E-commerce Export Logistics: ETGB, IOSS & FBA Guide

In e-commerce exporting, logistics splits into one of two main paths depending on your sales model: micro-exports, where individual orders are sent by courier directly to the end customer (usually under an ETGB, Turkey's electronic e-commerce customs declaration), or B2B bulk shipments, where goods are sent in bulk to a warehouse in the target market, such as Amazon FBA. In the first, speed and cost per parcel are what matter; in the second, customs clearance, importer of record status and warehouse rules are decisive. As your volume grows, consolidation with a freight forwarder is the way to improve unit cost and predictability.

E-Export Models and Their Logistics Differences

Today, Turkish sellers can sell to Europe and other markets through their own websites, international marketplaces (such as Amazon, Etsy and eBay), or the cross-border channels of Turkish platforms. Whatever the sales channel, there are three basic models from a logistics standpoint:

1. Micro-exports: Courier direct to the customer

Each order leaves Turkey as a separate parcel and travels to the buyer's door via a courier (express carrier) or postal service. Export customs formalities in Turkey are mostly handled with an ETGB (Electronic Commerce Customs Declaration). The advantage is that inventory risk stays in Turkey; the drawback is that freight per parcel is high and each parcel is taxed separately in the destination country.

2. B2B bulk shipments: Sending stock to a fulfillment warehouse

Goods leave Turkey in cartons or on pallets under a standard export declaration; import customs clearance is carried out in the destination country and the stock is placed in a fulfillment warehouse (Amazon FBA, an independent 3PL warehouse, etc.). Orders are then delivered by local carriers. In this model, transport can be by LTL / groupage freight, full truckload, air cargo or LCL ocean freight. Freight per unit drops significantly, but obligations arise in the destination country, such as acting as importer of record, VAT registration and warehouse inbound rules.

3. Hybrid model: Consolidation + local distribution

Orders accumulate in Turkey, are moved by the forwarder to the target region as a single shipment, and are handed over to a local distribution network there to reach buyers through last-mile delivery. It is a middle-ground solution for sellers with regular volume who do not want to move to a full warehouse model. Which customs regime applies (ETGB or a standard declaration; an import declaration at destination or IOSS) should be clarified in advance based on how the shipment is structured.

What Is ETGB and When Is It Used?

ETGB is the electronic customs declaration used in Turkey for exporting shipments sold through e-commerce that stay below certain value and weight limits. The declaration is filed through express courier companies authorized by the Ministry of Trade or through the postal administration; the seller can have the export officially recorded without going through the conventional export declaration process.

Points to watch:

• Limits: ETGB eligibility is defined by per-shipment value and gross weight limits set in the regulations. These limits are updated from time to time; confirm the current values with your courier company or customs broker before planning shipments.
• Excluded goods: Products subject to export restrictions or requiring a license or permit may not be shippable under ETGB.
• Invoice consistency: The value declared on the ETGB must match the e-archive/e-invoice and the marketplace order record. Any mismatch causes problems both in documenting the export and on the tax side.
• Tax and incentives: Sales made under ETGB are recorded as exports. Clarify the conditions for the VAT exemption, refunds and any support programs with your accountant; implementation details may change.

ETGB only covers the export from Turkey. How the parcel is taxed in the destination country depends on that country's rules.

VAT and IOSS When Selling to the EU

If you sell directly to end consumers in the European Union, import VAT comes into play with every parcel. The EU abolished the former VAT exemption for low-value consignments and replaced it with the IOSS (Import One-Stop Shop) scheme.

• How IOSS works: The seller (or marketplace) collects the VAT of the buyer's country at the time of sale, on the checkout page, and declares it through a single IOSS registration in one EU country. Because the parcel is declared at customs with the IOSS number, the buyer is not asked for additional VAT on delivery.
• Scope: IOSS can be used for consignments with an intrinsic value not exceeding EUR 150. Above this value, standard import customs clearance applies, and customs duty and import VAT are charged separately.
• Non-EU sellers: Sellers not established in the EU generally need to appoint an EU-established intermediary for IOSS registration.
• Marketplaces: In many cases, the marketplace itself collects the VAT on sales made through it. For sales made on your own website, the responsibility lies with you.

If you do not use IOSS, taxes and clearance fees are collected from the buyer on delivery. This increases the risk of refused deliveries, returns and negative reviews. EU customs rules for e-commerce shipments are under review; since thresholds and implementation may change, check the current situation regularly. In non-EU markets (the UK, the US, the Gulf countries, etc.), each country has its own de minimis threshold and tax collection method.

With bulk shipments, on the other hand, taxes are paid by the importer during import customs clearance. We explain in detail how the delivery term (DAP or DDP) determines who pays the taxes in our Incoterms 2020 guide.

Bulk Shipments to Amazon FBA and Fulfillment Warehouses

When sending stock to FBA or a similar warehouse, logistics is a completely different job from micro-exporting. Checklist:

1. Importer of record: Amazon generally does not act as importer of record. Decide from the outset who will import in the destination country (your own company, a representative, or indirect representation through a forwarder). An EORI number is required for imports into the EU.
2. VAT registration: Holding stock in an EU country requires VAT registration in that country in most cases. Plan this together with your tax advisor.
3. HS code and origin: Determine the correct HS code for each product. For industrial products covered by the Turkey–EU Customs Union, the A.TR movement certificate can provide a customs duty advantage; different rules apply to agricultural products. Customs duty rates vary by HS code; check the current tariff.
4. Warehouse inbound rules: Amazon and other warehouses apply detailed rules for carton dimensions, weight, pallet build, product labels (FNSKU, etc.) and carton labels. These rules are updated frequently; check the current requirements before every shipment.
5. Appointment and delivery: Warehouses require a delivery appointment. Plan together with your forwarder so that the transit time aligns with the appointment date.

