Customs Valuation of Samples and Prototypes in Turkey: Import Rules for Foreign Companies — 2026 Current Guide

How are samples and prototypes valued in Turkey? Learn the customs rules for free-of-charge, temporary and testing imports, required documents, VAT risks and legal remedies in 2026.

Foreign companies often send samples and prototypes to Turkey for testing, demonstrations, customer approval, research, exhibitions or product development. Although these goods may have little or no commercial resale value, Turkish Customs may still require a customs value and supporting documentation.

The statement “no commercial value” does not automatically mean that no customs duty or import VAT is payable. The applicable result depends on the purpose of the shipment, customs procedure, product type, declared value, temporary-import conditions and whether the goods will be returned, destroyed or sold in Turkey.

What Is a Sample or Prototype?

A sample is generally a limited quantity of goods sent to demonstrate a product, obtain orders, conduct testing or evaluate market interest.

A prototype is usually a development or pre-production item supplied for:

• Research and development;
• Technical testing;
• Customer approval;
• Demonstration;
• Design verification;
• Compatibility testing;
• Performance trials;
• Exhibition or presentation;
• Regulatory testing;
• Product development.

The customs treatment depends on the actual purpose, not merely the description on the invoice.

“No Commercial Value” Is Not the Same as “Zero Customs Value”

A pro forma invoice may state that the goods have no commercial resale value. This can explain the commercial purpose, but Customs may still require a value for:

• Customs control;
• Import VAT calculation;
• Statistical purposes;
• Risk analysis;
• Temporary-admission security;
• Product-safety review;
• Verification of the transaction.

If the goods were supplied free of charge, Customs may use an alternative valuation method based on identical or similar goods, deductive value, computed value or a fallback method.

The Turkish Ministry of Trade explains the customs valuation methods in its official customs valuation guidance.

Samples Imported for Testing or Demonstration

Samples may be imported for:

• Laboratory testing;
• Customer demonstrations;
• Product evaluation;
• Trade fairs;
• Technical trials;
• Market research;
• Sales presentations;
• Compatibility checks.

The importer should clearly state the purpose and whether the sample will be:

• Returned abroad;
• Destroyed under customs supervision;
• Consumed during testing;
• Distributed without charge;
• Sold after testing;
• Converted into another product;
• Used in production.

A sample intended for resale may be treated differently from a sample that will be destroyed or re-exported.

Prototypes and Temporary Admission

A prototype may qualify for temporary admission or another special customs procedure if the legal conditions are satisfied.

Potential requirements may include:

• A clear re-export commitment;
• Identification by serial number;
• Security or guarantee;
• A defined period of stay;
• No unauthorised sale or transfer;
• Customs approval;
• Record-keeping;
• Re-export or approved destruction.

Temporary admission is not automatic merely because the product is called a prototype. The importer should apply for the appropriate procedure before the goods arrive whenever possible.

If the prototype is later sold, transferred, consumed or permanently used in Turkey, the importer may need to change the customs procedure and pay the applicable duties and taxes.

How Is the Value of a Free-of-Charge Sample Determined?

Where no sale price exists, the importer should provide:

• Manufacturer’s price list;
• Comparable sales;
• Production cost;
• Supplier quotation;
• Insurance value;
• Replacement value;
• Previous import value;
• Technical value;
• Cost of materials and production.

The declared value should not be artificially reduced simply because the goods are free of charge. A zero invoice may be commercially accurate but may not be accepted as the customs value.

A reasonable value should be declared for customs purposes, with the commercial “free sample” status explained separately.

Courier and Express Shipments

Samples and prototypes frequently arrive by express courier. The simplified procedure may reduce paperwork, but it does not eliminate customs obligations.

The importer should ensure that the courier receives:

• Accurate product description;
• Correct HS code;
• Quantity;
• Weight;
• Customs value;
• Purpose of import;
• Return or destruction information;
• Origin;
• Technical documents;
• Consignee details.

Descriptions such as “sample,” “prototype” or “parts” may be too general for Customs and product-safety authorities.

Customs Value of Prototype Components

A prototype may contain:

• Electronic components;
• Special tooling;
• Software;
• Testing equipment;
• Replacement parts;
• Batteries;
• Chemicals;
• Technical samples;
• Packaging;
• Embedded technology.

The importer should identify each component and determine whether:

• It is part of the imported prototype;
• It will be consumed during testing;
• It will be returned;
• It is supplied free of charge;
• It is subject to a separate licence or safety requirement;
• It has a different HS classification.

A single lump-sum value may create problems where the shipment contains goods with different customs treatment.

Documents Required for Samples and Prototypes

A complete file should contain:

• Commercial or pro forma invoice;
• Packing list;
• Bill of lading or airway bill;
• Import declaration;
• Export declaration;
• Product description;
• Technical specifications;
• Serial numbers;
• Photographs;
• Purpose-of-import letter;
• Testing or research agreement;
• Customer demonstration agreement;
• Return or re-export undertaking;
• Destruction plan, where applicable;
• Manufacturer’s price list;
• Comparable-value evidence;
• Insurance records;
• Freight documents;
• Customs procedure approval;
• Product-safety and conformity documents.

The invoice should clearly state whether the goods are free of charge, temporary, non-resalable, for testing or intended for eventual return.

Samples That Will Be Destroyed

Some samples are consumed or destroyed during testing. The importer should not assume that destruction automatically eliminates customs debt.

The company should obtain prior Customs guidance regarding:

• The approved destruction method;
• Supervision requirements;
• Evidence of destruction;
• Waste or environmental obligations;
• Closure of the customs procedure;
• Security release;
• Potential duty and VAT.

