Introduction: Why Turkey’s Scrap Import Policy Is a Wake-Up Call for ASEAN Exporters

The global trade in recycled metals is undergoing a profound shift. Environmental awareness, compliance mandates, and shifting regulatory frameworks are no longer peripheral concerns—they now drive real business decisions. Nowhere is this more evident than in Turkey, one of the world’s leading importers of ferrous and non-ferrous scrap metals.

For ASEAN exporters, this evolution offers both a strategic challenge and a compelling opportunity. Markets like Thailand, Indonesia, Vietnam, and Malaysia are key nodes in the global recycling supply chain, yet many of their exporters still lag in policy translation and operational alignment.

Turkey’s latest updates around import controls are not just about border checks—they represent a deeper alignment with EU directives, climate goals, and circular economy benchmarks. In this expanded guide, we lift the lid on the significant updates, explore how they influence logistics strategy, customs compliance, scrap grading precision, and port selection, and provide practical frameworks ASEAN exporters can use to thrive in this evolving trade environment.

Deep Dive: Understanding the Turkey Scrap Import Controls

One of the core entities in this conversation is Turkey’s Ministry of Environment and Urbanization (MoEU), which has become more assertive in enforcing its Environmental Law No. 2872 and Waste Management Regulation. Designed to ensure imported scrap complies with international environmental protection standards, these rules aren't just compliance hurdles—they define market access.

Entity-Based Optimization: Role of Regulatory Bodies

Turkey’s regulatory shifts aim to reduce the import of contaminated or low-quality scrap by:

• Mandating full material traceability under Basel Convention standards.

• Classifying and monitoring waste materials using the European Waste Catalogue (EWC) codes.

• Enforcing physical inspections at entry ports under the Customs Enforcement Directorate.

The 2023–2024 clampdown aligns closely with EU environmental compliance, making Turkey a bellwether market for exporters looking to future-proof their operations.

Statistical Note: According to data from the Turkish Steel Producers Association (TÇÜD), Turkey imported approximately 20.3 million metric tons of ferrous scrap in 2023, up 4.2% YoY. However, container rejection rates also rose by 11% primarily due to non-compliance issues.

This spike reflects a harsh reality: Any ASEAN exporter not aligning quickly risks lost revenue, delayed consignments, and damaged relationships.

Expanded: Practical Implication 1 – Making Compliance-Ready Shipment Paperwork Routine

In the world of international scrap trade, documentation is king. A missing field, inconsistent coding, or vague material description can prevent an entire shipment from clearing customs.

Optimized Phrase-Based Content: Scrap Compliance Documentation

ASEAN exporters must now treat documentation as a sales enabler—not an afterthought.

Enhanced Details on Certificate of Origin (CoO)

With Turkey’s regulations prioritizing proof of material origin, the CoO must offer:

• Digital time-stamps and facility registration numbers for traceability.

• Geo-tagging metadata (especially if the scrap is aggregated from multiple facilities).

• Supplier license verification numbers registered with local ASEAN environmental authorities.

Case Study: A Vietnam-based aluminum scrap supplier increased on-time delivery by 27% after switching to CoOs embedded with unique QR codes linking to a secure blockchain record of origin.

Advanced MSDS Practices

Beyond listing elemental analysis, MSDS documents now need to declare:

• Primary extraction methods (manual, mechanical, automated).

• Cleaning procedures used to remove oils, polymers, or residues.

• Toxicity leaching test results, particularly for electronic scrap and copper wire.

AI Tools for Documentation

AI-based document validators—like TradeLens and SEDAS—are being used by leading exporters to cross-verify shipment files against Turkish customs filters, flagging inconsistencies before they become rejections.

Insight: Companies who pre-submit digital files for 'green list' review experienced customs clearing times faster by 2.1 days on average, boosting cash flow and warehouse throughput.

Expanded: Practical Implication 2 – Meeting Grade Eligibility & Purity Expectations

If paperwork opens the door, grade and purity keep it from slamming shut.

