G/SG/N/10/TUR/16/Suppl.4  
G/SG/N/11/TUR/22/Suppl.4  
 
6 February  2024 
(24-0994) Page: 1/7 
Committee on Safeguards  Original: English  
 
  
NOTIFICATION UNDER ARTICLES 7.2 AND 12.1(C) OF THE AGREEMENT  
ON SAFEGUARDS ON TAKING A DECISION TO APPLY A SAFEGUARD MEASURE  
(EXTENSION OF THE EXISTING MEASURE)  
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2  
OF THE AGREEMENT ON SAFEGUARDS  
TÜRKIYE  
Toothbrushes  
Supplement  
The following communication, dated and received on 6 February  2024, is being circulated at the 
request of the delegation of Türkiye. 
 
_______________  
 
 
We enclose a  notification pursuant to Article 7.2, 12.1(c) an d Article 9, footnote 2 of the Agreement 
on Safeguards, on taking a decision to extend a safeguard measure that is being applied against 
imports of toothbrushes  and non-application of the safeguard measure to developing countries.  First 
extension of the safeguard measure was notified with the document s G/SG/N/10/TUR/16/Suppl.2  
and G/SG/N/11/TUR/22/Suppl.2 , dated January  14 2021. The initiation of a review pursuant to 
Article 7.2 reg arding the extension of a safeguard measure was a lso notified with the documents 
G/SG/N/6/TUR/23/Suppl.2  and G/SG/N/14/TU R/11/Suppl.1  dated  July 20, 2023. 
Consistent with Article 12.3 of the Agreement on Safeguards , Türkiye  is ready to hold consultations 
with those Members having a substantial interest as exporters of the product concerned.  
1  NOTIFICATION UNDER ARTICLE S 7.2 AND  12.1(C) OF THE AGREEMENT ON 
SAFEGUARDS UPON TAKING A DECISION TO EXTEND A SAFEGUARD MEASURE  
1.1  Evidence that the safeguard measure continues to be necessary to prevent or remedy 
serious injury or threat thereof caused by increased imports  
The investigation has been conducted by the Turkish Investigating Authority. In order to review the 
situation of the domestic industry after  introduction of the safeguard measure, an evaluation of all 
relevant factors of an objective and quantifiable nature was undertaken for the period under 
consideration (PUC), for the years 2019-2022 and  January -June period for the years  2022-2023. 
The data, which were submitted by the applicant companies and used  in this analysis, represent s 
major proportion of the total domestic production of the product involved according to the 20 22 
figures.  
i. Consumption  
Unit 2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Consumption  
(Indexed)  100 109 95 91 100 91 G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  Consumption data was calculated by consolidation of the total domestic sales data of the applicant 
companies  and import data.  
Consumption showed a declining trend except for 2020. Index,  which was 100 in 2019, increased to 
109 in 2021 . Index declined in 20 21 and 2022 and came forth as 91 in 2022. Periodic consumption 
index , which was 100 in the first six  months of 2022, decreased to 91  in the same period of 2023.  
ii. Production  
Unit 2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Production  
(Indexed)  100 107 97 100 100 97 
 
Production followed a fluctuating course during the PUC.  Production index, which was 100 in 2019, 
increased to 107 in 2020, decreased to 97 in 2021 and increased to 100 in 2022. Index, which was 
100 in the first six months of 2022, decreased to 97 in the same period of 2023.  
iii. Domestic Sales  
Unit 2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Domestic Sales  
(Indexed)  100 106 104 105 100 105 
 
Domestic sales index, which was 100, increased to 106 in 2020 and declined to 104 in 2021. Index 
increased as of 2022 and reached to 105 in 2022. Periodic index, which was 100 in the first part of 
2022 increased to 105 in the same period of 2023.  
iv. Capacity and Capacity U tilization  
Unit 2019  2020  2021  2022  2022 (1 -6) 2023(1 -6) 
Capacity (Indexed)  100 100 100 100 100 100 
CUR(%) (Indexed)  100 107 97 100 100 97 
 
