Sourcing hair transplant supplies from Türkiye for European clinics

Why do European clinics buy supplies from Türkiye?

Istanbul has a large hair transplant sector, and many instrument makers and hair-care brands that serve it are based there. For clinics in Poland, Italy, Germany or the UK, buying directly can mean a wider choice of instrument sizes, aftercare products designed for transplant patients and a direct line to the manufacturer. It also means you become responsible for parts of the import process that a local distributor would otherwise handle.

This guide covers the basics a clinic owner or practice manager should understand before placing a first order. It is general information, not customs, tax or legal advice. Always confirm the details for your products with a customs broker and your national regulator.

What does the EU–Türkiye Customs Union cover?

According to the European Commission's Access2Markets page on the EU–Türkiye Customs Union, the Customs Union covers industrial products and processed agricultural products. Agricultural products and coal and steel products are outside it and are handled under separate arrangements.

Goods that are produced in the customs union, or have been put into free circulation there, can move within its territory when they are accompanied by proof of their customs status: the A.TR movement certificate. For instruments and most cosmetic or hair-care products, which are industrial goods, the A.TR is the key document to ask your Turkish supplier for.

Two points are often misunderstood:

• The A.TR proves customs status, not "origin" in the free-trade sense. Your broker may still ask for other documents, depending on the goods.
• The Customs Union is not a VAT union. Türkiye is outside the EU VAT area, so import VAT is generally due when the goods are released for free circulation in your country, at your national rate. Some countries let businesses account for import VAT in the VAT return instead of paying at the border; ask your broker or tax adviser what applies to you.

How is the UK different?

Since leaving the EU, the UK is not part of the EU–Türkiye Customs Union. Trade runs under the UK–Türkiye free trade agreement. The GOV.UK guidance on trade with Turkey explains that to benefit from preferential tariffs, goods must meet the UK–Türkiye preferential rules of origin, and that entitlement is based on a declaration on origin issued by the exporter, which can be in electronic form. Goods that do not meet the rules can still be imported, but without the preferential rate.

In practice, this means a UK clinic should ask its Turkish supplier whether the goods qualify as originating and, if so, to include the origin declaration on the invoice or a separate document. The A.TR used for EU imports does not replace this.

Which registrations and numbers do you need?

• EORI number. Businesses established in the EU need an Economic Operators Registration and Identification (EORI) number for customs declarations, issued by the customs authority of the Member State where they are established. Businesses moving goods into Great Britain also need an EORI number; GOV.UK explains how to apply.
• Commodity codes. Each product needs the right tariff classification. Look up duty and import VAT rates yourself in the EU's TARIC database or, for imports into the UK, the GOV.UK Trade Tariff service. Do not rely on a rate quoted in a blog or by a supplier; rates depend on the exact code and can change.
• A customs broker or forwarder. Most clinics use one to lodge the import declaration. Give them your EORI, VAT number and the product details in advance.

Incoterms: who pays for what?

Incoterms are standard trade terms published by the International Chamber of Commerce. The current edition, Incoterms® 2020, contains 11 rules that allocate costs, risks and obligations between seller and buyer. Three come up often in small medical-supply orders:

• EXW (Ex Works). The seller makes the goods available at its premises. The buyer arranges almost everything else, including transport and customs formalities. For a foreign clinic this is often the least convenient option, because export formalities happen in Türkiye.
• DAP (Delivered at Place). The seller delivers to a named place, such as your clinic, ready for unloading. Import clearance, duties and import VAT remain with the buyer. This is a common choice for courier shipments.
• DDP (Delivered Duty Paid). The seller carries all costs and risks up to the named place, including import clearance and duties. The seller then acts as importer, which it may not be able to do without registrations in your country. Check before you agree to it.

Write the chosen rule and the named place on the quote and invoice, for example "DAP Warsaw, Incoterms® 2020".

Which documents should come with the shipment?

• Commercial invoice with seller and buyer details, a clear description of each item, quantities, unit values, currency, the Incoterms rule and, ideally, commodity codes.
• Packing list with the number of parcels, weights and contents per parcel.
• A.TR movement certificate for EU imports of goods covered by the Customs Union, or an origin declaration for UK imports under the UK–Türkiye agreement.
• Regulatory documents for the product type: for medical devices, the declaration of conformity and labelling information; for cosmetics, confirmation of the responsible person and notification status.
• Transport document (courier waybill or freight document) and tracking number.

What regulatory status do instruments and aftercare products need?

Medical devices in the EU

Many hair transplant instruments are regulated as medical devices. In the EU, Regulation (EU) 2017/745 (MDR) sets out obligations for importers. Before placing a device on the market, Article 13 requires importers to verify that the device is CE marked with an EU declaration of conformity, that the manufacturer is identified and has designated an authorised representative, that labelling and instructions for use are in place and, where applicable, that a UDI has been assigned. If your clinic brings devices in directly from outside the EU, it may take on some of these obligations. Check with your national competent authority.

Medical devices in Great Britain

The MHRA's guidance on registering medical devices states that all medical devices must be registered with the MHRA before they are placed on the market in Great Britain, and that a manufacturer based outside the UK must appoint a single UK Responsible Person. Northern Ireland has different requirements.