For such shipments from Turkey to Europe, the most commonly used options are road freight (LTL or full truckload, under CMR) and, for urgent stock replenishment, air cargo. For distant markets, LCL or FCL ocean freight is also used.

Courier or Forwarder Consolidation?

The right choice depends on order volume, product value, delivery speed expectations and destination countries. A simple approach:

When deciding, do not look only at freight per parcel. Add customs clearance, taxes, warehousing, local distribution, returns and the risk of loss/damage to the total cost. On the courier side, pricing is usually based on volumetric (dimensional) weight; in air cargo the standard volumetric divisor is 1:6000, although express companies may use different divisors. Packaging dimensions therefore directly affect cost. We cover the forwarder's role in this process in more depth in our article what is a freight forwarder.

Packaging and Labeling

• Right-sized box: Packaging with empty space increases dimensional weight. Use a box and void fill suited to the product.
• Durability: International shipments pass through multiple transfer points. For fragile products, choose double-wall corrugated cartons and inner protection.
• Commercial invoice: The product description must be clear (vague terms such as “gift” or “sample” cause delays at customs), and the HS code, country of origin, quantity and unit value must be stated.
• Postal shipments: CN22/CN23 customs declaration forms are used for shipments sent by post.
• Product labels: Check the target market's mandatory labeling rules, such as language, CE marking, energy, textile composition and food ingredients. Products found non-compliant at customs may be rejected.
• Dangerous goods: Items such as products with lithium batteries, perfume and aerosols are subject to special rules in air transport; ask your courier company about its acceptance conditions in advance.

For the required document set, see our article on shipping documents from Turkey to Europe.

Returns Logistics

In consumer sales in Europe, returns are a normal part of e-commerce because of the right of withdrawal. Bringing each return back to Turkey individually often costs more than the product itself. Options:

• Local returns address: Collect returns in the destination country using a warehouse or returns point there, and put undamaged products back up for sale.
• Consolidated return: Bring accumulated returns back to Turkey at set intervals as a single shipment. Exported goods returning to Turkey may be imported duty-free under the “returned goods” provisions; keep the records documenting the export (ETGB or declaration, invoice) and confirm the conditions with your customs broker.
• Local disposal or discounted sale: For low-value products, local solutions may be more economical than bringing them back.
• Refund policy: For some low-value products, issuing a refund without taking the product back can lower the total cost.

We can assess together, based on your shipment volume, how to set up warehousing and logistics services for local stock and returns management.

Common Mistakes

• Undervaluing goods: this can lead to seizure at customs, penalties and problems with your marketplace account.
• Not stating the taxes and fees the buyer will pay on the product page: this leads to refused deliveries and returns.
• Guessing the HS code: wrong duty rate and delays.
• Leaving the importer of record and VAT registration to the last minute on FBA shipments.
• Thinking about the returns process only after sales have started.
• Comparing only freight rates instead of total cost.

How to Get Started with KEY Forwarding

KEY Forwarding has been providing international transport and customs clearance services from its Istanbul headquarters since 2005. To plan your e-export logistics, simply share your product type, HS code (if available), destination countries, monthly order or carton count and sales channel. Based on this, we will assess together which option suits your business: micro-exports, consolidation or bulk shipments.

Frequently Asked Questions

What is e-export?

E-export is the sale and shipment of products to buyers abroad over the internet (via your own website or marketplaces). From a logistics standpoint, it can be done by shipping individual parcels (micro-exports) or by sending bulk stock to a warehouse in the destination country.

What is ETGB and who can use it?

ETGB is the electronic customs declaration used in Turkey for exporting shipments sold through e-commerce that stay below the value and weight limits set in the regulations. It is filed through authorized express courier companies and the postal administration; check the current limits before shipping.

What is IOSS, and is it mandatory?

IOSS is the scheme that allows VAT on consignments to the EU not exceeding EUR 150 to be collected at the time of sale and declared through a single registration. It is not mandatory, but if it is not used, VAT and fees are collected from the buyer on delivery.

What do you need to send products to Amazon FBA?

You need an importer of record in the destination country, an EORI number for the EU, in most cases VAT registration in the country where stock is held, the correct HS code and a commercial invoice, and preparation in line with Amazon's current carton, pallet and labeling rules.

Is a courier or a forwarder better for e-commerce?

For a small number of orders sent to scattered countries, a courier is practical. If you have regular sales in a specific market or are sending stock to a fulfillment warehouse, consolidation or bulk shipments with a forwarder generally lower the total cost.

Can returns from abroad be brought back into Turkey duty-free?

When exported goods are returned, duty-free import may be possible under the “returned goods” provisions. This requires the export to be documented and the conditions in the regulations to be met; confirm with your customs broker.

Which documents are required for an e-commerce shipment to Europe?

For micro-exports, the commercial invoice and the courier company's shipping documents are sufficient; the ETGB is filed via the courier. For bulk shipments, an export declaration, commercial invoice, packing list, CMR for road freight and, where applicable, the A.TR movement certificate are used.