Incoterms 2020 cost allocation table: which charge falls to whom Which charge falls to whom.
There is no single point at which costs transfer under Incoterms® 2020; each of the eleven rules divides them somewhere different. Broadly: under the E rule (EXW) almost everything falls to the buyer; under the F rules (FCA, FAS, FOB) the seller bears costs up to export clearance; under the C rules (CFR, CIF, CPT, CIP) the seller pays the main carriage but risk passes early; under the D rules (DAP, DPU, DDP) the seller bears costs to destination. The table below sets it out line by line.
The cost allocation table
Rows are the eleven Incoterms® 2020 rules; columns are the charges that actually appear on an invoice. The line-item names follow the ones you will see on a Turkish shipment, including the delivery order, because that is how the invoice reads.
← Scroll the table →
| Rule | Packing | Loading | Export clearance | Pre-carriage | Origin THC | Main freight | Insurance | Destination THC | Delivery order | Import duties | On-carriage | Unloading |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| EXW | S | B | B | B | B | B | — | B | B | B | B | B |
| FCA | S | D | S | D | B | B | — | B | B | B | B | B |
| FAS | S | S | S | S | D | B | — | B | B | B | B | B |
| FOB | S | S | S | S | S | B | — | B | B | B | B | B |
| CFR | S | S | S | S | S | S | — | D | B | B | B | B |
| CIF | S | S | S | S | S | S | S | D | B | B | B | B |
| CPT | S | S | S | S | S | S | — | D | B | B | B | B |
| CIP | S | S | S | S | S | S | S | D | B | B | B | B |
| DAP | S | S | S | S | S | S | — | S | S | B | S | B |
| DPU | S | S | S | S | S | S | — | S | S | B | S | S |
| DDP | S | S | S | S | S | S | — | S | S | S | S | B |
A dash in the insurance column means there is no contractual obligation, not that insurance is unnecessary. Only CIF and CIP oblige the seller to insure. Under every other rule the party carrying the risk insures in its own interest; most cargo claims start where that distinction was missed. More detail: Incoterms® 2020: the eleven rules.
Risk transfer is not cost transfer
This is what the table alone cannot show. Under the Incoterms® rules the point at which risk passes and the point at which costs end are defined separately, and under the C rules they are deliberately pulled apart.
On a CIF shipment the seller pays the freight to the destination port, but risk passes to the buyer the moment the goods are loaded on board. If the vessel is lost in transit, the loss is the buyer's even though the seller paid the freight; the buyer's recourse is against the carrier and the insurer, not the seller.
Under CPT and CIP risk passes even earlier: on delivery to the first carrier. For an exporter selling CPT from an inland Turkish factory to a European destination, that first carrier is usually the domestic haulier, so risk passes at the factory gate while the seller keeps paying carriage all the way.
How to read the table
A "D" does not mean "unclear"; it means "check the contract". It appears in three places, each for a different reason:
- FCA · loading and pre-carriage
- If the named place is the seller's premises, the seller loads the goods onto the buyer's vehicle. If it is anywhere else, the seller delivers on its own vehicle, not unloaded. The obligation reverses with the place, which is why "FCA Istanbul" is not enough; the full address is needed.
- FAS · origin terminal charges
- The seller places the goods alongside the vessel. Who bears loading from quay to ship, and the terminal items attached to it, depends on port practice and the contract.
- C rules · destination terminal charges
- The seller has paid the freight, but whether handling at the destination terminal is included in that freight depends on the contract of carriage. This is the source of the double-billing problem below.
Why THC gets invoiced twice
Under a C rule (CFR and CIF in particular) the seller assumes the destination terminal charge is covered by the freight it has paid. The line then bills the buyer separately for terminal handling at destination. The same item is paid twice and each side blames the other.
Incoterms® 2020 gathers all cost items for each rule into a single article: A9 for the seller and B9 for the buyer. Under Incoterms® 2010 costs sat in A6/B6 with some items scattered elsewhere. The change was made precisely to end this argument: a party can now read its cost exposure in one place.
In practice it still comes down to the contract. When taking a quotation, ask in writing whether the freight is "all-in" or ocean freight only, and whether destination terminal charges are included.
Most of these items are charged per container, and how many containers you need depends on whether volume or weight fills first in your cargo.
If the cargo is containerised, choose FCA rather than FOB. A container is handed over days before it is loaded aboard. Because FOB passes risk only on loading, any damage between gate-in and loading still sits with the seller, even though the goods are no longer under the seller's control.
To quote a delivered price without taking on import clearance, choose DAP rather than DDP. Under DDP the seller files the import declaration; most countries require the declarant to be established and tax-registered there. A non-established seller also cannot recover the import VAT.
