Article to be published in Nasıl Bir Ekonomi newspaper on September 15, 2025

There is a very meaningful proverb: “Stick the needle in yourself before sticking the awl into others.” We must first learn to criticize ourselves before evaluating the shortcomings and mistakes of others.

In this context, by examining the historical development of the “Authorized Economic Operator (AEO) status” in the world and in our country, it would be a more accurate approach to look at what improvements have been made throughout the process and what is still needed today.

The importance and development of the AEO in global trade was shaped within the framework of the World Customs Organization (WCO) SAFE Framework of Standards to Secure and Facilitate Global Trade, adopted in 2005. This program is a customs–business partnership initiative aiming to ensure international supply chain security and facilitate legitimate trade. By granting customs simplifications to reliable economic operators, AEO status offers both time and cost savings.

The increasingly complex structure of global trade and rising security concerns have pushed countries to standardize customs procedures and reward reliable operators. Therefore, by comparatively analyzing the AEO application requirements in Turkey under the Regulation on the Facilitation of Customs Procedures with those in other countries, and by identifying in which country it is easier to apply for AEO status, we can make a start.

As part of the activities of our Association, which has gained “international” status, we have conducted many visits abroad. During these visits, we also had the opportunity to compare AEO requirements across different countries.

To list Turkey’s AEO application requirements in order:

AEO status in Turkey was established by the Regulation on the Facilitation of Customs Procedures, published in the Official Gazette dated May 21, 2014, and numbered 29006. The application requirements in Turkey are built around four main criteria.

Basic application conditions: The company must be established in the Turkish Customs Territory, including Free Zones, and must have been operating for at least three years. In terms of declarations, it must have lodged at least 100 customs declarations in the previous year or the year before.

The four main criteria in Turkey’s implementation are as follows:

• Reliability Requirement: The applicant must not have committed serious or repeated violations of customs legislation. Board members, real persons holding more than 10% of the company’s shares, and employees authorized to represent the company in customs and foreign trade matters must not have any convictions for serious criminal or financial offenses that threaten public safety.
• Reliable and Traceable Commercial Records: The applicant’s commercial and, if applicable, transport-related records must allow for proper and effective customs controls and show the movement of goods. Commercial documents must be properly archived and preserved. The applicant must also have appropriate IT security measures to protect its systems from unauthorized access and safeguard its data.
• Financial Solvency: The applicant must have the financial capacity to fulfill its obligations.
• Safety and Security Standards: The company must hold ISO 27001 (Information Security Management System) and ISO 9001 (Quality Management System) certifications.

The European Union’s AEO program, launched in 2007, is open to all actors in the supply chain. In the EU, AEO status is granted in three types: Customs Simplifications (AEOC), Security and Safety (AEOS), or a combination of both (AEOC/AEOS).

In addition to the requirements set by Turkey’s Regulation on the Facilitation of Customs Procedures, the EU AEO application requirements are as follows:

• Place of Establishment: Must be established in the EU customs territory.
• EORI Number: Must have an Economic Operator Registration and Identification number.
• International Supply Chain Participation: Must be part of the international supply chain and involved in customs-related activities.

The five main EU AEO criteria can be listed as:

• Compliance with EU customs and tax regulations: No serious or repeated offenses related to economic activities.
• Appropriate record-keeping: Having a system that enables proper and effective customs controls.
• Financial solvency: The ability to meet obligations.
• Practical standards or professional competence: Having sufficient skills to carry out the relevant customs procedures (for AEOC).
• Appropriate security and safety measures: Having sufficient safeguards to ensure supply chain security (for AEOS).

Applications in the EU are submitted to the competent authority of the member state where the applicant’s customs accounts are kept or accessible and where at least part of the AEO-related activities are carried out. An AEO status granted by one member state is recognized by all other EU member states.

Looking beyond Turkey and the EU: In the United States, the AEO program is managed by Customs and Border Protection (CBP). The U.S. program is more security-focused, with requirements including:

• Implementation of supply chain security procedures,
• Physical access controls,
• Personnel security measures,
• Training and awareness programs,
• Partner security measures,
• Use of security technologies.

Other country examples:

• South Korea: One of the early adopters of AEO programs. AEO-certified companies benefit from simplified customs procedures, partial inspection exemptions, and reduced logistics costs among countries with Mutual Recognition Agreements.
• Japan and China: Both countries have implemented AEO programs. Their requirements are largely similar to those of the EU, with minor differences based on national regulations.

When comparing Turkey, the EU, and other countries, the analysis shows that Turkey’s Authorized Economic Operator program shares significant similarities with the EU’s AEO program. Both programs are based on four main pillars: reliability, record-keeping, financial solvency, and security.

On Mutual Recognition Agreements, Turkey also aims to establish such agreements with the EU. On facilitations, both programs provide similar customs benefits such as “green lane,” “priority processing,” and “reduced inspections.”

Regarding differences, the U.S. program is observed to be more security-oriented, with customs simplifications taking a secondary role.

In summary, Turkey’s Authorized Economic Operator program is largely aligned with the EU’s AEO program. However, Turkey’s additional requirements—such as mandatory ISO certifications, minimum operational period, and declaration thresholds—make it more stringent. This creates barriers, particularly for SMEs wishing to participate.

From an application-ease perspective, the EU’s program offers more flexible conditions and appeals to a broader range of operators. Over time, it is essential for Turkey to simplify its program and implement measures encouraging SME participation.

In conclusion, considering the comparative analysis, it is clear that there is a need for revision in Turkey’s Regulation on the Facilitation of Customs Procedures. With full awareness of its responsibilities, the AEO Association declares its readiness for cooperation, and its commitment to supporting the Ministry of Trade through international research, academic studies, awareness activities, and report preparation.

Mehmet Altay YEGİN
Chairman of the Board
International Authorized Economic Operator (AEO) Association