How the bonded warehouse types differ
General bonded warehouses come in Types A, B and F; private ones in Types C, D and E. What separates them is who is liable for the goods, who keeps the stock records and who lodges the warehouse declaration.
The warehouse types are set out in Article 329 of the Turkish Customs Regulation. The article first splits customs warehouses into two groups. Anyone can place goods in a general bonded warehouse; a private bonded warehouse is set up only for goods that belong to its operator (Regulation, Art. 328; Customs Law No. 4458, Art. 94). It then defines six types according to how they work in practice: A, B and F for general warehouses, C, D and E for private ones. There are no other letters. The legislation has no G or H type.
Two roles drive the differences. The warehouse operator is the person licensed to run the customs warehouse. The user is the person who makes the warehousing declaration for the goods, or the person to whom that person’s rights and obligations have passed (Law, Art. 93/2). So the warehouse declaration is, as a rule, the job of the user: the party placing the goods under the regime. The operator must make sure the goods stay under customs supervision for as long as they are in the warehouse (Law, Art. 96). The user, for their part, remains liable in every case for the obligations that come with the regime (Law, Art. 97/2).
General bonded warehouses: A, B and F
A general warehouse can take in goods from many different firms. The three types differ in where liability sits.
Type A: records and liability with the operator
In a Type A warehouse the operator keeps the stock records. If any shortage is found in the goods placed in the warehouse, the operator is also liable for paying the customs duties. Whoever owns the goods, the records are kept in one place. The warehouse declaration is lodged by the user as a rule; for part loads arriving by road, it may also be lodged by the Type A operator if the owner of the goods authorises it (Regulation, Art. 332/1). The typical user is an importer who keeps goods in someone else’s warehouse and wants the operator to hold the records.
Type B: liability with the user
Type B puts liability for the goods on the user, who also lodges the warehouse declaration (Regulation, Art. 329). The type rests on Article 97(1) of the Law: a general warehouse licence may state that some of the operator’s obligations belong to the user alone. The Regulation treats the operator’s liability here as limited; the operator simply provides the warehouse. No warehouse stock records are kept. Customs controls rely on the declaration and the supporting documents. It suits a user who can run their own records and paperwork.
Type F: run by the customs administration
Type F is a general warehouse operated by the customs administration. The operator is not a company but the administration itself, so it is not a type a business can apply to open. The Regulation sets no separate liability or record-keeping rule for it. The user’s obligations under the regime still apply.
Private bonded warehouses: C, D and E
Private warehouses have one person in both roles: the operator is also the user, and only that person’s goods go in. The same person makes the declaration and answers for the goods. The three types differ in the rule that applies.
Type C: own goods, own liability
The operator-user is liable for the goods taken into the warehouse. A firm holding its own imported goods in its own warehouse is the usual example.
Type D: taxation tied to the date of entry
Operator and user are again the same; the difference lies in taxation. Article 104(3) of the Law applies. If goods under the regime are released for free circulation without being presented to customs and before a declaration is lodged, duties are calculated using the rates and other taxation elements in force on the date the goods were placed under the regime. This depends on the nature, customs value and quantity of the goods having been established on that date. The person liable may instead ask for the goods to be dealt with on the basis of their state on the date the free circulation declaration is registered.
Type E: a storage place treated as a warehouse
Type E rests on Article 93(4) of the Law. The licence holder’s storage place is treated as a warehouse; even where there is no storage place, the warehousing rules can be applied to the goods. Here too, operator and user are one and the same.
All six types at a glance
| Type | Group | Operator | Liable for the goods | Declaration by |
|---|---|---|---|---|
| A | General | Warehouse operator | Operator (duties on any shortage) | User; operator with authority for road part loads |
| B | General | Warehouse operator | User | User |
| F | General | Customs administration | No type-specific rule | User |
| C | Private | The user itself | Operator-user | Operator-user |
| D | Private | The user itself | Operator-user | Operator-user |
| E | Private | The user itself | Operator-user | Operator-user |
Compiled from Articles 329 and 332/1 of the Regulation and Articles 93/2, 96 and 97 of the Law.
What it means for the owner of the goods
A company that wants to keep imported goods in someone else’s warehouse needs a general warehouse; a private warehouse is only for the operator’s own goods. At a general warehouse run by a firm, the types you will meet are A and B. They differ in three places.
- Liability. In Type A the operator is liable for the customs duties if a shortage is found. In Type B the user is liable for the goods. In both, the user’s own obligations under the regime remain.
- Stock records. In Type A the operator keeps the warehouse stock records. In Type B none are kept, and customs controls rely on the user’s declaration and documents.
- Declaration. In both types the user lodges the warehouse declaration as a rule. In Type A, for part loads arriving by road, the operator may lodge it with the owner’s authority.
None of this is about price or time. It decides who holds the records and who carries the duty liability for the goods.
Which type is our Hadımköy warehouse?
Type A. In short: a Type A general bonded warehouse in Hadımköy, attached to Ambarlı Customs Directorate, with 18,600 m² of covered storage for two product groups: plastic raw materials and paper reels.
The Type A rule applies to us as it does to any operator. We keep the stock records as the operator. We make sure the goods stay under customs supervision for as long as they are in the warehouse. Under the legislation, if a shortage is found, the operator is the one liable for the customs duties. The warehouse declaration, as a rule, is lodged by the user: the party placing the goods under the regime.
We describe who runs the Hadımköy warehouse and how, including the six steps from receipt to dispatch, on our About Us page. Whatever the warehouse type, the regime lets duties wait while the goods are stored; we explain how in what the customs warehousing regime provides. Other topics sit in our archive of regulatory notes, each with its article numbers. If you would like to discuss the right set-up for your goods, use the form to request a bonded storage quote and tell us your product group and volume.
Sources
- Customs Law No. 4458: Art. 93/2 and 93/4 (operator, user, place treated as a warehouse), Art. 94 (general and private warehouses), Art. 96 (operator’s obligations), Art. 97 (user’s liability), Art. 104/3 (taxation in Type D).
- Customs Regulation: Art. 328 (definitions), Art. 329 (customs warehouse types), Art. 332/1 (declaration by a Type A operator for part loads).
- Article texts checked on 26 October 2026 against the version in force at mevzuat.gov.tr. Current text of the Law: Customs Law No. 4458, in Turkish. First publication of the Regulation: Customs Regulation in the Official Gazette (7 October 2009, No. 27369, repeat issue; in Turkish).
This note is for general information; for any specific transaction the current text of the legislation and the advice of your customs broker apply.