Free Tooling, Moulds, Dies and Design Assists in Turkish Customs Value: Article 27 (2026)
Short and Clear Answer
Customs Law No. 4458 Article 27 requires the appropriate value of specified goods and services supplied by the buyer free of charge or at reduced cost for use in producing imported goods to be added to customs value when that value is not already included in the price. The Ministry of Trade lists materials and components incorporated in the goods, tools, dies and moulds used in production, materials consumed in production, and specified engineering, development, artwork, design work, plans and sketches undertaken outside Turkey and necessary for production.
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The addition is not a penalty and it is not based on an arbitrary estimate. The importer must identify the assist, establish its value, allocate that value appropriately to the imported goods and prevent double counting. Foreign manufacturers and Turkish buyers should therefore record buyer-supplied tooling and design arrangements before the first shipment.
Buyer-supplied tooling and design can increase customs value even when no amount appears on the commercial invoice.
Contents
1. Article 27 Requires Buyer Assists to Be Tested Separately from Invoice Price
Transaction value under Article 24 begins with the price actually paid or payable. Article 27 then requires specified additions when their value has not already been included. Buyer assists are important because the foreign seller may receive production inputs or services without charging for them in the merchandise invoice.
If the Turkish buyer provides a mould worth EUR 100,000 to the foreign producer free of charge, the producer can quote a lower unit price because it did not bear that tooling cost. Article 27 prevents customs value from being understated by ignoring the buyer-funded production input.
The rule also applies where the buyer supplies the item or service at a reduced cost. The customs analysis identifies the value not reflected in the price and allocates the legally relevant amount to the imported goods.
2. Materials, Components and Parts Incorporated in Imported Goods
The Ministry of Trade customs-value guidance identifies materials, components, parts and similar items incorporated in the imported goods as a category of buyer assist. This includes physical inputs that become part of the final imported product.
A Turkish buyer may send specialized chips, fabric, chemicals, subassemblies or branded packaging components to a contract manufacturer abroad. If those items are provided free or below cost for production of goods later imported into Turkey and their value is not already in the price, Article 27 must be applied.
Importers should track quantity flows. If buyer-supplied components are used for both Turkish-bound production and goods sold to other countries, the allocation must reflect the goods imported into Turkey rather than charging all supplied components to Turkish entries.
3. Tools, Dies, Moulds and Similar Production Items
Tools, dies, moulds and similar items used in production are expressly within the Article 27 assist framework. These assets can be expensive and may remain at the foreign manufacturer for years, making them a major valuation issue in automotive, plastics, electronics, metalworking and consumer-goods supply chains.
The fact that the mould never physically enters Turkey does not remove the issue. Its role is to produce the imported goods. Customs value therefore examines the buyer’s contribution to production rather than asking whether the assist itself was imported.
Tooling contracts should state who owns the tool, who paid for it, where it is located, its expected production volume, whether it will be used for other customers and how the cost is recovered. Those facts determine the valuation and allocation evidence.
4. Materials Consumed in Production
Article 27 also covers materials consumed in producing the imported goods. A material does not have to remain physically identifiable in the finished product if it falls within the statutory category and is used in production.
Examples include specialized catalysts, processing chemicals, abrasives or other buyer-supplied inputs consumed during manufacturing. The company must establish actual use and avoid including items that are unrelated to the imported production.
Production records, bills of materials and consumption reports are stronger evidence than an after-the-fact estimate. Customs valuation should be connected to the manufacturer’s normal production accounting.
5. Engineering, Development, Artwork, Design, Plans and Sketches
The Ministry guidance also lists specified engineering, development, artwork, design work, plans and sketches undertaken outside the country of importation and necessary for the production of imported goods. These intangible production inputs can be Article 27 assists even though no physical tool is supplied.
A Turkish buyer may pay an independent engineering company in Germany to design a component manufactured in China and imported into Turkey. The goods invoice from the Chinese manufacturer may contain no design charge. The design payment must nevertheless be reviewed under Article 27 because it can be a buyer-supplied production service.
The legal analysis focuses on whether the service falls within the statutory category, where it was performed, whether it was necessary for production and whether its value is already reflected in the price.
6. Location of Design Work Matters
The location requirement for engineering and design work is important. The Ministry guidance identifies work undertaken outside the country of importation in the assist category. Domestic work requires separate analysis under the text of the valuation rules.
Companies should therefore preserve service-provider addresses, project records and evidence showing where the relevant work was performed. Global project teams can make this fact difficult to establish if the contract only names a multinational service company without identifying the work location.
