International Trade & Customs
Customs, Sanctions, Export Controls & Trade Remedies
International trade practice has been substantially reshaped over the past decade by the return of trade as an instrument of geopolitical contest. Tariffs, sanctions, export controls and trade remedy proceedings now arrive at velocities that legal teams must absorb without slowing the underlying business. Mermeroglu Legal advises exporters, importers, manufacturers and trading houses on the full spectrum of cross-border trade regulation, with particular focus on Türkiye's position within the EU Customs Union and as a regional trade hub.
The Türkiye-EU Customs Union, in force since 1996, fundamentally shapes Turkish international trade practice — eliminating customs duties on industrial trade, aligning Türkiye with the EU Common Customs Tariff for third-country trade and requiring adoption of substantial elements of the EU acquis in trade-related areas. A single export shipment from Türkiye may simultaneously engage Turkish customs compliance, EU CBAM reporting, the importing country's customs procedures, and sanctions compliance under US OFAC, EU restrictive measures and UK frameworks. The contemporary trade lawyer must be fluent in all these frameworks in parallel.
Legal Framework
Four Practice Categories
Trade Compliance
The day-to-day work: customs classification, tariff calculation, origin determination, preferential trade agreement utilisation and the documentation required for international shipments. Under the Customs Union, Türkiye aligns with the EU Combined Nomenclature, the Common Customs Tariff for third-country goods and the substantial procedural framework of the Union Customs Code.
Regulatory Layer
Sanctions compliance, export licensing, dual-use control and end-user verification. The regulatory layer has expanded dramatically since 2022, with 14 successive EU sanctions packages against Russia, intensified US OFAC enforcement, record penalties and the expanding extraterritorial reach of US export controls — reshaping the operating framework for any business with international payment flows or US-origin technology.
Remedies Layer
Trade remedy proceedings — anti-dumping, countervailing duty, safeguard — customs dispute resolution and trade-related litigation. Türkiye is among the most active trade remedy users globally under Law No. 3577 and is simultaneously a frequent target of foreign trade remedy investigations, including substantial Indian DGTR proceedings against Turkish exporters in steel, chemicals and textiles.
Sustainability & Supply Chain
Increasingly significant in contemporary practice: CBAM compliance for Turkish exporters in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen; supply chain due diligence under CSDDD; conflict minerals compliance under the EU Regulation and OECD Guidance; and forced labour due diligence under the US UFLPA and the EU Forced Labour Regulation.
Service Areas
Customs Classification & Compliance
Advisory on customs tariff classification, customs valuation, origin determination and preferential origin (Türkiye-EU Customs Union, Turkish FTA network), import licensing and the documentation framework for cross-border shipments — including binding tariff information procedures and customs audit defence before Turkish customs authorities.
Sanctions Compliance & Advisory
Compliance advisory for Turkish and international businesses on EU restrictive measures, US OFAC sanctions (SDN, sectoral, secondary sanctions), UK OFSI sanctions and Turkish autonomous sanctions. Includes transaction screening, customer and counterparty due diligence, sanctions risk assessment, voluntary disclosure and defence in sanctions investigations.
Export Controls & Dual-Use
Advisory on export licensing under the EU Dual-Use Regulation (2021/821), US Export Administration Regulations (EAR) and ITAR, and Turkish dual-use export control framework — including commodity classification, licence determination, end-user certificate requirements and the framework for brokering and transit controls. Particular focus on semiconductor export controls and the expanding Chinese and Russian export control restrictions.
Anti-Dumping & Trade Remedy Defence
Defence of Turkish and international exporters in anti-dumping, countervailing duty and safeguard proceedings before EU, Indian, US and other national trade remedy authorities — including questionnaire responses, hearing representation, review proceedings and WTO dispute settlement engagement. Advisory on Turkish trade remedy initiation and proceedings before the Directorate General of Imports.
CBAM Compliance for Turkish Exporters
Legal and compliance advisory for Turkish exporters in CBAM-covered sectors — emissions monitoring at production facility level, third-party verification, data collection systems, engagement with EU importers on embedded emissions reporting, preparation for the certificate purchase phase from January 2026 and coordination with the Turkish ETS framework for Turkish installations.
Free Trade Agreement Utilisation
Advisory on preferential origin qualification and documentation under the Türkiye-EU Customs Union, the Turkish FTA network (30+ agreements including the UK, EFTA, UAE-CEPA 2023, Egypt, Morocco, South Korea and the Western Balkans) and rules of origin compliance — covering supplier declarations, movement certificates (EUR.1, ATR) and origin audit defence.
Trade Finance & Documentary Compliance
Advisory on the legal framework for trade finance instruments — letters of credit, documentary collections, bank guarantees and standby LCs — covering Incoterms 2020 allocation of risk and obligation, UCP 600 and ISBP 745 compliance, sanctions screening in trade finance and the legal framework for cross-border sales contracts and agency/distribution arrangements.
Supply Chain Due Diligence
Advisory on conflict minerals due diligence under the EU Conflict Minerals Regulation (2017/821) and OECD Due Diligence Guidance, forced labour due diligence under the US UFLPA and the EU Forced Labour Regulation, and supply chain transparency obligations under the CSDDD — with particular focus on Turkish exporters' supply chain exposure in affected sectors.
Customs Dispute Resolution
Advisory and representation in customs classification disputes, post-clearance audit proceedings, customs valuation challenges and origin disputes before Turkish customs authorities and administrative courts — including binding tariff information challenges, penalty defence and the recovery of overpaid customs duties through administrative review and litigation.
Trade Compliance Programme Design
Design and implementation of trade compliance programmes for Turkish and international businesses — covering sanctions screening systems, export control classification matrices, customs compliance procedures, internal audit frameworks and training. Includes Authorised Economic Operator (AEO) applications and the AEO mutual recognition arrangements Türkiye operates with the EU, Japan, South Korea and other partners.
