The Presidential Circular no. 2021/24 on the use of "Türkiye" as a brand for export products (“Circular”), was published in Official Gazette no. 31679 on 4 December 2021. In this Circular, the Turkish Government aims to represent the state and nation's long experience. The Circular regulated that the phrase "Made in Türkiye", instead of "Made in Turkey", will now begin to be used on export products.
In the Circular, the General Directorate of Product Safety and Inspection of Ministry of Trade (“Directorate”) declared that any package and label entitled "Made in Turkey" or "Produce of Turkey" is accepted until 1 March 2022; exporters will not suffer any immediate action. There is as yet no regulation on sanctions for not using "Made in Türkiye".
The officer of the Ministry of Trade unofficially declared that the date for acceptance of the labels entitled "Made in Turkey" or "Produce of Turkey" is extended to an undetermined date.
Additionally, in current practice, customs officers do not impose any sanctions on exports that do not comply with the Circular.
As an example to sanctions that would be applied to not complying with the Circular we may state that, agricultural product exporters located in Turkey can receive export refunds if they fulfil the conditions are regulated under "Circular on the Implementation Procedures and Principles of the Money-Credit and Coordination Board Decision No. 2018/12 on Export Refund Aid in Agricultural Products and the Operation over the Support Management System". One of the conditions is exported agricultural products must bear "Made in Turkey" or "Produce of Turkey" or same phrase in the language of the importing country. Likewise, upon the entry into force of Presidential Circular no. 2021/24, the lack of compliance with the Circular may prevent export refunds. However, as mentioned above, there is as yet no regulation about sanctions for not using "Made in Türkiye".
Considering the above, we recommend that preparations be made to change labels bearing “Made in Turkey” to "Made in Türkiye", so as to avoid possible sanctions when the time comes.
At the time of issue, there is no regulation prepared based on the Circular. We will monitor the matter closely and keep you informed of any updates concerning sanctions regulation.