A.TR certificate: importing from Turkey to Poland

A seller preparing a first commercial shipment from Turkey to Poland usually asks: "Is the A.TR certificate enough, and what else will I pay?" The A.TR solves the customs duty question for most products, but it is not enough on its own: on the Polish side you also need import VAT, an EORI number and a representative to lodge the customs declaration. This article walks through the customs and tax side of a shipment in order. Selling on a marketplace is covered in the Allegro article, and VAT on consumer sales in the OSS and IOSS article.

Short answer: The A.TR certificate is a movement certificate showing that goods are in free circulation in Turkey; industrial products and processed agricultural products covered by the EU–Turkey customs union enter Poland with it without customs duty. The A.TR is not a certificate of origin; agricultural products, coal and steel are outside the customs union. Even with zero duty, import VAT arises separately in Poland. The importing company needs an EORI number; a customs representative usually lodges the declaration, and if the conditions are met the VAT is settled in the VAT return instead of being paid at customs (art. 33a).

What the EU–Turkey customs union covers and what it does not

According to the European Commission's Access2Markets page, the customs union provides zero customs duties and zero quotas between the two sides for goods within its scope. The scope is:

Covered: industrial products and processed agricultural products.
Not covered: agricultural products (those listed in Annex I to the Treaty on the Functioning of the EU); these fall under a separate 1998 decision on agricultural trade.
Not covered: coal and steel products of the European Coal and Steel Community (ECSC); a separate free trade agreement applies to them.

Which group your product falls into is decided by its tariff heading (CN code), not by its name; even within one category, one product can be covered and another not. Clarifying this code with the customs representative before the first shipment is always cheaper than correcting it afterwards.

What the A.TR certificate is, who issues it, how long it is valid

According to the Turkish Ministry of Trade's page on origin and movement certificates, the A.TR allows goods in free circulation in Turkey or in the EU to benefit from the preferential regime of the customs union. It is made out by the customs administration or by bodies it authorises, and endorsed by customs. Four points to know:

It is not a certificate of origin. The A.TR shows that goods are in free circulation, not where they were produced. An industrial product imported into Turkey from another country, with duties paid, can also travel to Poland with an A.TR.
Its validity is limited. Under Decision No 1/2006 of the EU–Turkey Customs Cooperation Committee, the A.TR must be submitted to the customs of the importing country within four months of the date of issue by the customs of the exporting country; late acceptance remains possible in exceptional circumstances.
It can be electronic. According to the Commission's Turkey page, since 8 July 2024 EU countries accept A.TR certificates issued electronically by the Turkish authorities, bearing a QR code and without a wet-ink signature.
Direct transport is required. Under Decision No 1/2006, the A.TR is used when goods are transported directly between the two parts of the customs union; shipments passing through or waiting in a third country are assessed separately.

Proof of origin for products outside the customs union

For agricultural products, coal and steel, preferential tariffs require a proof of origin (EUR.1 or EUR-MED), not an A.TR. In the Ministry of Trade's words, the EUR.1 is the document that proves the origin of goods. For these products the preferential rate, quota and origin rule differ product by product; the Commission points to the product tool on Access2Markets for this check. If you ship fresh fruit, vegetables, nuts or steel products, the first step is to set out in writing the tariff and origin rule that apply to your code.

Zero customs duty, but import VAT arises separately in Poland

The A.TR zeroes the customs duty, not the VAT. According to biznes.gov.pl's page on import VAT:

The VAT base on import is the customs value plus customs duty; additional costs up to the first destination in Poland, such as commission, packaging, transport and insurance, are also added.
VAT rates on import are the same as for domestic supplies. According to podatki.gov.pl, the standard rate has been 23% since 1 January 2011; reduced rates apply to some product groups, and your product's rate is clarified together with its tariff code.
Under the general procedure, import VAT is paid within 10 days of the day the customs authority notifies you of the amount.
A company that is an active VAT taxpayer can deduct import VAT on goods used in its business. An importer that is not an active taxpayer cannot recover this VAT.

So under the general procedure, import VAT is first paid in cash and then deducted in the VAT return. The gap between the two is felt in cash flow, especially on the first large shipment.

Art. 33a: settling import VAT in the VAT return

Article 33a of the Polish VAT Act is the simplified procedure that removes this cash burden: import VAT is not paid at customs but shown in the company's monthly JPK_V7 return as both output and input VAT. According to biznes.gov.pl and the PUESC document submission service, the conditions are:

The company must be an active VAT taxpayer (podatnik VAT czynny).
Within the 6 months before the import, the following must have been submitted to the head of the customs and tax office (naczelnik urzędu celno-skarbowego): documents confirming no social insurance (ZUS) arrears, no arrears in taxes that are state budget revenue (the condition is not met if arrears exceed 3% of the liability), and active VAT registration. Declarations made under criminal liability can be submitted instead of certificates.
The documents are renewed every 6 months; if they are not, the right to use the procedure lapses.
Customs declarations must be lodged through a customs representative (direct or indirect representation); companies with Authorised Economic Operator (AEO) status or certain customs simplification authorisations are exempt from this condition.
Companies without a seat in Poland submit the documents to the Head of the Lower Silesian Customs and Tax Office in Wrocław (Naczelnik Dolnośląskiego Urzędu Celno-Skarbowego).
A company using this procedure files monthly, not quarterly, returns. If import VAT is not reported in the return for the month in which it arose, there are 4 months to correct it; if this deadline is missed, the VAT is paid with interest.

Art. 33a is a right, not an automatic feature. To have these documents ready for a newly formed company's first shipment, the calendar has to be planned right after formation; the order of post-formation registrations is in the first 90 days article.