Production capacity did not change during the investigation period . Capacity utilization ratio (CUR) 
index , which was 100 in 2019 increased to 107 in 2020, decreased to  97 in 2021 and increased to 
100 in 2022. CUR index also showed a slight decrease in the first half of 2023 and index, which was 
100 in the fi rst half of 2022 decreased to 97 in the same period of  2023.  
v. Employment  
Number of 
Workers  2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Employment  
(Indexed)  100 106 106 118 100 110 
 
Annual e mployment index reached 1 18 in 2022 , showing a continuous increase during the PUC. The 
number of workers increased by 10 per cent in the first 6 months of 202 3 compared to the same 
period of 20 22. 
vi. Productivity  
Unit per Worker  2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Productivity  
(Indexed)  100 101 92 85 100 88 
Index on labor productivity, which decreased  continuously during the PUC, dropped  from 100 in 
2019 to 85 in 2022. Periodical index, which was 100 in the first 6 months of 2022, decreased to 88 
in the same period of 2023.  G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  vii. Stocks  
Unit 2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Stocks  
(Indexed)  100 162 197 222 100 96 
 
End of period stocks increased steadily on annual basis. Index increased from 100 in 2019 to 222 in 
2022. Periodical index decreased from 100 in the first half of 2022 to 96 in the same period of 2023.  
viii. Profitability  
Net Profit/Total 
Sales  2019  2020  2021  2022  2022 (1 -6) 2023 (1-6) 
Profitability  
(Indexed)  100 80 62 141 100 93 
 
Profitability index, which was 100 in 2019, decreased to 80 in 2020, and to 62 in 2021  Index 
increased to 141 in 2022, marking its highest level during the PUC.  In the first 6 months of 202 3, 
index decreased  by 7 per cent compared to the same period of 20 22. 
ix. Conclusion  
Domestic toothbrushes consumption decreased since 2022 in the PUC. P roduction figures followed 
a fluctuating course  annua lly, and decreased in the first half of 2023. End of stock s increased steadily 
on annual basis. Domestic sales increased since 2022 . 
While the capacity of domestic production did not change during the PUC capacity utilization rates 
followed a fluctuating course in parallel with the production and CUR index showed a decrease in the 
first half of 2023.  
Although employment figures showed a  constant improvement throughout the PUC, productivity 
data showed a continuous deterioration during the PUC.  Showing a fluctuating course, while 
profitability of domestic producers reached its highest level in 2022, it decreased in the first 6 months 
of 2023. 
1.2  Information on imports in absolute term and relative to domestic production  
An analysis of the increase in imports into T ürkiye  of the product concerned both in absolute and 
relative terms are given below .  
i. General View of Imports  
IMPORTS  Quantity  Value  Unit Price  Per Cent Change  
Period  Pcs Kg $ ($/Pcs)  ($/Kg)  Pcs Kg $ 
2019  33.813.414  594.091  17.249.850  0,51 29,0    
2020  41.268.279  799.879  20.812.367  0,50 26,0 22 35 21 
2021  33.703.790  560.266  12.701.159  0,38 22,7 -18 -30 -39 
2022  30.516.843  525.672  12.156.826  0,40 23,1 -9 -6 -4 
2022 (6)  17.871.467  275.955  6.144.976  0,34 22,3    
2023 (6)  11.683.203  284.230  5.887.276  0,50 20,7 -35 3 -4 
Quanti ty of imports, which was approximately 33,8 million pcs in 2019, increased  by 22  per cent in 
2020 and became 41,3 million pcs . In 2021, imports decreased by 18 per cent and dropped  to the 
level of 33,7 million pcs. In 2022, toothbrush imports decreased to 30,5 million pcs, marking a 9  
per cent decrease.  Imports decreased by 35 per cent in the first half of 2023 compared to the same 
period of the previous year and become 11,7 million pcs.  G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  On value basis, imports increased from the level of 17,2 million dollars in  2019 to 20,8 million dollars 
in 2020, marking a 21 per cent increase. Thereafter, imports decreased steadily on annual basis and 
dropped to 12,2 million dollars in 2022, marking a 4 percent decrease compared to the previous 
year. In the first half of 2023  imports decreased by 4 per cent compared to the same period of the 
previous year and reached to 5,9 million dollars.  
Import unit prices decreased between 2019 -2021 on annual basis. Unit prices decreased from 
0,51 $/pcs in 2019 to 0,38 $/pcs in 2021. Unit prices increased to 0,40 $/pcs in 2022. Periodically, 
unit prices increased from 0,34 in the first half of period of 2022 to 0,50 in the same period of 2023.  
ii. Imports Relative to Domestic Production  
Imports/  
Production  2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Index  100 115 103 90 100 67 
 
