Are free samples, discounted imports and promotional goods really duty-free in Turkey? Learn how Turkish customs determines customs value when there is no purchase price, when discounts may be rejected, what evidence importers need and how international companies can challenge customs assessments in 2026.

International companies frequently send products to Turkey without charging the Turkish recipient the ordinary commercial price. A foreign manufacturer may provide free samples to a Turkish distributor, send promotional products to support a marketing campaign, supply bonus goods together with a large commercial order or grant substantial volume, launch, clearance or distributor discounts. A commercial invoice may therefore state “free of charge,” “no commercial value,” “sample,” “promotional goods” or show a price substantially below the supplier’s normal list price. One of the most dangerous assumptions for an importer is that a zero invoice automatically means a zero customs value. It does not. Customs value and the amount appearing on a commercial invoice are different legal concepts. Under Turkish customs legislation, customs value is determined according to the valuation methods prescribed by Customs Law No. 4458 and the Customs Regulation. The transaction-value method is generally considered first, followed, where it cannot be used, by the transaction value of identical goods, transaction value of similar goods, deductive value, computed value and finally the fallback method. (https://ticaret.gov.tr) This distinction is especially important for free samples and promotional goods because there may be no sale for export to Turkey capable of supporting the ordinary transaction-value method. Discounts create a different problem: there may be a genuine sale, but customs can investigate whether the reduced price represents the real commercial transaction. International companies importing samples, bonus goods or deeply discounted products into Turkey in 2026 should therefore document the commercial circumstances before the shipment reaches customs.

Does “Free of Charge” Mean Zero Customs Value?

No.

The absence of payment does not necessarily mean that imported goods have no customs value.

Customs value exists for the purpose of applying ad valorem customs duties and relevant trade measures.

Accordingly, customs authorities may need to establish a value even where the recipient paid nothing to the foreign supplier. (https://ticaret.gov.tr)

Why Does This Matter?

Suppose a German manufacturer sends ten demonstration machines to its Turkish distributor without charge.

Each machine ordinarily sells for EUR 20,000.

Writing “FREE SAMPLE – VALUE EUR 0” on the invoice does not necessarily mean that Turkish customs must accept a customs value of zero.

The machines remain economically valuable goods.

Free Goods and Customs Exemptions Are Different Questions

Another common mistake is confusing “free of charge” with “exempt from customs duties.”

These concepts are not synonymous.

A shipment may be supplied free of charge but still require customs valuation and taxation unless a specific exemption or other legal treatment applies.

What Is a Free Sample?

Commercial samples are commonly supplied so that a potential customer, distributor or business partner can examine a product before purchasing larger quantities.

Examples include cosmetics, textile samples, machine components, electronic devices, pharmaceutical-related samples, industrial materials and consumer products.

The customs treatment depends on the characteristics, quantity, purpose and applicable legal regime.

Not Everything Called a “Sample” Is Necessarily Treated as One

Customs authorities can examine the objective nature of the goods.

If an importer receives 5,000 fully marketable products and labels them “samples,” authorities may question whether the shipment genuinely has a sample function.

Quantity Can Be Important

A few units sent for testing may be commercially understandable.

Hundreds or thousands of ordinary retail units require a more detailed explanation.

Commercial Usability Can Also Matter

A product that can immediately be sold in the Turkish market may receive different scrutiny from a product permanently marked or modified so that it can only be used for demonstration or testing.

“Not for Resale” Labels

Marking goods “Not for Resale” can support the company’s explanation of their intended use.

But the label itself does not automatically determine customs value or establish an exemption.

The actual transaction remains relevant.

How Is a Free Sample Valued?

Where there is no sale for export to Turkey capable of supporting the transaction-value method, the customs valuation framework moves through the legally prescribed alternative methods.

The Ministry of Trade describes six methods applied sequentially: transaction value, transaction value of identical goods, transaction value of similar goods, deductive value, computed value and the fallback method. (https://ticaret.gov.tr)

Identical Goods Can Become Important

Suppose a manufacturer sends 100 units free of charge.

