Customs Valuation of Second-Hand Goods in Turkey: Legal Risks for Importers — 2026 Current Guide

How are second-hand goods valued in Turkey? Learn about used-product customs valuation, depreciation, free transfers, related-party purchases, import permits, penalties and appeal options in 2026.

Importing second-hand goods into Turkey can create difficult customs valuation questions. Used vehicles, machinery, electronics, spare parts, furniture, medical equipment and industrial assets often have no standard market price.

The declared price may be low because of age, wear, damage, missing parts, obsolescence or refurbishment. Turkish Customs may nevertheless question the invoice and determine a higher value using comparable goods or another legally permitted method.

An incorrect valuation can lead to additional customs duty, import VAT, interest, administrative penalties, storage costs and delayed delivery.

What Are Second-Hand Goods?

Second-hand goods may include:

• Used machinery;
• Industrial equipment;
• Vehicles and construction equipment;
• Refurbished electronics;
• Used medical devices;
• Spare parts;
• Laboratory equipment;
• Furniture;
• Production lines;
• Demonstration products;
• Auctioned assets;
• Leased or returned goods;
• Goods transferred within a corporate group.

The customs treatment depends on the product, condition, transaction structure, HS classification and applicable import controls.

Transaction Value Is the Starting Point

The primary customs valuation method is generally the price actually paid or payable for goods sold for export to Turkey, subject to legally required additions.

The Turkish Ministry of Trade explains the transaction-value system and alternative methods in its official customs valuation guidance.

A used-goods invoice may be accepted where:

• The sale is genuine;
• The price was agreed commercially;
• Payment is documented;
• The goods correspond to the invoice;
• No hidden payment exists;
• The parties’ relationship did not influence the price;
• Freight and insurance are correctly treated;
• The condition of the goods is documented.

There is no universal rule that a second-hand item must be valued at a fixed percentage of its original price.

Why Does Customs Question a Used-Goods Invoice?

Customs may investigate where:

• The price is significantly below comparable goods;
• The seller and buyer are related;
• The goods were transferred without payment;
• Depreciation is unsupported;
• The invoice does not mention defects;
• Refurbishment is not documented;
• A new-product reference price is used;
• Payment records differ from the invoice;
• Accessories are omitted;
• The goods were acquired through leasing or auction;
• The product is subject to special import controls.

A low price is not automatically artificial. The importer must demonstrate why the price is commercially reasonable.

Evidence of the Actual Used-Goods Price

A strong file should contain:

• Sales contract;
• Purchase order;
• Commercial invoice;
• Auction documents;
• Supplier quotation;
• Bank payment records;
• Account statement;
• Product photographs;
• Serial number;
• Manufacturing year;
• Operating-hour records;
• Maintenance history;
• Defect report;
• Independent appraisal;
• Repair quotations;
• Refurbishment invoices;
• Market comparisons;
• Freight and insurance documents;
• Export declaration;
• Import declaration.

The evidence should connect the condition of the goods to the agreed price.

Depreciation and Market Value

Depreciation may support the declared value but does not automatically determine it.

The importer should distinguish between:

• Original acquisition cost;
• Accounting book value;
• Market value;
• Purchase price;
• Residual value;
• Replacement cost;
• Insurance value;
• Refurbished value.

A machine may have a low book value but remain commercially valuable. Conversely, an asset with a high historical cost may have little market value because of technological obsolescence.

An independent appraisal should explain the valuation factors and methodology.

Defects, Damage and Missing Parts

A used product may be discounted because it:

• Does not operate;
• Has worn components;
• Requires major repair;
• Lacks accessories;
• Has software restrictions;
• Is obsolete;
• Has cosmetic or structural damage;
• Has a short remaining useful life;
• Cannot satisfy current technical standards.

The importer should document the defect before importation. Photographs, inspection reports, repair estimates and correspondence with the seller can demonstrate why the price was reduced.

A general statement such as “used and damaged” may not be enough.

Refurbished and Reconditioned Goods

Refurbished goods may have a value different from both new and unrefurbished second-hand products.

Customs may examine:

• Refurbishment date;
• Parts replaced;
• Labour costs;
• Testing;
• Warranty;
• Safety upgrades;
• Software updates;
• Production capacity;
• Condition before and after refurbishment.

Pre-import refurbishment costs may affect the value of the goods. Post-import installation, maintenance or repair may require separate treatment if separately identified.

Free Transfers and Group Reorganisations

Second-hand goods may enter Turkey without a conventional sale because of:

• Corporate restructuring;
• Capital contribution;
• Factory relocation;
• Merger;
• Lease termination;
• Group reorganisation;
• Replacement arrangement;
• Internal transfer;
• Loan or temporary use.

Where there is no sale price, Customs may apply an alternative valuation method. The importer should provide an independent appraisal, ownership records, accounting entries and an explanation of the transfer.

A zero-value or nominal-value invoice does not automatically establish zero customs value.