Entity-Based Integration: Material Grades

Turkey now classifies imported recyclable materials using EU-based standards such as EN 13920 (for aluminum) and ISRI (Institute of Scrap Recycling Industries) code equivalencies for ferrous scrap.

Updated Limit Thresholds by Material (EAV Model)

• Copper (Millberry): Minimum 99.95% purity by ICP-OES testing; insulation tolerance: 0.01%.

• Aluminum (Taint/Tabor): Must be free of oil, paint, and magnesium content < 0.1%.

• Brass (Honey and Ocean): Tin and zinc levels must be disclosed with heatmapping or XRF breakdown.

• Ferrous (HMS 1 & 2): Must exclude motor blocks, unseparated galvanized steel, or sealed containers.

Phrase Optimization: Keywords like “metal purity certification,” “compliance with ISRI code,” and “contaminant-free grade classification” are essential for SEO-rich content.

ASEAN Source Upgrades

To meet these expectations, exporters are now:

• Using eddy current separators and x-ray sorting at material recovery facilities (MRFs).

• Collaborating with SGS, BV, and TÜV Rheinland for verification audits.

• Implementing Continuous Sampling Protocols (CSP) using AI-monitored conveyor systems.

Pro Tip: Bundled or baled scrap that hides contamination within can now result in multi-shipment bans from Turkish importers. Label your exports with clear grade specification sheets and inline QR-code stickers for random inspector scans.

Expanded: Practical Implication 3 – Strategic Port Routing and Freight Forwarder Standardization

Ports are no longer just gateways—they’re compliance chokepoints. The ability to route scrap shipments to ports with optimized inspection infrastructure can make or break your delivery cycle.

Optimization via Phrase & Predicate Precision

Sentence Structuring Example (Sentence-Based Optimization):
Instead of: "Some ports may be more efficient," use:
"İzmir and Mersin ports consistently outperform others in customs clearance efficiency due to advanced scanner integration, pre-clearance APIs, and experienced scrap-handling terminals."

Analytical Comparison: Key Turkish Scrap Ports

| Port | Scrap Handling Volume | Avg. Clearance Time | Recommended For |
||--||--|
| İzmir | High | 1–2 days | Ferrous scrap |
| Mersin | Moderate–High | 2–3 days | Mixed metals |
| İskenderun | Low–Moderate | 3–5 days | Bulk shipments |
| Ambarlı/Istanbul | Moderate | 2–3 days | E-scrap, OEM cargo |

Named Entity Optimization: These ports serve as both geographic and regulatory entities—incorporating their names enhances NER clarity in NLP indexing.

Optimized Freight Forwarding

Work only with freight partners who offer:

• Customs Brokerage Integration with MoEU systems.

• Real-time Document Tracking Dashboards.

• Pre-arrival Smart e-File Submission: Especially B/L and HS documentation before vessel docking.

Tip: Select forwarders with ISO 9001:2015-certified follow-through processes. Several partnerships in the ASEAN-Turkey corridor now use automated customs analytics to predict decision pathways on Turkish screens.

Expanded Industry Recommendation: ASEAN Export SOP Revitalization Framework (2024 Edition)

Global scrap leadership requires internal transformation.

What Leading Firms Are Doing Differently:

• Setting up Cloud-Based Export Hubs: Housing AI audit bots that pre-scan certificates.

• Creating Compliance Simulation Systems: Training logistics and export teams on mock Turkish document scenarios.

• Hiring Trade Policy Officers: Professionals dedicated to interpreting regional import laws and updating operations.

• Digital Scrap Chain-of-Custody Portals: Bringing visibility to both buyers and Turkish customs agents.

Statistically Backed Result: A survey conducted by the ASEAN Recyclers’ Network in Q4 2023 found that exporters who implemented advanced compliance SOPs achieved an average of 92% first-time customs clearances, up from 65% in 2020.

Forecasting the ASEAN–Turkey Scrap Trade Future

The near future will not loosen controls—it will increase accountability.

Global Trends Shaping Turkey’s Import Climate:

• EU Green Deal Compliance Extension: As Turkey integrates more energy-intensive industries, it aligns its import with Green Deal timelines.