The same manufacturer sold 10,000 identical units to another Turkish importer at EUR 25 each around the same period.

That transaction may become relevant to the valuation analysis.

Quantity Differences Must Be Considered

However, customs should not mechanically assume that the 100 free units must necessarily be valued at exactly the same unit price as a 10,000-unit commercial shipment.

Under the identical-goods method, commercial-level and quantity differences may require adjustments where adequately supported. (https://ticaret.gov.tr)

Similar Goods Can Be Used Where Appropriate

Where there are no qualifying identical-goods transactions, sales of similar goods may become relevant under the statutory sequence.

Again, genuine comparability matters.

Customs Cannot Simply Pick an Arbitrary Price

This protection is important for importers.

The Ministry of Trade expressly states that the fallback method cannot be based on arbitrary or fictitious values, minimum customs values or a system automatically choosing the higher of two alternative values. (https://ticaret.gov.tr)

Promotional Goods Create Similar Problems

A foreign company may provide promotional products to its Turkish subsidiary or distributor.

Examples include display products, branded accessories, point-of-sale materials, launch products and merchandise supplied for marketing campaigns.

The fact that the foreign company does not request payment does not automatically settle the customs valuation issue.

Example: Free Promotional Products

A foreign cosmetics company sells EUR 1 million of products to its Turkish distributor.

It additionally supplies 20,000 promotional cosmetic products free of charge for a launch campaign.

The importer should determine whether those goods are genuinely separate free promotional products, part of the overall commercial pricing arrangement or economically connected with the paid shipment.

“Buy 100, Get 10 Free” Arrangements

Bonus-goods transactions require particularly careful analysis.

Suppose an importer purchases 100 units for EUR 100 each and receives another 10 units “free.”

Commercially, the transaction may be viewed as:

EUR 10,000 paid for 110 units.

The customs analysis should therefore consider the entire commercial arrangement rather than mechanically assigning zero economic value to ten units.

Hidden Discount Versus Free Goods

The difference matters.

The supplier may genuinely give separate promotional goods.

Alternatively, the “free” units may effectively represent a quantity discount on the total shipment.

Contracts, price lists and correspondence can clarify the arrangement.

Volume Discounts

Legitimate volume discounts are common in international commerce.

An importer buying 100,000 units may receive a substantially lower price than an importer purchasing 500 units.

A low unit price therefore does not automatically establish undervaluation.

Customs May Ask Why the Discount Exists

The importer should be able to demonstrate the commercial basis.

Useful evidence may include the supply agreement, supplier price lists, volume thresholds, purchase orders and historical transactions.

Example: Quantity Discount

Supplier’s standard price:

EUR 50 per unit.

Orders above 10,000 units:

EUR 42 per unit.

Orders above 50,000 units:

EUR 35 per unit.

The Turkish importer purchases 75,000 units at EUR 35.

A documented pricing policy can strongly support the declared transaction price.

Discounts Should Exist Before the Customs Dispute

A company should not attempt to create a discount agreement after customs questions the declared value.

Contemporaneous documentation is substantially more persuasive.

Early-Payment Discounts

A supplier may reduce the purchase price because the importer pays before production or shipment.

The payment terms should appear in the commercial agreement or other contemporaneous documentation.

Distributor Discounts

Exclusive or high-volume distributors may receive preferential pricing.

The distribution agreement can explain the commercial reason.

Launch Discounts

A manufacturer entering the Turkish market may deliberately offer introductory pricing.

Marketing plans, management approvals and contemporaneous correspondence can support the discount.

Clearance Discounts

Obsolete or discontinued products may be sold at substantial reductions.

Inventory reports and supplier records can demonstrate why.

Damaged or Second-Quality Goods

Products containing defects may legitimately be sold below the standard price.

Inspection reports, photographs, quality certificates and contractual descriptions should establish the condition of the goods.

