Türkiye and the EU share a customs union, which means most industrial goods enter the EU free of customs duty. But “no duty” and “no customs” are not the same thing. The goods are still declared, the consignee’s registration is still checked, and import VAT arises in the destination country regardless. Companies exporting into the EU for the first time almost always get stuck on one of those three points.
A.TR: what it covers and what it does not
The A.TR movement certificate shows that goods are in free circulation under the customs union. It is not a proof of origin — it certifies free circulation in Türkiye, not where the goods were made. A product manufactured in China on which Turkish import duties have been paid can still travel to the EU under an A.TR.
| Product group | Document | Duty in the EU |
|---|---|---|
| Industrial goods | A.TR | Relieved under the customs union |
| Processed agricultural goods | A.TR plus agricultural component calculation | Industrial element relieved, agricultural element charged |
| Basic agricultural goods | EUR.1 or EUR-MED | Preferential rate; full rate where outside scope |
| ECSC goods (iron and steel) | EUR.1 | Preferential under a separate agreement |
A.TR and EUR.1 are therefore not alternatives to each other; they belong to different product groups. Which one applies is determined by the HS code, and guessing means the goods wait at the border. Our A.TR versus EUR.1 article sets out the comparison in detail.
EORI: the consignee’s prerequisite
To lodge an import declaration in the EU the consignee needs an EORI number. It is valid across the EU and obtained once. A buyer importing for the first time usually does not have one, and discovering that after the goods have reached the port keeps the container standing.
Our practice is simple: on every new EU consignee we ask for the EORI number in writing before the goods load. If it is missing, obtaining it takes a few days — but those days pass before loading rather than at the port.
Import VAT: it arises even when duty is zero
The customs union removes duty, not VAT. When goods enter the EU, the destination country’s import VAT is assessed and the importer pays it. A VAT-registered buyer normally recovers it, making it a cash-flow item rather than a final cost — but the goods are not released until it is settled.
This is where the Incoterms choice becomes decisive:
- DAP — import formalities and VAT sit with the buyer. The most common and least troublesome structure.
- DDP — duty and VAT sit with the seller. This requires the seller to hold a VAT registration or an importer of record arrangement in the destination country, which is not straightforward everywhere.
- FCA / EXW — export declaration and everything after sits with the buyer; the Turkish export declaration is still lodged in the exporter’s name.
If you are considering DDP we confirm in advance that the structure can actually be put in place — our DDP import solutions page explains when it is feasible.
Germany as the worked example
- Document check. Invoice, packing list, HS code, the consignee’s EORI and VAT numbers — before loading.
- Export declaration in Türkiye. Lodged in the exporter’s name; the goods leave customs.
- A.TR issued. Endorsed by the customs authority.
- Transport. By road typically a few days, varying with the lane and the border crossing used.
- Import declaration in Germany. The consignee’s broker files through the ATLAS system; import VAT (Einfuhrumsatzsteuer) is assessed.
- Release and delivery.
If the product falls into a category requiring CE marking, that is a separate matter: conformity is the domain of market surveillance rather than customs, but its absence means the goods cannot lawfully be placed on the market. We ask about it at quotation stage too.
What must be ready before loading
- Commercial invoice, carrying the consignee’s name, address, VAT and EORI numbers
- Packing list with package count, net and gross weight, dimensions
- HS code and the document decision that follows from it (A.TR or EUR.1)
- Certificate of origin where origin has to be proven
- CE or conformity documentation according to the product category
- The delivery term and who acts as importer
The import declaration on the EU side cannot be lodged unless the buyer is registered. What that registration is, and when you need one yourself, is covered in our guide to the EORI number.
Frequently asked questions
Is duty payable on goods exported from Türkiye to the EU?
Industrial goods within the customs union are relieved of customs duty under an A.TR. Agricultural goods and former ECSC products fall outside it and use EUR.1 for a preferential rate instead. Import VAT arises in the destination country in every case.
Is an A.TR a certificate of origin?
No. The A.TR shows that the goods are in free circulation, not where they were produced. Where origin must be proven, a certificate of origin or a EUR.1 is issued separately. Confusing the two is the most common documentary error on EU shipments.
What happens if the consignee has no EORI number?
The import declaration cannot be lodged and the goods wait in customs. An EORI application generally takes a few days. This is why we ask every new EU consignee for the number in writing before loading.
Can the seller pay the import VAT?
Under DDP yes, but it requires the seller to hold a VAT registration or an importer of record arrangement in the destination country. That structure is not available for every country and product; where it is not, DAP is the more realistic choice.
Does groupage change the documentary process?
The documents are the same, but the timing changes: on a groupage vehicle one consignment’s missing paper can hold the whole load. That is why we close the document check earlier on part loads.
Is CE marking checked at customs?
Conformity is primarily a market surveillance matter, though for some product groups checks can also occur at the customs stage. Its absence usually surfaces as an inability to place the goods on the EU market — which is why we ask about the product category when quoting.
What if the goods pass through the EU to a third country?
Then no import takes place: the goods move under a transit regime. They travel on a T1, no duty or import VAT arises, and a guarantee valid for the duration is provided instead.
Send the invoice, the packing list and the HS code, and we will set out which document applies, what the consignee needs to have ready and the real transit time. Scope is on our customs clearance page; to open an enquiry use the quote form.