Customs Valuation of Used Machinery in Turkey: How Is the Import Value Determined? — 2026 Current Guide

How is the customs value of used machinery determined in Turkey? Learn the rules for second-hand equipment, depreciation, related-party purchases, leasing, valuation evidence and appeals in 2026.

Importing used machinery into Turkey can create both customs valuation and regulatory risks. A second-hand machine may have a low purchase price because of age, operating hours, technical defects, outdated technology or refurbishment requirements. Nevertheless, Turkish Customs may question an invoice that appears unusually low or is not supported by reliable evidence.

The customs value of used machinery is not determined automatically by the original purchase price, book value or depreciation shown in the exporter’s accounts. Customs must examine the actual transaction, the condition of the machine and the applicable valuation method.

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

What Is Used Machinery?

Used machinery may include:

• Production lines;
• CNC machines;
• Printing equipment;
• Packaging machinery;
• Industrial robots;
• Construction equipment;
• Agricultural machinery;
• Medical or laboratory equipment;
• Energy-generation equipment;
• Compressors and generators;
• Textile machinery;
• Recycling and processing equipment;
• Mining and quarry machinery.

The machine’s age alone does not determine the customs value. Customs may also consider condition, capacity, maintenance history, remaining useful life, technology, accessories and market demand.

Transaction Value Is the Starting Point

Where the machine was purchased for export to Turkey, the first method is generally the transaction value: the price actually paid or payable, subject to legally required additions.

The importer should prove:

• The sale was genuine;
• The invoice price was actually agreed;
• Payment was made or remains payable;
• The machine corresponds to the invoice;
• No hidden payment exists;
• The seller and buyer relationship did not distort the price;
• Freight and insurance were correctly treated;
• Required additions were included.

A low price can be accepted if it reflects the machine’s actual condition and commercial value.

Why Does Customs Question Used-Machine Prices?

Turkish Customs may investigate where:

• The invoice price is far below market value;
• The machinery was purchased from a related company;
• The machine was transferred within a group;
• The declared value is lower than the seller’s book value;
• The invoice does not mention defects;
• The machine appears recently refurbished;
• The equipment has high capacity or advanced technology;
• Payment records do not match the invoice;
• The machine was acquired through leasing or financing;
• Accessories or tooling were omitted;
• The declared price does not include freight or insurance.

Customs may request an expert report, market comparison or technical inspection.

Evidence for the Value of Used Machinery

A strong customs file should contain:

• Sales contract;
• Commercial invoice;
• Purchase order;
• Payment records;
• Bank statements;
• Serial number;
• Manufacturing year;
• Operating-hour records;
• Maintenance history;
• Repair records;
• Technical specifications;
• Photographs and videos;
• Condition report;
• Inspection report;
• Valuation or appraisal report;
• Auction records;
• Comparable used-machine prices;
• Warranty terms;
• Refurbishment invoices;
• Freight and insurance documents;
• Export declaration;
• Import declaration.

The documents should explain why the machine is worth the declared amount.

Depreciation and Book Value

Accounting depreciation can support the analysis, but it does not automatically determine customs value.

A machine may have:

• A low accounting book value but significant market value;
• A high historical cost but limited current value;
• A low purchase price because of defects;
• A high price because of refurbishment;
• A different value in Turkey and the exporting country.

Customs may consider book value as evidence but can request additional market and technical information.

The importer should distinguish:

• Historical acquisition cost;
• Accounting net book value;
• Market value;
• Purchase price;
• Residual value;
• Refurbishment cost;
• Replacement cost;
• Insurance value.

Technical Condition and Defects

The condition of used machinery is often the most important factor.

The importer should document:

• Visible damage;
• Missing components;
• Wear and tear;
• Production capacity;
• Accuracy and tolerance;
• Safety deficiencies;
• Software limitations;
• Maintenance needs;
• Remaining useful life;
• Obsolescence;
• Repair costs;
• Decommissioning expenses.

A machine purchased at a discount because it cannot operate without major repairs should be supported by an independent technical report and repair quotations.

Refurbished and Reconditioned Machinery

Refurbished machinery may have a value significantly different from its original used condition.

Customs may examine:

• Who performed the refurbishment;
• The cost of parts and labour;
• The date of refurbishment;
• New components;
• Updated software;
• Safety upgrades;
• Warranty;
• Testing and certification;
• The value before and after refurbishment.

Refurbishment costs incurred before importation may be relevant to customs value. Post-importation repair or installation costs may require separate treatment if they are separately identified.

Related-Party Purchases

A used-machine purchase between related companies may receive additional scrutiny. The importer should provide:

• Group-structure documents;
• Intercompany sale agreement;
• Transfer-pricing analysis;
• Independent valuation;
• Comparable market prices;
• Technical condition report;
• Payment records;
• Approval documents;
• Explanation of the commercial reason for the transfer.

Related-party status does not automatically invalidate the invoice. The importer can prove that the price reflects the machine’s condition and market circumstances.

Free-of-Charge or Transferred Machinery

Machinery may be transferred without payment as part of:

• A corporate restructuring;
• A capital contribution;
• A factory relocation;
• A merger or acquisition;
• A group reorganisation;
• A lease termination;
• A temporary transfer;
• A replacement arrangement.

Where no sale price exists, Customs may use an alternative valuation method. The importer should provide an independent appraisal and explain the legal and commercial basis of the transfer.

