Importing Clothing from Turkey into the EU: EORI, Customs Representative, A.TR and Import VAT

Confirm product classification, origin and documentation with your customs representative for the destination market and date of import.

What the customs union removes, and what it leaves

The customs union removes the duty, not the import. The Commission's Taxation and Customs Union service describes it as covering goods wholly produced in, or put into free circulation in, Türkiye or the EU, under Decision No 1/95 of the EC–Turkey Association Council of 22 December 1995; agricultural products and coal and steel products stay outside it and trade under separate agreements. Garments are industrial products, so they move without customs duty when the goods are in free circulation and an A.TR accompanies them.

What remains is the customs formality and the tax. The goods are declared for release for free circulation, import VAT is charged in the Member State of import, and the party placing them on the EU market takes on product-compliance duties. How the EU, UK and US answers differ for the same production run is set out in one production run, three markets.

Step 1: an EORI number

Anyone who lodges a customs declaration in the EU needs an EORI number. Under Article 9 of the Union Customs Code (Regulation (EU) No 952/2013), economic operators established in the EU register with the customs authorities where they are established; operators not established in the EU register where they first lodge a declaration or apply for a decision. The Commission's EORI guidance adds that one number is used across the whole customs territory.

Germany. The EORI number is issued free of charge by the Generalzolldirektion, Dienstort Dresden. Zoll states that from 1 October 2026 applications must go through the Zoll-Portal, and that the paper form 0870 is accepted only in exceptional cases after 30 September 2026. The Austrian procedure is in the Austria section below.

Step 2: who lodges the declaration: direct or indirect representation

The declarant must be established in the EU. Article 170(2) of the Union Customs Code says so, with narrow exceptions for transit, temporary admission, occasional declarations the authorities accept, and declarants from adjacent countries at the border. A Turkish exporter therefore cannot declare the goods into free circulation itself as a matter of routine, and an EU buyer usually hands the work to a customs representative.

Under Article 18(2) the representative must itself be established in the EU. Under Article 19 it must state whether it acts directly or indirectly, and a person who acts without being empowered is treated as acting in its own name. The choice matters beyond duty, because Germany and Austria apply customs rules correspondingly to import VAT (§ 21(2) UStG in Germany, § 26(1) UStG 1994 in Austria), so the representation you pick also decides who answers for the import VAT.

Step 3: the A.TR, and why the EUR.1 is not the document for garments

The A.TR movement certificate is the document that lets garments cross without duty. Turkish customs issue it at the exporter's request under Decision No 1/2006 of the EC–Turkey Customs Cooperation Committee, and it evidences that the goods are in free circulation, which is a customs status. It does not certify where the goods were made. Since 8 July 2024 EU Member States accept A.TR certificates issued electronically by the Turkish authorities with a QR code and without a wet-ink signature. A 2026 Commission proposal (2026/0270 (NLE)) would replace Decision No 1/2006 with a new decision, so confirm the current rules with your representative.

The EUR.1 is a proof of preferential origin. It belongs to preferential arrangements with their own rules of origin, which in EU–Türkiye trade means the products outside the customs union, such as agricultural and coal and steel products. For garments, the A.TR is the document your representative expects. Origin is still declared on the import and can matter for other measures and for any origin claim on the label, as the A.TR guide explains.

Step 4: import VAT and how it is accounted

Import VAT is due even when customs duty is nil. Under the VAT Directive (Council Directive 2006/112/EC), VAT becomes chargeable when goods are imported (Article 70). The taxable amount is the customs value (Article 85) plus taxes, duties and charges due by reason of the import and incidental costs such as commission, packing, transport and insurance up to the first place of destination in the Member State of import (Article 86). The Member State of import designates who pays (Article 201).

• Where it is due. The Member State where the goods enter the EU (Article 60). If they travel under external transit, for example by truck through Bulgaria, it is the Member State where they leave transit (Article 61).
• How it is paid. Member States may let businesses enter import VAT in the VAT return instead of paying it at the border (Article 211). Each country sets its own rule, which is why the German and Austrian methods below differ.
• How it comes back. A business deducts import VAT on goods used for its taxed transactions (Article 168(e)) in the Member State of import, which in practice needs a VAT registration there.