During the PUC, ratio of imports to domestic production  decreased except for 2020. Annual index 
decreased from 100 in 2019 to 90 in 2022, while periodic index decreased from 100 in the first 
period of 2022 to 67 in the same period of 2023.   
Market Share of Imports  
Market Share of 
Imports  2019  2020  2021  2022  2022 (1 -6) 2023 (1 -6) 
Index  100 111 97 90 100 70 
 
Market share of imports decreased during the PUC except for 2020. Index, which increased from 
100 in 2019 to 111 in 2022, decreased to 90 in 2022. Periodic index decreased from 100 in the first 
part of 2022 to 70 in the same  period of 2023.  
1.3  Precise descrip tion of the product involved  
The product involved is classified under 12 -digit Customs Code 9603.21.00.00.19  in Turkish Customs 
Tariff Schedule of 2024. 
1.4  Description of any part of the imported product that will no longer be subject to the 
measure in the extension  
Not applicable . 
1.5  Precise description of the proposed measure  
The safeguard measure  is proposed to be extended for 3 years until  February 2, 2027 
(February  2, 2027 is included)  in the form of fixed duty which will be implemented as shown in the 
table below.  
Turkish Customs 
Tariff Code  Description of The 
Product  1st Period  
(3.2.202 4-2.2.202 5) 2nd Period  
(3.2.202 5-2.2.202 6) 3rd Period  
(3.2.202 6-2.2.202 7) 
9603.21.00.00.19  Others  0.13 USD/Pcs  0.11 USD/Pcs  0.09 USD/Pcs  
1.6  Proposed date of introduction of the measure  
The measure enters into force on February 3, 2024 with the publication of the related 
Presidential  Decree in the Official Gazette .  
The related Presidential  Decree and the Communiqué were published in the Official Gazette . 
1.7  Expected duration of the measure  
The expected  duration of the proposed measure is three  years.  G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  1.8  Proposed date for the review  
Not applicable . 
1.9  Expected timetable for progressive liberalization of the measure  
The measure  is proposed to be liberalized annually  as stated in the Section  1.5. 
1.10  If the notification relates only to a finding of serious injury or threat thereof, and 
does not relate to a decision to apply or extend a safeguard measure:  
Not applicable . 
1.11  Information relating to the extension of a safeguard measure  
i. Evidence that the safeguard measure continues to be necessary to prevent or remedy 
serious injury or threat thereof:  
Domestic toothbrush market contracted since 2022  as a result of the decrease in imports and 
consumption. Both total imports and the ratio of imports to domestic production of the product under 
investigation decreased since 2021. Market share of imports also decreased since 2021 , while share 
of imports from Viet  Nam and China (the two main exporters to Türkiye of the pro duct under 
investigation) reached to 31 per cent and 40 per cent respectively  in 2022 . Unit prices for total 
imports increased  since 2021.  
Majority of e conomic figures of the domestic industry recovered to some extent, particularly in 2020 
and 2022. Deteriorations also occurred in domestic producer 's end of stocks data between 
2019-2022, in productivity data since 2022, in production, CUR and profitability rates in the first half 
of 2023. On the other hand, improvements were observed in domestic production 's employment and 
domestic sales figures  during the PUC, as well as in end of stocks data in the first half of 2023.  
Alongside the declining trend in total imports and increasing unit prices, import shares of China and 
Viet Nam, where more than half of the imports took place, increased recently. At the same time, 
unit prices for imports from these two countries realized  below the unit prices of other countries 
during the PUC.  This situation shows that  there exists a harsh pric e competition between Chinese 
and Viet  Nam originated imports and domestic industry. As the products having Viet  Nam origin 
continuously undercut the price of the domestic products during the PUC, price undercutting 
increased from X% in the first 6 months of 2022 to X% in the first 6 months of 2023. The unit price 
of the products having Chinese  origin converged to the level of the unit price of the domestic products 
