Learn how importers can challenge an incorrect Additional Customs Duty assessment in Turkey in 2026, including GTIP, origin and A.TR disputes, administrative objections, customs refunds, deadlines and tax court remedies.

Additional Customs Duty in Turkey, commonly referred to as ACD or İlave Gümrük Vergisi (İGV), can substantially increase the cost of importing goods into the Turkish market. Foreign manufacturers, international suppliers, multinational companies and Turkish importers may unexpectedly face an additional assessment because customs authorities dispute the declared GTIP classification, country of origin, preferential tariff treatment or documentation submitted during customs clearance.

An Additional Customs Duty assessment should not automatically be accepted as legally correct. Depending on the circumstances, the importer may be able to challenge the assessment through administrative objection procedures and, where necessary, judicial proceedings before the competent Turkish tax court. If the duty has already been paid, repayment may also become an issue where the importer can establish that the amount was collected without a valid legal basis.

The main regulatory framework includes Customs Law No. 4458, the Import Regime Decision and the Decision on the Application of Additional Customs Duty, Presidential Decision No. 3351, together with its annexes and subsequent amendments. The Ministry of Trade maintains a consolidated version of Decision No. 3351 and its schedules, currently updated as of 17 July 2026.

For companies importing into Turkey in 2026, the most important principle is that the applicable Additional Customs Duty cannot be determined simply by looking at the product name. The correct assessment may depend on the GTIP, country of origin, applicable country group, preferential trade arrangements, supporting origin documentation and legislation in force on the date of importation.

What Is Additional Customs Duty in Turkey?

Additional Customs Duty is an additional financial burden applied to the importation of specified goods under Turkey’s trade-policy framework. It operates alongside the ordinary customs duty regime and is intended, among other policy objectives, to provide additional protection for domestic production in designated product categories.

The rates are not uniform. Different goods may be subject to different rates depending on their GTIP classification and the country or country group from which the relevant customs treatment derives. Some products may not be subject to Additional Customs Duty at all, while others may face commercially significant additional rates.

For this reason, an importer should never calculate Additional Customs Duty solely by reference to a previous shipment. The applicable legislation and schedules should be checked for the specific import date.

This point is particularly important in 2026 because Turkey has made several amendments to its import framework during the year. The Ministry of Trade’s 2026 records show amendments to the Additional Customs Duty Decision, including Presidential Decision No. 11508 dated 11 July 2026 and earlier amendments during the year.

Why Can an Additional Customs Duty Assessment Be Incorrect?

An incorrect assessment can result from several different legal or factual issues. One of the most common is an incorrect GTIP classification. If customs authorities classify a product under a tariff position carrying Additional Customs Duty while the importer believes that another GTIP should legally apply, the entire additional assessment may depend on resolving the classification dispute.

Origin is another major source of disagreement. A shipment may travel through an EU Member State but contain goods originating in a third country. Conversely, an importer may possess documentation demonstrating preferential origin that changes the applicable Additional Customs Duty treatment.

Errors can also result from failure to apply an exemption, incorrect interpretation of an applicable free trade agreement, use of the wrong country column in the relevant schedule or application of a rate that was not legally in force on the date the customs declaration was registered.

A proper challenge should therefore identify exactly why the assessment is incorrect rather than simply arguing that the tax is too high.

Why Is GTIP Classification So Important?

GTIP classification is one of the first issues that should be reviewed when an importer receives an unexpected Additional Customs Duty assessment.

Turkey’s customs tariff uses detailed tariff classifications to determine the legal treatment of imported goods. A difference between two closely related GTIP codes can change the applicable ordinary customs duty, Additional Customs Duty and other import requirements.

For technically complex products, classification should be based on the objective characteristics of the goods rather than merely their commercial name. The analysis may require examination of the product’s composition, material, function, technical characteristics, manufacturing process and intended use together with the relevant tariff headings, section notes and chapter notes.

The Ministry of Trade published updated customs practice guides in May 2026, including materials specifically addressing Tariff Classification, Frequently Made Tariff Mistakes and Determination of Tariff Classification.

This reinforces why foreign importers should preserve technical specifications, product catalogues, engineering documents and other evidence capable of establishing the correct classification.

Can an Incorrect GTIP Assessment Be Challenged?

Potentially, yes. If the customs administration determines that the imported product belongs under a GTIP subject to a higher Additional Customs Duty, the importer may challenge that determination where there are valid technical and legal grounds.

A strong classification challenge should explain why the customs authority’s proposed GTIP is incorrect and why the importer’s classification better reflects the objective characteristics of the goods.

For example, a dispute concerning industrial machinery may depend on the machine’s principal function, while a chemical product may require analysis of its composition. Electronic products and composite goods may require even more detailed technical interpretation.

