The questions, with answers
Does the customs union mean I pay no duty? customs union, not an FTA
It works differently from a free trade agreement, and the difference matters. The EU–Turkey customs union has existed since 1995 and lets industrial goods in free circulation move without customs duty — evidenced by an A.TR movement certificate, not by a statement on origin. Agricultural goods and coal and steel sit outside it and follow the ordinary rules.
Whether a preference actually applies is decided per product by the origin rule in the agreement, not by where the goods were shipped from. Rules of origin works that through, and the goods code decides which rule you are under. A claim without valid proof is recovered from the importer, three years back, with interest.
Source: EU–Turkey customs union (Decision 1/95), in place since 1995. Checked: 4 September 2026.
Does the Türkiye–EU customs union exempt me from GPSR?
No — this is the most expensive misconception in Turkish export. The customs union removes customs duties on goods in free circulation; it does not touch product-safety law. GPSR, CE marking, REACH and the Responsible Person apply to Turkish products exactly as to products from China or the US. The border is free; the rules are not.
Source: Decision No 1/95 of the EC–Türkiye Association Council (customs union); Regulation (EU) 2023/988. Checked: 4 September 2026.
Do I need an EU Responsible Person if I have a Turkish subsidiary in Germany?
Only if that subsidiary is the economic operator that places the products on the EU market. If your German company imports and sells, it is the Responsible Person for those goods — no separate appointment needed. If the Turkish parent sells direct, the Responsible Person must be appointed separately.
Source: Regulation (EU) 2023/988, Article 16. Checked: 4 September 2026.
My factory has CE marking. Is GPSR automatic?
No. CE and GPSR are separate frameworks: CE proves conformity with technical directives; GPSR is the general safety net. Many Turkish manufacturers already carry CE for machinery, toys or electronics — that changes nothing about the GPSR Responsible Person and labelling duties on top.
Source: Regulation (EU) 2023/988; the CE directives. Checked: 4 September 2026.
I export textiles or clothing. What applies?
GPSR for the consumer product, the EU textile labelling regulation (fibre composition), and REACH for restricted substances in the fabric — azo dyes, formaldehyde, certain softeners. France adds textile-EPR on top of packaging-EPR. The product is simple; the layers on top are not.
Source: Regulation (EU) 1007/2011 (textile labelling); Regulation (EC) 1907/2006 (REACH); Regulation (EU) 2023/988 (GPSR). Checked: 4 September 2026.
Who can do this for me?
Source: Editorial list, checked 4 September 2026.
Next steps
Appoint a Responsible Person before your listings are suspended, not after — restoring a suspended listing takes longer than setting one up. The full guide covers GPSR, REACH, EPR and CBAM, each with regulation, article and the date it was last verified.
Selling into several EU countries at once? Labelling and warnings must be right per country — that is in the labelling answer.