A zero-value invoice may be commercially accurate but will not necessarily be accepted as the customs value.

Leasing and Finance Arrangements

Used machinery may enter Turkey under:

• Finance lease;
• Operating lease;
• Rental;
• Temporary admission;
• Sale and leaseback;
• Loaned equipment;
• Demonstration arrangement.

The customs treatment depends on whether ownership is transferred, whether the machine will be re-exported and whether the lease payments represent the price of the goods.

The importer should provide:

• Lease agreement;
• Purchase option;
• Payment schedule;
• Residual-value clause;
• Ownership documents;
• Insurance;
• Re-export undertaking;
• Customs procedure approval.

Freight, Insurance and Additional Costs

Freight and insurance costs to the Turkish customs entry point may generally be relevant to customs value if they are not already included in the invoice price.

Potential additions may also include:

• Packing costs;
• Commissions;
• Buyer-supplied tools;
• Engineering and design;
• Royalties or licence fees;
• Accessories and attachments;
• Free-of-charge components.

Post-import transport, installation, maintenance and technical assistance may often be excluded if separately identified and documented.

Import Controls for Used Machinery

Customs value is only one part of the import process. Used, refurbished or reconditioned machinery may also be subject to:

• Import permits;
• Product-safety rules;
• CE requirements;
• Machinery-safety documentation;
• Environmental controls;
• Energy-efficiency requirements;
• TAREKS or other conformity procedures;
• Technical inspection;
• Waste and hazardous-material rules;
• Special rules under the annual Import Regime.

A machine may have an acceptable customs value but still be detained because the required technical or import authorisation is missing.

Alternative Valuation Methods

If Customs rejects the transaction value, it may consider:

1. The value of identical used machinery;
2. The value of similar used machinery;
3. Deductive value;
4. Computed value;
5. A fallback method.

The importer should ask Customs to explain:

• Why the invoice price was rejected;
• Which comparable machinery was selected;
• How age and condition were adjusted;
• Whether refurbishment was considered;
• How accessories were valued;
• How freight and insurance were treated;
• How the final duty was calculated.

A reference price that ignores the machine’s age, damage or operating hours may be challenged.

Customs Audits and Post-Clearance Assessments

Turkish Customs may investigate used machinery after release. The audit may examine:

• Several machines;
• Earlier imports;
• Related-party purchases;
• Leasing arrangements;
• Bank payments;
• Repair and refurbishment costs;
• Transfer-pricing files;
• Technical 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.

Financial and Penalty Risks

If Customs concludes that the machinery was undervalued, the importer may face:

• Additional customs duty;
• Import VAT;
• Additional customs duties;
• Interest;
• Administrative customs penalties;
• Storage and demurrage;
• Delayed production;
• Financing losses;
• Contractual disputes.

A genuine valuation error should be distinguished from intentional concealment. False invoices, hidden payments or fabricated condition reports may create more serious administrative or criminal exposure.

How Can the Importer Challenge the Valuation?

The importer may argue that:

• The invoice reflects the actual purchase price;
• The machine was defective or obsolete;
• Customs used new-machine prices;
• Comparable machinery was not genuinely comparable;
• Age and operating hours were ignored;
• Refurbishment costs were double counted;
• Post-import costs were incorrectly included;
• The transaction was not between related parties;
• The alternative method was applied prematurely;
• The duty and penalty calculation is incorrect.

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 Checklist

Before importing used machinery, the company should:

1. Confirm the correct HS classification.
2. Check whether used-goods import controls apply.
3. Obtain an independent technical appraisal.
4. Document age, capacity and operating hours.
5. Record defects and repair costs.
6. Prepare comparable market evidence.
7. Verify related-party pricing.
8. Separate freight and insurance.
9. Identify accessories and tooling.
10. Prepare customs and product-safety documents.
11. Maintain payment and accounting records.
12. Review the file before the customs declaration is submitted.

Frequently Asked Questions (FAQ)

1. Is the purchase price of used machinery automatically accepted?

No. Customs may examine whether the price is genuine, commercially justified and supported by evidence.

2. Can accounting book value determine customs value?

Not automatically. Book value may support the analysis but does not necessarily equal market or transaction value.

3. How can defects reduce customs value?

Defects may justify a lower price if supported by technical reports, photographs, repair quotations and contractual evidence.

4. Can Customs compare used machinery with new machinery?

It may use comparable data, but differences in age, condition, capacity and technology should be taken into account.

5. Are related-party machinery transfers automatically rejected?

No. An independent appraisal and transfer-pricing evidence may demonstrate that the price is arm’s length.

6. How is machinery transferred without payment valued?

Customs may apply an alternative method using comparable machinery, computed value or another legally permitted approach.

7. Are refurbishment costs included in customs value?

Costs incurred before importation may be relevant, while post-import costs may often be excluded if separately identified.

8. Can used machinery be imported temporarily?

Possibly, if the conditions of temporary admission or another special customs procedure are satisfied.

9. Can Customs reassess used machinery after release?

Yes. Post-clearance audits may result in additional duty, VAT, interest and penalties.

10. What is the deadline to challenge a used-machinery 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 Used Machinery Imports

Fırat Fesih Kaya Law Office advises foreign companies, manufacturers, investors, leasing companies and Turkish importers on used machinery valuation and import compliance.

Lawyer Fırat Fesih Kaya can assist with technical appraisal, customs valuation, related-party transfers, temporary admission, import permits, product-safety documentation, 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