Customs Adds Freight and Insurance Costs to Import Value: When Is It Lawful? — 2026 Current Guide

When can Turkish Customs lawfully add freight and insurance costs to import value? Learn the border-point rule, Incoterms, evidence, exclusions, penalties and appeal options in 2026.

Turkish Customs may add freight and insurance costs to the customs value of imported goods when those costs relate to transporting the goods to the Turkish customs entry point and were not already included in the price paid or payable.

This does not mean that every transport, handling or insurance invoice can be added automatically. The charge must be legally relevant, objectively measurable and connected to the imported goods. Costs incurred after arrival in Turkey may often be excluded if they are separately identified and properly documented.

The Turkish Ministry of Trade explains the customs valuation framework and the treatment of transport and insurance in its official customs valuation guidance.

Why Are Freight and Insurance Added?

Under the transaction-value method, customs value is generally based on the price actually paid or payable, together with legally required additions.

Freight and insurance costs up to the relevant Turkish customs entry point may be included where they are not already reflected in the invoice price. The purpose is to determine the customs value of the goods at the point where they enter the customs territory.

The charge may be added even if:

• The importer paid the carrier directly;
• The seller paid freight and included it in a separate invoice;
• Insurance was arranged by the buyer;
• Freight was prepaid;
• The invoice uses an ex-works or similar delivery term;
• The transport cost was paid to a related logistics company.

The authority should avoid double counting. If the invoice price already includes freight and insurance to the entry point, the same amount should not be added again.

The Customs Entry-Point Rule

The central question is where the transport or insurance cost was incurred.

Costs up to the Turkish customs entry point may generally form part of customs value. The relevant point may be:

• The Turkish seaport where goods are unloaded;
• The land border entry point;
• The international airport;
• Another legally recognised place of entry.

Costs incurred after that point may be excluded when they are separately shown and can be objectively identified.

For example, international freight from Germany to a Turkish seaport may be included, while inland transport from that port to the importer’s warehouse may be excluded if it is separately invoiced and documented.

How Do Incoterms Affect the Analysis?

Incoterms help determine which party pays freight and insurance, but they do not alone decide the customs value.

EXW

Under EXW, the buyer commonly bears most transport costs. Freight and insurance to the Turkish entry point may need to be added if they are not included in the invoice.

FCA or FOB

The invoice may exclude international freight and insurance. The importer should provide the relevant transport invoices and insurance records.

CIF or CIP

The invoice may already include transport and insurance to the agreed destination. Customs should verify the included elements before making any additional adjustment.

DDP

The price may include significant delivery costs and import-related charges. The importer should separate foreign transport, post-entry transport, import duty and domestic taxes.

The commercial term should be read together with the contract, invoice, freight documents and payment records.

When Is Adding Freight Lawful?

An addition is generally more defensible when:

• The cost relates to the imported goods;
• The transport is for the shipment under review;
• The cost is incurred up to the Turkish entry point;
• The amount is supported by an invoice or carrier record;
• The cost was not already included in the declared price;
• The calculation is objective and measurable;
• The same cost has not been added twice.

Customs should explain the calculation, especially where a consolidated freight invoice covers several shipments or products.

A general estimate without a clear connection to the goods may be challenged.

Insurance Costs

Insurance may be added where it covers the goods during transport to the Turkish entry point and was not included in the price actually paid or payable.

Useful evidence includes:

• Insurance policy;
• Certificate of insurance;
• Premium invoice;
• Shipment reference;
• Coverage period;
• Insured value;
• Allocation schedule;
• Broker statement.

If one policy covers multiple shipments, the importer should explain how the premium was allocated.

Insurance after arrival in Turkey, domestic warehouse insurance and unrelated corporate insurance should not automatically be included in customs value.

Post-Entry Transport and Other Exclusions

Where separately identified, the following costs may often be excluded:

• Inland transport after arrival in Turkey;
• Delivery from the port to the importer’s warehouse;
• Domestic insurance after entry;
• Post-importation assembly;
• Installation after import;
• Maintenance;
• Technical assistance after import;
• Certain financing interest;
• Import duties and domestic taxes;
• Buying commissions.

The importer should show these costs separately on the invoice, freight statement, contract or accounting records. A single combined amount makes it more difficult to prove that post-entry expenses should be excluded.

Freight Paid by a Related Company

International groups often arrange freight through a parent company, logistics affiliate or central procurement department.

Customs may ask:

• Who contracted the carrier;
• Who paid the freight;
• Whether the freight company is related;
• Whether the amount reflects an arm’s-length charge;
• Whether a management or handling fee was added;
• Whether the invoice includes post-entry transport;
• Whether the amount was allocated correctly.

A related-party freight payment is not automatically unacceptable. The importer should provide the logistics agreement, carrier invoice, payment record and allocation method.

Consolidated Shipments

A consolidated freight invoice may cover:

• Several suppliers;
• Multiple import declarations;
• Different products;
• Several containers;
• More than one destination.

The importer should prepare a shipment-level allocation based on weight, volume, value, distance or another commercially reasonable method. The method should be applied consistently and supported by records.

Customs may challenge an allocation that shifts an excessive share of freight to one product merely because that product has a higher customs duty rate.

