (3rd repeated issue), in the same issue as the annual amendment to the Import Regime Decision (No. 10790). The two have different legal bases and different names on the declaration, and confusing them is a common source of error.

The Legal Basis: Law No. 2976 and the Presidential Decision

Law No. 2976 is unusually short, six articles in total, and the whole regime rests on three of them.

Article 2 confers the rule-making power: the President is authorised to make regulations on matters within the scope of the Law. Article 3 then tells you where to look for the operative content of any given measure: the type, the amount, the collection, the follow-up, the refund, the recording as budget revenue where required, the pooling in a fund and the principles governing that fund “are shown in the Presidential Decision”. The second paragraph of the same article adds that Law No. 6183 on the Procedure for the Collection of Public Receivables applies to the collection of additional financial obligations.

The consequence for an importer is straightforward and easy to underestimate: the Decision is the law of the measure. There is no general EMY code to consult. A dispute about scope, rate, base or origin is a dispute about the text of one Presidential Decision as it stood on the date the declaration was registered.

That also shapes the litigation strategy. Article 7 of Law No. 2577 provides that time runs from publication for regulatory acts that must be published, but it then continues: where such an act is applied, the persons concerned may bring proceedings against the regulatory act, against the act applying it, or against both together, and the fact that the regulatory act has not been annulled does not prevent annulment of the act based on it. In practice this means the Presidential Decision and the individual assessment can be attacked in the same proceedings.

How is the charge assessed and collected?

Article 15 of Law No. 4458 fixes the timing rule for customs duties: they are calculated according to the customs tariff in force on the date the customs obligation begins. Its second paragraph extends the logic to measures like this one, other measures laid down by special provisions on trade in goods are applied, where required, according to the tariff position of the goods. The tariff code and the registration date, not the contract date or the shipping date, therefore decide exposure, and where customs and the importer disagree on the code itself the problem becomes one of tariff classification and binding tariff information.

Collection is handled by customs. Decisions in this field routinely provide that the obligation is collected by the customs administrations separately from the customs duties and other financial obligations levied on import, and recorded as revenue to the general budget, and that the provisions of Law No. 4458 and other customs legislation on registration, accrual, collection, refund, follow-up and the taking of guarantees apply as to procedure and form to the additional financial obligation as well. That last qualification repays attention: the customs machinery is borrowed for procedure, not for substance, so a substantive relief available for customs duty does not transplant itself automatically.

Two further bridges matter. Article 3 of Law No. 4458 defines “import duties” as the customs duty payable on the importation of goods together with other charges having equivalent effect and financial burdens, which is why an EMY is treated as part of the import-duty package for the purposes of the customs penalty and recovery provisions. And where goods are entered under a suspensive arrangement, the inward processing regime, for instance, or brought into one of Türkiye’s free zones, the question is not whether an EMY exists for the line but whether a customs obligation arises at all on that movement.

A Worked Example: Decision No. 7480 and Its Repeal

The clearest way to see the architecture is through a measure whose full life cycle is now on the public record.

Decision No. 7480, “Decision on the Application of an Additional Financial Obligation on the Importation of Certain Products”, was published in the Official Gazette of 8 August 2023 No. 32273. Article 1 confined it to goods originating in countries other than the European Union and countries with which Türkiye has signed a free trade agreement. Article 2 provided that the obligation is collected by the customs administrations separately from the customs duties and other financial obligations levied on import and recorded as general budget revenue. Article 3 imported the procedural and formal customs rules described above. Article 4 brought the measure into force on the third day following publication.

Its annexed table is a compact illustration of how narrowly these measures are drawn:

Source: Presidential Decision No. 7480, Official Gazette of 8 August 2023 No. 32273. This measure was repealed with effect from 1 February 2026 by Presidential Decision No. 10804, Official Gazette of 31 December 2025 No. 33124 (5th repeated issue). The table is reproduced as a worked example of how a Decision is structured, not as a statement of charges in force.

The repeal is as instructive as the imposition. A measure that governed six tariff lines for roughly two and a half years ended on a date fixed in a single Decision published in a year-end repeated issue. An importer relying on a summary written in 2024 would have been wrong about the same goods in 2026, and an importer who paid the charge on a declaration registered after 1 February 2026 would have a recovery claim rather than a policy complaint. The volatility runs the other way too: the instrument has also served as a retaliatory lever, as with the measure on certain products originating in the United States, amended by Presidential Decision No. 21 in the Official Gazette of 15 August 2018 No. 30510.

The operating rule that follows is simple: verify the Decision, by tariff code and origin, against the registration date of the declaration in front of you. Nothing else is safe.

The January 2026 list and the distinction between İGV and EMY

Decision No. 10791 amends the annexes to the additional customs duty decision. Its Ek-1 table is headed “İlave Gümrük Vergisi (İGV) Oranı”. The product groups at the top of this page summarize the listed headings. The Gazette’s original Ek-1 steel lines appear on printed pages 657–666; the applicable entry is the complete tariff code, rather than the four-digit heading alone.

Footnote (12), on printed page 702, says that 15 per cent applies to non-WTO origins, except Azerbaijan. It is attached to the grinding-ball lines 7325.91.00.00.00 and 7326.11.00.00.00 in the İGV table; it is not an EMY provision. Footnotes (10) and (11) separately and expressly provide for per-tonne EMY on the lines marked with those notes. The two instruments must therefore be checked separately, rather than described as a single steel levy.

