HS Code (GTIP), Customs Duties & KKDİK Compliance for Fragrance Raw Material Imports

Before you bring a fragrance oil across the border, you must give it an identity. That identity is its HS code (Harmonised System / Customs Tariff Statistical Position, known in Turkey as GTIP). The wrong code means the wrong tax and the wrong permits. The right code makes everything else flow.

Fragrance oils and aroma chemicals most commonly live in Chapter 33. This chapter covers mixtures of volatile oils, mixtures of resinoids, mixtures of volatile oils with resinoids, and preparations based on odoriferous substances. For the perfumer, the key position is 33.02: mixtures of odoriferous substances and mixtures — including alcoholic solutions — used as industrial raw materials.

Single-molecule synthetic aroma chemicals change the picture: these are generally classified under Chapter 29 (organic chemicals — for example, alcohol/terpene derivatives such as heading 2906). The question "mixture or pure substance?" splits the HS code decision from the outset.

You do not guess the HS code; the customs laboratory confirms it through analysis. Customs directorates determine a product's tariff position on the basis of the General Interpretive Rules and laboratory reports. If you are uncertain, submit a Binding Tariff Information (BTI) application before importing — it is the cleanest way to avoid surprises at the border.

This table is for guidance only and is not binding. Sub-positions (10–12 digits) vary according to origin and composition. You can look up customs duty rates by HS code via the Ministry of Trade's Tariff Search Application.

Once the HS code is confirmed, the focus shifts to cost. What you pay on import is not just the goods value. The country of origin can make or break the tax burden.

The general framework is as follows: customs duty rates on many industrial products are relatively low — and for industrial goods originating in EU countries, the duty is zero under the Customs Union. Turkey's average MFN rate on industrial goods is around 5%, with rates typically in the low 0–10% range. This means that for a fragrance oil of EU origin, customs duty can often be eliminated — but an origin document (ATR / EUR.1) is mandatory.

The real surprise in the tax burden comes from VAT and, where applicable, Special Consumption Tax (SCT). The SCT risk on solutions containing ethyl alcohol is significant — which is why most manufacturers prefer to source alcohol domestically and import an alcohol-free compound (fragrance concentrate) from abroad. Importing alcohol across the border is an entirely separate world in terms of both taxation and permits.

It would not be appropriate to quote exact rates here — tariffs change frequently. Check the current rate by HS code via the Ministry of Trade's Tariff Search Application. Build your pricing on the real landed cost at the border; correcting it once the product is on the shelf is expensive.

A good importer smells the sample before placing a bulk order. A good importer also never accepts a sample without documentation. At the border, paperwork does the talking.

There is a customs facilitation/exemption framework for small quantities of samples with no commercial value — but writing "sample" on the label is not enough. The bottle must be labelled "sample, not for sale", the invoice must show a nominal value, and a sample declaration must be included. A high-quantity sample shipment is treated as a "covert commercial consignment" and loses its exemption. Even for samples, an SDS is mandatory — because you are dealing with a volatile, flammable chemical.

The minimum document file to request from your supplier is clear. These documents feed both the customs process and the subsequent KKDİK and ÜTS steps. You must ensure that your supplier holds risk communication documents — such as hazard classifications, labelling information, and safety data sheets.

Do not confuse the SDS and the COA: the SDS describes safety; the COA proves the quality of that specific batch. Never place a bulk order without both. We cover why the IFRA compliance certificate matters in detail in What Are IFRA Standards and How Do They Affect Your Product?

Clearing customs is only half the job. The other half is KKDİK (Registration, Evaluation, Authorisation and Restriction of Chemicals) — Turkey's equivalent of REACH. And here the responsibility usually falls on you, the importer.

The core principle is simple, but its consequences are serious: a company not established in Turkey has no direct KKDİK obligations; the obligation lies with the firms that import from abroad. Unless your overseas manufacturer explicitly agrees to handle it, you are the party responsible for registration.

The threshold is clear: if a substance is imported at 1 tonne or more per year per importer, registration is required. Take note: the threshold is calculated separately for each individual substance within a mixture. A company that produces mixtures is a downstream user of the substances it uses to make those mixtures. If you import a compound fragrance oil, you must track the annual tonnage of each individual substance it contains.

The process steps are advancing on a current schedule. Under the regulation dated 05.08.2025, companies importing chemical substances into Turkey — whether on their own, in mixtures, or in articles — are required to submit a pre-registration (Pre-SIEF notification) via the KKS system.

Two dates on the schedule are critical. Full registration deadlines have been set at 31 December 2026, 31 December 2028 and 31 December 2030 depending on tonnage band. An interim mechanism exists for those who struggle to meet the deadline: provisional registration is not mandatory, but it is a facilitation option available to companies that cannot complete the full registration dossier in time. However, it is not an escape route: companies that submit a provisional registration are not exempt from the full registration obligation and must still submit a complete dossier at the relevant subsequent stage.

Keep your records: it is generally recommended that documents — including import declarations, invoices, registration certificates, safety reports and up-to-date SDSs — are retained for at least 10 years. We explore the KKDİK dimension of fragrance oil trading in depth in What You Need to Know About Buying and Selling Fragrance Oils Under KKDİK.

You have imported the raw material and completed registration. But what if you are going to sell a finished perfume? That is where ÜTS (Product Tracking System) and cosmetic product notification come in. Importation and placing a product on the market are two separate journeys.

Keep the process and the responsibility distinct: product notification (the notification steps) is a procedure; the responsible person / manufacturer obligation is the ongoing responsibility of the party placing the product on the market. If you are going to sell a cosmetic perfume, we walk you through the ÜTS side step by step in ÜTS Registration: What You Need to Do Before Selling a Cosmetic Perfume. For the definitive procedure, fee amounts and possible sanctions, always refer to the current TİTCK source.

One final point of clarity: the fact that the raw material you import is natural rather than synthetic does not mean it is safe. Safety depends not on the source but on the molecule and the use level. Some of the most strictly IFRA-restricted allergens (citral, eugenol, oakmoss and the like) are present in high concentrations in natural essential oils; natural bergamot is phototoxic. Conversely, certain synthetics such as Ambroxan and Iso E Super are virtually free of allergenic concern. IFRA limits also apply not to the total fragrance concentration but to individual substances within the fragrance and the product category — always obtain your supplier's IFRA compliance certificate for that specific formulation.