Merely demonstrating that the company historically used the same GTIP may not be sufficient. Previous customs clearance does not necessarily establish that the classification was legally correct.

Why Is Country of Origin Important for Additional Customs Duty?

Origin is frequently decisive.

The country from which goods are shipped should not automatically be treated as the country in which the goods originate. Goods may be manufactured in one country, transported through another and exported to Turkey from a third jurisdiction.

The legal origin of the goods must therefore be determined under the applicable origin rules.

Depending on the circumstances, relevant evidence may include certificates of origin, supplier declarations, manufacturing information, bills of materials, preferential-origin documentation and documentation showing where sufficient production or processing occurred.

Where Additional Customs Duty depends on origin, an incorrect origin determination can substantially increase the amount payable.

Does an A.TR Certificate Exempt Goods from Additional Customs Duty?

Not automatically.

This is one of the most important issues for companies trading between Turkey and the European Union.

An A.TR Movement Certificate principally establishes the free-circulation status of qualifying goods within the EU–Türkiye Customs Union framework. It should not automatically be treated as proof that the goods are of EU preferential origin.

This distinction becomes critical when goods originating in a third country are placed in free circulation in the European Union and subsequently exported to Turkey with an A.TR certificate.

The current consolidated Additional Customs Duty Decision expressly contains rules addressing goods imported from the European Union with A.TR documentation that are not of Turkish or EU origin. The applicable treatment can also depend on whether preferential origin is demonstrated within the relevant cross-cumulation framework.

Therefore, where Turkish customs assesses Additional Customs Duty despite the existence of an A.TR certificate, the correct legal response is not simply to argue that “A.TR means no tax.” The importer should examine the actual origin of the goods and the applicable preferential trade rules.

What Documents Can Be Used to Prove Origin?

The appropriate evidence depends on the applicable trade arrangement and origin rules. In some cases, a certificate of origin may be relevant. In others, preferential-origin documents or supplier declarations may be required.

Importers dealing with goods manufactured through multinational supply chains should preserve records showing where the product was manufactured, where its principal materials originated and what processing occurred in each country.

Origin disputes can become particularly difficult where the foreign supplier cannot provide manufacturing documentation after customs authorities begin an investigation.

For this reason, origin evidence should ideally be collected before importation rather than after an Additional Customs Duty assessment has already been issued.

Can Additional Customs Duty Apply to Goods Coming from the European Union?

Potentially, depending on the origin and circumstances.

Goods physically shipped from Germany, France, Italy or another EU Member State are not necessarily EU-origin goods. For example, a product manufactured in a third country may enter free circulation in the European Union before subsequently being exported to Turkey.

Where Additional Customs Duty treatment depends on actual origin, the fact that the commercial invoice was issued by an EU company or the shipment physically departed from the EU may not resolve the question.

Foreign importers should therefore distinguish between country of shipment, country of export, free circulation and country of origin.

What Changed in Turkey’s Additional Customs Duty Rules in 2026?

Turkey’s 2026 import regime introduced and continued several important changes relevant to importers.

At the beginning of the year, the Ministry of Trade announced that the 2026 Import Regime Decision, amendments to the Additional Customs Duty Decision and the 2026 Import Communiqués had been published. The Ministry explained that the annexes to the Additional Customs Duty Decision were updated in line with changes to the 2026 Turkish Customs Tariff Schedule, including amendments to tariff statistical positions and descriptions of goods.

The Ministry also announced an important structural change concerning certain precious metals and jewellery products. A 20% additional financial liability previously imposed under a separate measure was transferred into the Additional Customs Duty framework at the same 20% rate, with the new structure taking effect from 1 February 2026.

Further amendments followed during 2026. The Ministry’s current list records amendments to the Additional Customs Duty Decision, including Presidential Decision No. 11508 dated 11 July 2026, while the consolidated Decision No. 3351 is currently marked as updated on 17 July 2026.

The Import Regime itself was also amended repeatedly during 2026, including changes dated 12 March, 3 April, 25 April, 1 July and 11 July 2026.

These changes make it particularly important to determine the rules that were legally applicable on the date of the relevant customs declaration.

What Should an Importer Do After Receiving an Incorrect Assessment?

The importer should first obtain the formal assessment and identify its notification date. The company should then determine the precise reason why Additional Customs Duty was imposed.

The customs declaration, GTIP, country of origin, A.TR or other movement documents, preferential-origin evidence, commercial invoice, purchase agreement and relevant Additional Customs Duty schedule should be reviewed together.

The importer should then calculate the difference between the amount assessed by customs and the amount that it considers legally payable.

If the dispute concerns classification, technical documentation should be collected immediately. If it concerns origin, supply-chain evidence should be secured from the manufacturer or supplier before documents become difficult to obtain.

Most importantly, the importer should identify whether a statutory objection period has begun.

