A Chinese-made filter consolidated in a Rotterdam warehouse and shipped to Türkiye under a movement certificate pays the other-countries rate, because that certificate proves free circulation and not origin. Parts and lubricants then run under two different regulators with almost nothing in common. We work out which regime each of your lines sits in, and which firms hold what each one needs.
The demand case is straightforward and unusually well documented. The sector association’s 2025 analysis puts the total aftermarket at 10.2 billion dollars including medium and heavy commercial vehicles, with light vehicle aftermarket revenue of 7.57 billion. The light vehicle parc stood at 22.8 million with an average age of 14.3 years, and 74% of light vehicles were more than five years old. An old, large parc is exactly the condition an aftermarket brand wants.
The supply case is harder, and most entry plans understate it. Türkiye’s component industry exports on the order of fifteen billion dollars a year, anchored on German original equipment supply chains. Many of the part families an importer wants to sell are already made here to original specification. Worse for a newcomer, the block exemption’s own definition of an original spare part includes one made by an independent manufacturer to the vehicle maker’s specification and sold straight into the aftermarket. Your local competitor can legitimately call its part original.
Lubricants are a separate business with a separate regulator and a separate shape. The industry association put the market at 610,879 tonnes in 2024, down 5.8% on 2023, with automotive oils roughly half of it. That figure comes from eight distributors supplying data voluntarily, so it is a careful estimate rather than a census, and the association says so itself.
Where the two halves meet is at the border, and that is where most money is lost. The customs union removes tariffs on industrial goods and a movement certificate gets a parts consignment a clearance reference without a separate inspection application. What it does not do is change where a part was made.
Parts sit with the industry ministry, which is both the type approval authority and the market surveillance authority, with physical inspection at the border through the standards institute. A manufacturer established outside the EU must appoint a representative established in Türkiye, and the importer has to put its own name, trademark and contact address on the product or its packaging and keep the approval documents for five years. Lubricants sit somewhere else entirely, with the energy regulator, under a petroleum licensing regime that has nothing to do with vehicles.
That second regime carries a trap worth knowing before any conversation about local blending. A lubricant licence may not be transferred under any circumstances bar one narrow financing carve-out, and every pack above a litre has to print the licence holder’s name and licence number. So if your brand is blended here, your partner’s licence details are on your packaging and that licence cannot follow you to a new partner. Changing distributor means finding another licence holder, or qualifying a facility from scratch against a capacity-report threshold.
On the parts side the trade is structured by the motor vehicle block exemption, which is more prescriptive than its European cousin in places. It sets market share thresholds of 30% for spare parts distribution and for repair services, and it protects the independent channel directly: an authorised dealer or repairer cannot be stopped from selling parts to independent repairers, and a supplier cannot be stopped from supplying independent distributors and repairers. Authorised networks may be required to use original parts for warranty work, free maintenance and recalls, and not otherwise.
The lubricants trade answers to the energy regulator instead, under petroleum licensing. Blending here needs a lubricant licence; storage needs its own licence again; importing bulk base oil runs through a conformity letter tied to a capacity report. Importing finished product in ordinary trade packaging is a lighter exercise, but we would not tell any brand owner its line is exempt without reading the annex against its own customs codes, because the consequence of being wrong is an unlicensed-activity finding.
What both halves share is a regulator that has been active. In June 2026 the competition authority announced fines totalling 3.63 billion lira across sixteen tyre producers, importers and distributors, for price coordination, resale price maintenance, territorial and customer restrictions on dealers, and no-poach agreements. The decision is subject to judicial review and the reasoned version was not published at the announcement, so we would not call it final. But the remedies tell you where the line now sits: producers were required to code price lists by dealer, to use individual dealer portals rather than group channels, and to write penalty and termination provisions into contracts to stop dealers sharing forward price information.
The two lists barely overlap, which is why a firm that is convincing on one side of your range may be irrelevant on the other.
These are document requests and factual tests. The first three can be done from your own records before anyone in Türkiye is contacted.
Go line by line and establish where each part was actually manufactured, not where it ships from. Goods that are neither EU nor Turkish in origin pay the other-countries rate even when they arrive from Europe under a movement certificate, and the importer is responsible for declaring it. For a European brand with Asian sourcing, this single exercise frequently moves the landed cost enough to change the business case.
Import surveillance sets a per-kilogram customs value below which a certificate is required; for passenger car tyres the figure has been 5.50 dollars a kilogram since October 2025. Where your transfer price sits relative to that threshold is something to know before you set it, not after.
A sixty per cent anti-dumping measure applies to certain heavy vehicle, agricultural and construction machinery tyres from China, and passenger car tyres from Czechia, Korea, Serbia and Slovakia went under investigation in June 2026 with both provisional and retroactive measures available. Two of those four are EU member states, which is the point.
