Incoterms on Turkish declarations and e-invoices Three documents, the same three letters.
On an export from Türkiye the Incoterms rule is written in three places: the sales contract, the export e-invoice and box 20 of the customs declaration. On the declaration the first part of the box takes the code from the Ministry of Trade's list and the second part the name of the place of delivery. The e-invoice carries the same code in its delivery terms field with the attribute schemeID="INCOTERMS", and on an export invoice that field cannot be left empty. All three must state the same rule: if the invoice and the declaration disagree, the tax office asks customs for information when it handles the VAT exemption file.
Box 20 of the declaration
How a Turkish customs declaration is filled in is set out in the Instructions for Use in Annex 14 of the Customs Regulation. Under those instructions box 20 is "Teslim şekli" (delivery terms) and has three subdivisions: the first takes the code for the delivery terms, the second the name of the place where the goods are delivered, and the third is left blank. The import declaration uses the box in the same way.
The instructions do not contain the codes themselves; they say the codes for the boxes are announced on the Ministry's website. The delivery terms codes are published there, on the Ministry of Trade's "Teslim Şekli Kodları" page.
The delivery terms touch two more boxes. Box 22 takes the invoice currency and the total invoice amount, box 46, on the export declaration, the statistical value of that amount expressed as FOB in US dollars (CIF in US dollars on the import declaration). If the invoice is CIF or CIP, box 22 carries an amount that includes freight and insurance; to find the FOB equivalent for box 46 you need to know those two shares separately. Which cost belongs to whom under each rule is the input for that calculation; the method for converting a price from one rule to another is on the Incoterms price conversion page.
The two official code lists side by side
The Ministry of Trade keeps one list for the declaration, the Revenue Administration (GİB) another for the e-invoice. We pulled both from source on 24 Oct 2026. They largely overlap but are not identical, and both carry more than the Incoterms® 2020 rules in force.
| Code | Declaration list | e-Invoice list | Incoterms® 2020 |
|---|---|---|---|
| EXW | Yes | Yes | Rule |
| FCA | Yes | Yes | Rule |
| CPT | Yes | Yes | Rule |
| CIP | Yes | Yes | Rule |
| DAP | Yes | Yes | Rule |
| DPU | Yes | Yes | Rule |
| DDP | Yes | Yes | Rule |
| FAS | Yes | Yes | Rule (sea) |
| FOB | Yes | Yes | Rule (sea) |
| CFR | Yes | Yes | Rule (sea) |
| CIF | Yes | Yes | Rule (sea) |
| DAF | Yes | Yes | No: removed in 2010 |
| DES | Yes | Yes | No: removed in 2010 |
| DEQ | Yes | Yes | No: removed in 2010 |
| DDU | Yes | Yes | No: removed in 2010 |
| XXX | Yes ("Other") | No | Not a rule |
| DAT | No | No | No: became DPU in 2020 |
The declaration list has 16 codes, the e-invoice list 15. In the 2010 revision the ICC removed DAF, DES, DEQ and DDU and added DAT and DAP; in 2020 DAT's initials became DPU. A code being on a list does not make it an Incoterms® 2020 rule in force.
The Turkish names differ between the two lists as well: EXW is "Fabrika çıkışında teslim" on the declaration list and "İşyerinde Teslim" on the GİB list. When comparing documents, look at the three-letter code, not the description.
Delivery terms on the export e-invoice
Under GİB's e-Invoice Customs Procedures Guide, the obligation to issue an export invoice as an e-invoice applies to invoices for goods exports attached to a customs declaration. On such an invoice the profile is IHRACAT and the invoice type ISTISNA; the VAT exemption code is 301, described as "11/1-a Mal ihracatı" (export of goods).
The delivery terms go into the Delivery/DeliveryTerms/ID element of the invoice line, and its schemeID attribute must be INCOTERMS. The validation rules (schematron) in GİB's e-Invoice package check two things: under the IHRACAT profile there must be at least one delivery term with that attribute, on each line or at invoice level, and the value must be one of the 15 codes on the code list. The same rules also require a delivery address and a transport mode code.
The field takes the code only; place information such as "FCA Mersin" is not part of that element. The guide's DeliveryAddress element is defined as the place where the goods are delivered and paid for, and it is a separate address; do not treat it as the named place of the Incoterms rule.