Before writing EXW, consider who will file the Turkish export declaration. As a rule, a foreign buyer cannot act as exporter of record in Türkiye (Customs Law art. 62/2). Even with EXW in the contract, the exporter ends up filing, and carries an obligation and a cost it never agreed to.
When it goes wrong
No version stated in the contract
"FOB Izmir" with no version. If one side relies on Incoterms® 2010 and the other on 2020, disputes arise over points such as DPU's former name (DAT) and the CIP insurance level. Which version applies is then left to the tribunal.
Correct form: rule + the most precise place possible + version. For example: "FCA Ambarlı Port, İstanbul, Incoterms® 2020".
CIP priced on the old insurance level
One of the substantive changes in Incoterms® 2020: under CIP the minimum cover the seller must provide was raised to Institute Cargo Clauses (A), "all risks". Under CIF the minimum stayed at (C).
If the policy is issued at (C) level the seller has breached CIP and pays the shortfall itself on a claim. The reverse error is as common: forgetting to reflect the higher premium in the price.
Clause (C) mistaken for "all risks"
CIF's minimum cover, ICC clause (C), responds to a limited list of named perils. Theft, non-delivery, wetting, breakage and crushing are typically outside it. The buyer files a claim, the underwriter declines, and a contractual dispute follows.
The credit conflicts with the trade term
The classic case: the sale is FCA but the credit calls for an "on board" ocean bill of lading. Because the seller completes delivery under FCA before loading, it cannot obtain that document; the presentation is discrepant and payment depends on the applicant's acceptance.
Correct form: choose FCA, write the transport document requirement into the contract expressly, and have the credit wording amended to match.
A DDP invoice taken as the customs value
A DDP price includes inland transport and import duties. Where they can be distinguished from the price, they are not part of the customs value (Customs Law art. 28); if they are not separated out, the declared value inflates and excess duty and VAT are paid. Where the invoice is a single flat delivered price corresponding to the price at the place of entry, inland transport within Türkiye is not deducted, unless it is documented that the price delivered at the border is lower (Customs Regulation art. 51/7). The mirror error is as common: omitting overseas freight and insurance from an EXW invoice.
For goods imported into Türkiye the cut-off point is not "the border" but "the place of entry", and it changes with the mode of transport. Under the Customs Regulation it is, by sea, the port of discharge in Türkiye (or a port of transhipment if customs documents it) and, by road and rail, the first border customs office reached. The Regulation does not list air separately; according to the Ministry of Trade it is the airport customs office where the goods are unloaded. Freight and insurance up to that point are part of the customs value.
The practical result: by sea and by air, the distance travelled inside Türkiye after the border can also fall within the value. The shortcut "it stops at the border" gives the wrong answer in those two modes.
DPU's unloading obligation overlooked
DPU is the only one of the eleven rules that puts unloading on the seller. Quote DPU to a warehouse or site with no crane and the seller has to hire a mobile crane; the waiting-time invoice for the truck standing by also goes to the seller.
Frequently asked
Is there an Incoterms 2026?
No. As at 24 October 2026 the only version in force is Incoterms® 2020.
Work on the next version has begun, however: in its Global Policy Commissions Workplan 2026, published in January 2026, the ICC stated that it would begin work on revising the Incoterms® rules and named the target version Incoterms® 2030. According to the timeline reported by ICC national committees, publication is planned for late 2029; there is no firm publication or entry-into-force date.
Has DDU been abolished, and what should I write instead?
DDU was dropped with Incoterms® 2010, and its present-day equivalent is DAP. In the same way, DAT was renamed DPU in Incoterms® 2020; the name changed because the place of destination no longer has to be a "terminal".
CNF and C&F are not Incoterms® rules at all; what they mean is CFR. Both still turn up in quotations and credits, but neither belongs in a contract.
Who pays the freight under FOB?
The buyer. Under FOB the seller's costs end when the goods are loaded on board at the port of shipment; the main freight, insurance and everything at destination fall to the buyer.
Note that this is only the cost split. Risk passes at the same point. FOB is for sea and inland waterway transport only.
Who is obliged to insure?
Only two rules impose a contractual obligation: CIF (minimum ICC clause (C)) and CIP (minimum ICC clause (A)). Under the other nine neither party is obliged to insure.
That does not mean going uninsured. The party bearing the risk insures in its own interest. Under DAP the seller carries risk to destination, so the seller should insure, but as self-protection rather than as a contractual duty.
Does the delivery terms code on the Turkish customs declaration have to match the rule in the contract?
Yes, it should. The Turkish Ministry of Trade publishes the delivery terms codes used on the declaration, and the code must match the Incoterms® rule in the sales contract.
A caution: the Ministry of Trade's list of delivery-term codes still carries codes from earlier versions: its 16 codes include DAF, DES, DEQ and DDU. A code appearing on the list does not make it a current Incoterms® 2020 rule. Download the current list from the Ministry's own page and check it.
