Freight, Insurance, Loading and Handling in Turkish Customs Value: Articles 27–28 (2026)
Short and Clear Answer
Turkish customs value includes the transport, loading, handling and insurance costs legally attributable to bringing imported goods to the relevant place of introduction, while qualifying transport and insurance costs incurred after that point are excluded when separately distinguished. Customs Law Articles 27 and 28 therefore require a route-and-cost analysis, not a simple rule that all freight is included or all domestic freight is excluded.
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Incoterms do not themselves determine customs value. They help identify which party bears particular costs, but the statutory customs treatment follows Articles 27–28 and the Customs Regulation. Foreign sellers and Turkish importers should split international freight, port charges, inland movement, insurance and related charges on invoices or supporting schedules so the declared value can be audited.
Articles 27–28 require transport costs to be split according to the legally relevant point of introduction and the nature of each charge.
Contents
1. Articles 27 and 28 Must Be Read Together
Article 24 starts with the price actually paid or payable. Article 27 adds specified costs not already included, including transport-related elements connected with bringing the goods to the legally relevant point. Article 28 excludes specified costs when they are separately distinguished, including qualifying transport and insurance costs after arrival at the place of introduction.
This structure prevents two opposite errors. The importer cannot omit international freight merely because the supplier invoices goods on an EXW basis. Customs value must add the transport elements required by Article 27. At the same time, customs value should not include qualifying post-entry transport merely because the supplier issued one combined DDP-style invoice if the post-entry amount can be separately established under Article 28.
The company therefore needs a transport-cost map for each supply lane. It should show origin pickup, export terminal, international carriage, Turkish entry point, port or airport charges, subsequent inland carriage and final delivery.
2. The Place of Introduction Is Legally Important
The Ministry of Trade customs-value guidance distinguishes transport and insurance before and after arrival at the place of introduction into the Turkish customs territory and the customs territories of a customs union to which Turkey is party under agreements. The legal point therefore controls cost treatment.
A logistics invoice may not use customs terminology. It can describe door-to-door freight as one charge. The importer must obtain enough detail to separate the legally relevant pre-entry and post-entry portions.
Routes through multiple ports or border crossings require accurate documentation. The customs declaration, bill of lading, CMR document, airway bill or multimodal transport document should identify the actual movement rather than rely on a generic route assumption.
3. International Freight Must Be Included When Article 27 Requires It
Where the price does not already contain the legally relevant freight, Article 27 requires the appropriate addition. EXW and FCA transactions commonly require a separate freight addition because the goods price can exclude substantial transport before arrival in Turkey.
The amount should be based on actual contractual and invoiced transport costs where available. If one freight charge covers several consignments, the allocation must be reasonable and documented. Weight, volume, container space or another objective logistics measure can be relevant depending on the actual pricing of the carrier.
Freight paid by a related group logistics company remains subject to the same customs analysis. Accounting the amount in a separate entity does not remove the cost from the customs-value calculation.
4. Transport Insurance Follows the Same Pre-Entry/Post-Entry Logic
Insurance associated with bringing goods to the relevant entry point must be reviewed under Article 27. If the goods price is CIF or another term in which qualifying insurance is already included, the importer must avoid adding the same amount twice.
Annual cargo policies can make allocation more complex because the premium is not invoiced shipment by shipment. The importer should establish a documented method for allocating the relevant insurance cost to imports and retain the policy, premium invoices and calculation.
Insurance after the relevant introduction point is treated under Article 28 when its conditions are met and the amount is separately distinguished. A door-to-door policy should therefore be split on an objective basis when possible.
5. Loading, Unloading and Handling Charges Require Functional Classification
Transport invoices often include terminal handling, loading, unloading, security, documentation, port and equipment charges. Their customs treatment depends on what the charge actually represents and where the service occurs. A label such as THC or handling is not a complete legal analysis.
The company should identify whether each cost is connected with bringing goods to the relevant introduction point or with post-entry operations. Carrier invoices, port statements and freight-forwarder breakdowns should be preserved.
If the freight forwarder issues one bundled amount, request a supporting schedule. A customs value cannot be audited reliably where a large logistics charge is split only by an unsupported percentage chosen after the declaration.
6. Qualifying Post-Entry Transport and Insurance Are Excluded Under Article 28
The Ministry of Trade guidance states that transport and insurance costs after arrival at the place of introduction are not included in customs value when they are separately distinguished from the price actually paid or payable. This is a statutory exclusion, not a discretionary concession.
A supplier can sell on delivered terms that include Turkish inland transport. The existence of a delivered price does not force the entire delivery cost into customs value. The importer must establish the eligible post-entry component and distinguish it from the goods price and pre-entry costs.
The most reliable evidence is a contract and invoice structure that states the transport components separately. Where that is not commercially possible, carrier invoices and a transparent reconciliation can support the exclusion.
