Incoterms 2020 for Turkey–EU: FCA, DAP, DDP Compared

Incoterms 2020 are eleven standard trade terms from the International Chamber of Commerce (ICC) that divide tasks, costs and risk between seller and buyer when goods are delivered. For machined parts moving by road from Bursa to the EU, the usual choices are FCA, DAP and DDP: FCA leaves main carriage and import clearance with the buyer, DAP puts carriage to the named place on the Turkish seller, and DDP adds EU import clearance and duty.

What are Incoterms 2020, and what do they not regulate?

ICC describes the rules as clarifying "the tasks, costs and risks involved in the delivery of goods from sellers to buyers". They entered into force on 1 January 2020. Seven rules apply to any mode of transport (EXW, FCA, CPT, CIP, DAP, DPU, DDP) and four to sea and inland waterway transport only (FAS, FOB, CFR, CIF). A road shipment from Bursa uses the first group.

The rules stop short of several points. According to ICC's introduction they do not deal with the transfer of property, title or ownership, with the time, place, method or currency of payment, or with the imposition of tariffs. They do not apply automatically either: they bind the parties only when incorporated into the sales contract. Duty and VAT rates therefore come from law, here the EU–Türkiye customs union and the VAT rules of the destination country, and the Incoterm only decides who handles and pays them. See the EU–Türkiye customs union and machined parts.

How do EXW, FCA, DAP and DDP differ for a shipment from Bursa?

Table 1 sets the four rules side by side for an export from Türkiye into the EU. The named place fixes where risk passes and where the seller's work ends.

Table 1. Delivery, carriage and customs duties under four Incoterms 2020 rules, Türkiye to EU

Source: ICC Academy, "FCA and EXW", "DAP and DDP" and "Including tariffs" (Incoterms 2020); ICC, Incoterms 2020.

FCA suits a buyer who books its own freight. At the seller's premises the seller loads the buyer's collecting vehicle; at any other named place the goods are delivered on the seller's vehicle, ready for unloading. In both cases the seller completes export formalities. The buyer's cargo insurance has to start at that handover.

DAP moves the road leg onto the seller. The seller carries the risk until the goods reach the named place, and the buyer unloads. ICC states that none of the D rules obliges the seller to insure for the buyer: any cover the seller buys protects the seller. On a typical road transit of 5 to 10 days from Bursa to central Europe, the difference between FCA and DAP is therefore whose risk those days are. Lead time from Turkey to Europe breaks that transit down.

DDP adds EU import clearance and the duties and taxes that clearance triggers. ICC cautions that foreign sellers may find import clearance difficult under DDP, and that "in some countries, foreign entities are prohibited from carrying out import customs and tax formalities altogether". Access2Markets notes that an importer normally needs to be established in the EU, so a Turkish workshop without an EU entity would have to appoint a representative. ICC advises DAP instead of DDP where possible.

Under EXW the buyer clears export, and ICC says traders are "strongly encouraged to consider using FCA instead of EXW where the goods are crossing a border".

Which Incoterm fits which sourcing situation?

Choose the rule by who is better placed to do the work. Table 2 is our reading of the ICC guidance for parts shipped from Türkiye.

Table 2. Choosing an Incoterm 2020 rule by situation

Source: Ertaş Engineering, based on ICC Academy, "FCA and EXW" and "DDP and EXW" (Incoterms 2020).

Who clears customs and pays import VAT under each rule?

On the Turkish side, goods leaving Türkiye are declared to customs by a customs declaration. The Ministry of Trade describes an exporter as any person holding a tax ID number who is also a member of the exporters' association; its FAQ does not say whether a foreign buyer can qualify. That is one more reason to put export clearance with the seller, as FCA does. Under Article 11(1)(a) of VAT Law No. 3065, export deliveries are exempt from Turkish VAT; ask the supplier which export documents it needs for that treatment.

On the EU side, Zoll states that a customs declaration is not limited to one person and that declarants can generally be represented directly or indirectly. Who files in practice follows the Incoterm. Under FCA and DAP the buyer, or its broker, files. Under DDP the seller carries out the formalities.

Two amounts arise at import:

• Duty: for industrial products covered by the EU–Türkiye customs union, the Commission states zero customs duties and zero quotas, provided the goods carry an A.TR movement certificate as proof of customs status. See the A.TR movement certificate.
• Import VAT: Access2Markets says it is usually paid by the importer, and Zoll states that only businesses may deduct it as input tax, on proof such as the import duty notice. The ICC pages cited here on DDP speak of tariffs, taxes and customs formalities but do not name VAT, so the order should say who is declarant and who bears import VAT.

Importing machined parts from Turkey into Germany walks through the German clearance steps, EORI and VAT deduction.

How does the Incoterm change the EU customs value?