Freight, Insurance and Customs Value Evidence

A complete file should contain:

• Commercial invoice;
• Purchase contract;
• Incoterms clause;
• Bill of lading or airway bill;
• Freight invoice;
• Insurance policy and premium invoice;
• Carrier booking confirmation;
• Packing list;
• Container details;
• Port or border entry records;
• Domestic delivery invoice;
• Freight allocation schedule;
• Bank payment records;
• Accounting entries;
• Customs declaration;
• Correspondence with the supplier or carrier.

The importer should reconcile the freight and insurance amounts with the customs declaration. Differences in currency, shipment date or allocation should be explained.

Can Customs Add Freight Automatically?

Customs may request evidence where freight or insurance is missing, understated or unclear. However, an automatic or unexplained addition may be challenged where:

• The invoice already includes the cost;
• Customs used an unsupported estimate;
• The cost relates to post-entry transport;
• The freight belongs to another shipment;
• The insurance covers unrelated risks;
• The calculation ignores contract terms;
• The same amount was added twice.

The importer should request the legal and factual basis for the adjustment and ask Customs to identify the data used.

Financial and Penalty Risks

If freight or insurance is omitted from customs value, the importer may face:

• Additional customs duty;
• Import VAT on the revised base;
• Additional customs duties;
• Interest;
• Administrative customs penalties;
• Storage and demurrage costs.

Where Customs considers the omission intentional or materially misleading, the penalty exposure may increase. A clerical or allocation error should be distinguished from deliberate undervaluation.

Post-Clearance Audits

Freight and insurance may be examined after the goods have been released. Customs may compare:

• Freight invoices;
• Bank payments;
• Accounting records;
• Carrier data;
• ERP entries;
• Customs declarations;
• Incoterms;
• Transfer-pricing records.

Under the general framework of Customs Law No. 4458, under-assessed customs duties may generally be notified within three years from the date the customs debt arose, subject to statutory exceptions.

Companies should maintain shipment-level freight records for the applicable retention period.

How Can an Importer Challenge the Addition?

The importer should request the complete assessment and calculation. The objection may argue that:

• Freight was already included in the invoice;
• Insurance was already included in the declared price;
• The cost was incurred after the Turkish entry point;
• The allocation method was incorrect;
• Customs used an unsupported estimate;
• The amount relates to another shipment;
• The same expense was counted twice;
• The penalty is disproportionate;
• Notification or limitation rules were not followed.

Under Article 242 of Customs Law No. 4458, an objection is generally filed within 15 days from lawful notification of the customs decision.

If the objection is rejected, the importer may bring proceedings before the competent tax court within the applicable procedural period. A lawsuit does not automatically suspend collection. A separate suspension-of-execution request may be necessary where immediate payment would cause serious and difficult-to-repair harm.

Settlement may be available for certain customs debts and penalties, but the importer should compare settlement with litigation and possible repayment procedures.

2026 Compliance Priorities

In 2026, Turkish Customs increasingly compares freight and insurance data with:

• Electronic customs declarations;
• Carrier platforms;
• E-invoices;
• ERP records;
• Bank payments;
• Insurance databases;
• Importer accounting systems.

Importers should create a landed-cost file before clearance, showing the invoice price, international freight, insurance, post-entry transport and domestic costs separately.

Practical Checklist

When Customs adds freight or insurance, the importer should:

1. Obtain the written adjustment and calculation.
2. Identify the exact entry point used.
3. Review the Incoterms provision.
4. Check whether the invoice already includes freight or insurance.
5. Obtain carrier and insurance records.
6. Separate pre-entry and post-entry costs.
7. Reconcile consolidated shipment allocations.
8. Check for double counting.
9. Record the notification date.
10. File an objection within the applicable deadline.

Frequently Asked Questions (FAQ)

1. Can Turkish Customs add international freight to customs value?

Yes, freight to the Turkish customs entry point may generally be included if it is not already included in the invoice price.

2. Can post-import domestic transport be excluded?

Often yes, if it is separately identified and supported by objective records.

3. Is insurance always included in customs value?

Only insurance related to transport to the relevant customs entry point and not already included in the declared price should generally be considered.

4. Do Incoterms determine customs value automatically?

No. Incoterms are important evidence, but Customs must examine the actual contract, invoice and costs.

5. Can Customs use an estimated freight amount?

It may request evidence or apply a legally permitted method where reliable data is unavailable, but an unsupported estimate can be challenged.

6. What if one freight invoice covers many declarations?

The importer should provide a reasonable, documented allocation method connecting the cost to each shipment.

7. Can Customs add freight paid by a parent company?

Potentially yes, if it relates to transport to the Turkish entry point. The importer should document the group arrangement and payment.

8. Can freight be added twice?

No. If it is already included in the invoice or another customs-value element, double counting should be challenged.

9. What is the objection deadline?

An objection is generally filed within 15 days from lawful notification under Article 242 of Customs Law No. 4458.

10. Can a freight and insurance adjustment be challenged in court?

Yes. After the administrative objection stage, tax-court proceedings may be available within the applicable procedural period.

This article is intended for general informational purposes only. To avoid any loss of rights, we recommend consulting your lawyer regarding your specific circumstances.

Legal Support for Freight and Insurance Customs Disputes

Fırat Fesih Kaya Law Office advises foreign companies, Turkish importers, manufacturers, distributors, logistics providers and insurers on customs valuation and freight-related assessments.

Lawyer Fırat Fesih Kaya can assist with freight and insurance calculations, Incoterms analysis, customs audits, additional-duty assessments, import VAT disputes, administrative objections, suspension requests and tax-court proceedings.

For urgent legal support:

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