Seasonal Discounts

Fashion, tourism-related products and seasonal consumer goods can lose substantial value after a selling season.

A genuine end-of-season discount can therefore have a commercial explanation.

Retroactive Discounts Are More Complicated

A supplier may issue a credit note after importation.

For example, a Turkish distributor purchases goods throughout the year and receives a 5% rebate after meeting an annual sales target.

The customs implications require separate analysis.

Annual Rebates

The importer should determine:

why the rebate was granted;

when the right to the rebate arose;

how it was calculated;

which imports it concerns;

and how it was reflected in accounting records.

Credit Notes Do Not Automatically Reduce Customs Value

A later credit note should not simply be deducted from historical customs values without analyzing its legal and commercial basis.

Transfer Pricing Adjustments

Related companies may also make year-end debit or credit adjustments.

These should be distinguished from ordinary commercial discounts.

A transfer-pricing adjustment can create separate customs valuation issues.

Related-Party Discounts Receive Additional Scrutiny

Suppose a foreign parent sells goods to its Turkish subsidiary at a 40% discount compared with independent customers.

Customs may examine whether the relationship influenced the price.

However, the Ministry of Trade confirms that the existence of a relationship alone is not sufficient to reject transaction value; the circumstances of the sale must be examined. (https://ticaret.gov.tr)

Free Samples From a Parent Company

Related-party structures can therefore combine two valuation issues:

there is no ordinary sale for the free goods;

and the supplier and recipient are related.

The company should prepare particularly strong evidence explaining the purpose and value of the shipment.

What Documents Should Be Prepared for Free Samples?

The importer should preserve the supplier’s sample letter, pro forma or customs invoice, product description, quantity information, ordinary commercial price where relevant, reason for shipment and records showing the intended testing or promotional use.

Sample Request

If the Turkish company requested samples before entering a supply agreement, preserve that correspondence.

It helps demonstrate commercial purpose.

Testing Records

Where products are imported for laboratory or technical testing, preserve test protocols, laboratory records and subsequent reports.

Demonstration Equipment

Where machinery is imported solely for demonstration, documents should explain where it will be used, for how long and whether it will later be exported, sold or retained.

Promotional Campaign Records

For promotional goods, preserve campaign plans, distribution records and marketing approvals.

These can help establish why large quantities were supplied without direct payment.

Customs Invoice Should Be Accurate

A customs or pro forma invoice for free goods should describe the transaction honestly.

Writing “no commercial value” where goods plainly have significant economic value can create unnecessary suspicion.

Avoid Artificial EUR 1 Values

Companies sometimes place EUR 1 on an invoice simply because their ERP system requires a numerical amount.

This should not be assumed to represent the legally correct customs value.

Explain Nominal Invoice Values

If the invoice contains a nominal amount for administrative reasons, accompanying documentation should explain this clearly.

Do Not Confuse Invoice Value With Customs Value

The commercial or pro forma invoice can state that no payment is due while customs valuation is established separately according to the applicable legal method.

Buyer-Supplied Free Materials

There is another form of “free” transaction that creates the opposite customs problem.

Sometimes the importer supplies materials, components, tools, moulds, designs or engineering to the foreign manufacturer free of charge or at a reduced price.

These are commonly known as assists.

Assists Can Increase Customs Value

The Ministry of Trade’s customs valuation guidance states that certain goods and services supplied directly or indirectly by the buyer free of charge or at reduced cost for use in producing and selling the imported goods for export can require an appropriate addition to the price actually paid or payable. (https://ticaret.gov.tr)

Example: Free Mould

A Turkish automotive company provides a EUR 500,000 mould free of charge to a foreign manufacturer.

The manufacturer then uses the mould to produce components imported into Turkey.

The importer should not assume that the commercial invoices for the components alone necessarily establish the complete customs value.

Free Components

Similarly, a Turkish company may provide specialized components to a foreign manufacturer without charge.