Leasing, Rental and Returned Goods

Used goods may be imported under:

• Finance lease;
• Operating lease;
• Rental;
• Sale and leaseback;
• Temporary admission;
• Goods returned after repair;
• Demonstration arrangements.

The importer should provide:

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

If the goods are later purchased or permanently used in Turkey, the customs procedure and duty consequences should be reviewed.

Related-Party Second-Hand Goods

Used-goods transfers between related companies may receive additional scrutiny. The importer should provide:

• Group structure;
• Intercompany agreement;
• Transfer-pricing analysis;
• Independent valuation;
• Comparable market prices;
• Condition report;
• Payment records;
• Management approvals;
• Explanation of the business purpose.

Related-party status does not automatically invalidate the price. The importer must demonstrate that the transaction was commercially determined.

Alternative Valuation Methods

If Customs rejects the transaction value, it may consider:

1. The value of identical second-hand goods;
2. The value of similar second-hand goods;
3. Deductive value;
4. Computed value;
5. A fallback method.

The importer should ask Customs to explain:

• Why the declared price was rejected;
• Which comparable goods were selected;
• How age and condition were adjusted;
• Whether refurbishment was considered;
• Whether accessories were included;
• How freight and insurance were treated;
• How the final value was calculated.

A comparison with new goods or substantially different equipment may be challenged.

Import Permits and Product Safety

Customs valuation is only one part of second-hand imports. Depending on the product, the importer may also need:

• Import permission;
• Product-safety documentation;
• CE conformity;
• Technical inspection;
• Environmental approval;
• Machinery-safety records;
• Medical-device documentation;
• TAREKS or similar compliance;
• Waste and hazardous-material permits;
• Special approval under the annual Import Regime.

A used product may have an acceptable customs value but still be detained because it cannot lawfully be imported or used in Turkey.

Third-Country Routing

If second-hand goods pass through another country, the importer should preserve:

• Transit declarations;
• Warehouse records;
• Re-export documents;
• Customs seals;
• Repair records;
• Non-manipulation evidence;
• Carrier confirmations.

Third-country storage does not automatically change origin, but repairs or substantial processing may affect the customs and origin analysis.

Customs Audits and Post-Clearance Risks

Turkish Customs may review second-hand goods after release. The audit may examine:

• Invoice price;
• Payment records;
• Book value;
• Market value;
• Refurbishment costs;
• Related-party transactions;
• Lease payments;
• Customs procedure;
• Import permits;
• Product classification.

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 goods were undervalued, the importer may face:

• Additional customs duty;
• Import VAT;
• Additional customs duties;
• Interest;
• Administrative customs penalties;
• Storage and demurrage;
• Delayed production;
• Re-export or destruction costs;
• Contractual disputes.

An honest valuation error should be distinguished from intentional concealment. False invoices, fabricated appraisals or hidden payments may create more serious administrative or criminal risks.

How Can the Importer Challenge the Valuation?

The importer may argue that:

• The invoice reflects the actual purchase price;
• The goods were defective or obsolete;
• Customs used new-goods prices;
• The comparable goods were not genuinely similar;
• Depreciation was ignored;
• Refurbishment was double counted;
• Post-import costs were improperly included;
• The transfer was not a sale;
• The alternative method was applied prematurely;
• The duty or 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 second-hand goods, the company should:

1. Confirm the HS classification.
2. Check used-goods import restrictions.
3. Obtain an independent appraisal.
4. Document age, condition and operating hours.
5. Record defects and missing parts.
6. Preserve market comparisons.
7. Verify related-party pricing.
8. Separate freight and insurance.
9. Document refurbishment.
10. Prepare product-safety records.
11. Confirm the customs procedure.
12. Review the file before declaration.

Frequently Asked Questions (FAQ)

1. Is the invoice price of second-hand goods automatically accepted?

No. Customs may investigate whether the price is genuine and supported by reliable evidence.

2. Can depreciation reduce customs value?

It may support a lower value, but depreciation alone does not determine customs value.

3. Can Customs compare used goods with new goods?

It may use comparable data, but age, condition, capacity and technology must be considered.

4. How can defects be proven?

Inspection reports, photographs, repair estimates, maintenance records and seller correspondence are useful evidence.

5. Are free transfers subject to customs value?

Potentially yes. If there is no sale price, Customs may apply an alternative valuation method.

6. Are related-party transfers automatically rejected?

No. An independent appraisal and commercial explanation may support the declared value.

7. Can leased second-hand goods be imported temporarily?

Possibly, if the conditions of the relevant customs procedure are satisfied.

8. Are used goods subject to import permits?

Some used or refurbished products may require separate permits, conformity documents or technical approvals.

9. Can Customs reassess second-hand goods after release?

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

10. What is the deadline to challenge a valuation 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 Second-Hand Goods Imports

Fırat Fesih Kaya Law Office advises foreign companies, investors, manufacturers, leasing firms, auction purchasers and Turkish importers on second-hand goods and customs valuation.

Lawyer Fırat Fesih Kaya can assist with appraisals, customs procedures, 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