Do the Incoterms rules say when title passes?
No. The Incoterms® rules do not deal with the transfer of title at all. Nor do they address whether a contract has been formed, the characteristics of the goods, the time, place, method or currency of payment, or the consequences of breach.
Reducing a contract to a single line such as "CIF Hamburg, Incoterms® 2020" is therefore risky. Retention of title, governing law and dispute resolution must be written separately.
Sources
- ICC — Incoterms® 2020 official page Scope and entry into force of the rules · iccwbo.org · accessed 1 Sep 2026
- ICC — History of the Incoterms® rules The list of versions since 1936; no commitment to a fixed revision cycle · iccwbo.org · accessed 1 Sep 2026
- ICC — Incoterms® 2020 Checklist and Flowcharts The ICC's own decision flowcharts: choose FCA for containerised or multimodal movements, FOB for general or bulk cargo loaded on board in the traditional way; CIP carries "all risks" (LMA/IUA clause A) cover · ICC Publication No. 817E, ISBN 978-92-842-0626-1, © 2022 · library.iccwbo.org (free PDF) · accessed 1 Sep 2026
- ICC — Global Policy Commissions Workplan 2026 States that work will begin on revising the Incoterms® rules, with Incoterms® 2030 as the target version · iccwbo.org (PDF) · accessed 1 Sep 2026
- ICC — Incoterms® trademark and copyright policy The explanations on this page are written in our own words and are not quoted from the ICC text · iccwbo.org · accessed 1 Sep 2026
- UTİKAD — Incoterms 2020 announcement (No. 2020/009) Confirms that DAT was withdrawn and DPU introduced, and the clarification made to FCA · utikad.org.tr · accessed 1 Sep 2026
- Türkiye Ministry of Trade — Delivery terms codes The code list used on the customs declaration (page dated 4 May 2026, list supplied as an Excel file); the list has 16 codes, including DAF, DES, DEQ and DDU · ticaret.gov.tr · accessed 24 Oct 2026
- Türkiye Ministry of Trade — Customs value (FAQ) The point up to which freight and insurance are included in the customs value · ticaret.gov.tr · accessed 1 Sep 2026
- WTO — Agreement on Implementation of Article VII of GATT 1994 (Customs Valuation) Article 8.2 gives members discretion whether to include freight and insurance in the customs value — the origin of the "FOB-based" and "CIF-based" distinction between countries · wto.org · accessed 1 Sep 2026
- Customs Regulation (Gümrük Yönetmeliği), arts. 43/1-e and 51/7 Definition of the place of entry by mode of transport; inland transport not deducted from a flat delivered price · mevzuat.gov.tr · accessed 29 Sep 2026
- Customs Law No. 4458, art. 28 and 62/2 Freight and insurance after the place of entry and duties payable in Türkiye are excluded from the value, provided they can be distinguished from the price; art. 62/2: the declarant must as a rule be established in Türkiye, with exceptions · mevzuat.gov.tr · accessed 24 Oct 2026
- ICC Austria — Incoterms® 2030 The new edition is under development; on the current timeline publication is planned for late 2029; until then Incoterms® 2020 applies · icc-austria.org · accessed 24 Oct 2026
- ICC Netherlands — Incoterms® 2030: a Dutch Working Group is being formed (31 Aug 2026) The revision has begun; the final launch of Incoterms® 2030 is planned for late 2029; the working documents of the revision are confidential · iccwbo.nl · accessed 24 Oct 2026
This page is for information only and is not legal or customs advice. The Incoterms® rules form part of the contract of sale, and how they apply to a given case depends on the contract as a whole, the governing law and the destination country's regulations. The binding source for the rule texts is the ICC's own publication; the explanations here are summary and interpretation. Consult your customs broker and legal adviser before making a binding decision. Incoterms® is a registered trademark of the ICC.
Change log
- Correction: "as a rule" was added to the statement that a foreign buyer cannot act as exporter of record in Türkiye; Customs Law art. 62/2 sets it as a rule with exceptions. The FAQ on delivery-term codes is now definite: the Ministry's 16-code list still carries DAF, DES, DEQ and DDU. The Incoterms 2030 answer now gives the late-2029 timeline reported by ICC national committees, and its "as at" date was moved to 24 October 2026.
- Correction: the place-of-entry definition was rewritten to follow Customs Regulation art. 43/1-e: the Regulation groups road and rail together and does not list air separately; the airport wording comes from the Ministry of Trade's explanation. The DDP paragraph now states the condition that costs must be distinguishable from the price (Customs Law art. 28) and the flat delivered price rule (art. 51/7).
- Page published. Basis: ICC Incoterms® 2020. The ICC's January 2026 Workplan confirms that work on an Incoterms® 2030 revision has begun; no publication date has been announced.