• Digital Border Control Systems: Expected rollout of Turkey’s e-Customs 2.0 in 2025 for real-time scrap cargo data ingestion.

• Carbon Border Adjustment Mechanism (CBAM) adaptation: Turkey is considering scrap carbon scoring for imports by 2026 to align with EU border taxes.

Future-Proofing Advice for ASEAN Exporters:

• Shift investment toward ESG + compliance fusion systems.

• Tag emissions scores on each material type.

• Begin zero-waste certification pilots by 2025 to stay ahead.

Final Thoughts: Compliance Leadership Is Market Leadership

Winning in the Turkish scrap market—even with tightening policies—is entirely achievable for ASEAN exporters who go beyond minimum requirements.

By turning compliance into a core differentiator, companies don't just improve customs outcomes—they elevate brand trust in data-sensitive, ESG-conscious buyer networks.

This is not policy to fear. It’s policy to lead with.

Need Expert Guidance?
[Your Company Name] provides tailored consultancy for ASEAN businesses looking to expand into high-regulatory jurisdictions like Turkey. Get export audits, PSI setup, and compliant logistics coordination—fast.

➤ Book your free readiness consultation today.

Part 2 — Turkey Scrap Import Compliance Audit Scorecard (ASEAN Exporters)

Use this scorecard before every shipment (and once per quarter as a facility audit). It converts the policy guidance from Part 1 into a practical, weighted checklist with clear go/no-go gates, evidence to attach, and a 0–100 readiness score.

How to use (5 steps)

Create one row per shipment (or one sheet per month).

Complete every gate (A–I). Any “Fail” = No-Ship until fixed.

Score each criterion 0–5 (0 = missing/unacceptable, 3 = acceptable, 5 = best-practice).

Attach evidence named ShipmentID_Section_Item.pdf/png/csv.

Compute readiness % with the weights below and classify:

Green (85–100): Ready to ship

Amber (70–84): Ship with corrective actions noted and buyer’s OK

Red (<70 or any Gate = Fail): Do not ship

Weights & Gates (Overview)

• Section A: Identity & Traceability

  • Focus: Identity & Traceability

  • Weight: 12%

  • Gate? Yes

• Section B: Documentation Stack

  • Focus: Documentation Stack

  • Weight: 18%

  • Gate? Yes

• Section C: Grade & Purity

  • Focus: Grade & Purity

  • Weight: 18%

  • Gate? Yes

• Section D: Packing & Load Plan

  • Focus: Packing & Load Plan

  • Weight: 8%

  • Gate? Yes

• Section E: Port & Routing

  • Focus: Port & Routing

  • Weight: 8%

  • Gate? No

• Section F: PSI & In-Process QA

  • Focus: PSI & In-Process QA

  • Weight: 12%

  • Gate? Yes

• Section G: Digital Pre-Submission

  • Focus: Digital Pre-Submission

  • Weight: 10%

  • Gate? No

• Section H: ESG/CBAM Readiness

  • Focus: ESG/CBAM Readiness

  • Weight: 7%

  • Gate? No

• Section I: Org SOPs & Training

  • Focus: Org SOPs & Training

  • Weight: 7%

  • Gate? No

Readiness % formula (Sheets/Excel):

=ROUND(SUMPRODUCT({0.12,0.18,0.18,0.08,0.08,0.12,0.10,0.07,0.07},{A_Score,B_Score,C_Score,D_Score,E_Score,F_Score,G_Score,H_Score,I_Score})*20,0)
(Because each section is 0–5, multiply by 20 to scale to 100.)

Detailed scorecard (with gates, scoring rubrics & evidence)

A) Identity & Traceability (12%) — Gate

Score 0–5:
5: CoO includes facility registration, geo-tagged origin, QR link to immutable record; batch IDs tie to inward gate logs.

3: CoO complete; batch IDs present; limited metadata.

0–2: Gaps in origin chain; mismatched supplier IDs.