EORI number: who needs one, where to get it in Poland

According to the Commission's EORI page, an EORI (Economic Operators Registration and Identification) number is mandatory for every customs operation in the EU, including import, export and transit. A company established in the EU gets the number from the customs authority of the country where it is established; the number is valid throughout the EU and does not expire.

According to biznes.gov.pl's EORI page, the process in Poland is:

The application is made through PUESC, the electronic platform of the Polish customs and tax administration. First the natural person who will represent the company opens a personal account, then the company's data is registered with form WRP0001 and an EORI is requested in the "customs" area of activity.
The service is free; if a proxy applies, stamp duty is paid for the power of attorney.
A Polish company's EORI number consists of "PL" and the company's NIP number.
A business has a single EORI number for the whole EU. A company with its seat in another EU country gets its EORI in that country.

The role of the customs representative

In Poland most importers do not lodge the customs declaration themselves but through a customs representative (przedstawiciel celny; in practice an agencja celna). The representative checks the invoice, packing list, transport document and A.TR; enters the tariff code, customs value and VAT calculation in the declaration; and answers customs queries if needed. Representation can be direct or indirect; which one is chosen and how liability is shared is set out in writing with the representative. If you will use art. 33a, a representative is required anyway.

What to give the representative before the first shipment: the EORI number, the VAT number, the power of representation, the tariff codes and technical descriptions of the products, and the invoice and packing list template. A mismatch between the A.TR details (consignor, consignee, number of packages, description of goods) and the invoice is the most common hold-up at the border.

Product compliance: CE, GPSR, Polish labelling

Clearing customs does not mean the product can be sold in Poland. Three topics are checked separately:

CE and declaration of conformity. For product groups covered by EU legislation, such as toys, electrical products or personal protective equipment, the CE marking, EU declaration of conformity and technical file must be ready before shipment.
GPSR. The General Product Safety Regulation (GPSR), applicable since 13 December 2024, requires an economic operator established in the EU to be responsible for a product sold in the EU. When your Polish company is the importer, this role falls to it. How this works on a marketplace is in the Allegro article.
Polish information. Under the GPSR, warnings and safety information must be in a language easily understood by consumers, as decided by the country of sale; for products sold to consumers in Poland, the label, warnings and instructions are prepared in Polish.

Small parcels: shipping directly to consumers

The setup above is for commercial imports, where goods arrive in bulk and enter the Polish company's stock. If you send individual parcels from Turkey to consumers, the rules differ: for consignments not exceeding EUR 150, VAT can be collected through IOSS; details in the OSS and IOSS article. According to the Commission's announcement on low-value consignments, from 1 July 2026 to 1 July 2028 a temporary customs duty of EUR 3 per item applies to these consignments. Goods covered by the customs union are excluded only if the VAT has not been collected through IOSS and the consignment is declared with a standard declaration (H1). Take this distinction into account before choosing a small-parcel model; for the warehouse option see the 3PL warehouse in Poland article.

Frequently asked

Who issues the A.TR certificate, the exporter or the buyer?

The A.TR is issued in the country the goods leave: for goods shipped from Turkey, it is made out by the Turkish customs administration or bodies it authorises, and endorsed by customs. The exporter has it prepared; the buyer in Poland or its representative attaches it to the import declaration. It must be submitted to Polish customs within four months of its date of issue.

If I have an A.TR, do I pay no tax at all in Poland?

For a product covered by the customs union you pay no customs duty, but import VAT arises; the standard rate is 23%. A company that is an active VAT taxpayer can deduct this VAT; if it meets the art. 33a conditions, it settles it in the VAT return without paying cash at customs. Agricultural products, coal or steel may also involve customs duty and origin rules.

Can I import into Poland with my Turkish company's EORI number?

A non-EU company can get an EORI in the EU country where it carries out its first customs operation. But if you will stock and sell the goods in Poland, you also need Polish VAT registration, which a non-EU company can only obtain through a fiscal representative (VAT Act art. 18a). This is why, for regular imports, we usually proceed with a Polish company and its EORI number.

How we run it

We map your product list, tariff codes and shipment plan with you, and set out in a written summary whether the goods fall under the customs union and which documents are needed. We coordinate the Polish company, VAT and EORI registrations with the Start a Company page and keep the calendar for the art. 33a documents. Customs declarations and representation sit with our customs representative partner, VAT returns and the final tax assessment with our certified accountant partner; we run the Turkish-language coordination between the exporter in Turkey, the carrier and the partners in Poland. Your situation first, then a written quote; no fixed package prices.

Sources

Last checked: 26 September 2026. This article is general information; your own case needs assessment by a licensed partner.

Tell us your situation or see the Expand to Europe page.

This article is for information only and is not legal or tax advice. Basis: Decision No 1/95 of the EU–Turkey Association Council and Decision No 1/2006 of the Customs Cooperation Committee (A.TR), the European Commission's Access2Markets and customs pages, art. 33a of the Polish VAT Act, guidance from biznes.gov.pl, podatki.gov.pl and PUESC, and the General Product Safety Regulation (EU) 2023/988; as of September 2026. Tariff codes, rates and documents are decided product by product; on customs the last word rests with our customs representative partner, on tax with our certified accountant partner.

Author

Savaş Dere · Founder, CEO

Close to twenty years in software and e-commerce: web and application development, automation, digital products. At Senavia he runs process design, the technology infrastructure and integrations; a founder who has been through company formation and settling in Poland himself.

Meet the team

Shipping goods from Turkey to Poland: the A.TR certificate, the customs union, import VAT and EORI