Germany. Einfuhrumsatzsteuer is assessed and collected by customs together with any duty. A business deducts it as input tax under § 15(1) no. 2 UStG, with the customs import duty notice or the electronic ATLAS notice as proof. An importer with a deferment account (Zahlungsaufschub, Article 110(b) UCC, applied for on form 0580) pays deferred import VAT by the 26th day of the second following month (§ 21(3a) UStG), and deferment without security is available only for import VAT that is fully deductible.

Import to Austria

Austria collects import VAT through the tax office account rather than by deferment. Under § 26(3) no. 1 UStG 1994 the Zollamt Österreich assesses the Einfuhrumsatzsteuer, but under § 26(3) no. 2 the tax office collects it when three conditions are met: the debt arose under Article 77 of the Union Customs Code and is not a later correction; the debtor is a business registered for VAT in Austria importing for its business; and the debtor declares in the customs declaration that it uses this rule.

• Timing. Import VAT booked this way falls due on the 15th of the month after booking, and at the earliest on the 15th of the second month after the VAT period in which it arose (§ 26(5)(a)). It is booked together with the VAT account, so it can be deducted in the same return.
• Indirect representation. The declarant acting as indirect representative is not liable for the import VAT if it holds the importer's written instruction to use the account method (§ 26(5)(e)).
• From 1 January 2027. An amendment (BGBl. I Nr. 62/2026) lets the authorities require collection by customs for up to two years where a financial offence is suspected.
• EORI. Since 6 June 2024 Austrian businesses self-register through the Portal Zoll, which legal persons reach through the Unternehmensserviceportal (USP) and natural persons through FinanzOnline.

Where Austria differs from Germany: Austria's route is the tax office account under § 26(3) no. 2, Germany's is payment to customs with an optional deferment account, and the EORI portals differ. The Union Customs Code rules on declarants, representation and the A.TR are the same in both.

Packaging licensing: pointers only

Polybags, cartons and hangtags can make the importer a packaging producer. The EU Packaging and Packaging Waste Regulation (EU) 2025/40 applies from 12 August 2026, and the national schemes continue alongside it. In Austria, the ministry's June 2026 fact sheet on the regulation confirms that the Verpackungsverordnung 2014 still applies, that household packaging is licensed with a collection and recovery system (Sammel- und Verwertungssystem), and that the importer of packaged goods is the primary obligated party. In Germany, a producer under the regulation registers in the LUCID Packaging Register and joins a system for packaging that ends up with private final consumers; a foreign company selling directly to German consumers without a branch appoints an authorised representative. The packing specification itself is covered in folding and polybagging.

The importer's product-compliance duties

The party that places the garments on the EU market carries duties that a customs representative does not. Three sets apply to consumer clothing, and each has its own guide.

• Product safety. Under Article 11 of the General Product Safety Regulation (EU) 2023/988, an importer checks before placing a product on the market that it meets the general safety requirement and that the manufacturer has done its part, puts its name, registered trade name or trade mark and postal and electronic address on the product, packaging or an accompanying document, and keeps the technical documentation for 10 years. See GPSR for apparel.
• Fibre labelling. Under Article 15(1) of Regulation (EU) No 1007/2011, when the manufacturer is not established in the EU, the importer ensures the fibre label is supplied and accurate; a distributor selling under its own brand counts as manufacturer (Article 15(2)). See EU apparel labelling compliance.
• Textile EPR. Directive (EU) 2025/1892 requires every Member State to set up extended producer responsibility for textiles, with registration and fees set nationally. See EU textile EPR and who is the producer.

How a Turkish manufacturer's documents fit

Routes, Incoterms and transit times are covered in shipping apparel from Turkey. If the A.TR is missing or does not match the invoice, the representative cannot claim the duty-free treatment on that declaration, so check the certificate against the invoice before the goods leave.