The temporary import regime suspends customs duties entirely or reduces them through partial relief, on the condition that the goods leave Türkiye unchanged within a defined period and are not placed on the domestic market. Commercial sample shipments, by contrast, most often enter under the free circulation regime; even when they are free of charge, a customs value must be declared and normal duties apply. For clinical research equipment the critical questions are whether the item is directly linked to a study protocol, what the planned re-export date is, and who holds operational responsibility while the equipment is in use. Choosing the right regime is directly tied to whether the re-export commitment can realistically be kept.
Not every import is a release into free circulation. Some goods enter the country for a defined period and must leave again unchanged; some are brought in purely for testing or demonstration and are never placed on the market; and research equipment enters temporarily as part of a clinical study, with a limited and purpose-driven use. The customs treatment, taxation and documentary needs of these three scenarios are quite different, and when the setup is wrong the result is either an unnecessary duty burden or the failure to meet a re-export commitment. This article explains how the temporary import regime works, how it differs from sample shipments, the equipment scenarios that arise most often in the clinical research and healthcare sectors, and what documents belong in the file for each scenario.
Who is this for?
Sponsors and CROs installing equipment temporarily at clinical trial sites, manufacturers and distributors bringing products to a fair or promotional event, suppliers sending demo or evaluation devices, importers planning shipments of products treated as samples that are not destined for the market, customs brokers and operations teams are the intended audience. In a clinical research setting, depot operators and quality units are also directly involved: receiving the equipment, registering it in inventory, tracking its time limit and preparing the re-export are shared responsibilities. Marketing teams also need the line between temporary import and samples clear, because the wrong regime choice can result in retroactive duties and penalties.
Which products does it cover?
The scope covers the product groups you will encounter most often in the health and research sector: analytical instruments, refrigerators and freezers, mobile medical devices and biomedical measurement equipment used in clinical studies; medical device prototypes brought for demonstration or evaluation; kits or reagent sets shipped as samples; laboratory-scale pilot production equipment; and devices brought in under lease for a limited period. Each group has different criteria that shape the regime choice: the direct link of the equipment to a clinical trial protocol, whether the sample will be placed on the market, the lease period and whether the goods will be re-exported in their original condition. These criteria should be answered on the importer's own checklist before a customs broker is consulted.
When does it apply?
The temporary import regime comes into play when goods enter the country for the express purpose of leaving again without change. The most common scenarios are: installation of an analytical instrument or freezer at a clinical trial site, to be removed at study end; bringing a medical device to a medical congress for demonstration and returning it afterwards; a manufacturer sending a demo device for an evaluation period; leasing laboratory equipment for a defined term. Whenever the goods are not entering free circulation, are not being held in stock and are not being sold to third parties, the temporary import regime should be evaluated. If the goods have been modified, consumed or sold, the temporary import regime no longer applies and the situation must be reported to the customs administration.
Legal framework and authority
The temporary import regime is framed by the provisions of the Customs Code and the regulations issued under them; Türkiye is also party to international conventions in this area. The competent authority in practice is the Ministry of Trade: regime applications are filed with customs offices and period extensions are requested through the same channel. The Ministry's temporary import FAQ page summarises how the regime works in official terms and is the primary reference of this article. In addition, the Customs Guidance portal hosts guidance documents on temporary import; both applicants and brokers rely on these resources for duty calculation formulas and time-limit rules. The links are numbered in the sources section.
Step-by-step process
- Assess whether the goods qualify for the temporary import regime: will the goods leave the country unchanged, is the intended use and duration defined, and is there any plan to sell or transfer them to third parties? If the answers are affirmative, temporary import is suitable.
- Decide between partial and full relief: research and public-interest uses may qualify for full relief; commercial uses most often receive partial relief.
- Collect the supporting documents: a contract or protocol showing the purpose and duration of use, equipment list, invoice or value declaration, re-export undertaking and any required permit.
- Hand the file to the customs broker and secure declaration registration: confirm that the regime code is correctly entered and the time limit is recorded.
- Register the equipment in inventory on receipt: serial number, delivery date and planned re-export date must appear in the file.
- Centralise time management: all temporary import files should feed into a single calendar; re-export preparation must start a reasonable time before the limit expires.
- If an extension is needed, apply before the deadline: extension requests filed too late may cause the regime conditions to lapse.
- Do not use the equipment for purposes outside the contract or protocol: purpose deviation breaches the regime and triggers duty liability.
- Carry out the re-export and attach the export declaration to the file: the closing of the export declaration is proof that the undertaking was fulfilled.
- Close and archive the file: declaration, export document, period correspondence and inventory records should be kept together.