The Incoterm does not change the customs duty rate, but it changes the invoice the customs value starts from. Zoll adds transport and insurance costs up to the place where the goods enter the Union to the price paid or payable, and states that transport costs incurred inside the Union can be deducted. Zoll also names the delivery terms as the starting point for checking whether the price needs adjusting for transport. For two common cases:

• Under FCA the invoice normally contains no freight, so the importer adds carriage and insurance up to the EU entry point to reach the customs value.
• Under DAP to a named place inside the EU the invoice includes freight to that place. Ask the supplier to show the freight as a separate line, so that the part after entry into the Union can be taken out.

The customs value then forms the base of import VAT. Zoll defines the base as the customs value plus duties plus transport costs from the EU border to the first destination in the Union, where not already included. Even at zero duty, freight therefore enters the VAT base. The landed cost model for machined parts from Turkey turns these lines into a per-part figure.

How do you write the Incoterm into a purchase order?

ICC advises naming the rule, the place and the edition, for example "FCA Bursa, Incoterms 2020" with the full address, and warns that "leaving the year out could cause problems that may be difficult to resolve". It also advises being as geographically specific as possible in naming the place. Add three lines the Incoterm does not supply:

• Who is declarant for import and who bears import VAT.
• That the goods travel with an A.TR where the customs union applies.
• Who insures the cargo from handover to the named place, since only CIF and CIP oblige the seller to insure for the buyer.

Title and payment terms belong in the sales contract, because Incoterms do not cover them.

Is Incoterms 2020 still the current edition?

Yes, as of 2026-10-30. ICC's page on the rules calls Incoterms 2020 the most recent version, and its 2026 policy workplan lists the beginning of work on a revision "laying the groundwork for Incoterms 2030". No new edition and no publication date appear in those documents. Keep citing "Incoterms 2020" with the year until a new edition exists and both parties have agreed to adopt it.

Frequently asked questions

What is the difference between FCA and DAP?

Under FCA the seller hands the goods to the buyer's carrier at the named place, clears export, and the buyer arranges and pays main carriage and import. Under DAP the seller arranges carriage and carries the transit risk up to the named place of destination, ready for unloading; the buyer unloads and clears import.

Who pays import duty and import VAT under DDP?

ICC describes DDP as the rule under which the seller carries out and pays all customs formalities, including import. For machined parts that are industrial goods in free circulation and travel with an A.TR, EU duty is zero. ICC's pages on DDP do not say who bears import VAT, and Access2Markets notes that VAT is usually paid by the importer, so name the declarant and the VAT bearer in the order.

Is EXW suitable for shipments from Turkey to the EU?

ICC recommends FCA instead of EXW where goods cross a border, because under EXW the buyer must clear export. Turkey's Ministry of Trade describes an exporter as a person holding a Turkish tax ID number who belongs to an exporters' association, which a buyer abroad may not meet.

Does the Incoterm decide when I own the goods?

No. ICC states that the Incoterms rules do not deal with the transfer of property, title or ownership, nor with the time, place, method or currency of payment. Agree those points separately in the sales contract.

Is Incoterms 2020 still the current edition in 2026?

Yes. ICC's 2026 policy workplan lists the start of work on a revision, laying the groundwork for Incoterms 2030. No new edition is published as of 2026-10-30, so contracts should keep citing Incoterms 2020 with the year.

Sources

1. ICC: Incoterms 2020
2. ICC: Incoterms rules (in force since 1 January 2020)
3. ICC Knowledge 2 Go: Incoterms 2020 rule groups
4. ICC Library: Incoterms 2020 introduction (title, payment, edition, named place)
5. ICC Academy: FCA and EXW, Incoterms 2020 explained
6. ICC Academy: DAP and DDP, Incoterms 2020 explained
7. ICC Academy: DDP and EXW, Incoterms 2020 explained
8. ICC Academy: Incoterms 2020 C rules vs D rules, risk transfer and insurance
9. ICC Academy: Including tariffs in your Incoterms training sessions
10. ICC: Global Policy Commissions Workplan 2026, commercial law and practice (p. 5)
11. European Commission, Access2Markets: guide for import of goods
12. European Commission, Access2Markets: EU–Türkiye customs union
13. Zoll: Beförderungs- und Versicherungskosten (customs value, place of entry)
14. Zoll: Bemessungsgrundlage der Einfuhrumsatzsteuer
15. Zoll: Vorsteuerabzug bei der Einfuhrumsatzsteuer
16. Zoll: Zollanmeldung (ATLAS, Vertretung)
17. Republic of Türkiye, Ministry of Trade: Export regime (FAQ)
18. Türkiye: VAT Law No. 3065, Article 11(1)(a), export exemption (Mevzuat Bilgi Sistemi)

Questions on a drawing? sales@ertas.engineering

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