A.TR and EUR.1 Certificates: When Is Each Used?

Executive Summary

A.TR and EUR.1 documents do not serve the same legal purpose.

A.TR is a circulatory document, which is included in the Customs Union between Turkey and the European Union.

EUR.1 is one of the documents used in the respective preferential trade agreements and regulations, in the evidence of the preferential origin status of the goods.

The presence of A.TR document does not show only that the goods are European Union or Turkish origin.

The presence of EUR.1 document does not eliminate the need for assessment regarding the rules of origin and other terms of the relevant agreement.

When determining the right document of the companies, it is necessary to evaluate the GTİP of the goods, its origin, free circulation status, the scope of the traded country and the relevant agreement.

1. What is A.TR Circulating Certificate?

A.TR circulatory document is the document used for free circulation status of goods under the Customs Union between Turkey and the European Union.

This document is important in the evaluation of the preferred tariff application in terms of products covered by the Customs Union.

However, the legal nature of A.TR should be understood correctly.

A.TR is not a certificate of origin.

The document cannot prove that the goods are produced in a certain country or that country is originated alone.

For example, a product manufactured in China can be free circulation in the European Union by completing the related customs clearance.

A.TR document may be used if the related conditions are provided, then in the submission of this product to Turkey.

But this situation does not automatically change the Chinese origin of the product.

2. What is EUR.1 Circulating Certificate?

An EUR.1 movement certificate is one of the documents used to prove the preferential origin of goods under the applicable preferential trade arrangements.

The use of EUR.1 depends on the preferential trade arrangement in force with the relevant country or country group of Turkey.

In this context, it is necessary to meet the rules of origin prescribed in the agreement on the respective agreement of the goods.

For example, it may not be enough for a product to be manufactured in a specific country, to accept that country origin alone or to benefit from the advantage of the preferred tariff under EUR.1.

The production process of the product should be evaluated together with the inputs used and related rules of origin.

Also, EUR.1 is not used in each preferential trade arrangement. According to the relevant arrangement, the statement of origin may be subject to EUR-MED or other proof methods.

3. Basic Differences Between A.TR and EUR.1

This table is a general comparison. The scope of the product in the somut processes, the relevant agreement and the applicable regulations should be undertaken.

4. Difference Between Origin with Free Circulation

A.TR and EUR.1 documents must be separated from each other for the correct understanding of free circulation and origin.

Free circulationIt is the customs status earned as a result of meeting certain conditions within the scope of the customs regulations related to the goods.

Origin means which country is accepted according to the rules of origin of the goods.

These two concepts are not the same.

For example, a free circulation in the European Union of a Chinese origin product, does not eliminate the Chinese origin of the product itself.

Similarly, it does not mean that a product is derived from Turkey, in any case, it can benefit from the A.TR application under the Customs Union.

The scope and related trade arrangement of goods should also be evaluated.

5. What Products Are A.TR Certificate Used?

Turkey–European Union Customs Union has a structure that mainly covers the relevant industrial products and regulations for the industrial share of processed agricultural products.

However, it is not correct to evaluate all product groups in the same context.

Different preferential trade regulations and rules of origin can be applied in certain products within the scope of the European Coal and Steel Community with agricultural products.

Therefore, it does not mean that only the trade is realized between Turkey and the European Union, the A.TR document for each product is appropriate.

First, the scope of the GTIP and the corresponding arrangement of the goods should be determined.

Then the free circulation terms and other document conditions should be evaluated.

6. What Status is used for EUR.1 Certificate?

The EUR.1 document can be used in the processes that the relevant preferably trade arrangement is accepted as a proof tool of origin.

This may cover certain free trading deals and other related preferential trade regulations.

However, the EUR.1 document is not a valid general document for each country, every agreement or every product.

For example, there is a preferential trade arrangement between two countries, it does not necessarily mean that it will be used EUR.1 in the arrangement.

For this reason, the current origin protocol and proof provisions of the relevant agreement should be reviewed while selection of documents.

7. Is A.TR Certificate Always Resets Customs Tax?

No.

The presence of A.TR document can provide certain customs tax benefits if the related product enters the scope of the Customs Union and other requirements are provided.

However, A.TR document does not automatically eliminate all tax and financial obligations that may be applied in import.

For example, different trading policy measures may come to the origin of the product, GTIP or related regulation.

In addition, VAT and other financial obligations are evaluated according to their legislation.

Therefore, the presence of A.TR document should not be interpreted as the import process is exempt from all financial obligations.

8. Is EUR.1 Certificate of Customs Tax Always Resets?

No.

The EUR.1 document may be one of the evidence tools of origin prescribed in the relevant preferably trading arrangement.

However, the preferred rate of tariff is determined according to the provisions of the product GTIP and the corresponding agreement.

While zero customs tax can be applied on some products, discount rates or different regulations may be subject to some products.

It is not enough only to have a certificate of origin.

It is necessary to meet the rules of origin and to provide other conditions.

9. A.TR Usage in Third Country Origin Products

Practical results of the absence of origin of the A.TR document appear especially in the third country-based products.

Let’s assume that a piece of machine made in China is imported to Germany.

The product is completed related operations and get free circulation in the European Union.

Then this product is sold to a buyer in Turkey.

It can be possible to be shipped with A.TR document if the product enters the scope of the Customs Union and is provided by other terms.

However, the origin of the product does not only turn into German origin, due to the introduction of free circulation in Germany.

This distinction is especially important in the evaluation of origin-based trading policy measures.

Free circulation status with A.TR does not eliminate the need to evaluate the origin of the goods as well.

10. Sample Application: Same Product, Different Documents

The following examples show that the selection of documents will not only be structured according to the shipping country.

Script A — Industry product from Germany to Turkey

A free circulation in Germany and a industry product under the Turkish-EU Customs Union is sent to Turkey.

A.TR document can be used if applicable conditions are provided.

The product does not necessarily have German origin.

Scenario B — Product under preferential trade agreement

The product that meets the conditions of origin from a country with a preferential trade arrangement with Turkey is imported.

This document can be used if the relevant arrangement accepts EUR.1 document.

However, the preferred status of the product should be really available.

Script C — product from the European Union but outside the scope of the Customs Union

A product sent to Turkey from the European Union may be outside the scope of the relevant Customs Union.

In this case, a different preferential trade arrangement and proof method of origin may come to agenda instead of A.TR.

Which document is determined according to the GTIP of the product to be used and the corresponding arrangement.

11. Frequent Errors in A.TR and EUR.1 Documents

The main mistakes that companies should pay attention to the document management are:

1. Accepting A.TR document as a origin certificate.
2. If you have the EUR.1 document valid for each country.
3. Registration of the country directly as the country of origin.
4. The scope of the Customs Union of the product is not controlled.
5. Review of origin-based trading policy measures.
6. Not to verify the information of origin given by the supplier.
7. No changes in preferential trade regulations are followed.
8. The consistency of the document information on the customs declaration shall not be checked.

Each of these deficiencies may not mean direct legislation breach. However, the use of incorrect document or the risk of incorrect tariff application may increase.

12. After Check A.TR and EUR.1 Documents

After the control, the circulatory and origin documents relating to past import operations can be examined.

In these reviews;

• whether the document is suitable for related processing,
• the product does not enter and enter the scope of the related trade regulation,
• whether the preferential origin conditions are provided and not provided,
• consistency of commercial records with origin information,
• applicable financial obligations shall not be applied correctly and applied

can be assessed.

In terms of proof documents of origin such as EUR.1, verification mechanisms may also take importance from the prescribed after the corresponding agreement is prescribed.

The terms of free circulation status and related regulations are taken in the examination of the A.TR document.

In terms of both documents, review and verification processes may occur in accordance with the relevant legislation.

C-INSPEC Perspective

The Legal Accuracy of the Commercial Transaction with Document Accuracy Is Not The Same

A.TR or EUR.1 document in customs transactions can create a thought that most of the related commercial transactions are documented adequately in terms of the preferred tariff.

However, there are different topics to really meet the legal conditions related to the document.

For example, A.TR document can ruin free circulation status of goods.

However, this document does not show that the product is exempt from all the trading policy measures based on origin.

Similarly, the EUR.1 document is regulated, does not eliminate the need to review the rules of the agreement in relation to which the relevant production process really meets.

Therefore, in the C-INSPEC approach, document controls should not only be limited to whether the document is available.

The product should be assessed together with GTİP, origin, free circulation status, related agreement and applicable financial obligations.

Reliable foreign trade compliance requires the correct understanding of which legal outcome of the document, so as to use the right document.

It is important that companies identify this separation in an open way, especially among purchasing, logistics and foreign trade departments.

13. Five Stage Document Control Program for Companies

Step 1 — Determination of product and transaction scope

The product is determined by the GTİP, the origin, the dispatch country and the related trade arrangement.

Step 2 — Selection of the appropriate document type

The process is determined whether A.TR is assessed and assessed under the proof method of EUR.1 or another origin.

Step 3 — Control of document and legal conditions

The terms of validity, scope and relevant regulation of the document are evaluated.

Step 4 — Declaration and financial obligation control

The document is compared to the customs declaration with the information; the taxes and trade policy measures to be applied are checked.

Step 5 — Continuous monitoring

Agreement changes, rules of origin and document regulations are updated and related procedures are updated.

This approach supports the management of circulatory and origin documents not only as operational paperwork, but as an important element of the customs compliance system.

Frequently Asked Questions

Conclusion

A.TR and EUR.1 documents are important in international trade and have different legal functions.

An A.TR movement certificate evidences the free circulation status of the relevant goods under the Türkiye–EU Customs Union. An EUR.1 movement certificate may be used to prove preferential origin under the applicable preferential trade arrangements.

The correct understanding of this separation is especially important in the trade of third-party products, preferred tariff applications and evaluation of origin-based obligations.

It is not enough for companies to rely solely on the document selection or the document offered by the supplier.

GTİP should be evaluated together with the origin, free circulation status and related trade arrangement.

The use of the right document in foreign trade starts not only from the document supply, but from the correct understanding of the legal conditions based on the document.

Legislation and Official Sources

1. Customs Law No. 4458.
2. Customs Regulation.
3. Partnership Council Decision No. 1/95 on the Customs Union of Turkey–European Union and related application regulations.
4. Free trade deals and origin protocols related to Turkey’s side.
5. The Ministry of Commerce — A.TR circulatory document, EUR.1 circulatory document and official explanations on the rules of origin.