A.TR, EUR.1 or Certificate of Origin? Türkiye–EU Packaging Guide

Three documents come up when packaging moves between Türkiye and the EU. The A.TR movement certificate shows that industrial goods are in free circulation in the customs union, so they cross without customs duties. The EUR.1 proves preferential origin and is used between Türkiye and the EU only for agricultural products and coal and steel products. The certificate of origin (Turkish: menşe şahadetnamesi) proves non-preferential origin and is needed only when someone asks for it. For paper cups, food containers, bagasse items and wooden cutlery, the A.TR is the document that matters.

This guide explains each document, who issues it in Türkiye, which goods the customs union covers, the commercial and transport papers that travel with every shipment, Incoterms, transport routes and a checklist for buyers. For the sourcing side (why buyers source from Türkiye, food-contact and PPWR documents), see our sourcing guide for sustainable food packaging from Türkiye.

A.TR vs EUR.1 vs certificate of origin at a glance

What is an A.TR certificate?

The A.TR is the movement certificate of the customs union that Decision No 1/95 of the EC–Turkey Association Council completed at the end of 1995. Its detailed rules are in Decision No 1/2006 of the Customs Cooperation Committee. Türkiye’s Ministry of Trade puts it plainly: the A.TR shows that goods are in free circulation and does not show their origin.

Practical points:

• Validity. The A.TR must be presented to the customs of the importing country within four months of the date of issue (Article 8 of Decision No 1/2006). Late submission is accepted only in exceptional circumstances.
• Electronic A.TR. Since 1 May 2024 Turkish A.TR certificates are issued through MEDOS, Türkiye’s electronic system for origin and movement documents, with a QR code. Since 8 July 2024 EU customs accept them without a wet-ink signature. Decision No 1/2025 of the EU–Türkiye Customs Cooperation Committee (24 April 2025) confirmed this practice with effect from that date.
• Approved exporters. Exporters who ship frequently can be authorized by customs to complete A.TR certificates themselves (Article 11 of Decision No 1/2006).

Free circulation is not origin

Goods are in free circulation in Türkiye when they were made there, or when they were imported from a third country and Turkish import formalities were completed and customs duties paid. Only then can they travel to the EU with an A.TR. Their origin does not change: a product made in a third country keeps that country’s origin. That is why trade-defence duties still apply. If the EU has anti-dumping duties on a product from a given origin, an A.TR does not remove them.

What is an EUR.1 certificate?

The EUR.1 movement certificate proves preferential origin under a free trade agreement. The customs union does not cover agricultural products or coal and steel products. Agricultural products have their own preferential regime (Decision No 1/98) and coal and steel products a separate 1996 agreement, so for these goods duty relief depends on proof of origin, either an EUR.1 or an origin declaration on the invoice. According to Türkiye’s Ministry of Trade, any exporter may make an invoice declaration for consignments up to €6,000; above that, only approved exporters may.

Türkiye also uses EUR.1 with countries outside the EU with which it has free trade agreements. For paper and fiber packaging traded between Türkiye and the EU, an EUR.1 is normally not part of the file.

What is a certificate of origin (menşe şahadetnamesi)?

A certificate of origin proves the non-preferential origin of goods. It gives no duty reduction. In Türkiye it is issued by chambers of commerce, industry and commodity exchanges in the TOBB network. Since 8 April 2020 these certificates are issued and approved only electronically through MEDOS, with a QR code and a verification code.

Türkiye’s Ministry of Trade states that a certificate of origin is not mandatory for exports; it is issued when the importing country asks for it. In practice an EU buyer asks for one when:

• a letter of credit or the buyer’s bank requires it;
• a public tender or the end customer asks for documented origin;
• customs must check an origin-based measure, such as anti-dumping duties.

Which goods does the customs union cover?

Food packaging items (paper cups, paper food containers, molded-fiber or bagasse items, cartons, paper bags, wooden and bamboo cutlery) are industrial products, so they fall under the customs union.

Which HS codes are typical for food packaging?

The customs tariff number decides the duty, the statistics and any measures. These Harmonized System headings are common for food packaging; the EU Combined Nomenclature and Türkiye’s tariff add further digits.

Classification is decided item by item, from the material and the function. Confirm the code with your customs broker, or ask your customs authority for a binding tariff information decision when the volume justifies it.

Which documents travel with every shipment?

Check that the invoice, the packing list and the A.TR show the same goods, quantities and parties. Most delays at import come from mismatched documents, not from the goods.

Incoterms: who does what?

The ICC Incoterms rules set who pays for transport and insurance, where the risk passes and who handles customs. Common choices for packaging from Türkiye:

• EXW / FCA: the buyer’s forwarder collects the goods; with FCA the seller clears the goods for export, which is usually the practical choice.
• CPT / CIP / CIF: the seller pays the main carriage; risk passes when the goods are handed to the first carrier or loaded on board.
• DAP: the seller delivers to the agreed place in the EU; the buyer handles import clearance and import VAT.
• DDP: the seller also handles EU import clearance and taxes, which usually needs a VAT registration or a fiscal representative in the country of import.

Name the place precisely (for example “FCA İzmir warehouse” or “DAP Hamburg”) and agree who prepares the A.TR and who files the EU import declaration.

How do goods travel from Türkiye to the EU?

• Road. Direct trucks from western Türkiye to the EU via the Balkans. Door-to-door without transshipment; transit time depends on the destination and on waiting times at border crossings.
• Ro-Ro. Trailers travel by ferry from Turkish ports to Italy or France and continue by road or rail. DFDS, for example, lists Pendik–Trieste, Mersin–Trieste, Martaş–Trieste and Yalova–Sète; the Pendik–Trieste crossing takes about 65 hours.
• Container sea freight. Full (FCL) or shared (LCL) containers from Turkish ports to EU ports. It suits large volumes; transit time depends on the line and any transshipment.

Road and Ro-Ro usually take days rather than weeks. Ask your forwarder for the current schedule and transit time on your lane before you plan stock.

Which taxes and fees remain?

Zero customs duty is not zero cost at the border:

• Import VAT is charged in the EU Member State where the goods are imported, as for any import from outside the EU VAT area. Many countries offer deferment or reverse-charge schemes for regular importers.
• Packaging EPR. Registration and fees under national schemes and the PPWR apply in the country where the packaging is placed on the market. See the guide to EU packaging regulations.
• Trade defence. Anti-dumping, anti-subsidy or safeguard duties follow the goods’ origin and product, not the A.TR.

Checklist for buyers

1. Ask where each item is produced and whether it is in free circulation in Türkiye.
2. Agree the Incoterm, the named place and who files export and import declarations.
3. Confirm the HS code of each line with your customs broker.
4. Check that an A.TR will be issued and presented within four months of issue.
5. Ask for a certificate of origin if your bank, tender or customs check needs it.
6. Check whether trade-defence measures apply to the product and its origin.
7. Match the invoice, packing list, A.TR and transport document before the goods leave.
8. Plan import VAT and EPR registration in each country of sale.
9. Keep the product documents (food contact, PPWR) with the shipment file.

Documents with Ekoroll

Ekoroll is a manufacturer-direct supply partner based in İzmir, Türkiye, for paper cups, paper food containers and bagasse food containers. Each quote states where the item is produced, the shipping route and which customs documents apply; the commercial and transport documents travel with every shipment. Samples are available before a bulk order. Contact us with your destination and Incoterm, or browse the catalog.