Under Turkish customs legislation, customs warehouses (antrepo) are divided into public and private. Public warehouses, where anyone can store goods, are types A, B and F; private warehouses, where only the operator can store its own goods, are types C, D and E. The types differ according to whether liability for customs duties lies with the operator or the user, and how goods are entered into the procedure.
How do public and private warehouses differ?
Article 94 of Customs Law No. 4458 (Gümrük Kanunu) divides customs warehouses into two: public warehouses can be used by anyone to store goods, while private warehouses are set up only for goods belonging to the warehouse operator. The two concepts need to be read correctly. The operator is the person granted the authorisation to operate the warehouse. The user is the person who declares the goods for the customs warehousing procedure, i.e. the owner of the goods or the person declaring on their behalf. In a public warehouse these are two different persons; in a private warehouse they are the same. Authorisation to operate a warehouse is granted only to persons established in Türkiye. The general workings of the procedure are explained in what is a customs warehouse.
What do the six warehouse types mean?
| Type | Group | Key feature | Suitable for |
|---|---|---|---|
| A | Public | The operator keeps the stock records; if goods are found missing, the operator is liable for the customs duties. | Multi-client logistics and warehousing companies |
| B | Public | The user is liable for the goods; the user submits the warehouse declaration. | Goods owners who take on the tax liability themselves |
| F | Public | Operated by the customs administration. | Storage needs operated by the administration itself |
| C | Private | Operator and user are the same person; this person is liable for the goods. | Manufacturers or importers storing their own imported inputs |
| D | Private | Operator and user are the same; entry into the procedure is by entry in the records. | Companies with frequent, high-volume entries using a simplified procedure |
| E | Private | The authorisation holder's own storage facilities count as the warehouse. | Large businesses wishing to keep goods at their own premises |
How do liability and guarantees work?
Under Article 96 of the Law, the operator is responsible for ensuring that the goods remain under customs supervision while in the warehouse, for the storage obligations and for complying with the special conditions in the authorisation. Article 97 provides that in public warehouses these obligations may be assigned exclusively to the user in the operating authorisation; type B is based on this flexibility. The user, in all cases, is responsible for the obligations arising from placing the goods under the procedure.
The customs administration requires a guarantee from the operator according to the principles laid down in the regulation. No guarantee is required for goods placed in fairs and exhibitions, goods exempt from import duties, or goods placed in a warehouse for export. Even if a guarantee has been provided, goods may not be removed from the warehouse in part or in full without the permission of the customs administration. In practice, type A operators keep counting, camera and seal checks tighter because they will pay the duty on a missing pallet themselves, and they reflect this risk in their prices.
Which type suits whom?
- A company that imports occasionally and has no warehouse of its own: Renting space in a type A public warehouse is the option with the lowest set-up cost.
- A manufacturer using imported raw materials regularly: Opening a type C private warehouse at its own premises spreads duty payments over time by releasing goods into free circulation only as needed. For the authorisation process, see customs warehouse authorisation.
- An importer with high-volume, continuous entries: The entry-in-the-records option of type D reduces the administrative workload.
- A large business with several facilities: Type E allows the goods to be kept at the authorisation holder's own storage facilities.
A customs warehouse should not be confused with temporary storage facilities at ports and airports; the difference is explained in temporary storage vs customs warehouse.
Common mistakes
- Signing a contract with a type B warehouse without realising that the tax liability lies with the user.
- Trying to place another company's goods in a private warehouse.
- Writing the wrong warehouse code on the declaration; for code lookup, see customs warehouse code.
- Directing flammable, explosive or specially protected goods to a warehouse not suited to them.
How does Voltim Global support this?
For import and transit shipments, Voltim Global assesses which type of warehouse the goods will be placed in together with the customs clearance plan, and coordinates entry, handling and withdrawal documents as part of its customs warehouse and storage operations.