Provisional Article 1 preserves the pre-1 January rates or obligations for goods for which İGV and/or EMY was introduced or increased under this decision if the import declaration was registered by 31 January 2026 inclusive. This is a conditional transition, not an exemption for every January import. Provisional Article 2 separately addresses preferential-origin evidence for specified A.TR imports. For the exact coverage and later amendments, use the official decision and Ministry links above.

What penalty does underpayment carry?

Two separate exposures can arise from the same shortfall, and they come from different statutes.

Article 4 of Law No. 2976 provides that those who carry out import, export or other foreign trade transactions without meeting additional financial obligations collected by Presidential Decision are fined twice the deficient obligation. This is the sanction attached to the EMY regime itself.

Article 234 of Law No. 4458 then operates on the declaration, and its first paragraph is confined to goods entered for release for free circulation or for temporary importation with partial relief. Where examination or post-clearance control shows a discrepancy in the elements forming the Customs Tariff referred to in article 15, or in the measures such as number, head or weight on which taxation is based, and the difference between the import duties calculated on the declaration and those due exceeds 5%, a fine of three times that difference is imposed in addition to the duties. The same multiple applies where the declared value of goods subject to ad valorem import duties is found deficient against the value determined under articles 23 to 31. Where the quantity difference does not exceed 5% of the sales unit, or the understatement results from an arithmetical error, the fine is half the difference. Where the goods were instead entered under the inward processing regime, under processing under customs control, or under temporary importation with full relief, the second paragraph of article 234 sets the fine at half the duty difference for the same discrepancies, a materially different exposure that turns on the regime, not on the size of the error. Crucially, article 234 also provides that where the discrepancy is notified by the declarant before the customs administration detects it, those fines are applied at ten per cent of their amount, which is the single most valuable provision in the article for a company that finds a classification error in its own records. Where a customs broker lodged the declaration, how the shortfall is shared is covered in the customs broker’s joint liability and the importer’s position.

How is an additional financial obligation challenged?

The route is administrative first, judicial second, and the periods are short.

Three details decide more cases than the headline periods. First, article 242 provides that where the objection is filed with the wrong authority within time, it is deemed to have been made in time and the administration forwards it to the competent authority, a rare piece of procedural mercy in Turkish customs practice. Second, article 244 allows a conciliation request within fifteen days, and expressly provides that making the request suspends the objection and litigation periods; if conciliation is not reached, the period resumes where it left off, and if fewer than five days remain it is completed to five. But conciliation minutes are final: the taxpayer can neither sue nor complain about what has been agreed, and the mechanism does not apply where the act is connected with the smuggling offences in Law No. 5607. Third, article 197 provides that duties notified under that article become final if no objection is lodged within the article 242 periods or no timely application is made to the administrative courts.

Jurisdiction follows the nature of the charge. Under article 6 of Law No. 2576, tax courts resolve cases concerning taxes, duties and charges accruing to the general budget and similar financial obligations, together with their surcharges and penalties, which is where an EMY recorded as general budget revenue lands. Article 242 of Law No. 4458 fixes the venue as the administrative judicial authority at the place where the transaction was carried out, so the competent court follows the customs office, not the company’s registered address. Because the sequence is technical and the periods run from notification rather than from discovery, disputes of this kind are usually handled as part of a company’s wider customs law file rather than in isolation.

On collection, article 27 of Law No. 2577 provides that bringing proceedings does not of itself suspend execution, but that in tax courts the filing of a case arising from a tax dispute suspends collection of the disputed portion of the assessed taxes, duties, similar financial obligations and their surcharges and penalties. The provision then narrows itself: collection continues in files struck out under article 26/3, and cases brought against acts arising from returns filed with reservation, and against collection acts themselves, do not suspend collection, a stay of execution must be requested separately. Assuming the automatic stay applies is a frequent and expensive mistake.

Recovering a Charge That Was Never Due

Where an EMY has been paid on goods that fell outside the Decision, the wrong tariff code, an origin the Decision exempts, or a declaration registered after the measure was repealed, the recovery route is article 211 of Law No. 4458. Duties paid although not legally payable are refunded, and duties accrued although they should not have been accrued are remitted, on application to the customs administration within three years of notification; where a control or audit identifies a refund or remission situation, the administration is to act directly within the same period, and the period may be extended in cases of force majeure or unforeseeable circumstances.

The article does not stop there. It goes on to refuse refund and remission applications where the duties were paid or accrued as a result of a deliberate falsification by the person concerned, or as a result of the declarant increasing, in its own declaration, the customs value of goods subject to trade policy measures. A company correcting its own past declarations should read that limitation before framing the application, because how the correction is characterised can determine whether the door to recovery is open at all.

What to Do Before the Declaration Is Registered

Additional financial obligations reward preparation and punish assumption. The tariff code and the origin should be settled before goods ship, and the Decision in force should be checked against the intended registration date rather than the order date. Where a discrepancy is found internally, article 234 makes voluntary disclosure materially cheaper than detection. And where an assessment has already been notified, the fifteen-day clock in article 242 runs from that notification, not from the day the accounting department noticed the entry. Rates, tariff lines and covered origins change by Presidential Decision, often in the year-end repeated issues of the Official Gazette, so the figures above are given with their references precisely so that they can be re-checked against the Decision in force for any live shipment. Because article 3 of Law No. 4458 treats the charge as part of the import-duty package, an underpayment is followed by a customs administrative fine, and the choice between the fifteen-day objection and the settlement route is worked through in objecting to a customs administrative fine. A trade-defence duty is a different instrument answering to Law No. 3577 rather than to Law No. 2976, and it can attach to the same consignment where the goods are caught by an anti-circumvention investigation.