How Can an Additional Customs Duty Assessment Be Challenged?

Customs disputes in Turkey are subject to specific administrative procedures.

Under Article 242 of Customs Law No. 4458, qualifying customs duties, penalties and administrative decisions can be challenged through the applicable administrative objection procedure. The objection period is generally 15 days from notification of the relevant customs decision.

This short deadline is particularly important for foreign companies because internal approval processes can consume valuable time. A multinational company should not wait several weeks for headquarters approval before determining whether an objection must be filed.

A properly prepared objection should identify the challenged assessment, customs declaration, notification date, amount in dispute, applicable GTIP, origin and legal basis for the requested cancellation or correction.

What Arguments Can Be Used Against an Incorrect Assessment?

The correct argument depends on the error.

An importer may argue that customs applied the wrong GTIP, incorrectly determined the country of origin, failed to recognize legally sufficient preferential-origin evidence, applied the wrong country group or tariff column, used an Additional Customs Duty rate that was not in force on the declaration date or incorrectly interpreted an exemption.

A procedural defense may also arise where the customs administration failed to comply with applicable notification, reasoning or assessment requirements.

The strongest customs cases generally combine legal analysis with technical and commercial evidence rather than relying on broad statements that the assessment is unfair.

What If the Importer Has Already Paid the Additional Customs Duty?

Payment does not necessarily mean that an incorrect assessment can never be challenged or recovered.

Where Additional Customs Duty was paid despite not being legally due, or where an amount exceeding the legally payable amount was collected, the importer may need to examine the repayment and remission mechanisms under Customs Law No. 4458.

This may involve Article 211 and related customs refund procedures, depending on the circumstances.

For example, an importer may later establish that the correct GTIP was subject to a lower rate or that valid origin evidence entitled the goods to different treatment.

The refund analysis should determine what was actually paid, what should legally have been paid and the precise reason for the difference.

Can an Incorrect Additional Customs Duty Decision Be Taken to Court?

Potentially, yes.

Where the applicable administrative objection procedure has been completed and the dispute remains unresolved, judicial review may become available before the competent Turkish tax court.

The court may need to determine whether the customs authority correctly interpreted the GTIP, origin rules, Additional Customs Duty Decision, applicable preferential trade arrangement or other relevant legislation.

The administrative objection deadline and judicial litigation deadline should be treated separately. Informal negotiations with customs should not be assumed to suspend statutory periods.

Can a Stay of Execution Be Requested?

Depending on the nature of the dispute and procedural circumstances, the importer may need to evaluate whether a stay of execution can be requested during judicial proceedings.

The filing of a lawsuit does not automatically mean that every customs measure will be suspended. The statutory requirements applicable to stays of execution must be satisfied.

This issue can become commercially important where the disputed assessment is substantial or where the customs measure is preventing the release of valuable goods.

Can Goods Be Released While the Additional Customs Duty Is Disputed?

This depends on the customs status of the goods and the particular procedural circumstances.

Where customs refuses to complete clearance unless the disputed Additional Customs Duty is dealt with, the importer may need to evaluate available payment, security, objection and release mechanisms.

The commercial consequences should be considered alongside the legal dispute because storage, warehouse and demurrage costs can accumulate rapidly.

For high-value or time-sensitive shipments, the economically optimal strategy may therefore require balancing immediate cargo release against preservation of the company’s right to challenge or recover the disputed amount.

Can an Incorrect Assessment Affect Previous Imports?

Potentially, yes.

If customs determines that a product has been consistently classified under an incorrect GTIP or that the importer has systematically applied an incorrect origin treatment, the authorities may examine earlier declarations involving the same goods.

The opposite can also occur. An importer reviewing an unexpected Additional Customs Duty assessment may discover that it previously overpaid Additional Customs Duty on numerous historical imports.

A significant assessment should therefore trigger a broader customs compliance review covering historical GTIPs, origin documentation and Additional Customs Duty calculations.

What If the Foreign Supplier Provided Incorrect Origin Information?

The importer should distinguish between its relationship with Turkish customs and its contractual relationship with the foreign supplier.

The customs administration may assess the importer’s obligations according to Turkish customs legislation regardless of whether the underlying mistake originated with the supplier.

Separately, the importer may have contractual claims against the supplier where incorrect origin information, certificates or representations caused additional customs liabilities.

Supply agreements involving products exposed to substantial Additional Customs Duty should therefore contain clear provisions concerning origin documentation, customs classification information, cooperation during audits and responsibility for inaccurate supplier declarations.

Can Foreign Companies Challenge Additional Customs Duty Without Coming to Turkey?

In many cases, appropriate administrative and judicial procedures may be conducted through an authorized Turkish lawyer, subject to applicable power-of-attorney requirements.

This can be particularly important for foreign manufacturers and international suppliers whose goods are imported through Turkish subsidiaries, distributors or commercial partners.