Destruction without customs approval may be treated as unauthorised disposal.

Samples That Will Be Returned

Where goods are intended to be re-exported, the importer should maintain:

• Entry declaration;
• Temporary-admission approval;
• Re-export declaration;
• Transport documents;
• Serial-number records;
• Customs seals;
• Warehouse records;
• Proof of exit;
• Correspondence with the foreign supplier.

The re-export deadline should be monitored carefully. Failure to re-export on time may result in duties, taxes, penalties or enforcement action.

Samples Later Sold in Turkey

If a sample or prototype is later sold, rented, transferred or incorporated into production, the importer should review whether:

• The customs procedure must be changed;
• Duty and VAT become payable;
• A new declaration is required;
• Product-safety requirements apply;
• The initial declared value remains correct;
• The buyer becomes responsible for customs obligations.

The importer should not sell goods under a temporary procedure without confirming the legal consequences.

Product Safety and Technical Compliance

Samples and prototypes may still be subject to:

• CE requirements;
• Machinery safety rules;
• Electrical and electronic controls;
• Chemical restrictions;
• Medical-device rules;
• Radio and telecommunications requirements;
• TAREKS or similar controls;
• Environmental obligations;
• Battery and waste regulations.

Customs-value relief does not automatically remove technical compliance obligations. A prototype may require additional permits even if it is not intended for commercial sale.

Third-Country Routing

If a sample or prototype passes through another country, the importer should retain:

• Transit documents;
• Warehouse records;
• Customs seal information;
• Re-export evidence;
• Non-manipulation records;
• Carrier confirmations.

The route may be relevant to origin, customs status and valuation, especially where the sample was processed, repaired or reconfigured before entering Turkey.

Customs Audits and Valuation Risks

Turkish Customs may review samples and prototypes after release. The authority may investigate:

• Whether the goods were genuinely free of charge;
• Whether the declared value was realistic;
• Whether the goods were sold later;
• Whether temporary admission conditions were satisfied;
• Whether the shipment contained commercial goods;
• Whether the importer used samples to avoid ordinary customs duty;
• Whether the product description and HS code were accurate.

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.

Financial and Penalty Risks

If Customs rejects the declared value or procedure, the importer may face:

• Customs duty;
• Import VAT;
• Additional customs duties;
• Interest;
• Administrative penalties;
• Security enforcement;
• Storage charges;
• Demurrage;
• Re-export costs;
• Destruction expenses.

Where Customs alleges that a commercial shipment was disguised as a free sample, the matter may receive more serious scrutiny. A documentation error does not automatically establish fraud, but false descriptions or fabricated values create substantial risk.

How Can the Importer Challenge the Assessment?

The importer may challenge:

• Rejection of the declared sample value;
• Use of an unsupported comparable value;
• Refusal of temporary admission;
• Incorrect HS classification;
• Incorrect treatment of a free-of-charge shipment;
• Inclusion of post-entry costs;
• Unlawful penalty;
• Incorrect VAT calculation;
• Notification or limitation defects.

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, proceedings may be brought before the competent tax court within the applicable procedural period. An objection or 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.

2026 Compliance Priorities

In 2026, Customs increasingly compares sample declarations with:

• Courier data;
• E-invoices;
• ERP records;
• Supplier databases;
• Freight systems;
• Product-safety records;
• Re-export declarations;
• Customer sales records.

Foreign companies should use a standard sample-and-prototype template containing the purpose, value, HS code, temporary status, return date and responsible employee.

Practical Checklist

Before shipping a sample or prototype to Turkey:

1. Confirm the customs procedure.
2. Determine whether temporary admission is available.
3. Use an accurate product description.
4. Assign the correct HS code.
5. Declare a reasonable customs value.
6. Mark the invoice as free of charge only where accurate.
7. State the purpose of import.
8. Include serial numbers and photographs.
9. Provide technical and safety documents.
10. Document return, destruction or sale plans.
11. Track customs deadlines.
12. Obtain specialist advice for high-value prototypes.

Frequently Asked Questions (FAQ)

1. Can a free sample be imported into Turkey without customs duty?

Possibly, depending on the value, purpose, customs procedure and applicable exemption. “Free sample” status alone does not guarantee duty-free treatment.

2. Can an invoice state “no commercial value”?

Yes, but Customs may still require a reasonable value for control, VAT, security or valuation purposes.

3. Are prototypes automatically eligible for temporary admission?

No. The importer must satisfy the conditions of the relevant special customs procedure.

4. How is a free-of-charge sample valued?

Customs may use comparable goods, production cost or another legally permitted valuation method where no sale price exists.

5. Can a sample be sold after importation?

Possibly, but the importer may need to change the customs procedure and pay applicable duties and taxes.

6. What happens if a prototype is destroyed during testing?

Destruction should generally be documented and carried out under the procedure or supervision required by Customs.

7. Can courier companies declare prototypes with a zero value?

They may use simplified procedures, but Customs can still request a reasonable customs value and technical information.

8. Are samples subject to CE or product-safety controls?

Potentially yes. Customs-value relief does not automatically remove technical compliance obligations.

9. Can Customs audit samples after release?

Yes. Post-clearance control may examine value, procedure, sale, re-export and product classification.

10. What is the deadline to object to a customs assessment?

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

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 Sample and Prototype Imports

Fırat Fesih Kaya Law Office advises foreign companies, manufacturers, research groups, technology businesses and Turkish importers on samples, prototypes, temporary admission and customs valuation.

Lawyer Fırat Fesih Kaya can assist with customs procedures, value declarations, exemption applications, technical documentation, re-export obligations, post-clearance audits, additional-duty assessments and customs litigation.

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