Parts answer to the industry ministry; lubricants answer to the energy regulator under petroleum licensing. Ask each candidate to produce what the relevant regime requires rather than describing its capability, and expect a firm that is strong on one side to be thin on the other.
Ask to see the lubricant licence, its grant date and its term, and confirm who holds it. Then plan on the basis that it cannot be transferred to you or to a successor, and that its number will be printed on your packs.
Under the block exemption a fixed-term agreement must run at least five years with six months’ notice of non-renewal, and an open-ended one needs two years’ notice, reduced to one in defined circumstances. An appointment made casually is a five-year commitment with a notice period attached.
After the June 2026 remedies, a credible producer or distributor in this sector should already be coding price lists by dealer and distributing them through individual portals rather than group channels. A candidate still sending forward prices to a dealer group chat is telling you about its compliance culture.
Importers count as producers for waste oil and for end-of-life tyres, with collection duties, annual filings and membership of an authorised organisation. The recycling contribution is set annually and is per unit for tyres and per kilogram for oil. None of this is large on its own; all of it is frequently left out of the first model.
This is the most expensive ordinary error in the sector. The certificate proves free circulation and smooths the conformity check. It does not make an Asian part European, and the additional duty follows origin. The cost lands on the importer, who declared it, and then on the relationship.
Blend in Türkiye and the licence holder’s name and number go on every pack above a litre. That licence cannot be transferred. Ending the relationship means finding another holder or qualifying a facility against the capacity-report threshold, and relabelling in the meantime.
The customs union removes tariffs. It does not remove Turkish trade defence, and EU-origin goods have been the subject of it. A supply plan built on the assumption that European manufacture is safe from duty has a hole in it.
Motor vehicle sector agreements carry minimum terms and notice periods. A one-year trial appointment with ninety days’ notice, which is how these often start, does not fit the regime it will be judged against.
In an operation reported in June 2024, authorities raided nineteen workplaces belonging to sixteen companies across six provinces and seized more than 1.6 million counterfeit and smuggled parts. Logos had been stamped onto imported parts in warehouses and the goods sold as original and legal to companies, large fleets and public institutions. Who holds your channel determines whose parts carry your name.
Between Türkiye residents, a sale of goods may be priced in foreign currency but settlement must be made and accepted in lira, with carve-outs including goods under customs warehouse and free zone regimes. That rule does not reach your own supply agreement, which is between a resident and a non-resident and can be priced and paid in euro or dollars. It reaches your distributor’s onward sales, which is exactly where the exposure sits.
For duty purposes it depends on where the goods were made, not where they were shipped from. A movement certificate evidences free circulation and will get a parts consignment a clearance reference without a separate inspection application. But goods that are neither EU nor Turkish in origin attract the other-countries rate of additional duty, and the importer carries the responsibility for declaring origin correctly. European consolidation of Asian-made parts is the common case and the common surprise.
If you are a manufacturer established outside the EU, yes. The type approval regulation requires a representative established in Türkiye for type approval and for market surveillance, and one person may hold both roles. Think carefully before that person is your distributor, because the two appointments then end together.
Importing finished product in ordinary trade packaging is a lighter exercise than blending, and there are packaging-size exemptions from the conformity letter regime. We would not tell you your specific line is exempt without checking the annexes against your own customs codes, because unlicensed activity in this market carries fines in the millions of lira. What is clear is that blending here needs a licence, storage needs its own, and bulk base oil runs through a capacity-report mechanism.
Longer than most brand owners expect. Under the motor vehicle block exemption a fixed-term agreement must run at least five years, with at least six months’ notice of non-renewal from either side. An open-ended agreement requires at least two years’ notice, reduced to one year where the supplier terminates and either pays appropriate compensation or has to restructure its distribution substantially. Non-compete obligations longer than five years fall outside the exemption.
No, and this is actively enforced here. The June 2026 tyre decision covered resale price maintenance alongside price coordination and dealer territorial restrictions, across sixteen firms. The remedies went further than fines, requiring dealer-specific coding of price lists and individual rather than group distribution of price communications. Recommended pricing conversations need Turkish advice before they happen.
More than the border. The importer puts its own name and contact details on the product, provides Turkish instructions, retains approval documents for five years and remains liable for product safety whatever the clearance reference says. On top of that, importers count as producers for waste oil and end-of-life tyres, which brings collection duties, an annual filing and membership of an authorised organisation, plus a per-unit or per-kilogram recycling contribution set each year.
Your importer’s name goes on the part, and if you blend here your partner’s licence number goes on the pack. Neither is quick to undo, which is a reason to be sure before rather than sorry after.
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