

What should a Turkish importer do when a foreign supplier moves production to another country? Learn when origin documents, supplier declarations, preferential treatment and customs declarations must be reviewed.
A Turkish importer may purchase the same product from the same foreign supplier for years. The model number, brand, price and commercial invoice may remain almost identical.
However, one important fact may change:
The supplier moves production to another country.
For example:
Previous production: Germany
New production: China
or:
Previous production: Italy
New production: Türkiye’s FTA partner
or:
Previous production: Country A
New production: Country B.
This change can materially affect customs origin, preferential treatment, additional customs duties, trade-defense measures and the documentation supporting future Turkish import declarations.
The safest rule is straightforward:
A production-country change should trigger an immediate customs-origin review before the next shipment is declared.
Turkish Customs distinguishes preferential and non-preferential origin, and origin can directly affect both customs duties and commercial-policy measures. A Certificate of Origin generally establishes non-preferential origin, while documents such as EUR.1 and supplier declarations serve different preferential-origin functions.
Not necessarily.
The physical production location is highly relevant, but customs origin must still be determined according to the applicable origin rules.
Suppose a supplier moves only final assembly from Country A to Country B while most manufacturing continues in Country A.
Whether Country B becomes the new origin depends on:
Therefore, the importer should not simply replace one country name with another.
Origin may determine:
The Ministry of Trade expressly describes origin as the economic nationality of goods and notes its importance for customs duties and commercial-policy measures.
A factory relocation can therefore change the total landed cost of the product.
This is one of the most common compliance mistakes.
Suppose:
Supplier: ABC Global Ltd.
The company previously manufactured Product X in Poland.
It now manufactures Product X in Vietnam.
The commercial supplier remains ABC Global Ltd.
But this does not mean the historical Polish-origin documentation can automatically continue to be used.
Supplier identity and product origin are separate questions.
The supplier may continue using:
Yet origin may change because the manufacturing structure changed.
Customs compliance systems should therefore not determine origin solely from the product master code.
When the supplier announces a production transfer, determine whether it involves:
complete manufacturing relocation
partial production relocation
final assembly relocation
component sourcing change
contract manufacturer change
or
packaging and distribution relocation only.
These scenarios can produce different origin results.
Suppose goods continue to be manufactured in Country A but are shipped to Country B for:
The fact that invoices or shipments now originate from Country B does not automatically establish Country B origin.
The underlying production must be examined.
The importer should obtain information concerning:
The previous origin analysis should not simply be copied.
A factory move can affect both.
This may matter for origin-based trade-policy measures, additional customs duties and similar measures.
This determines whether the product satisfies the rules required to benefit from a preferential trade arrangement.
A Certificate of Origin cannot simply substitute for a supplier declaration because the two documents serve different origin functions.
Suppose a long-term supplier declaration was issued based on production in Country A.
The supplier later moves manufacturing to Country B.
The importer should determine whether that existing declaration remains valid for goods produced after the change.
Do not continue using an old declaration simply because its stated calendar validity period has not yet expired.
A product previously qualified for preferential origin.
After production moves, it may no longer satisfy the relevant rule.
Alternatively, the new production structure may qualify under a different preferential arrangement.
The importer should verify eligibility before claiming preferential treatment on subsequent shipments.
Where EU trade is involved, this distinction is particularly important.
The Ministry confirms that A.TR demonstrates free-circulation status rather than origin.
Therefore:
A.TR issued after the production move
does not automatically prove:
EU origin.
Companies using ERP or customs-management systems should immediately review:
Old master data can otherwise cause repeated incorrect declarations.
The importer should not assume that its customs broker knows the supplier has changed factories.
Provide written instructions identifying:
This creates a clear compliance record.
One practical problem is distinguishing old-factory inventory from new-factory production.
For example:
Factory transfer date: 1 July
but
old inventory continues shipping until: 15 August.
Do not assume every shipment after July automatically has the new origin.
Create a product- and batch-specific cut-off system.
For products with traceability systems, connect:
serial number
or
batch number
to:
manufacturing factory
and
production date.
This can prevent origin confusion during the transition.
Request written confirmation identifying:
This should be retained in the customs compliance file.
A factory move frequently changes suppliers.
The product may look identical but use:
These changes can alter preferential-origin calculations.
A factory relocation does not normally change classification merely because production moved.
However, the new factory may produce a technically different version of the product.
Confirm that the historical HS code remains correct.
Once classification is confirmed, identify the applicable origin rule for the new production structure.
The rule may involve:
Do not assume the old origin calculation remains valid.
The old factory may have benefited from cumulation that is unavailable to the new factory.
Conversely, the new factory may have access to a different cumulation structure.
This issue is especially important in 2026 because the revised Pan-Euro-Mediterranean origin framework has been implemented progressively across Turkey’s preferential arrangements.
In 2026, importers should not rely on an old general PEM assumption.
The Ministry has continued updating the applicable matrix as individual arrangements transition to revised rules.
Therefore, after a production-country change, verify:
production country
→ export country
→ destination Turkey
→ applicable agreement
→ rule set
→ cumulation eligibility.
Where a Certificate of Origin is required for the particular import measure, obtain documentation consistent with the new production structure.
The Ministry states that origin documentation is required in specified cases involving origin-based commercial-policy measures, additional customs duty and other financial obligations.
Do not continue presenting historical origin documents for newly manufactured goods.
Turkey recognizes properly issued electronic origin and movement documents from countries that have notified the Ministry under the relevant system.
However, electronic issuance does not eliminate substantive origin requirements. The Ministry’s August 2026 update confirms that electronically issued documents remain subject to Customs controls.
A new origin may produce a different additional customs duty outcome.
Before the first shipment from the new factory, calculate:
old landed customs cost
versus
new landed customs cost.
