United Kingdom
A hotel furniture supplier for UK projects, in Gemlik.
Naggarco Group supplies UK hotel projects direct from its own production in Gemlik, Bursa, Türkiye: guestroom casegoods, architectural joinery and contract upholstery, with soft furnishings, lighting and installation carried on the same contract. Into the UK the proof of origin is a EUR.1 movement certificate or an origin declaration on the invoice, never an A.TR: the UK sits outside the EU–Türkiye customs union. Chapter 94 lets the exporter choose between a change of tariff heading and a 50% value cap.
We manufacture hotel interiors in Gemlik, Bursa: guestroom casegoods, architectural joinery and upholstery, with soft furnishings and lighting supplied in the same package and installation managed by us on site. A UK project differs from a European one in exactly one structural way. Most suppliers get it wrong in the first meeting. The United Kingdom is outside the EU–Türkiye customs union, so an A.TR does nothing here and origin becomes a calculation somebody has to actually run.
What we supply into the UK
5,000 m² in Gemlik, machining to upholstery
Guestroom casegoods (beds, wardrobes, desks, minibar units, vanities and TV units), architectural joinery including wall panelling, reception desks and doors, and contract upholstery from headboards to lounge seating. Machining, veneer, finishing and upholstery all happen in one building in Gemlik: 5,000 m² of production, a 350 m² showroom and 8 model rooms.
Everything inside the shell, on one purchase order
Soft furnishings, curtains, carpets and decorative lighting, plus flooring, wet areas and interior MEP, executed by trades we subcontract and manage. The boundary is the shell. Structure and civil works sit outside it, operating supplies sit outside it, and everything inside the room is on one purchase order.
BS 7176, EN 16139, EN 15372, EN 16121
BS 7176 with its hazard category for anything upholstered, BS EN 16139 for non-domestic seating, BS EN 15372 at the application level for tables and BS EN 16121 for storage. The build-up is engineered against what your schedule names.
Guestrooms delivered for Marriott, Hilton and Mövenpick
Mövenpick Istanbul, Hilton Garden Inn Jeddah, DoubleTree Jeddah, Holiday Inn Al Khobar, Marriott Belgrade and Citadines by Ascott Istanbul. We have manufactured guest rooms to Marriott, Hilton, Mövenpick, Rotana and Ascott standards, and a UK buyer is welcome in the showroom in Gemlik to open the wardrobes before signing anything.
The document, and the one everybody sends by mistake
A EUR.1, or an origin declaration on the invoice
Preferential treatment into the UK runs on a proof of origin: a EUR.1 movement certificate, or an origin declaration made out on the invoice. Under the revised rules exactly two proofs exist; the older third form is retired, and a supplier still naming it is quoting a rule set that has lapsed.
An A.TR is the wrong document here
A.TR proves free circulation inside the EU–Türkiye customs union. The UK is not in it. If a broker asks us for an A.TR for a Manchester delivery, the correct answer is that the instrument is a EUR.1. Getting that right in the room is worth more than any duty figure.
Small consignments need no EUR.1 at all
Below the low-value threshold, any exporter may make out an origin declaration on the invoice without a certificate. It matters for sample shipments and for a single replacement piece, which is exactly when the paperwork usually gets improvised.
A EUR.1 has a shelf life
Ten months from issue under the revised rules, a different clock from the A.TR's four months. Phased hotel deliveries running across a long programme are where that difference turns into a problem nobody planned for.
What proving origin means for furniture
Chapter 94 covers seating, other furniture, mattresses and lighting. Its list rule has two branches, and the revised text is explicit that the exporter chooses which one to use, consignment by consignment:
Branch one — change of heading
Manufacture from materials of any heading except that of the product itself. A wardrobe of 9403 built from board, hardware and finishes that are not themselves 9403 satisfies it, whatever those inputs cost and wherever they came from.
Branch two — the 50% value cap
Or: manufacture in which the value of all materials used does not exceed 50% of the ex-works price of the product. This is the branch that survives bought-in components sitting in the same heading.