The value attributable to those materials may require customs analysis.

Engineering and Design

Certain engineering, development, artwork, design work, plans and sketches performed outside the country of importation and necessary for producing the imported goods may also fall within the customs valuation additions when supplied by the buyer under the relevant conditions. (https://ticaret.gov.tr)

Free Samples Can Therefore Create Two Opposite Issues

Goods supplied free to the Turkish importer: customs must determine their value despite the absence of an ordinary purchase price.

Goods or services supplied free by the Turkish importer to the foreign producer: their value may potentially need to be added to the imported goods’ transaction value.

International companies should distinguish these scenarios.

What Evidence Can Customs Request?

A valuation investigation may involve purchase orders, supply agreements, price lists, commercial and pro forma invoices, bank records, accounting records, promotional agreements, credit notes, rebate calculations and correspondence.

Supplier Price Lists Can Be Important

The ordinary selling price can help explain the commercial context.

But list price should not automatically be treated as customs value.

Actual commercial transactions may occur at different prices.

Historical Imports

Customs may compare free or discounted goods with previous paid shipments involving the same products.

Foreign Supplier Records

The supplier’s accounting and inventory records can demonstrate that goods were genuinely supplied without payment.

Bank Records

Where goods are described as free, banking evidence can help establish that no hidden payment was made.

Beware of Separate Payments

If the importer receives “free” promotional goods but simultaneously makes unexplained payments to the supplier, customs may investigate whether the goods were actually free.

Third-Party Payments

Payments to another company may also be examined where authorities suspect that they economically relate to the imported goods.

Marketing Contributions

A supplier may provide promotional goods but require the Turkish distributor to contribute to a marketing fund.

The relationship between the two arrangements should be examined.

Advertising Agreements

A genuine advertising obligation should be documented separately.

Free Replacement Goods

Warranty replacements create another common scenario.

A foreign manufacturer may send a replacement product without charging the Turkish customer or distributor.

The absence of payment does not by itself answer every customs valuation question.

Warranty Documentation

The importer should preserve the original purchase, warranty terms, defect report and replacement authorization.

Free Spare Parts

Manufacturers may also supply free spare parts under a warranty or maintenance arrangement.

Again, the overall commercial structure matters.

Samples That Are Later Sold

If goods imported for testing or promotion are later sold commercially, the company should examine whether the change in use creates additional customs or regulatory consequences under the particular regime applied at importation.

Keep Distribution Records

Companies importing large quantities of promotional goods should document where those products went.

A shipment described as promotional that later appears entirely in commercial inventory can create credibility problems.

Customs Valuation Is Not Based on the Highest Possible Price

Where the transaction-value method cannot be used, the statutory sequence still matters.

For identical goods, the Ministry of Trade states that commercial-level and quantity differences should be taken into account where properly demonstrated, and if more than one qualifying value is identified, the lowest is used for that method. (https://ticaret.gov.tr)

Fallback Valuation Has Limits

The final method cannot lawfully rely on minimum customs values, arbitrary values or automatically selecting the higher of two alternatives. (https://ticaret.gov.tr)

This can provide an important argument where customs assigns an unsupported value to promotional or free goods.

Can Customs Impose Additional Duties?

Yes, where authorities determine that the declared customs value was too low and that additional import duties should have been paid.

Can Administrative Penalties Follow?

Potentially.

Where an incorrect customs value results in deficient duties, administrative penalty provisions may become relevant depending on the facts and applicable rules.

Can a Free-Goods Dispute Become Criminal?

A genuine disagreement about how promotional goods should be valued is not automatically a criminal matter.

The risk becomes more serious where authorities allege deliberate use of fake invoices, concealed payments, artificial discounts or other intentional conduct designed to evade customs liabilities.

Do Not Create Fake Discount Documents

If customs challenges the price, companies should never respond by creating retrospective discount schedules or altering supplier invoices.

