A foreign laboratory test report has been rejected during a TAREKS inspection in Turkey. Learn how importers can challenge the rejection, submit technical evidence, request further review and protect goods from mounting storage costs.

A Turkish importer may submit a foreign laboratory test report showing that imported goods comply with applicable technical standards, only to discover that the report is not accepted during the TAREKS control process.

This can immediately delay customs clearance.

The goods may remain at the port or temporary storage facility while storage, demurrage, detention and other logistics costs continue to accumulate.

The critical question is:

Does rejection of a foreign test report automatically mean that the imported product is non-compliant?

Not necessarily.

The importer should first determine why the report was rejected. A problem with the laboratory, accreditation, applicable standard, model identification or scope of testing can be different from an actual finding that the product itself violates Turkish technical requirements.

1. Why Can a Foreign Test Report Be Rejected?

Possible reasons include:

• Laboratory accreditation problems;
• Report does not cover the imported model;
• Wrong technical standard;
• Outdated standard;
• Incomplete testing;
• Manufacturer discrepancy;
• Product-description inconsistency;
• Missing report pages;
• Unverifiable report;
• Test method does not satisfy the applicable requirement;
• Imported product differs from the tested sample.

The importer should obtain the precise reason rather than simply accepting the statement that the “foreign report is invalid.”

2. Obtain the Formal Reason for Rejection

Ask:

Which requirement does the report fail to satisfy?

The answer should identify the specific problem.

For example:

“Report rejected because Model X-200 is not covered”

is very different from:

“Product failed the applicable safety test.”

This distinction determines the next step.

3. Report Rejection Is Not Always Product Rejection

A test report is evidence concerning the product.

Therefore:

Report unacceptable

does not necessarily equal:

Product non-compliant.

The importer may still be able to establish conformity through other legally acceptable technical evidence or through the applicable inspection and testing procedure.

4. Verify the Laboratory

Immediately identify:

• Laboratory name;
• Country;
• Accreditation status;
• Accreditation scope;
• Testing facility;
• Report number;
• Report date.

Do not assume that the laboratory’s general accreditation automatically covers every test appearing in the report.

5. Check the Accreditation Scope

A laboratory may be accredited but the specific test method used for the imported product may fall outside its accredited scope.

This is a frequent technical issue.

The importer should therefore compare:

laboratory accreditation

with

specific standard and test method used.

6. Confirm the Applicable Turkish Technical Requirement

Before challenging the rejection, establish which technical regulation actually applies to the imported goods.

The analysis should begin with:

Product

→ HS classification

→ TAREKS control

→ applicable technical legislation

→ relevant standard or conformity requirement.

An appeal based on the wrong standard will not resolve the dispute.

7. Check Whether the Correct Standard Version Was Used

Technical standards can be amended or replaced.

The foreign laboratory may have tested according to:

Standard Version A

while the applicable import-control procedure requires:

Standard Version B.

The difference may be substantive or merely technical, but it must be examined.

8. Determine Whether the Report Covers the Exact Product

Compare:

Imported model

Tested model

Brand

Manufacturer

Technical specifications.

Even a small model-number difference can trigger questions.

9. Similar Model Numbers Need Technical Explanation

Suppose:

Imported product: RX-500B

Test report: RX-500.

The importer should obtain evidence explaining whether RX-500B is:

• A cosmetic variation;
• A commercial model designation;
• A technically identical variant;
• A materially different product.

The manufacturer should provide a model-comparison document where appropriate.

10. Do Not Alter the Test Report

Never change:

• Model number;
• Manufacturer;
• Test date;
• Laboratory information;
• Test result.

If the report contains an error, the issuing laboratory should make any legitimate correction according to its own procedures.

11. Contact the Foreign Manufacturer Immediately

Request:

• Complete test report;
• Accreditation documentation;
• Technical file;
• Product specifications;
• Model comparison;
• Relevant conformity documentation;
• Laboratory contact information.

Foreign manufacturers should treat a TAREKS rejection as urgent because delays can generate significant costs for the Turkish importer.

12. Contact the Foreign Laboratory Where Necessary

If authenticity or report scope is questioned, obtain confirmation directly from the issuing laboratory.

Useful confirmation may address:

• Report authenticity;
• Tested model;
• Test method;
• Standard;
• Laboratory accreditation;
• Model-family coverage.

This can sometimes resolve misunderstandings more efficiently than repeated submissions from the supplier.

13. Confirm Manufacturer Identity

A report may identify Manufacturer A while the commercial invoice identifies Company B.

This does not automatically invalidate the report.

Company B might be:

• Brand owner;
• Exporter;
• Distributor;
• Parent company.

But the relationship must be explained.

14. Factory and Brand Owner Can Differ

Where contract manufacturing is used, prepare evidence showing:

Brand owner

→ manufacturer

→ factory

→ tested product

→ imported product.

The documentation chain should be understandable to the inspecting authority.

15. Check Whether the Complete Report Was Submitted

Foreign manufacturers sometimes provide only:

• Cover page;
• Summary;
• Certificate;
• Selected test pages.

The authority may require the complete report.

Before challenging rejection, verify whether the complete technical evidence was actually submitted.

16. Test Reports and Certificates Are Not Always Interchangeable

A certificate referring to laboratory testing may not contain the same evidence as the underlying test report.

If the authority requests the actual test report, submitting only a certificate may be insufficient.

17. Translation Problems Should Be Addressed

A foreign-language report may use technical terminology that does not correspond directly with the terminology used in the Turkish regulatory procedure.

Where necessary, provide a reliable explanation or translation while preserving the original document unchanged.

18. What If TAREKS Requires Physical Inspection?

Even a valid foreign report may not necessarily prevent physical inspection where the applicable control procedure permits it.

The importer should cooperate with inspection while preserving its objections concerning unnecessary or incorrect rejection of existing technical evidence.

19. What If Samples Are Taken?

Record:

• Product;
• Model;
• Batch;
• Serial number;
• Sampling date;
• Sample quantity.

The importer must later be able to confirm that the tested sample came from the relevant shipment.

20. Turkish Laboratory Testing May Follow

If the foreign report is not accepted, the authorities may require testing under the applicable product-control procedure.

The importer should immediately prepare for comparison between:

foreign laboratory result

and

Turkish laboratory result.

21. Conflicting Laboratory Results Require Technical Analysis

Suppose:

Foreign laboratory: compliant.

Turkish laboratory: non-compliant.

Do not automatically assume one report is correct.

Compare:

• Sample identity;
• Standard;
• Standard version;
• Test method;
• Equipment;
• Measurement tolerance;
• Product condition.

A technical expert may be necessary.

22. Sample Identity Can Be Critical

The company should confirm whether both laboratories tested:

the same model

and ideally products from:

the same production batch.

Testing different product variants can explain conflicting results.

23. Product Damage During Transport May Matter

For certain products, transport or storage conditions can affect testing.

If relevant, document:

• Packaging condition;
• Moisture;
• Temperature;
• Physical damage;
• Storage conditions.

This is product-specific but should not be ignored.

24. Review Sampling Procedure

Where the adverse result depends on a sample, examine whether:

• Correct product was sampled;
• Sample was properly identified;
• Batch was recorded;
• Chain of custody can be established.

Sampling disputes can become central to a technical challenge.

25. Check Available Second-Test or Review Procedures

Depending on the applicable TAREKS control and product legislation, further technical review, second analysis or another procedural mechanism may be available.

These possibilities should be investigated immediately after an adverse result because procedural deadlines can apply.

26. Do Not Wait for Storage Costs to Become Excessive

While technical review continues, calculate daily:

storage

demurrage

detention

terminal charges

warehouse expenses.

The company should understand the financial cost of every additional day.

27. Request Commercial Cost Mitigation

Contact:

• Shipping line;
• Carrier;
• Terminal;
• Warehouse operator.

Seek available extensions, reductions or waivers.

Even if the importer ultimately succeeds legally, reducing the loss while the dispute continues is commercially important.

28. Keep a TAREKS Timeline

Prepare:

Date	Event	Status
Day 1	TAREKS application	Submitted
Day 3	Foreign report questioned	Review
Day 4	Additional evidence supplied	Submitted
Day 7	Physical inspection	Completed
Day 8	Sample taken	Laboratory
Day 15	Laboratory result	Disputed

This record can later become important in challenging delay or seeking damages.

29. Separate Importer Delay From Administrative Delay

If the importer took eight days to provide the full report, those eight days should be distinguished from any later period during which a complete file remained unresolved.

This distinction can be important in a compensation claim.

30. Can the Importer Submit Another Foreign Test Report?

Potentially, if permitted and genuinely relevant.

However, submitting multiple contradictory reports can weaken the file.

Any additional report should clearly concern the imported product and applicable technical requirement.

31. A New Report Should Not Rewrite Historical Facts

Do not commission a report designed merely to create documentation that falsely appears to predate the importation.

Any new testing should transparently state when and how it was performed.

32. What If the Foreign Report Is Genuine but Technically Insufficient?

Then the focus should shift from authenticity to substantive evidence.

The importer may need:

• Additional testing;
• Supplementary technical documents;
• Manufacturer evidence;
• An authorized review mechanism.

A genuine document is not necessarily a legally sufficient document.

33. What If TAREKS Ultimately Finds the Product Non-Compliant?

Obtain the formal technical and legal basis.

Determine:

• Which requirement failed;
• Which product was tested;
• Which standard was applied;
• Which test result caused failure;
• What legal consequence follows.

Only then should the challenge strategy be finalized.

34. Can an Adverse TAREKS Decision Be Challenged?

Potentially.

The appropriate administrative or judicial route depends on the type of decision, competent authority and applicable product legislation.

The formal notification date should be recorded immediately.

35. Technical Evidence Should Accompany the Legal Challenge

A strong challenge may combine:

legal argument

• technical expert opinion
• manufacturer evidence
• laboratory evidence.

A purely legal objection may be insufficient where the dispute turns on engineering or laboratory testing.

36. Urgent Judicial Protection May Need Consideration

Where goods are high-value, perishable, production-critical or accumulating substantial daily costs, available urgent remedies should be evaluated without unnecessary delay.

Whether urgent judicial relief is available depends on the particular administrative decision and procedural posture.

37. Can Storage Losses Be Claimed?

Potentially in appropriate circumstances, but reimbursement is not automatic.

A damages case may require evidence concerning:

• Unlawful administrative conduct;
• Actual financial loss;
• Causation;
• Importer’s conduct;
• Mitigation.

Preserve the evidence while the TAREKS procedure is still ongoing.

38. Supplier Liability Should Also Be Investigated

If the foreign manufacturer provided an unusable report, review whether it contractually promised:

• Turkish regulatory compliance;
• Valid testing;
• Correct technical documentation;
• Cooperation with authorities.

The importer may have contractual recovery rights.

39. Laboratory Liability May Raise Separate Issues

If a foreign laboratory issued an inaccurate or defective report, potential contractual or professional responsibility may also need examination.

This will depend on the laboratory relationship, governing law and contractual framework.

40. Review Identical Historical Imports

If Customs questions the report used for one shipment, determine whether the same report supported previous imports.

Do not automatically assume those imports were unlawful.

But identify the potential historical exposure before authorities expand the review.

41. Review Goods Already in Transit

If the same foreign report is being used for other shipments, immediately stop relying on it until its status is clarified.

Obtain corrected or additional compliance evidence before the next shipment reaches Turkey where possible.

42. Create a Product-Level Compliance File

For recurring imports maintain:

Product

→ Model

→ Manufacturer

→ HS classification

→ Applicable technical regulation

→ Standard

→ Laboratory

→ Accreditation

→ Test report.

This significantly reduces future TAREKS risk.

43. Foreign Manufacturers Should Verify Turkey Requirements Before Shipment

Testing accepted in one jurisdiction is not automatically sufficient for every Turkish import-control procedure.

Manufacturers selling regularly into Turkey should verify applicable documentation before shipment.

44. Do Not Treat TAREKS as Only a Customs Broker Issue

A foreign-test-report dispute can require coordination among:

• Importer;
• Customs broker;
• Manufacturer;
• Laboratory;
• Engineer;
• Legal counsel.

