Short answer
Every export shipment requires a commercial invoice, a customs declaration (an ETGB for low-value express courier shipments), and a transport document (bill of lading, CMR, or AWB); in practice a packing list is also requested. Depending on the destination country, an A.TR, EUR.1, or certificate of origin is added. The type of product may require a health certificate or an analysis report. If payment is by letter of credit, the documents must correspond with the terms of the credit.
What documents make up an export file
Export documentation falls into four main groups: commercial documents, transport documents, customs documents, and origin/movement documents. Product-specific documents and an insurance document are added on top of these. Which document is required is determined by three variables: the goods’ GTİP number, the destination country, and the method of payment. The same product may travel to Germany with an A.TR Movement Certificate and to Iraq with a certificate of origin.
A more important question than the list itself is who issues each document. Some are produced by the exporter under its own stamp, some are issued by the carrier, and some carry no legal effect at all without a chamber and customs approval.
Commercial documents
The commercial invoice is the centerpiece of the file. The declaration, the certificate of origin, the packing list, and payment under a letter of credit are all based on the data on this invoice. It carries the seller’s and buyer’s details, the description of the goods, the GTİP, the quantity, unit price, total amount, the Incoterms delivery term and place, the method of payment, and the country of origin.
The proforma invoice is an offer; it does not create an accounting entry. It is used for the buyer to obtain an import permit or open a letter of credit. Because the letter of credit is opened on the basis of the proforma, the description of the goods on the proforma must be consistent with the description on the commercial invoice issued later; however, the bank compares the documents against the credit itself, not the proforma, so the invoice must conform to the credit.
The weight list (packing weight list) gives the breakdown of gross and net weight and dimensions. The packing list shows what is packed into which box. In practice the two are often merged into a single document; for mixed shipments, they may need to be issued separately.
| Document | Issued by | Required when |
|---|---|---|
| Proforma invoice | Exporter | Before the order, when opening a letter of credit |
| Commercial invoice | Exporter | Every shipment |
| Weight list | Exporter | Every shipment |
| Packing list | Exporter | Multi-item, mixed shipments |
Transport documents
The transport document is issued by the carrier or its agent, not by the exporter. The document changes with the mode of transport.
The bill of lading is used in sea freight and stands apart from the others: in its to-order form it is a document of title and represents the goods. Whoever holds the original to-order bill of lading can claim the goods at destination, and it can be transferred by endorsement. Under a straight bill of lading the goods are delivered only to the named consignee, and a sea waybill is not a document of title at all. It is generally issued in three original copies.
CMR is the abbreviation of the international road transport convention; in practice the consignment note issued under it is also called a CMR. AWB is used in air freight. In rail transport, CIM is used on the European network, SMGS on the CIS network, and a combined CIM/SMGS document on routes where the two meet. None of these documents represent the goods. The buyer can take delivery of the goods without presenting the document. For this reason, shipping by road or air before collecting payment for the goods carries higher risk than doing so by sea.
Customs documents
The customs declaration is the official record of the export. It is filed electronically on the exporter’s behalf either by a customs broker (indirect representation) or by the company’s own authorized staff (direct representation). The content of the declaration and the registration procedure are set out in the Customs Law and its related regulations.
Approval from the exporters’ union is normally obtained before the declaration is registered, and the exporter must be a member of the relevant union. Micro-export under an ETGB and certain free-of-charge and special-regime transactions are exempt from this approval. For express courier and postal shipments below a certain weight and value threshold, a simplified ETGB is issued instead of a normal declaration.
Depending on the product, a control certificate, prior permit, or conformity letter may be required. These must be in the file before the declaration is registered; completing them afterward is usually not possible.