Evidence: CoO PDF + QR landing (hash/chain), supplier license, inward gate logs (CSV).
Gate (Fail if any): Missing CoO, mismatched supplier license, or unverifiable QR link.

B) Documentation Stack (18%) — Gate

Must include: Commercial invoice, Packing list, B/L draft, HS code, EWC code, ISRI grade code, MSDS (as applicable), photos list.
Score 0–5:
5: All docs consistent; AI validator report shows 0 critical flags; HS/EWC/ISRI cross-aligned; timestamps & digital signatures.

3: Complete and consistent with ≤2 minor flags.

0–2: Inconsistencies across HS/EWC/ISRI; missing signatures/pages.

Evidence: Full document set + validator report (PDF).
Gate (Fail if any): HS/EWC mismatch, unsigned critical doc, missing MSDS when required.

C) Grade & Purity (18%) — Gate

Score 0–5:
5: Lab/XRF reports meet declared ISRI/EN thresholds; impurity ≤ tolerance; bale/bundle openness prevents hidden contamination; random-scan QR labels on units.

3: Meets grade with marginal impurity; inspection notes corrective actions.

0–2: Off-grade, unreported contaminants, mixed grades in same lot.

Evidence: XRF/ICP-OES results, sampling plan, grade spec sheet, bale/loose photos.
Gate (Fail if any): Off-grade vs. declared, concealed contamination, sealed containers/components where prohibited.

D) Packing & Load Plan (8%) — Gate

Score 0–5:
5: Load plan enforces segregation; containerized average weight ≥25 MT where agreed; tamper-evident seals; photo log per container stage.

3: Minor variances; corrective notes recorded.

0–2: Mixed packing that risks cross-contamination; missing photo stages.

Evidence: Load plan, container weight tickets, photo set: pre-load → 25/50/75% → sealed.
Gate (Fail if any): No seal record, mixed incompatible materials, missing weight assurance where contractually required.

E) Port & Routing (8%)

Score 0–5:
5: Port selected aligns with cargo type and historical clearance efficiency; pre-arrival file sent; forwarder has MoEU integration.

3: Reasonable port choice; standard brokerage.

0–2: Congested/misaligned port; no pre-arrival process.

Evidence: Port selection rationale, forwarder capability sheet, pre-arrival confirmation.

F) PSI & In-Process QA (12%) — Gate

Score 0–5:
5: PSI scope tailored (impurities %, density where applicable, cans % for shred, leach tests if relevant); in-process QA with CSP sampling; NCRs tracked to closure.

3: PSI done; sampling basic; NCRs logged.

0–2: No PSI or weak scope; no corrective tracking.

Evidence: PSI report, QA checklist, NCR log with photos & timestamps.
Gate (Fail if any): PSI skipped where buyer/route requires; unresolved critical NCRs.

G) Digital Pre-Submission & Data Integrity (10%)

Score 0–5:
5: e-files pre-submitted; checksum/hashes for docs; API/portal receipts stored; version control prevents “doc drift.”

3: E-submission via email/portal; limited integrity checks.

0–2: Paper-only; mismatched versions sent to stakeholders.

Evidence: Pre-submission receipts, hash manifest, version history export.

H) ESG/CBAM Readiness (7%)

Score 0–5:
5: Shipment tagged with emissions factor method; zero-waste/process notes; buyer receives ESG appendix.

3: Basic ESG statement; emissions factor estimated.

0–2: No ESG/CBAM data.

Evidence: ESG/CBAM appendix, factor methodology, process photos/notes.

I) Org SOPs, Training & Reviews (7%)

Score 0–5:
5: Current SOPs reflect Turkey/EU alignment; staff trained ≤90 days; mock audits performed; last 10 shipments KPI dashboard (rejections, delays).

3: SOPs current; training ≤180 days; basic KPIs.

0–2: Outdated SOPs; no training logs/KPIs.

Evidence: SOP index, training log, mock-audit report, KPI dashboard export.

Red-Flag Triggers (immediate No-Ship)

HS/EWC/ISRI inconsistency (B Gate).