The tolerance trap: 50 plus 15 is not 65
The 15% tolerance for non-originating materials cannot be used to exceed a percentage already set in the list rule. So it helps on the change-of-heading branch (a bought-in chair frame of 9401 going into a chair of 9401) and buys nothing at all on the 50% branch. Suppliers who add the two together are working to a number that does not exist.
The specification decides which branch you pass
The same wardrobe can pass on one branch and fail on the other depending on the board, the hardware and the finish specified. Origin is decided at material approval, alongside the fire standard.
Where we stop and your broker starts
A UK duty rate is run per specification. The rate turns on the ten-digit line and on the rule set in force for that lane. Rule sets move by administrative notice. We manufacture to a specification whose origin position we have run, raise the proof of origin, and hand your broker the arithmetic behind it to check. Anyone quoting you a firm UK landed rate without having seen the bill of materials is quoting a number they cannot defend.
Who does what at the border
You or your customs agent are the importer of record; we quote DAP to the named place. Two facts sit behind that. A non-established taxable person has no UK VAT registration threshold: registration is mandatory on any UK taxable supply, with no small-supplier exemption. Once registered, postponed VAT accounting avoids financing import VAT at the border, which keeps a hotel programme's cash flow intact. Whether a non-established seller can be named importer while an established agent lodges the declaration is a question for your broker on the specific entry. We manufacture, export-clear at Gemlik, raise the origin proof, carry the freight, and manage the installation through to a finished room.
BS 7176 and the hazard category
A UK hotel specification will call up BS 7176. A bedroom is medium hazard: EN 1021-1 (cigarette), EN 1021-2 (match) and BS 5852 ignition source 5, the 65 mm wooden crib usually written as crib 5. Public-area and bar seating in the same property is routinely specified higher. The FF&E schedule and the category table disagree more often than they agree. BS 7176 compliance is a manufacturer's declaration supported by test evidence on the composite as built, not a certificate issued by a body. It is engineered at material approval, and it lapses the moment a fabric is substituted.
Fire-rated upholstery: how it is actually certified →How a UK project runs
BOQ and drawings
Your bill of quantities and the architect's drawings.
Origin position run early
The bill of materials assessed against both branches of the list rule, so the proof of origin is a decision.
Standards named up front
Hazard category, ignition sources and strength level, fixed before production because they are build-up decisions.
Model room
Built and approved before the line opens. Eight are in our showroom in Gemlik.
Production and QC
Under our own production management in Gemlik.
EUR.1 and delivery
The proof raised per consignment, containers sequenced and labelled by room number, DAP to the named place, installation managed by us on site.
Common questions
- Can you send an A.TR for a UK delivery?
- We can raise one, but it would not do anything for you. The UK is outside the EU–Türkiye customs union, so the instrument is a EUR.1 movement certificate or an origin declaration on the invoice.
- What duty will we pay?
- It turns on the ten-digit line and the rule set in force for that lane, so the figure is run per consignment. Send the bill of quantities and we will run the origin position; your broker confirms the rate against it.
- Does it matter where your board and hardware come from?
- For the UK, yes. On an EU delivery an A.TR settles it and component origin never enters the calculation. Chapter 94 gives an exporter's choice between a change of heading and a 50% value cap, and which one a product passes on depends on what the specification names.
- Can you meet crib 5?
- Name it in the specification and the build-up is engineered to meet it, with the evidence produced against the approved composite. In a BS 7176 medium-hazard package crib 5 sits alongside EN 1021-1 and EN 1021-2.
- Will you be the importer of record?
- No. We quote DAP, and you or your customs agent lodge the entry. A non-established company has no UK VAT registration threshold, and the entry belongs with the party established to lodge it; your broker structures it for the specific shipment.
- What are your lead times?
- Set per project against scope and materials, and fixed in the offer together with the delivery date.
Send the BOQ.
A bill of quantities or a drawing set is enough to start. We come back with the scope we cover, the origin position we would run, and what the first room takes to build.