Recent Developments
Amendments to the Customs Regulation on the Bonded Warehouse Regime
The Regulation Amending the Customs Regulation (“Amendment“), published in the Official Gazette dated 22 August 2025 and numbered 32994, has introduced significant amendments to the Customs Regulation (“Regulation“).
The Amendment is available here (in Turkish).
What Does the Amendment Introduce?
Bonded Warehouse (Antrepo in Turkish) Regime
I. Bonded Warehouse Opening and Operation Permit
- The total open and/or closed areas of the places to be opened and operated as general bonded warehouses must be at least 5,000 square meters within the borders of metropolitan municipalities and at least 3,000 square meters in other places. With the Amendment, it is regulated that at least 20% of these areas must be closed areas.
- Another change introduced by the Amendment is that bonded warehouses on the same real property belonging to a bonded warehouse operator can be affiliated with a single customs directorate.
- It is regulated that the number of warehouses that are granted investment permits or bonded warehouse opening permits may be limited by the customs directorate or regional directorate. In introducing this limitation, the number of existing bonded warehouses and the volume of transactions based on quantity and / or value carried out in bonded warehouses for at least two years prior to the year in which the application for the investment permit and / or warehouse opening permit is made are considered.
II. Annual Price Tariffs
- Bonded warehouse operators shall send the annual price tariff to be applied in general bonded warehouses to the relevant regional directorate of customs and foreign trade by the end of January, and the regional directorate of customs and foreign trade shall publish it on the corporate website.
- The annual price tariff of general warehouses that have just started to operate shall be sent to the relevant regional directorate of customs and foreign trade by the end of the month following the month in which the opening and operation permit is granted, and the regional directorate of customs and foreign trade shall publish it on the corporate website. Otherwise, goods cannot enter the relevant warehouse.
- The annual price tariff to be applied in general warehouses shall be sent to the relevant regional directorate of customs and foreign trade within one month following the effective date of this Amendment, and the regional directorate of customs and foreign trade shall publish it on the corporate website.
III. Investment Permit Conditions
- Those who will apply for a bonded warehouse opening and operation permit can also apply for an investment permit from the customs directorate with which the warehouse will be affiliated before making an investment.
- Prior to the Amendment, investment permits were granted to public institutions, organizations and companies that had been operating for at least two years and met other conditions. The minimum period of operation has been increased from two years to three years.
- Changes were also made to the minimum amount of capital that companies must have to be granted investment permits. With the Amendment, the minimum amounts of capital have been updated as follows:
- TRY 40 million for the cities in the first and second regions
- TRY 20 million for the cities in the third and fourth regions
- TRY 10 million for cities in the fifth and sixth regions
- In investment permit applications, a letter from the tax office stating that there is no finalized tax debt, a letter stating that there is no debt to the Social Security Institution, and a letter stating that there is no finalized tax and penalty debt in accordance with customs legislation must be submitted to the regional directorate of customs and foreign trade, in addition to other documents.
Conclusion
The Amendment introduces significant updates to the Regulation concerning the bonded warehouse regime, particularly the conditions on the warehouse opening and operation permit. In this regard, stakeholders in the sector should closely examine the Amendment, act in accordance with the obligations it sets forth and take the necessary steps to ensure compliance.
