US-Turkey Trade and Tariff Developments 2026: What Businesses on Both Sides Need to Know

The United States and Turkey maintain a significant bilateral trade relationship, with Turkish exports to the US spanning textiles, automotive parts, machinery, chemicals, and agricultural products. In 2026, this relationship operates within a complex and evolving legal framework of tariffs, export controls, sanctions, and customs requirements. Both Turkish exporters and US companies importing Turkish goods must navigate this landscape carefully.

Turkey is a member of the World Trade Organization (WTO), and US imports of Turkish goods are generally subject to MFN tariff rates — the standard rates applied to all WTO members. MFN rates vary significantly by product category:

• Textiles and apparel: 10%–32% (among the highest MFN rates)
• Automotive parts: 2.5%–25% depending on classification
• Steel and aluminum: Subject to Section 232 tariffs (see below)
• Agricultural products: Variable; some face tariff-rate quotas
• Machinery and equipment: Generally 0%–5%
• Chemicals: Generally 0%–6.5%

The US has imposed Section 232 tariffs on steel (25%) and aluminum (10%) imports from most countries, including Turkey. These tariffs have significantly affected Turkish steel and aluminum exporters:

• Turkey is one of the world's largest steel producers and a significant exporter to the US
• Turkish steel producers have faced the full 25% Section 232 tariff
• Exclusion requests can be filed for specific products, but the process is competitive and outcomes are uncertain
• Turkish companies should monitor Section 232 developments, as tariff rates and country-specific arrangements can change

The US Generalized System of Preferences program, which provided duty-free treatment for certain Turkish exports, has had a complex history. Turkish companies should verify current GSP status for their specific products, as eligibility can change based on US trade policy decisions.

Several Turkish product categories are subject to US anti-dumping (AD) and countervailing duty (CVD) orders:

• Steel products: Multiple AD/CVD orders on various Turkish steel products
• Certain pipe and tube products: Subject to AD orders
• Other products: Turkish exporters should check the US International Trade Commission's AD/CVD database for current orders affecting their products

AD/CVD duties can be substantial — often 20%–100% or more — and are in addition to regular tariffs. Turkish exporters subject to AD/CVD orders must carefully manage their US pricing and cost structures.

The US Export Administration Regulations (EAR) control the export of dual-use goods, software, and technology. Turkish companies and individuals receiving US-origin technology must understand their obligations:

US-origin items are classified under ECCNs that determine export control requirements. Items classified as EAR99 (no specific ECCN) generally do not require a license for export to Turkey. Items with specific ECCNs may require licenses depending on:

• The item's technical characteristics
• The end use and end user in Turkey
• Turkey's status on various US control lists

The Bureau of Industry and Security (BIS) maintains an Entity List of parties subject to enhanced export control requirements. Turkish companies and individuals on the Entity List require a license for most US exports. US exporters must screen all Turkish customers against the Entity List and other denied party lists before each transaction.

Turkish companies that receive US-origin technology must comply with US re-export controls. Re-exporting US-origin items to third countries — including to Russia, Iran, or other sanctioned destinations — without appropriate authorization violates US law and can expose Turkish companies to significant penalties.

The Office of Foreign Assets Control (OFAC) administers US economic sanctions programs. Turkish companies with US operations or US-dollar transactions must maintain robust OFAC compliance programs:

Following Russia's invasion of Ukraine, the US imposed extensive sanctions on Russia. Turkish companies that maintain business relationships with Russia face significant compliance risks:

• Transactions involving sanctioned Russian entities are prohibited
• US-dollar transactions that benefit sanctioned parties can trigger OFAC liability even if the Turkish company is not itself sanctioned
• Secondary sanctions risk: Turkish companies that provide material support to sanctioned Russian entities may face US sanctions themselves

US sanctions on Iran are comprehensive. Turkish companies must ensure they do not facilitate transactions that benefit Iran or Iranian entities, including through third-country intermediaries.

Turkish companies with US operations must screen all counterparties against OFAC's Specially Designated Nationals (SDN) list before entering into transactions.

US Customs and Border Protection (CBP) requires accurate valuation of imported goods. Turkish exporters must ensure their invoices accurately reflect the transaction value of goods. Undervaluation — whether intentional or inadvertent — can result in penalties, additional duties, and exclusion from the US market.

Goods imported into the US must be marked with their country of origin ("Made in Turkey" or equivalent). Turkish exporters must ensure their products and packaging comply with US marking requirements.

For goods manufactured in Turkey using components from other countries, the country of origin is determined by whether a "substantial transformation" occurred in Turkey. This determination affects tariff classification, AD/CVD applicability, and government procurement eligibility.

US importers of Turkish goods must file an Importer Security Filing (ISF) with CBP at least 24 hours before goods are loaded at the Turkish port of export. Turkish exporters should coordinate with their US importers to ensure timely ISF filing.

The US and Turkey do not have a bilateral free trade agreement. Turkey's EU customs union membership means Turkish goods that incorporate significant EU content may face different treatment than purely Turkish-origin goods.

1. Tariff classification review: Ensure correct HTS classification for all US-bound products
2. AD/CVD check: Verify whether your products are subject to US AD/CVD orders
3. Export control screening: Classify your products under the EAR and screen US customers
4. OFAC screening: Screen all counterparties against OFAC's SDN list
5. Customs valuation documentation: Maintain accurate transaction value documentation
6. Origin documentation: Prepare certificates of origin and maintain supporting documentation

Our trade and customs attorneys advise Turkish exporters and US importers of Turkish goods on tariff classification, AD/CVD compliance, export controls, OFAC sanctions, and customs compliance. We help Turkish companies navigate the complex US trade regulatory environment and minimize compliance risk.

This article is for informational purposes only and does not constitute legal advice. Trade law is complex and subject to frequent change; please consult qualified counsel for current requirements specific to your products and transactions.