Do Not Backdate Promotional Agreements

The original commercial record should be preserved.

Do Not Delete Price Lists

An unfavorable list price can usually be explained more safely than destruction of evidence.

Internal Consistency Is Essential

The explanation given to customs should correspond with the company’s accounting records, supplier records, bank transfers and commercial correspondence.

Example: Genuine Free Samples

A medical equipment manufacturer sends five demonstration units to its Turkish distributor without charge.

The distributor produces the sample request, correspondence explaining the demonstration purpose, ordinary product information and records showing that the units are not commercial inventory.

The company can then address customs valuation through the appropriate legal methodology rather than pretending the products have no economic value.

Example: Genuine Volume Discount

A foreign manufacturer ordinarily sells a component for EUR 80.

Its documented pricing policy provides EUR 55 pricing for annual purchases exceeding 100,000 units.

The Turkish importer orders 150,000 units and pays EUR 55.

The supplier’s pricing policy, contract, purchase order, invoice, bank transfer and accounting records all correspond.

This provides a substantially stronger defense against an allegation of artificial undervaluation.

Example: Promotional Goods Connected With Paid Goods

A cosmetics importer buys 50,000 products and receives 5,000 additional units for a promotional campaign.

Rather than declaring the 5,000 units as economically worthless, the company should analyze whether the overall arrangement constitutes bonus goods, a quantity discount or genuinely separate promotional merchandise.

Example: Artificial Discount

A Turkish importer declares goods at a 60% “special discount.”

Bank records later show that the importer paid the remaining amount to another company controlled by the supplier.

Authorities may investigate whether the discount was genuine or whether part of the purchase price was concealed.

How Should International Companies Prepare?

Companies regularly importing samples and promotional goods should establish a written customs policy.

The commercial team should not decide customs values by simply entering “zero” into the ERP system.

Customs and Marketing Teams Should Communicate

Marketing departments often arrange free product shipments without realizing that customs valuation is required.

The customs team should review promotional campaigns before shipment.

Procurement Teams Should Document Discounts

A procurement manager negotiating a 45% discount should preserve the commercial reason.

This can become critical years later during a post-clearance audit.

Finance Teams Should Track Rebates

Annual rebates, credit notes and free-goods programs should be reconciled with customs declarations.

Review Related-Party Programs Separately

Multinational groups should examine whether discounts or free products between affiliates differ substantially from arrangements offered to independent customers.

Historical Audit

If a company discovers that it has declared thousands of free promotional goods at nominal values, it should identify affected declarations and assess potential exposure rather than waiting for customs authorities to discover the pattern.

First 24 Hours After Customs Challenges the Value

Preserve the customs declaration, invoice, supply agreement, promotional agreement, price lists, purchase orders, correspondence and accounting records.

Determine precisely why the goods were free or discounted.

First 72 Hours

Identify comparable commercial sales, reconstruct the pricing arrangement, confirm whether any direct or indirect payment was made and obtain evidence from the foreign supplier.

First Week

Review previous imports involving the same sample, discount or promotional program; determine the legally appropriate valuation methodology; calculate potential additional duty and penalty exposure; and protect applicable objection deadlines.