Version: GİB's e-Invoice page publishes the UBL-TR 1.2.1 package and guides; the code list in force is UBL-TR Code Lists version 1.43 (July 2026). The validation rules accept both TR1.2 and TR1.2.1 as the customisation identifier.
The Ministry generates a 23-digit reference number for an e-invoice attached to a declaration; the exporter declares that number and the document date in box 44 of the declaration. The full list of what goes into that file is on the export documents page.
Writing it correctly in the contract
The ICC's introduction to Incoterms® 2020 describes the safest way to incorporate a rule into a contract: [the chosen rule] [named port, place or point] Incoterms® 2020. One of its examples is "CIF Shanghai Incoterms® 2020". Leaving the year out leaves open which version applies; the ICC says this could cause problems that may be difficult to resolve. Using the ® symbol in the contract is not necessary.
An example FCA line: "FCA [terminal name], Mersin, Türkiye, Incoterms® 2020". The ICC advises naming the place as precisely as possible in geographical terms; how the loading obligation under FCA shifts with the place of delivery is explained on the FOB or FCA page.
One detail matters on the declaration. According to the ICC, under the C rules the named place is not the place of delivery but the destination to which the seller pays for carriage. The instructions, however, define the second subdivision of box 20 as the place where the goods are delivered and say nothing specific about the C rules. On a CIF or CPT sale, agree with your customs broker at the outset what goes into that subdivision.
Write the contract line first, then copy it. The rule and the place are set once in the contract; the proforma, the e-invoice and the declaration carry the same three letters.
Do not pick a code that is off the list or retired. DAP instead of DDU, DPU instead of DAT; details on the Incoterms by mode of transport page.
On a CIF or CIP invoice, keep freight and insurance separate. Box 46 asks for the FOB equivalent.
If the e-invoice has to change, do it before the declaration is registered. A change means cancelling the invoice and its reference number.
What a mismatch affects
Each consequence below rests on a written text. We have not added any sanction the texts do not state.
| Where | What the rule says | Basis |
|---|---|---|
| VAT export exemption | If the export invoice and the customs declaration do not match, the tax office asks the customs directorate concerned for information and acts on the result. | VAT General Implementation Communiqué, II/A-1.1.2 |
| Correcting the e-invoice | If the invoice has to change before or after registration, the invoice and its reference number are cancelled; a cancelled number cannot be used for registration. | GİB Customs Procedures Guide, 3.1.2 |
| Statistical value | Box 46 takes the FOB equivalent in US dollars of the invoice amount in box 22. | Customs Regulation Annex 14 |
| Documentary credit | If the credit states a trade term in the goods description, the invoice must show that trade term and, where its source is stated, the same source. | ICC ISBP 745, C8 |
A documentary credit is independent of the sales contract (ISBP 745, preliminary considerations iii). The bank compares the documents with the credit, not with the contract; data in the documents need not be identical but must not conflict (UCP 600 art. 14(d)).
The table does not say, and nor do we, that a mismatch always leads to a penalty or a refused refund. The Communiqué says the tax office will ask customs for information; that exchange decides the outcome.
When it goes wrong
Contract FCA, e-invoice CIF
At the last minute the buyer and seller agree that the price includes freight, the invoice is issued CIF, and the contract and the declaration stay FCA. That gap between invoice and declaration is exactly the kind of mismatch for which the Communiqué has the tax office ask customs for information in the VAT exemption file. Correcting the invoice means cancelling it and getting a new reference number.
Choosing a rule that has been retired
DDU and DAF are still on both official lists; the e-invoice validation rules treat them as valid. But if the contract refers to Incoterms® 2020, that version has no rule called DDU; the contract line has no counterpart in the ICC text. The code's equivalent is DAP; DDP, where the seller takes on the import duties, is a separate decision.
The credit names the version, the invoice does not
The credit says "CIF Hamburg Incoterms® 2020", the invoice says "CIF Hamburg". Under ISBP 745 C8, where the source is stated the invoice must show the same source; such an invoice is not compliant. The reverse is allowed: if the credit only says "CIF Hamburg", the invoice may add the version. The other fields of a credit are covered on the how to read a letter of credit page.
Frequently asked
Which box of the Turkish customs declaration holds the delivery terms?
Box 20. Under the instructions the box has three subdivisions: the first takes the code, the second the name of the place where the goods are delivered, and the third stays blank.
Where is the list of delivery terms codes?
