A customs broker (gümrük müşaviri) is a licensed professional, authorised by the Ministry of Trade (Ticaret Bakanlığı), who prepares customs declarations on behalf of importers, exporters or carriers, lodges them through the BİLGE system and completes the customs formalities for the goods. Under the Customs Law, the broker represents the client by indirect representation, that is, in the broker's own name but on the client's behalf.
The customs broker's scope of work
Customs brokers may follow up and complete all kinds of customs formalities (Customs Law, Art. 226). Most of the day-to-day work consists of:
- Preparing the customs declaration from the commercial invoice, packing list and origin documents
- Determining the GTİP (Turkish HS/tariff code) of the goods, calculating the customs value and assessing the duties and taxes
- Collecting permits and conformity documents for goods subject to import controls
- Attending the inspection and sampling of the goods
- Lodging declarations for procedures such as transit, customs warehousing, inward processing and temporary admission
- Advising the obligor during penalty, appeal and amendment procedures
Declarations are submitted electronically through the BİLGE system, and supporting documents are uploaded to the system as well.
Direct versus indirect representation
| Criterion | Direct representation | Indirect representation |
|---|---|---|
| In whose name? | In the name and on behalf of the obligor | In the representative's own name, on behalf of the obligor |
| Who carries it out? | Authorised staff of the company; carriers only for transit formalities for the goods they carry | Customs brokers |
| Liability for the customs debt | The obligor | The broker together with the obligor; the broker's liability is limited to cases where they knew, or by virtue of their profession should have known, that the data were incorrect |
This framework is based on Articles 5, 181 and 225 of the Customs Law. The representative must state on whose behalf they are acting and the type of representation, and must present the power of representation to the customs administration.
Who can become a customs broker?
- At least a bachelor's degree in law, economics, public finance, business administration, accounting, banking, public administration, political science or industrial engineering (or equivalent education listed in the Law)
- A one-year traineeship with a customs broker
- Passing the assistant customs broker examination, covering customs legislation and economic, commercial and financial subjects
- Two years as an assistant customs broker
- Passing the customs broker examination and obtaining the Customs Brokerage Permit (Gümrük Müşavirliği İzin Belgesi) from the Ministry
The Law provides exemptions from the traineeship or examination for public officials who have served in the customs administration for certain periods and in certain posts (Arts. 227–228). Assistant customs brokers handle work on the broker's behalf, and the financial liability arising from their transactions rests with the broker; trainees may not handle formalities at customs.
The broker's obligations
The broker must keep commercial books, powers of attorney and contracts, correspondence and expense records for five years and present them on inspection (Art. 230). If the brokerage is run as a company, the signing broker who knew or should have known of a situation causing a tax loss is held jointly and severally liable with the company (Art. 229).
Who is an authorised customs broker?
Some customs brokers are additionally authorised by the Ministry and take on certain verification tasks on behalf of the customs administration. For example, under the Customs Regulation (Gümrük Yönetmeliği), the check on goods being placed in a bonded warehouse may be carried out by an authorised customs broker instead of a customs officer. Bonded warehouses that have their stocks verified by a physical count every six months and submit the report to the customs directorate are excluded from the administration's annual count. This authorisation is a separate area of duty from ordinary declaration work.
What should you look for when choosing a broker?
- An office or representative at the customs offices you use most often
- Procedure experience: inward processing, customs warehousing, transit or project cargo each require different expertise
- How documents are checked before the declaration, and whether GTİP decisions are justified in writing
- Coordination with the carrier: who handles transport under customs control and guarantee matters
- Whether the fee is calculated per declaration or per item, and the list of additional services
Voltim Global's customs brokerage service handles import, export and transit declarations together with the transport plan, through contracted customs brokers.