Sector Intersections
Sectors in Which This Practice is Engaged
International trade and customs work cuts across sectors with substantial cross-border activity. The principal sector intersections include:
- Manufacturing & Industrial Products — customs classification, origin determination, anti-dumping defence and CBAM compliance for exports of in-scope goods.
- Defense & Aerospace — export licensing under Wassenaar, MTCR and national defense export regimes.
- Technology, Media & Telecommunications — dual-use export controls, semiconductor export controls and the EU AI Act extraterritorial application.
- Oil & Gas — sanctions exposure for petroleum trade, price cap compliance and end-user verification.
- Mining & Metals — conflict minerals due diligence, critical raw materials compliance and metals export licensing.
- Bullion & Money Exchange — gold sanctions, OECD due diligence for gold supply chains and DMCC responsible sourcing.
- Transport & Logistics — customs documentation, transit procedures and sanctions-compliant shipping.
- Construction & Infrastructure — sanctions compliance for international projects and dual-use construction equipment.
Jurisdictional Reach
Cross-Border Trade Advisory
International trade and customs frameworks vary substantially across jurisdictions in the design of customs procedure, the scope of export controls, the rigour of sanctions enforcement and the architecture of trade remedy systems. Mermeroglu Legal advises on trade matters engaging the regulatory frameworks of the following jurisdictions, among others:
Türkiye's unique position — as an EU Customs Union partner, the most active trade remedy user in its peer group, a target of major foreign trade remedy investigations, and a jurisdiction facing substantial CBAM compliance obligations — requires command of both Turkish trade law and the intersecting foreign frameworks that govern its principal trading relationships.
For detailed advice on jurisdictions not listed above — including emerging trade agreement regimes, country-specific export licensing procedures or jurisdiction-specific sanctions frameworks — please direct your enquiry through the firm's contact channels.
Standards & Instruments
International and Regional Instruments
International trade and customs work engages a dense framework of multilateral, regional and bilateral instruments. The most operationally significant include:
WTO Agreements (1994)
The WTO Agreements — including GATT 1994, the Anti-Dumping Agreement, the Subsidies and Countervailing Measures Agreement and the Safeguards Agreement — provide the multilateral framework for international trade. Türkiye has been a WTO Member since 1995. The WTO Appellate Body crisis (blocked since 2019) has substantially affected dispute settlement, with the MPIA providing an alternative for participating members.
Türkiye-EU Customs Union (1995) & FTA Network
Customs Union Decision No. 1/95 establishes the customs union for industrial goods, operationally fundamental to Turkish trade practice. Complemented by Türkiye's FTA network of 30+ agreements — including the UK, EFTA, UAE-CEPA (2023), Egypt, Morocco, South Korea, Malaysia and the Western Balkans — providing preferential market access for Turkish exports.
Wassenaar, MTCR, NSG & Australia Group
The principal multilateral export control regimes — addressing conventional arms and dual-use goods (Wassenaar, 42 states including Türkiye), missile technology (MTCR, Türkiye since 1997), nuclear-related goods (NSG, Türkiye since 2000) and chemical/biological materials (Australia Group, Türkiye since 2000). These regimes provide the agreed control lists forming the basis of national export licensing systems.
EU CBAM (Regulation 2023/956)
The EU Carbon Border Adjustment Mechanism entered transitional application in October 2023 and full operation from January 2026, imposing carbon pricing on imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Turkish exporters in affected sectors face substantial compliance obligations directly affecting commercial viability and pricing in the EU market.
EU & US Sanctions Regimes
EU restrictive measures under Article 215 TFEU and US sanctions under IEEPA and sanctions-specific statutes provide the principal extraterritorial sanctions frameworks affecting Turkish trade. The 14+ EU sanctions packages against Russia since 2022, record US OFAC penalties, and the expanding secondary sanctions targeting reshape the operating framework for businesses with international payment flows or US-origin technology.
Incoterms 2020 & UCP 600
The ICC Incoterms 2020 Rules provide the international standard for risk, cost and obligation allocation in cross-border sales contracts — widely incorporated into commercial documentation and affecting insurance, customs and liability analysis. UCP 600 and ISBP 745 govern documentary credits and are operationally significant for any transaction involving letter of credit payment mechanisms.
Our Approach
How Mermeroglu Legal Engages
International trade and customs mandates routinely engage the law of the exporting jurisdiction, the law of the importing jurisdiction, the law of any transit jurisdiction and the extraterritorial reach of sanctions, export control and supply chain regimes that may apply to the transaction. Our practice is structured to coordinate across those legal systems through a single point of accountability.
Each mandate is led by a single matter principal at the firm, supported by an internal team drawing on international trade, customs, sanctions compliance, sustainability and corporate practices. Where the matter requires advice on the law of jurisdictions outside Türkiye, we work through long-standing alliance arrangements with foreign counsel, including in Brussels (EU institutions), Washington DC (US sanctions and trade), London and the Gulf.
Our approach to international trade work places particular emphasis on the operational integration of compliance with commercial activity. Trade compliance is not a back-office function but a substantive determinant of commercial viability — the difference between a permitted and prohibited transaction is often a question of compliance design rather than commercial intent.
We treat sanctions and export controls as a continuing operational consideration rather than as a transactional clearance step. Operating clients face standing exposure to evolving sanctions designations, export control restrictions and supply chain due diligence requirements; we maintain continuing advisory relationships to support that operational reality.
INITIAL ENQUIRIES
Complex multi-jurisdictional sanctions matters and trade remedy proceedings are handled through coordinated internal and alliance teams.
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