Origin and movement documents
This group causes the most confusion, because it documents two separate things: free circulation status and origin.
| Document | Used where | Proves | Approval chain |
|---|---|---|---|
| A.TR | EU member states | Free circulation status | Chamber approval + customs endorsement |
| EUR.1 | Countries with an FTA; agricultural and coal/steel products bound for the EU | Preferential origin | Chamber approval + customs endorsement |
| EUR-MED | Pan-Euro-Mediterranean cross-cumulation routes | Preferential origin and cumulation | Chamber approval + customs endorsement |
| Certificate of origin | Countries without an FTA; other cases where the buyer requires proof of origin | Country of origin (non-preferential) | Chamber of commerce |
| Form A | GSP countries granting Türkiye unilateral preference | Preferential origin | Chamber approval, customs endorsement depending on the regime |
The critical distinction is this: A.TR is not a certificate of origin. It does not show that the goods are of Turkish or EU origin, only that they are in free circulation. Goods of Far Eastern origin on which import duties have been paid in Türkiye can also travel to the EU under A.TR. If the buyer additionally requires proof of origin, a certificate of origin is issued as well. Form A comes into play for exports to GSP countries that grant Türkiye unilateral preference; the EU, for its part, has moved from Form A to the registered exporter (REX) declaration under its GSP.
Product-specific documents and insurance
| Document | Issued by | Required when |
|---|---|---|
| Veterinary health certificate | Provincial directorate of the Ministry of Agriculture and Forestry | Animal products |
| Phytosanitary certificate | Provincial directorate of the Ministry of Agriculture and Forestry | Plants and plant products |
| Analysis report | Accredited laboratory | Food, chemicals, textiles; when requested by the buyer or destination country |
| Declaration of conformity / CE technical file | Manufacturer, notified body where required | Covered industrial products bound for the EU |
| Halal or kosher certificate | Accredited certification body | Markets that require it |
| ATA Carnet | Chambers of commerce | Temporary exports such as trade fair samples, professional equipment |
| Insurance policy or certificate | Insurance company | CIF and CIP deliveries, when required by a letter of credit |
The ATA Carnet is for temporary exports; where the goods will return in the same condition, it removes the burden of a declaration and guarantee, and is valid for a maximum of one year.
Who arranges insurance is determined by the Incoterms term. Under CIF and CIP the policy is taken out by the seller, made out in the buyer’s favour. Under Incoterms 2020, the minimum cover under CIP was raised to the broad (A) clause, while CIF remained at the narrow (C) clause. For other delivery terms, insurance is not mandatory, and the carrier’s limited liability is no substitute for cargo insurance.
Document discipline under letter-of-credit payment
Under a letter of credit, the bank does not see the goods, it sees the documents. Payment depends on the presented documents matching the credit’s terms. Even a single-letter discrepancy can be grounds for a reservation.
The description of the goods on the commercial invoice must correspond with the description in the letter of credit. It need not be word for word identical, but the description must not conflict with or go beyond the credit. A general description not conflicting with the credit is acceptable on the other documents. Banks have up to five banking days to examine the documents. If a reservation is raised, payment stops, and while the goods wait at the port of arrival, demurrage starts to run once the free time allowed by the carrier has expired.
Common causes of reservations: shipment made after the latest shipment date stated in the credit, documents not presented to the bank within the presentation period, a missing on-board notation on the bill of lading, and an insured amount below 110 percent of the invoice value.
Common mistakes
- The invoice and the packing list not matching. Gross weight, net weight, number of packages, and dimensions must be identical on both documents. If a box is added during loading and the invoice is not updated, the file gets held up at inspection.
- The product description changing from document to document. An invoice reading “stainless steel pipe” and a certificate of origin reading “steel profile” can lead all the way to the certificate of origin being rejected at the buyer’s customs.
- Assuming the certificate of origin can be obtained afterward. Movement and origin certificates can, under exceptional circumstances, be issued with an “issued retrospectively” notation, but this is not a right; by that point the importer will already have paid the duty.
- Mistaking A.TR for a certificate of origin. Sending A.TR to a buyer who requires proof of origin does not solve the problem.
- Writing the GTİP based on the buyer’s declaration. The wrong GTİP changes both the duty and the permit regime; responsibility lies with the exporter.
- Writing the buyer’s name and address differently from the letter of credit. Even an abbreviation can create grounds for a reservation.
- Overlooking the need for consular legalization. Some countries require legalization on top of chamber approval; this process is measured in days.
- Declaring a temporary export as a definitive one. If a normal declaration is used instead of an ATA Carnet for trade fair goods or samples, import duty will apply when the goods come back.
Working out the document list by country and GTİP before the shipment leaves is always cheaper than trying to correct it afterward. For complex files, customs brokerage and regulatory advisory processes are used to finalize this list before loading.
This page is general information, not legal advice. Regulations change; confirm the current position before acting.