Off-grade vs declared or concealed contamination (C Gate).

Missing CoO or unverifiable origin trail (A Gate).

Skipped PSI where required or unresolved critical NCR (F Gate).

Sealed components/pressurized containers in ferrous where prohibited (C/D Gates).

Per-shipment row template (copy-paste headers)

Shipment_ID | Buyer | Material | ISRI_Code | EWC_Code | Port | Fwd_Agent | ETD | ETA | A_Gate | A_Score | B_Gate | B_Score | C_Gate | C_Score | D_Gate | D_Score | E_Score | F_Gate | F_Score | G_Score | H_Score | I_Score | Readiness_% | Status(Green/Amber/Red) | Owner | Due_Date | Evidence_Link_Folder | Notes
Status formula (example):
=IF(OR(A_Gate="Fail",B_Gate="Fail",C_Gate="Fail",D_Gate="Fail",F_Gate="Fail"),
"Red",
IF(Readiness_%>=85,"Green",IF(Readiness_%>=70,"Amber","Red"))
)

PSI scope snippets (drop into your inspection request)

Material: Shred (or HMS/Al/Cu as applicable)

Sampling: CSP with randomization; minimum N containers × K samples/container

Measures:

Shred: % cans in random sample; non-metallic impurity %; density (where applicable)

Ferrous: exclusion of engine blocks/sealed items; galvanized separation

Non-ferrous: elemental assay (XRF/ICP-OES); oil/paint/magnesium thresholds per spec

Deliverables: Time-stamped photos during loading, sealed-container photos, impurity worksheet, exception/NCR list with corrective verification

Port selection quick rules (use in Section E)

Ferrous high volume: Prefer terminals with experienced scrap lanes and scanner capacity; align cut-offs to avoid weekend congestion.

Mixed metals / e-scrap: Choose ports with specialized handlers and clearer SOPs for inspections.

Always: Confirm pre-arrival e-file window and brokerage API capability.

JSON schema (for automation in Make.com/Notion/Sheets)

{
"shipment_id": "TUR-2025-0001",
"buyer": "string",
"material": "string",
"isri_code": "string",
"ewc_code": "string",
"port": "string",
"forwarder": "string",
"etd": "YYYY-MM-DD",
"eta": "YYYY-MM-DD",
"sections": {
"A_identity": {"gate":"Pass|Fail","score":0},
"B_docs": {"gate":"Pass|Fail","score":0},
"C_grade": {"gate":"Pass|Fail","score":0},
"D_packing": {"gate":"Pass|Fail","score":0},
"E_port": {"score":0},
"F_psi": {"gate":"Pass|Fail","score":0},
"G_digital": {"score":0},
"H_esg": {"score":0},
"I_sops": {"score":0}
},
"readiness_pct": 0,
"status": "Green|Amber|Red",
"owner": "string",
"due_date": "YYYY-MM-DD",
"evidence_link": "url",
"notes": "string"
}

Weight map (for your automation):
{"A":0.12,"B":0.18,"C":0.18,"D":0.08,"E":0.08,"F":0.12,"G":0.10,"H":0.07,"I":0.07}

Quarterly facility audit (lite)

Traceability walk-through: Reconcile 10 random batches from inward gate to export docs.

Grade controls: Review calibration logs for XRF/scale; re-test 3 retained samples.

SOP drill: Run a mock Turkey clearance with a deliberately tricky HS/EWC pair.

KPI review: First-pass clearance %, days-to-clear, NCRs/container, photo-stage completeness.

One-page printable checklist (for the floor)

A Gate ✅/❌ CoO + QR origin verified

B Gate ✅/❌ HS/EWC/ISRI aligned; signatures present

C Gate ✅/❌ Lab/assay meets spec; impurity ≤ tolerance

D Gate ✅/❌ Segregation; weight assurance; seal photos complete

F Gate ✅/❌ PSI done; NCRs closed

Photo stages: Pre-load → 25% → 50% → 75% → Sealed ✅

Pre-arrival e-files sent ✅

Evidence folder linked ✅