On the Ministry of Trade's "Teslim Şekli Kodları" page; the page is dated 04.05.2026 and lets you export the list to Excel. On 24 Oct 2026 the list had 16 codes. The separate list that applies to e-invoices is section 1.14 of GİB's UBL-TR Code Lists document.
Can the delivery terms be left empty on an export e-invoice?
No. Under the IHRACAT profile GİB's validation rules look for at least one delivery term with schemeID="INCOTERMS" on the line or at invoice level and check the value against the code list. If the field is empty or the code is not on the list, the invoice fails those rules.
When is the code XXX "Other" used?
The declaration list defines this code only as "Diğer" (other), and the instructions add no explanation. The e-invoice list has no XXX. If your contract is not based on one of the Incoterms® rules, work out the declaration together with your customs broker.
On an EXW sale, does the declaration say EXW?
EXW is on both code lists, and if the contract is EXW the documents say EXW. The questions EXW raises on the export clearance side for shipments from Türkiye are covered separately on the EXW exports from Türkiye page.
Sources
- Gümrük Yönetmeliği Ek 14 — Gümrük Beyannamesi Kullanma Talimatı (Customs Regulation Annex 14, amended: Official Gazette 07.02.2013, 28552) Box 20 "Teslim şekli" and its three subdivisions; box 22 invoice amount; box 44 supporting documents; box 46 statistical value (FOB on export, CIF in US dollars on import); codes announced on the Ministry's website · ticaret.gov.tr (DOC) · accessed 24 Oct 2026
- T.C. Ticaret Bakanlığı — Teslim Şekli Kodları (Ministry of Trade, delivery terms codes) The 16 codes used on the declaration and their descriptions (page dated 04.05.2026; list read from the page's own data source) · ticaret.gov.tr · accessed 24 Oct 2026
- GİB — e-Fatura Uygulaması Gümrük İşlemleri Kılavuzu, version 1.8 (February 2018)
Scope of the obligation; IHRACAT profile and ISTISNA type; delivery terms field and
schemeID="INCOTERMS"; 23-digit reference number and box 44; cancellation rule; exemption code 301 · ebelge.gib.gov.tr (ZIP) · accessed 24 Oct 2026 - GİB — UBL-TR Kod Listeleri, version 1.43 (July 2026) Section 1.14: INCOTERMS delivery terms codes (15 codes) · ebelge.gib.gov.tr (ZIP) · accessed 24 Oct 2026
- GİB — e-Fatura Paketi, UBL-TR validation rules (schematron) Under the IHRACAT profile, an INCOTERMS delivery term on the line or at invoice level, a delivery address and a transport mode are required; the valid code set; customisation identifiers TR1.2 and TR1.2.1 · ebelge.gib.gov.tr · accessed 24 Oct 2026
- Katma Değer Vergisi Genel Uygulama Tebliği (VAT General Implementation Communiqué, Official Gazette 26.04.2014, 28983) II/A-1.1.1 declaring the exemption and code 301; II/A-1.1.2 supporting documents and the request to customs where invoice and declaration do not match (text as first published) · resmigazete.gov.tr (DOCX) · accessed 24 Oct 2026
- ICC — Incoterms® 2020 Introduction (Publication No. 723E) Paragraphs 9–15: incorporating the rule into the contract, the year, a precise named place, the meaning of the place under the C rules, the ® symbol; DAT becoming DPU. The introduction is signed by Charles Debattista; by its own note the views are the author's · icc-switzerland.ch · accessed 24 Oct 2026
- ICC — Incoterms® rules history The 2010 revision removed DAF, DES, DEQ and DDU and added DAT and DAP · iccwbo.org · accessed 24 Oct 2026
- ICC — ISBP 745 (2013), International Standard Banking Practice Preliminary considerations iii (independence of the credit from the contract); C8 (trade term and its source on the invoice); reference to UCP 600 art. 14(d). Superseded by ISBP 821; text from the copy published by Aloqabank · aloqabank.uz (PDF) · accessed 24 Oct 2026
This page is for information only and is not legal, tax or customs advice. Filling in the declaration is your customs broker's job, the VAT refund file your accountant's, the credit text your bank's. Code lists can change; check the current list at source before you declare. Incoterms® is a registered trademark of the ICC.
Change log
- Page published together with the Turkish page. Basis: Customs Regulation Annex 14, the Ministry of Trade delivery terms codes, GİB UBL-TR Code Lists 1.43, the VAT General Implementation Communiqué, ICC Incoterms® 2020 and ISBP 745.