Importing from Turkey to the EU: duty, VAT, A.TR No customs duty, but VAT is still due.

What the customs union covers

Decision No 1/95 of the EC–Turkey Association Council of 22 December 1995 sets the rules for the final phase of the customs union. Its chapter on the free movement of goods applies to products other than agricultural products (Art. 2). Between the EU and Türkiye it abolishes import and export customs duties and charges having equivalent effect (Art. 4) and prohibits quantitative restrictions on imports (Art. 5).

The chapter covers two kinds of goods (Art. 3/1): goods produced in the EU or in Türkiye, including those made from third-country inputs in free circulation, and third-country goods in free circulation in either part. A third-country product is in free circulation in Türkiye once the import formalities have been completed there and the customs duties payable have been levied without total or partial refund (Art. 3/2).

Documents the EU importer needs

The import declaration is lodged in the member state of import by the importer or by a customs representative; the declarant is the debtor of any customs debt (Union Customs Code Art. 77/3). The file on the EU side rests on these documents:

• Commercial invoice: the price actually paid or payable is the primary basis of the customs value (UCC Art. 70), and import VAT is calculated from that value (VAT Directive Art. 85).
• A.TR movement certificate for customs union goods: issued at the exporter's request and endorsed by the customs authorities of the exporting State (Decision No 1/2006 Art. 5 and 7). It is made out in an official EU language, or in Turkish and an official EU language (Art. 9). The importing customs may ask for a translation and for a statement from the importer that the goods meet the conditions for free circulation (Art. 10).
• Proof of preferential origin (EUR.1 or an origin declaration) for agricultural products and coal and steel products. Which one, and when, is on the A.TR or EUR.1 page.
• Transport document: CMR consignment note, bill of lading or air waybill. If the goods pass through a third country, the A.TR can still be used only if they stay under customs surveillance there; a single transport document covering the passage is the first evidence the Decision lists (Art. 6/2–3).
• EORI number of the importer: mandatory for customs operations in the EU (UCC Art. 9). According to the Commission, operators not established in the EU need one too if they lodge customs or entry summary declarations or act as a carrier.
• Product requirements: technical, health and plant-health rules are separate from duty. Access2Markets lists them by product code in My Trade Assistant.

On the Turkish side the export declaration, the transport document and the A.TR are prepared together; the export documents page lists who issues each. On our road freight shipments, our own customs broker prepares the export declaration and movement certificates such as the A.TR and EUR.1; import clearance in the EU stays with the buyer's customs representative.

What the EU buyer still pays

Import VAT is not a customs union matter. The VAT Directive treats as an importation the entry into the Union of goods that are not in free circulation within the meaning of the EU Treaty (Art. 30), and VAT becomes chargeable when the goods are imported (Art. 70). The rate is the one the member state applies to the supply of like goods on its territory (Art. 94/2).

The taxable amount starts from the customs value (Art. 85). To it are added the taxes, duties and charges due by reason of importation, other than the VAT itself, and incidental expenses such as commission, packing, transport and insurance up to the first place of destination in the member state of import (Art. 86). The customs value already includes transport and insurance up to the place where the goods enter the EU (UCC Art. 71/1-e).

Who pays is decided by the member state of import (Art. 201). Member states may let businesses enter import VAT in their VAT return instead of paying it at import (Art. 211); whether that is possible depends on the country. Under DDP the seller takes on import formalities and duties; the Incoterms® 2020 page explains why that is hard for a seller not established in the country of import.

Anti-dumping and trade defence

The customs union does not switch off trade defence. By derogation from free movement, a party that has taken anti-dumping or other trade policy measures, in its relations with the other party or with third countries, may apply them to imports of the products concerned from the other party (Decision No 1/95 Art. 46). For products covered by such measures, the importing customs authority asks the importer to state the origin on the customs declaration, and may ask for further evidence where there are serious and well-founded doubts (Art. 47).

This applies both to goods of Turkish origin and to third-country goods in free circulation in Türkiye. A product of Chinese origin can travel on an A.TR without customs duty, but an EU anti-dumping duty on Chinese origin still applies. Measures are listed by product code and origin in TARIC.

CBAM

The CBAM definitive regime applies from 1 January 2026 to cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. EU importers, or their indirect customs representatives, who import more than 50 tonnes of CBAM goods (the threshold does not cover electricity and hydrogen, Regulation (EU) 2025/2083, Art. 2a) need authorised CBAM declarant status; each year they declare the emissions embedded in their imports and surrender the corresponding certificates. Some iron and steel products are affected twice: they are outside the customs union as coal and steel products, and they are CBAM goods. The exporter's side is on CBAM for Turkish exporters.

Entry summary declaration (ICS2)

Goods brought into the customs territory of the Union must be covered by an entry summary declaration (ENS), lodged at the customs office of first entry before the goods arrive. The carrier lodges it; the importer or consignee may lodge it instead (UCC Art. 127). Since 1 September 2025 the ICS2 system has run in all member states for all modes of transport, road and rail included; the temporary road and rail derogations that some member states had ended on 1 June 2026. From 1 June 2026 every consignment entering the EU should have a valid ENS, filed directly in ICS2 or, in the countries that opted in, with the transit declaration in NCTS Phase 6.

By road, the Turkish Ministry of Trade says the ENS must be lodged electronically at least one hour before the goods reach the point of entry, and a truck that leaves the EU and enters it again needs a new ENS for each entry. The Commission warns that goods may be stopped at the EU border if the ICS2 requirements are not met, and that in certain cases the final consignee established in the EU must also submit ENS data. Transit through third countries under a T1 is covered on the T1 transit and NCTS page; the Greece lane is on Türkiye–Greece road freight.

When it goes wrong

The A.TR reaches customs after four months

An A.TR must be submitted to the customs authorities of the importing State within four months of its date of issue (Decision No 1/2006 Art. 8/1). A late certificate may be accepted if the delay is due to exceptional circumstances, or if the goods were presented before the deadline (Art. 8/2–3). On 17 September 2026 the Commission proposed a ten-month period (COM(2026) 477, draft Art. 8/1); until it is adopted, four months applies.

No A.TR was issued at export

It can be issued retrospectively if it was not issued at export because of errors, involuntary omissions or special circumstances, or if it was issued but not accepted at import for technical reasons (Art. 15/1). The exporter applies stating the place and date of export and the reason (Art. 15/2).

Steel or an agricultural product travels on an A.TR

These goods are outside the customs union, so the A.TR does not give them duty relief. The preference depends on proof of preferential origin under the separate agreement.

The goods pass through a third country without evidence

The A.TR works only for goods carried directly between the two parts of the customs union, or through a third country under customs surveillance. Without a single transport document, a certificate from that country's customs or other substantiating documents, the importing customs can refuse the treatment (Art. 6/2–3).

Import VAT is left out of the landed cost

The A.TR removes customs duty, not VAT. VAT is calculated on the customs value plus duties and transport to the first place of destination; budget it from the start, or check whether your member state lets you enter it in the VAT return.