Technical and legal responses should be coordinated.

45. Immediate Action Plan

If a foreign test report is rejected during TAREKS inspection:

Obtain the exact reason for rejection

→ confirm the applicable product regulation

→ verify HS classification

→ check the laboratory’s accreditation and scope

→ confirm the correct standard and version

→ match the report to the exact imported model

→ contact the manufacturer and laboratory

→ submit reliable supplementary evidence where permitted

→ record any sampling

→ review Turkish laboratory testing

→ compare conflicting results technically

→ check available review or second-test mechanisms

→ monitor storage and demurrage

→ obtain the formal adverse decision

→ protect administrative and judicial remedies

→ review supplier liability.

25-Point Foreign Test Report Checklist

1. TAREKS application.
2. Imported product.
3. Model number.
4. Manufacturer.
5. Factory.
6. HS classification.
7. Applicable technical regulation.
8. Applicable standard.
9. Standard version.
10. Foreign laboratory.
11. Accreditation.
12. Accreditation scope.
13. Test report number.
14. Report date.
15. Tested model.
16. Imported model.
17. Model comparison.
18. Complete report.
19. Physical inspection.
20. Sample identity.
21. Turkish laboratory result.
22. Further review or testing.
23. Storage and demurrage.
24. Formal administrative decision.
25. Challenge and supplier-recovery strategy.

Frequently Asked Questions

1. Does rejection of a foreign test report mean the goods automatically fail TAREKS?

No. The report may be rejected for documentary, accreditation, scope or model-related reasons without necessarily establishing that the product itself is technically non-compliant.

2. Can an accredited foreign laboratory report still be rejected?

Potentially. The relevant question may include whether the laboratory’s accreditation scope covers the specific test and whether the report satisfies the applicable Turkish control requirements.

3. What if the model number on the report differs slightly?

The manufacturer should establish whether the tested and imported models are technically identical or covered by the same testing. Similar model names alone should not be relied upon.

4. Can the importer submit additional technical evidence?

Depending on the procedural stage and applicable rules, supplementary technical documentation may be possible. It should be submitted promptly and consistently.

5. What if Turkish and foreign laboratory results conflict?

The importer should compare sample identity, standards, test methods, technical thresholds and laboratory procedures and consider obtaining technical expert assistance.

6. Can another test be requested?

Further testing or review may be available under the applicable product-control procedure. The precise mechanism and deadlines should be checked immediately.

7. Can the importer challenge the TAREKS decision?

Potentially. Administrative and judicial remedies depend on the nature of the final decision, competent authority and applicable legislation.

8. Who pays storage costs while the dispute continues?

Commercially, charges may continue under the relevant carrier, terminal or warehouse arrangements. Whether losses can later be recovered from another party requires separate analysis.

9. Can the importer claim against the foreign manufacturer?

Potentially, particularly where the supplier promised compliant goods or valid technical documentation and the supplied report proves inadequate because of the supplier’s breach.

10. What should the importer do first?

Obtain the precise reason the foreign report was rejected. Before ordering expensive new tests or challenging the entire TAREKS procedure, determine whether the real problem is accreditation, model coverage, the applicable standard, missing documentation or actual product non-compliance.

Client-Focused Legal Support for TAREKS Test Report Disputes in Turkey

Foreign test report disputes can involve:

TAREKS inspections

Foreign laboratory reports

Laboratory accreditation

Technical standards

Model discrepancies

Sampling

Conflicting laboratory results

Product non-compliance findings

Storage and demurrage

and administrative challenges.

Fırat Fesih Kaya Law Office assists foreign manufacturers, international exporters and Turkish importers when foreign laboratory reports are rejected or questioned during TAREKS inspections in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance in reviewing the legal and technical basis of report rejection, coordinating manufacturer and laboratory evidence, analyzing conflicting test results, challenging adverse administrative decisions and evaluating claims arising from defective supplier documentation or prolonged import delays.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, Office No:148, 06520 Balgat, Çankaya, Ankara, Turkey