2026 Legal Strategy for Free Samples, Discounts and Promotional Goods in Turkey

An importer facing a Turkish customs valuation dispute involving free samples, promotional products or discounted goods should first determine the true commercial structure of the shipment. Where goods were genuinely supplied without a sale price, the company should not assume that zero invoice value means zero customs value; instead, the statutory valuation methods should be considered in their prescribed sequence. Where the goods were sold at a discount, the importer should prove that the reduced price was genuinely negotiated and actually paid through contemporaneous contracts, price lists, purchase orders, bank transfers and supplier accounting records. Bonus-goods arrangements such as “buy 100, receive 10 free” should be analyzed as an overall commercial transaction rather than automatically assigning zero value to the additional units. Promotional shipments should be supported by marketing plans and distribution records. Related-party discounts require additional scrutiny regarding whether the corporate relationship influenced the price. Companies should also distinguish goods received free of charge from materials, tools, designs or other assists supplied free or at reduced cost by the buyer to the foreign producer, because the latter can require additions to customs value under the applicable rules. (https://ticaret.gov.tr) The practical strategy is therefore: identify why the goods were supplied free or discounted → determine whether a sale exists → preserve contemporaneous commercial evidence → identify the appropriate customs valuation method → document legitimate discounts → analyze bonus and promotional goods → reconcile bank payments → check for hidden or third-party payments → analyze buyer-supplied assists → review related-party transactions → compare identical and similar goods correctly → challenge arbitrary customs values → audit previous shipments → calculate potential exposure → protect objection deadlines → pursue the appropriate administrative and judicial remedies.

Frequently Asked Questions

1. Do free samples automatically have a customs value of zero in Turkey?

No. A zero purchase price does not automatically mean zero customs value. Where the transaction-value method cannot be used, the other customs valuation methods must be considered according to their statutory sequence. (https://ticaret.gov.tr)

2. Are promotional goods automatically exempt from customs duties?

No. “Promotional” and “free of charge” do not by themselves establish a customs exemption. The specific goods, purpose, applicable regime and valuation rules must be examined.

3. Can Turkish customs reject a large commercial discount?

Customs may scrutinize a substantial discount, but a low price is not automatically artificial. Volume, commercial level and other proven differences can be relevant to valuation. (https://ticaret.gov.tr)

4. How can an importer prove that a discount is genuine?

The strongest evidence can include a pre-existing supply agreement, supplier pricing policy, volume-discount schedule, purchase order, correspondence, commercial invoice, bank payment and consistent accounting records.

5. How are “buy 100, get 10 free” imports treated?

The complete commercial arrangement should be analyzed. The additional units may economically form part of a quantity discount or overall price arrangement rather than being treated automatically as goods with zero value.

6. Can customs use identical or similar goods to value free samples?

Potentially, yes, where the applicable valuation sequence reaches those methods. Commercial level, quantity and other relevant differences must be considered where appropriate. (https://ticaret.gov.tr)

7. Can customs simply assign its own estimated price to free goods?

Customs valuation must follow the applicable statutory framework. The fallback method cannot be based on arbitrary or fictitious values or minimum customs values. (https://ticaret.gov.tr)

8. Do free moulds or components supplied by the Turkish buyer affect customs value?

Potentially, yes. Certain materials, components, tools, moulds, designs and other goods or services supplied by the buyer free of charge or at reduced cost for production of imported goods can require an appropriate addition to the price. (https://ticaret.gov.tr)

9. Can customs investigate previous free promotional shipments?

Yes, potentially within the applicable legal framework. A recurring practice involving nominal or zero customs values can lead to examination of historical declarations.

10. What should an importer do when customs challenges the value of samples or promotional goods?

Preserve the original shipment documents, explain the commercial purpose, obtain supplier evidence, identify comparable transactions, determine the appropriate customs valuation method, review previous shipments and protect all applicable objection deadlines.

Legal Support for Customs Valuation of Samples, Discounts and Promotional Goods in Turkey

Disputes concerning free and discounted imports can expose international companies to customs valuation adjustments, additional import duties, administrative penalties, historical declaration audits and, where intentional concealment is alleged, more serious customs investigations.

Fırat Fesih Kaya Law Office provides legal assistance to foreign exporters, multinational companies, Turkish importers and foreign-owned businesses facing customs valuation disputes involving free samples, bonus products, promotional merchandise, rebates and commercial discounts in Turkey.

Fırat Fesih Kaya can analyze the appropriate customs valuation method, prepare evidence supporting legitimate discounts and promotional arrangements, review identical and similar-goods comparisons, examine buyer-supplied assists, challenge additional customs assessments and penalties, review historical import declarations and represent companies in administrative and judicial proceedings.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey