Chinese Manufacturers in Türkiye: EU Access, Anti-Dumping & Free Zones

An investor-focused legal overview by Tercan Legal

Chinese manufacturers are rethinking where they produce goods for foreign markets. European trade-defence measures, changing customs rules and the need to be closer to customers are leading many of them to look beyond China for production and distribution.

Türkiye is one of the locations they are considering. It combines a customs union with the European Union, a network of free zones, investment incentives and an established industrial base, at the crossroads of Europe, the Middle East and Central Asia.

These advantages are real, but they are not automatic. Opening a company in Türkiye does not by itself give unrestricted access to the EU, remove anti-dumping duties or make a product Turkish. For Chinese investors, the key question is not only why invest in Türkiye, but how to structure the investment so that its advantages are legitimate and lasting. This article explains the rules that matter.

1. Türkiye as a manufacturing and trade hub

Türkiye sits between the European Union, the Middle East, North Africa and Central Asia. A production or distribution base in Türkiye can shorten delivery distances to European customers compared with shipping only from China, and can serve several regional markets from one location.

The country has an established industrial base in sectors such as automotive parts, machinery, electronics, textiles and chemicals, supported by organised industrial zones, ports and transport networks.

However, access to each market depends on its own customs duties, origin rules and product regulations. Location creates a commercial opportunity, not an exemption from trade rules.

2. The EU–Türkiye Customs Union

Türkiye’s most important trade advantage is its Customs Union with the European Union. It covers industrial products and processed agricultural products. Basic agricultural products, and coal and steel products, fall outside it and are governed by separate agreements.

Goods that are wholly produced in the Customs Union, or that have been put into free circulation there, can move between Türkiye and the EU without customs duties, accompanied by an A.TR movement certificate proving their customs status.

Key distinction. An A.TR certificate proves that goods are in free circulation. It does not prove that they originate in Türkiye. This difference is essential for Chinese manufacturers, because EU anti-dumping duties depend on origin, not on free circulation.

3. Anti-dumping duties: can production in Türkiye change the treatment?

The EU applies anti-dumping and anti-subsidy duties to many products originating in China. A central question for Chinese manufacturers is whether producing in Türkiye can give the finished product Turkish rather than Chinese origin.

Under EU customs rules, where production involves more than one country, origin generally depends on where the last substantial, economically justified processing took place, resulting in a new product or an important stage of manufacture. Repackaging, relabelling or minor processing of Chinese goods in Türkiye does not change their origin.

The EU anti-circumvention rule

The EU can also extend anti-dumping duties to imports from third countries when measures are being circumvented. Under Article 13 of Regulation (EU) 2016/1036, an assembly operation in a third country is treated as circumvention when:

the operation started or substantially increased around the start of the EU investigation, and the parts come from the country subject to measures;
those parts make up 60% or more of the total value of the parts of the assembled product, unless the value added during assembly is more than 25% of the manufacturing cost; and
the remedial effects of the duty are being undermined, and there is evidence of dumping.

Producers and importers that can show they are not related to producers subject to the measures may be exempted by a Commission decision.

What does not work

Relabelling Chinese goods as “Made in Türkiye” or carrying out only light finishing.
Assembling mainly Chinese parts in Türkiye with little local value added.
Assuming that an A.TR certificate removes anti-dumping duties.

A sustainable strategy is based on genuine manufacturing in Türkiye, with real local value added and production records documented from the start.

4. Turkish free zones: opportunities and limits

According to the Ministry of Trade, Türkiye has 19 operational free zones, governed by Free Zones Law No. 3218: Mersin, Antalya, Ege, İstanbul İhtisas, Trabzon, İstanbul Trakya, Adana Yumurtalık, İstanbul Endüstri ve Ticaret, Samsun, Avrupa, Rize, Kayseri, İzmir, Gaziantep, TÜBİTAK-MAM, Denizli, Bursa, Kocaeli and Batı Anadolu.

Tax advantages

Corporate tax: manufacturers holding operating licences issued after 6 February 2004 are exempt from income or corporate tax on profits from selling the goods they produce in the zone abroad, within the same free zone, or to other free zones. Sales into mainland Türkiye are not covered. (Law No. 7524 limited the exemption to export sales from 2025; Law No. 7577 added sales within and between free zones from 2026.)
Wages: income tax on staff wages is exempt for employers that export at least 85% of the FOB value of the goods they produce in the zone.
Stamp duty and fees: transactions and documents related to manufacturers’ activities in the zones are exempt.
Foreign staff: foreign managers and qualified personnel may be employed, subject to the applicable permit rules.

These exemptions apply until the end of the tax year in which Türkiye becomes a full EU member.

Customs status and sales into Türkiye

Free zones are treated as outside Türkiye’s customs territory for import duties, trade policy measures and foreign exchange rules. Goods from abroad can enter the zones without paying customs duties. Trade between a free zone and mainland Türkiye is subject to the foreign trade regime. For manufacturing users, goods taken from a zone into Türkiye are currently subject to a special account fee of 0.9% of their FOB value; other users are subject to different fee rules.

Does a free zone give automatic access to the EU?

No. According to the Ministry of Trade, goods in free circulation can be sent from free zones to EU countries with an A.TR certificate. Goods of third-country origin, such as Chinese components, can be sent to the EU with an A.TR only after customs duties are paid at the Common Customs Tariff rates. A customs status certificate (gümrük statü belgesi) is used as supporting evidence for the A.TR.

For origin purposes, free zones count as part of Türkiye. This does not mean that every product made there becomes Turkish-origin: the processing must still meet the origin rules.

5. Free zone or mainland company: which structure fits?

There is no single right answer: the best structure depends on the product, where it will be sold, how much processing takes place in Türkiye and the investor’s wider plans. The table below summarises the main differences.

	Direct export from China	Free zone company	Mainland Turkish company
EU customs duties	EU duties for the product’s classification and Chinese origin	Duties on third-country inputs must be paid before A.TR treatment	Goods in free circulation can move under A.TR
EU anti-dumping	Applies where measures exist for the product	Depends on the origin of the finished product	Depends on the origin of the finished product
Corporate tax	Chinese tax rules	Exempt on sales abroad and to free zones; taxed on sales into Türkiye	Standard rate; 12.5% on production income for qualifying manufacturers from 2027
Sales in Türkiye	Turkish import duties apply	Possible, with fees and import rules	Direct access to the domestic market
Often considered for	No investment in Türkiye	Export-focused production	Production for the EU and Turkish markets

These are general tendencies, not rules. The two options can also be combined, and the right choice should be made after a case-by-case assessment.

6. Investment incentives

Beyond free zones, Türkiye supports qualifying industrial projects through investment incentive certificates (yatırım teşvik belgesi), which can provide customs, tax and other support depending on the project. Eligibility is not automatic and must be assessed for each project.

The automotive sector shows how this policy works. In 2024, Türkiye introduced an additional duty on Chinese-origin passenger cars (Presidential Decision No. 8639) and exempted imports made under an investment incentive certificate (Presidential Decision No. 8724). In September 2025, the China-specific duty was lifted and replaced by an additional financial obligation on passenger cars imported from countries without a free trade agreement with Türkiye, including China, ranging from 25% (or at least USD 6,000 per car) up to 30% (or at least USD 8,500 per car) for electric cars (Presidential Decision No. 10436). The exemption for imports under an investment incentive certificate was kept. Rates are revised regularly and must be checked for each project, but the direction is clear: Türkiye encourages investment in local production.

Two further measures introduced by Law No. 7582 in June 2026 are relevant to Chinese investors:

12.5% corporate tax for manufacturers: companies holding an industrial registry certificate (sanayi sicil belgesi) and actually manufacturing pay 12.5% instead of the standard rate on income derived exclusively from production, for profits from 2027 onwards.
Deduction for transit trade: a Turkish company that buys goods abroad and sells them abroad without bringing them into Türkiye can deduct 95% of that profit from its corporate tax base, and up to 100% in certain regions, subject to the conditions set out in the law.

7. Türkiye as a base for the US and other markets

The Customs Union applies only to trade with the EU. Türkiye has no comparable arrangement with the United States, and US customs treatment depends on the product’s classification, its origin under US rules and the tariffs in force at the time.

Genuine production in Türkiye can still be part of a wider international strategy, adding capacity and diversifying supply chains. However, manufacturing in Türkiye does not automatically remove US duties on Chinese-origin products, and the position must be checked separately for each product and market.

8. Practical scenario: a Chinese manufacturer supplying European customers

A Chinese company makes industrial machinery components and exports them directly to customers in Germany and Italy. It is considering a factory in Türkiye to shorten delivery times and expand capacity. Before investing, it should answer five questions:

What will be produced in Türkiye? Full manufacturing, assembly or light processing? This decides the origin of the finished product.
Which duties apply to the product? Its customs classification and any EU anti-dumping measures in force.
Free zone or mainland company? The answer depends on its sales mix, its inputs and the tax and customs treatment of each option.
Which incentives are available? An investment incentive certificate, and the 12.5% manufacturing tax rate from 2027.
What obligations follow? Company formation, licences, work permits for Chinese staff, contracts and ongoing compliance.

This shows why the decision cannot be reduced to company registration. Customs, tax and regulatory questions must be assessed together.

9. How Tercan Legal can help

Tercan Legal is an Istanbul-based law firm that has advised international clients from more than 40 countries since 2013, and we serve clients throughout Türkiye. We assist Chinese investors with the legal side of establishing and structuring their activities here: choosing between a free zone and a mainland company, company formation, work permits for Chinese managers and staff, banking set-up and commercial contracts. Our team works with Chinese-speaking clients, and where a project needs product-specific customs classification or tax planning, we coordinate with experienced customs and tax advisers so that the legal, customs and tax pieces fit together.

Next step. Contact Tercan Legal to arrange an introductory meeting and discuss the right set-up for your products and markets.

Conclusion

Türkiye offers Chinese manufacturers a strong combination of location, industrial infrastructure, incentives and a customs union with the EU. But the Customs Union does not remove anti-dumping duties, a free zone does not guarantee duty-free access to the EU, and assembly in Türkiye does not automatically make a product Turkish.

The strongest strategy is genuine production, the right legal structure and careful compliance with Turkish and EU rules. Before investing, decide not only where to build, but how your structure will affect customs, tax and your access to each market.

Sources

Legal notice: This article is provided for general information only and does not constitute legal, tax or customs advice. Reading it does not create a lawyer–client relationship with Tercan Legal. It reflects legislation and official guidance as of October 2026; laws, rates and practice change frequently, and the outcome of any matter depends on its specific facts. Please obtain advice tailored to your situation before making any investment or structuring decision. Tercan Legal accepts no liability for actions taken solely on the basis of this article.

BlogWhy Chinese Manufacturers Are Investing in Türkiye: EU Market Access, Anti-Dumping and Free Zones (2026)