7. Incoterms Allocate Commercial Responsibility but Do Not Replace Customs Law
Incoterms rules such as EXW, FCA, FOB, CFR, CIF, CPT, CIP, DAP and DDP allocate defined delivery obligations, risk and cost between seller and buyer. They are important evidence because they help explain which costs are inside the commercial price.
They do not determine customs value by themselves. An EXW invoice usually requires additions, while a CIF invoice can already include international freight and insurance. A DDP price can include post-entry transport and Turkish taxes that require separation under Article 28.
The customs worksheet should begin with the commercial term but then apply Articles 27 and 28 to each cost. Customs legislation controls the declared value.
8. Combined Goods-and-Freight Invoices Need a Reconciliation
Foreign sellers frequently issue one invoice covering goods and freight. That format is acceptable commercial practice, but the importer must know whether the freight amount includes only international carriage or also Turkish inland delivery.
Where a single amount covers several legs, obtain the underlying carrier or freight-forwarder costs. If the seller adds a logistics markup, the customs analysis should identify whether the amount is part of the goods consideration or a separately identifiable transport service.
Currency conversion must also be consistent with customs rules. The company should preserve both the carrier invoice currency and the calculation used in the customs declaration.
9. Multimodal and Transit Routes Need Route-Specific Evidence
Containerized trade can involve truck pickup, rail, sea, transshipment and final truck delivery. Air cargo can include road feeder services. The legal treatment cannot be determined accurately from the main ocean or air freight alone.
For goods entering Turkey after transit through another country, the customs file should identify the actual introduction point relevant to Turkish customs valuation. Transport documents should establish the sequence of legs and the charges attributable to each.
Multimodal contracts should be reviewed before repeated imports begin. A standardized cost schedule attached to the customs file reduces inconsistent treatment across declarations.
10. Related-Party Logistics Must Be Priced and Documented Transparently
A multinational group may use a central logistics company that purchases freight and recharges Turkish affiliates. The recharge must be reconciled with actual transport and analyzed under customs valuation. The group company’s separate legal personality does not erase the cost.
If the recharge contains a service fee or management markup, the company should identify its nature. The customs treatment of freight and the treatment of a separate service component can differ.
Related-party goods pricing and logistics pricing should be reviewed together so the same freight is not omitted from both the goods invoice and the customs additions or counted twice.
11. Documents for Freight and Insurance Valuation
Keep the sales contract, Incoterms clause, commercial invoice, freight agreement, carrier invoice, freight-forwarder invoice, bill of lading, airway bill or CMR document, insurance policy, premium invoice, terminal statements and inland delivery invoice.
For annual or bundled costs, keep the allocation methodology and the source data used. The declared amount should reconcile to accounting and logistics records.
Customs Law Article 11 permits requests for information and documents; Article 13 governs retention. Foreign sellers should provide Turkish importers with transport breakdowns when delivered pricing is used.
12. Incorrect Freight Treatment Can Create Article 234(1)(b) Exposure
Omitting freight or insurance that Article 27 requires can reduce customs value. Where the goods are subject to ad valorem duties, Article 234(1)(b) requires the duty difference and prescribes a fine equal to three times that difference when its elements are present.
The same mistake repeated across a supply lane can affect hundreds of entries. Customs compliance should therefore use standardized valuation instructions for each Incoterms and logistics model.
If the dispute concerns whether a cost occurred before or after the relevant introduction point, the objection should present route documents and the statutory Article 27–28 analysis. Article 242 provides the fifteen-day administrative objection route.
Official and Related Sources
Frequently Asked Questions
Is international freight included in Turkish customs value?
The freight required by Article 27 for bringing goods to the legally relevant point is included if not already in the price.
Is Turkish inland freight always included?
No. Qualifying post-entry transport is excluded under Article 28 when its requirements are met and the amount is separately distinguished.
Does CIF mean no freight calculation is needed?
No. CIF indicates that freight and insurance are in the commercial price, but the importer must still verify that the amount covers the legally relevant costs and avoid double counting.
Does DDP mean the full invoice is customs value?
No. A delivered price can contain post-entry transport and Turkish taxes that require separation under Article 28.
How is annual cargo insurance allocated?
Through an objective, documented method tied to the imports covered by the policy.
Are terminal handling charges included?
Their treatment depends on the nature and location of the service under Articles 27–28.
What penalty applies to omitted freight?
Article 234(1)(b) applies to deficient customs value when its statutory elements are present.
What is the objection period?
Article 242 provides fifteen days from notification.
Lawyer Review and E-E-A-T
Prepared by: Attorney Halil BAKIRCI – Mersin Bar Association, Registration No. 3472
Legal review: Bakırcı & Keskin Law Office.
This guide was reviewed against Customs Law No. 4458 Articles 11, 13, 24, 27, 28, 234 and 242 and the Ministry of Trade’s customs-value guidance.
Contact Us About Freight in Turkish Customs Value
Last legal-source review: 12 September 2026.
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