What is a bonded warehouse?
A bonded warehouse (customs warehouse) is a place where goods that have not been released for free circulation are kept under customs supervision, without being subject to import duties or trade policy measures. While the goods wait in the warehouse, import duties do not accrue; the duty arises with the declaration for release for free circulation. Under the Customs Law, the time goods may remain under the customs warehousing procedure is, as a rule, unlimited.
What is the difference between a public and a private bonded warehouse?
The difference is who can use the warehouse. Article 94 of the Customs Law defines public customs warehouses as those "that can be used by anyone for the storage of goods", and private customs warehouses as those "set up solely for the storage of goods belonging to the warehouse operator". A public warehouse is a service business; a private warehouse is for the operator's own goods. Article 93 of the Law also separates the operator from the user: the operator is the person permitted to run a customs warehouse, and the user is the person who makes the declaration placing the goods under the warehousing procedure.
What do warehouse types A, B, C, D, E and F mean?
The types are distinguished by who holds responsibility and the stock record. Article 329 of the Customs Regulation provides that public warehouses are of types A, B and F, and private warehouses of types C, D and E. In type A the operator keeps the stock record and, if any goods are missing from those placed in the warehouse, is liable for the customs duties. In type B responsibility lies with the user, who files the warehouse declaration; the operator only rents out the facility, and because no stock record is kept, the declaration and the documents form the basis of customs control. In types C, D and E the operator and the user are the same person. Type F is operated by the customs administrations.
How does the bonded warehouse regime defer duty?
The deferral comes from the duty arising when the goods leave the warehouse, not when they enter it. Goods are placed without being charged import duties, and because the period is unlimited, import can be made in parts as the need arises, which eases cash flow. The price is obligation: the administration may ask for a guarantee, records are kept, and the duties on goods found missing are collected from the operator or the user depending on the type. Goods cannot leave the warehouse before the formalities are completed and the customs administration has given permission; the release itself is made by a declaration for free circulation (see customs clearance).
- Warehouse charges and the costs of keeping the goods while they stay in the warehouse are not included in the customs value, provided they are shown separately from the price actually paid or payable (Customs Law, Art. 104/1)
- In type D, duties are calculated at the rates and other elements of taxation in force on the date the goods were placed under the warehousing procedure, in accordance with the third paragraph of Article 104 of the Law
What is the difference between temporary storage and a bonded warehouse?
Temporary storage is a time-limited waiting status, while a bonded warehouse is a customs procedure. Goods presented to customs are in the status of temporarily stored goods until a customs-approved treatment or use is assigned to them. Under Article 46 of the Customs Law, these formalities must be completed within forty-five days from the date the summary declaration is lodged for goods arriving by sea, and within twenty days for goods arriving by any other mode, for example by road or by air. Goods for which formalities have not been started within this period enter the liquidation process. In a bonded warehouse there is no time limit; the status rests on a declaration.
What is the difference between a bonded warehouse and a free zone?
Both defer duty, but a free zone is a wider area. Article 152 of the Customs Law defines free zones as places which, although parts of the Turkish customs territory, are considered to be outside it for the purposes of applying import duties and trade policy measures. Entry into a bonded warehouse rests on a warehousing declaration; in a free zone, under Article 153 of the Law, the borders and the entry and exit points are under the supervision of the customs administrations, and a copy of the transport document that must accompany the goods on entry or exit has to be given to the customs administration or kept ready for inspection. In a bonded warehouse, ordinary handling operations depend on the permission of the customs administrations. The period of stay is, as a rule, unlimited in both.
Bonded warehouse types under Article 329 of the Customs Regulation
| Type |
Public / private |
Distinguishing feature |
| A |
Public |
The operator keeps the stock record; the operator is liable for customs duties on missing goods |
| B |
Public |
Responsibility lies with the user; the user files the warehouse declaration and the operator only rents out the facility |
| C |
Private |
Operator and user are the same person; this person is responsible for the goods placed in the warehouse |
| D |
Private |
Operator and user are the same person; the third paragraph of Article 104 of the Law applies |
| E |
Private |
The permit holder's storage place is deemed a bonded warehouse; the regime can apply even where there is no dedicated storage place |
| F |
Public |
Operated by the customs administrations |
Frequently asked questions
How long can goods stay in a bonded warehouse?
Article 101 of the Customs Law treats the period under the warehousing procedure as unlimited. In cases the customs administrations find necessary, however, a period can be set for a new customs-approved treatment or use to be assigned to the goods. An unlimited period does not mean that storage charges stop running.
Can goods in a bonded warehouse be worked on?
Only to a limited extent. Under Article 102 of the Customs Law, imported goods can undergo the ordinary handling operations set by regulation, for the purpose of preserving them, improving their appearance or marketable quality, or preparing them for distribution or resale, and these operations are carried out with the permission of the customs administrations. A bonded warehouse is not a production site.
Does a bonded warehouse remove storage costs?
No. A bonded warehouse defers duty, not the storage charge; the operator invoices on its own tariff. This item is separate from the carrier's demurrage and detention calculation. When deciding, set the cash-flow benefit of the deferred duty against the storage charges that build up.
Can the temporary storage period be extended?
Article 46 of the Customs Law provides that, where conditions require, the administration may set a shorter period or allow these periods to be extended; an extension beyond what is really needed cannot be given. The safe way is to have the declaration and its attachments ready before the ship arrives.