A sourcing decision that appears commercially attractive may become expensive after origin-dependent duties are considered.
This can be particularly serious.
Suppose production moves into a country covered by an anti-dumping measure applicable to the product.
The importer should identify this before shipment.
Conversely, moving production out of a covered country does not automatically eliminate anti-dumping exposure unless the new origin is legally established.
If most manufacturing remains in a country subject to a trade measure and goods undergo only minor operations elsewhere, Customs may question the claimed new origin.
The importer should understand the actual manufacturing transformation.
Obtain a process map showing:
raw materials
→ components
→ subassembly
→ final assembly
→ testing
→ packaging.
Identify where each stage occurs after the relocation.
Prepare:
| Issue | Old Factory | New Factory |
|---|---|---|
| Country | Country A | Country B |
| Manufacturer | Company A | Company B |
| Main components | Existing sources | New sources |
| Assembly | Country A | Country B |
| Testing | Country A | Country B |
| Preferential status | Previous analysis | Reassess |
This makes the customs impact visible.
The commercial invoice should not contain origin information inconsistent with the updated production structure.
But remember:
invoice country is not necessarily origin country.
The seller may remain unchanged even after production moves.
Review:
Inconsistent origin references can trigger Customs questions.
Supply agreements may contain an origin warranty.
The supplier may have promised:
“Goods shall be of Country A origin.”
If production moves to Country B, the supplier may need contractual approval before changing the sourcing structure.
Future contracts should require the supplier to notify the importer before changing:
The importer should have enough time to conduct customs analysis before shipment.
Origin review should occur before shipment.
Once goods arrive in Turkey, the importer may face:
Pre-shipment review is significantly safer.
If the importer learns of the factory change while goods are already moving to Turkey, immediately determine:
Do not assume the documents are correct simply because they were prepared before the importer learned of the change.
If the importer discovers that several recent declarations used old origin information after production had already moved, conduct an internal review immediately.
Identify:
Then assess the appropriate corrective strategy.
First establish the facts.
Some shipments may still consist of inventory manufactured at the old factory.
Others may have been produced at the new facility.
Use production dates, batch numbers and factory records to identify the actual affected population.
Where the review identifies incorrect declarations, determine whether Turkish customs legislation provides a corrective mechanism relevant to the circumstances.
This analysis should occur before making an unstructured admission to Customs.
If the new origin produces higher customs liability, the importer may face an additional assessment.
Whether an administrative penalty also applies requires separate analysis.
Relevant facts may include:
If the foreign supplier changed production without informing the Turkish importer and continued supplying obsolete origin documents, review potential contractual liability.
Relevant provisions may include:
Collect communications concerning:
These may become important in both a Customs investigation and supplier-recovery claim.
The procurement department may learn about a factory relocation months before the customs department.
Create an internal notification rule:
Procurement learns of factory change
→ Customs/compliance is automatically notified
→ imports are reviewed before next shipment.
This closes a common compliance gap.
A supplier may relocate only certain product lines.
Do not change the origin of the supplier’s entire catalogue.
Review:
product
→ factory
→ production period
→ origin.
Do not overwrite old origin data in the system without retaining history.
Customs may later ask why:
Product X was declared Country A origin in March
but
Country B origin in September.
Maintain evidence explaining the production transition.
For every significant production relocation, retain:
This file can be extremely valuable during a post-clearance audit.
When a foreign supplier changes production country:
Stop automatic reliance on historical origin data
→ identify the new factory
→ establish the production-change date
→ separate old inventory from new production
→ confirm HS classification
→ obtain the new bill of materials
→ recalculate preferential origin
→ review non-preferential origin
→ review cumulation
→ check additional customs duty
→ check anti-dumping and other measures
→ obtain revised origin documents
→ update ERP/customs master data
→ notify the customs broker
→ review already-imported shipments.
Yes. The change should trigger a customs-origin review because origin can affect customs duties, preferential treatment and trade-policy measures.
Not necessarily. The actual manufacturing operations and applicable origin rules must be analyzed.
It should not assume so. If the declaration was based on the previous production structure, its applicability to goods manufactured after the relocation must be reassessed.
Yes, where such a certificate is required or relied upon. The document must correspond to the actual origin position of the goods.
No. A.TR proves free-circulation status rather than origin.
A packaging-country change does not automatically mean the customs origin has changed. The actual production operations must be reviewed.
The importer should identify the affected declarations using production dates, batches, serial numbers and factory records, then assess any required corrective action.
Potentially yes. If the product and new origin fall within an applicable trade-defense measure, the customs consequences may change significantly.
Potentially, particularly where it breached origin warranties, failed to disclose the production change or supplied inaccurate origin documentation. The contractual terms and governing law must be reviewed.
Any change in production country, factory or material sourcing that could affect origin should be communicated to the Turkish importer’s customs team before the next shipment, followed by a documented reassessment of origin and all supporting customs documents.
Changes in international manufacturing structures can create customs issues involving:
Factory relocation
Production-country changes
Preferential origin
Non-preferential origin
Supplier declarations
EUR.1 documentation
Certificates of Origin
Additional customs duties
Anti-dumping measures
Post-clearance corrections
and customs penalties.
Fırat Fesih Kaya Law Office assists foreign manufacturers, multinational companies and Turkish importers when changes in production location affect the customs treatment of goods imported into Turkey.
Lawyer Fırat Fesih Kaya provides legal assistance in reviewing new manufacturing structures, origin rules, bills of materials, supplier declarations and customs documentation, assessing historical import exposure, responding to post-clearance investigations and challenging additional assessments and administrative penalties where appropriate.
Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, Office No:148, 06520 Balgat, Çankaya, Ankara, Turkey