Where work is split across countries, the importer should allocate the value on a documented basis rather than assigning the entire invoice to one location without evidence.
7. How the Value of an Assist Is Established
The customs value of an assist should be based on objective, supportable information. Where the buyer purchases a tool or design from an independent supplier, the purchase price and related acquisition costs provide core evidence. Where the buyer produces the item itself, production-cost records become relevant.
Used tooling requires evidence of its value when supplied to the producer. Companies should not simply reuse the original acquisition cost without considering the legal valuation rules and the facts affecting value.
Repairs, modifications and refurbishment carried out before or during the production program should be tracked separately so that the customs file explains whether and how those costs affect assist value.
8. Allocation Across Imported Units Must Be Reasonable and Documented
An assist used to manufacture many units is generally allocated across the production to which it relates. The company needs a method consistent with the production facts and customs rules. Expected production, actual production, imported quantities and the period of use can all affect the calculation.
A EUR 100,000 mould used for 100,000 units cannot simply be added in full to the first import without a legal basis. Conversely, ignoring the value until the end of the project understates early entries. The importer should select and document an allocation before shipments begin.
If actual production materially differs from the forecast, the customs compliance process should assess whether reconciliation is required. The allocation workbook should link to customs declarations and product codes.
9. Ownership, Reuse and Multi-Customer Production
Ownership is relevant evidence but not the sole test. A buyer can provide an assist through ownership, leasing, payment on behalf of the producer or another commercial arrangement. The customs question follows the economic benefit supplied for production.
Where the foreign manufacturer uses the same tool for goods sold to several customers or countries, the Turkish importer should identify its share. A contract granting exclusive use for the Turkish buyer supports a different allocation from a tool used broadly for unrelated production.
At the end of the program, disposal or return of the tool should also be documented. The customs file should explain whether residual value or later reuse affects any previous assumptions under the applicable rules.
10. Documents for an Assist Valuation File
Keep the tooling agreement, purchase invoice, proof of payment, ownership record, manufacturer acknowledgment, production forecast, actual output, bill of materials, engineering contract, design invoices, location evidence and allocation calculation. Each document should connect to the imported products.
Where multiple customs declarations share the assist value, maintain a schedule showing the amount allocated to each declaration or period. The schedule should reconcile to accounting records and not exceed the total amount legally allocable.
Customs Law Article 11 allows customs to request information and documents, while Article 13 governs retention. Foreign suppliers should cooperate contractually in providing production records needed to verify the allocation.
11. Omitted Assists and Article 234(1)(b)
If a required assist is omitted, declared customs value can be below the value determined under Articles 23–31. For goods subject to ad valorem duties, Article 234(1)(b) requires the duty difference and prescribes a fine equal to three times that difference when the statutory elements are present.
The risk compounds when the same tool supports hundreds of entries. Early identification is therefore a compliance issue with direct financial consequences.
Anti-Smuggling Law No. 5607 remains a separate criminal regime. An assist valuation dispute does not automatically establish criminal liability.
Official and Related Sources
Frequently Asked Questions
What is a customs assist in Turkey?
It is a buyer-supplied good or service within Article 27 that must be added to customs value when the statutory requirements are met and its value is not already in the price.
Are free moulds included?
Tools, dies, moulds and similar items used in production are expressly addressed by the Ministry’s Article 27 guidance.
What if the mould stays abroad?
Physical import of the mould is not required; the issue is its use in producing the imported goods.
Can overseas engineering be an assist?
Yes. Specified engineering, development, artwork, design, plans and sketches undertaken outside Turkey and necessary for production are within the Article 27 framework.
How is tooling allocated?
Through a reasonable, documented method tied to the production and imported goods.
What if one tool serves several countries?
The Turkish customs file should identify the portion allocable to goods imported into Turkey.
What penalty applies if an assist was omitted?
Article 234(1)(b) applies to deficient customs value when its statutory elements are present.
Can the importer correct future entries?
The importer should apply the correct assist treatment prospectively and separately assess the statutory correction, repayment or objection procedures for earlier entries.
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 and 234 and the Ministry of Trade’s customs-value guidance.
Contact Us About Customs Assists in Turkey
Last legal-source review: 12 September 2026.
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Bakırcı & Keskin Law Office has physical offices in Istanbul and Mersin. Matters throughout Turkey are coordinated from these offices. See also the transaction-value method guide.
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