Document checklist
- Temporary import declaration, with the correct regime code.
- Equipment list: brand, model, serial number, quantity and value.
- Contract, protocol or undertaking showing purpose and duration of use.
- Re-export undertaking or bond.
- Invoice or value declaration, even for free-of-charge goods.
- Supplier warranty and technical documents.
- Delivery and inventory registration form.
- Period extension correspondence, if any.
- Export declaration and closing record.
- Archive reference linking all documents to one file number.
Parties and responsibilities
| Party | Responsibility |
|---|---|
| Importer (regime holder) | Observing regime conditions, managing the time limit, carrying out the re-export |
| Sponsor / CRO | Planning equipment against the clinical protocol, maintaining the re-export calendar |
| Manufacturer / supplier | Providing technical documentation, clarifying warranty and service conditions |
| Customs broker | Correct declaration of regime code, time limit and relief type |
| Depot operator | Receiving, inventorying and safeguarding the equipment |
| Quality unit | Monitoring time limits and purpose compliance, audit-readiness of the file |
Exceptions and edge cases
Not all goods fit the temporary import regime: consumable items, single-use consumables and sample products intended for market placement fall outside it. Goods brought for a fair are usually limited to the duration of the event; once the event closes, the goods must either be re-exported or entered into free circulation. Equipment brought under lease may have a different valuation structure from one-off imports; the contract shape deserves careful review. In a clinical research setting, early termination of a study changes the re-export calendar and that change must be reported to the customs administration promptly. Where equipment has been serviced or repaired in Türkiye, the condition of re-export in unchanged form is not broken, but replacement parts or added components may trigger a fresh assessment; maintenance records should be retained.
Common mistakes
The most common error is confusing temporary import with commercial sample shipments; commercial samples mostly enter free circulation and pay normal duties. The second is failing to track the re-export date: when the period expires without an export, the regime conditions are deemed breached and duties are demanded with late-payment interest. The third is changing the purpose of use without informing the customs administration; diverting research equipment to commercial use constitutes a regime breach. The fourth is leaving the extension request to the last day; a missed deadline equals an automatic undertaking breach. The fifth is failing to document maintenance work carried out in Türkiye; when the goods' condition is questioned at re-export, missing service records slow the process. The sixth is attempting to use the temporary import regime for a sample shipment that will be given away or sold; if the goods are destined for market, the regime does not apply and the correct setup must be defined before the declaration.
Important notice
This article is general information and not legal or customs advice; the conditions of the temporary import regime differ for every piece of goods and every intended use, consult a licensed customs broker for a specific shipment and rely on current legislation. Time limits and relief conditions mentioned here are illustrative; GTİP examples are not binding and must be verified against current regulations before every declaration.
Frequently asked questions
Is customs duty paid under the temporary import regime?
Under full relief, customs duties and additional financial liabilities are suspended; when the goods are re-exported no assessment arises. Under partial relief, a specified percentage of the monthly duty amount is waived; it is not a complete exemption but a reduced-cost structure. Which relief applies depends on the intended use of the goods and the conditions under which they enter.
Are commercial sample shipments processed under the temporary import regime?
In most cases, no. A commercial sample is a product example the importer intends to show to customers and eventually place on the market; it most often enters under free circulation and, even when free of charge, requires a customs value declaration and normal taxation. The temporary import regime applies when the goods will leave the country unchanged; if the sample is being sold or given away, that condition is not met. The importer should clarify the purpose of the sample before the declaration and select the correct regime.
How is the time limit determined for clinical research equipment?
The time limit follows the period committed to in the customs declaration, typically supported by the study protocol or lease agreement. Extensions can be requested as the study continues; if the extension is not filed in time, the regime conditions are at risk. If the clinical study ends early, a new re-export date must be communicated to the customs administration immediately.
What happens if the equipment is serviced in Türkiye?
Maintenance and repair do not break the condition of re-export in unchanged form; however, replaced parts or added components may require a fresh assessment. The cost of the repair does not create a customs value dispute, but documenting the intervention is helpful when the condition of the goods is questioned at re-export. Warranty work carried out by the supplier should also be recorded.
Official sources
- Ministry of Trade Temporary Import FAQTicaret Bakanlığı · verified 07 Sep 2026
- Customs Guidance Portal: Temporary ImportTicaret Bakanlığı · verified 07 Sep 2026
- Ministry of Trade Commercial Import FAQTicaret Bakanlığı · verified 07 Sep 2026
Revision history
v1.1 · 07 Sep 2026 — Content import: external full text applied.
v1.0 · 02 Aug 2026 — Initial source-backed publication.