Foreign corporate documents and powers of attorney may require apostille, consular legalization or certified Turkish translation depending on the country of issuance and intended procedure.

What Are the Biggest Mistakes Importers Make in Additional Customs Duty Disputes?

One of the most serious mistakes is assuming that an A.TR certificate automatically eliminates Additional Customs Duty. Another is relying on a GTIP used for previous imports without checking whether the classification or applicable tariff schedule changed in 2026.

Companies also sometimes focus only on the percentage rate without reviewing whether customs selected the correct origin category or country group. Others allow internal discussions with the customs broker, supplier and overseas headquarters to continue until the 15-day administrative objection period is close to expiring.

Another significant mistake is treating the dispute as an isolated shipment. Where the same GTIP or origin methodology has been used repeatedly, the financial exposure or potential refund opportunity may extend across many declarations.

Frequently Asked Questions About Additional Customs Duty in Turkey

1. What is Additional Customs Duty in Turkey?

Additional Customs Duty is an additional import charge imposed on specified goods under Turkey’s trade-policy framework. The applicable treatment depends on factors including the product’s GTIP, origin and the rules in force on the date of importation.

2. Can an incorrect Additional Customs Duty assessment be challenged?

Potentially, yes. An importer may challenge an assessment based on incorrect GTIP classification, origin, preferential treatment, tariff rate, country group or another legal or factual error.

3. How long do I have to object to a customs assessment in Turkey?

Where the Article 242 administrative objection procedure applies, the objection period is generally 15 days from notification of the relevant customs decision. The particular decision and notification date should be checked immediately.

4. Does an A.TR certificate automatically exempt goods from Additional Customs Duty?

No. A.TR principally concerns free circulation under the EU–Türkiye Customs Union and should not automatically be treated as proof of EU preferential origin. Actual origin can remain decisive under the Additional Customs Duty rules.

5. Can goods shipped from the EU still be subject to Additional Customs Duty?

Potentially, yes. Goods shipped from an EU Member State may actually originate in a third country. Country of shipment and country of origin are legally distinct concepts.

6. Can an incorrect GTIP cause excessive Additional Customs Duty?

Yes. Because Additional Customs Duty schedules are linked to tariff classifications, using or being assessed under an incorrect GTIP can materially change the amount payable.

7. Can Additional Customs Duty already paid be recovered?

Potentially, where the importer establishes that the duty was not legally payable or was collected in excess. The repayment and remission provisions of Customs Law No. 4458 should be examined for the specific case.

8. Can a rejected Additional Customs Duty objection be taken to court?

Potentially, yes. After the applicable administrative procedure has been completed, qualifying disputes may be brought before the competent Turkish tax court within the applicable litigation period.

9. Did Turkey change its Additional Customs Duty rules in 2026?

Yes. Turkey updated the Additional Customs Duty framework for 2026 and made further amendments during the year. The Ministry of Trade currently maintains a consolidated Decision No. 3351 updated as of 17 July 2026.

10. Should previous imports be reviewed after an Additional Customs Duty dispute?

Yes, particularly where the same GTIP, origin or tariff methodology has been used repeatedly. A historical review may identify additional liability or, conversely, customs duties that were overpaid and may potentially be recoverable.

Legal Support for Additional Customs Duty Disputes in Turkey

An incorrect Additional Customs Duty assessment can significantly increase the landed cost of imported goods, particularly where the disputed classification or origin treatment has been used repeatedly across numerous shipments. The correct legal strategy should therefore examine not only the individual assessment but also the GTIP classification, actual country of origin, A.TR documentation, preferential-origin rules, applicable country group, rate in force on the declaration date and historical customs declarations.

The issue is especially important in 2026 because Turkey has amended both its Import Regime and Additional Customs Duty framework during the year. The current consolidated Additional Customs Duty Decision is updated as of 17 July 2026, while the Ministry of Trade’s records confirm several changes to the import regime during 2026.

Our law office provides professional legal assistance concerning Additional Customs Duty disputes, incorrect İGV assessments, GTIP classification disputes, origin investigations, A.TR and preferential-origin issues, customs refund claims, administrative objections and tax court proceedings in Turkey.

Fırat Fesih Kaya assists foreign importers, exporters, international manufacturers, investors and multinational companies with reviewing customs assessments, determining whether Additional Customs Duty has been calculated correctly, preparing administrative objections and pursuing appropriate judicial remedies.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yıldırım Tower No: 148, 06520 Balgat, Çankaya, Ankara, Turkey

For professional legal support concerning an incorrect Additional Customs Duty assessment in Turkey in 2026, you may contact our law office for a case-specific review of the GTIP, origin, A.TR documentation, applicable tariff rate, objection deadline and available administrative or judicial remedies.