in the recent period. The data from International Trade Center (ITC) show s that China keeps its 
position to be capable of exporting toothbrushes in low price levels to other countries, taking into 
account its annual export volume over 107.550 ton and the unit price about 8,89 $/Kg These figures 
point out a high probability for imports from China and Viet  Nam to Türkiye  to increase soon in case 
the application period of the measure is not extended .  
ii. Evidence that the industry concerned is adjusting:  
The two -term safeguard implementation and the resulting recoveries in the overall economic 
situatio n of domestic producers ended up with producers ' new investment plans as well as innovation 
activities in a way to fully adapt into new market conditions. It was determined during the on -spot 
investigations that producers concluded construction of a new to othbrush production facility, which 
are planned to begin their activities in the first half of 2024.  Also, new machinery investments were 
realized in these facilities, while they also invested into new machinery for the production of 
toothbrushes in premiu m segment. Thanks to this investment, the domestic industry managed to 
increase the share of the premium products in its total production during the PUC. It was affirmed 
that producers are planning to make new investments in the future.  
Domestic industry also started to establish a more  firm an d widespread marketing network to be 
able to more competitive with the global companies active in Turkish market. Domestic producers 
allocated a larger budget to new advertisement and marketing activ ities and made an investment in 
this field.  G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  Consequently , with new investments on both production, machinery and marketing, as well as with 
efforts to produce high -segment toothbrushes, domestic industry has better adapted to new market 
conditions by incr easing its competitiveness as well. These developments brought about an increase 
in efficiency in prod uction, a decrease in commercial  costs and an acceptable level of profitability. 
In this respect, the evidences above indicate that the domestic industry is adjusting.  
iii. Reference to the WTO document that notified the initial application of the measure:  
The introduction of the definitive safeguard measure was no tified with the document numbered  
G/SG/N/8/TUR/16 , G/SG/N/10/TUR/16  and G/SG/N/11/TUR/22 , dated October 17, 2017. 
iv. Duration of the measure from initial application till the date at which it will be extended:  
The safeguard measure was initiated on  February 3, 2018 and Türkiye  now intends to e xtend the 
safeguard measure until February  2, 2027. 
v. Precise description of the measure in place prior to the date of extension:  
The measure in place p rior to the date of extension i s a specific  duty, which  was put into force on 
imports of toothbrushes by Presidential Decree published in the Official Gazette dated  
February  2, 2021, n303 83. The levels of duty  are demonstrated  in the table below.   
Turkish Customs 
Tariff Code*  Description of The 
Product*  1st Period  
(3.2.20 21-2.2.20 22) 2nd Period  
(3.2.20 22-2.2.202 3) 3rd Period  
(3.2.202 3-2.2.202 4) 
9603.21.00.00. 19 Toothbrushes  0.19 USD/Pcs  0.17 USD/Pcs  0.15 USD/Pcs  
* Stated in accordance with Turkish Customs Tariff Schedule of 20 21. 
1.12  Information relating to exporting members  
i. The major exporting Members of the product concerned to T ürkiye : 
Countries  Quantity (000 pcs)  Value (000 $)  
2019  2020  2021  2022  2022  2023  
2019  2020  2021  2022  2022  
(6) 2023  
(6) -6 -6 
P.R.C.  18.445  20.246  14.840  12.210  7.512  6.078  8.615  6.310  4.355  3.383  1.897  1.961  
Viet Nam 2.169  2.712  7.075  9.467  6.116  1.189  232 282 792 1.269  833 128 
India 4.548  5.860  4.503  3.168  1.093  1.259  2.153  2.882  2.047  1.690  664 645 
Ireland  4.660  8.318  3.145  2.659  1.599  1.461  3.224  6.760  1.749  2.163  1.290  1.426  
Switzerland  573 561 603 1.131  507 140 611 807 984 2.193  684 409 
Russian 
Federation  452 502 977 935 440 504 379 448 855 735 313 472 
Germany  1.102  1.360  1.100  314 254 161 780 1.805  988 216 171 304 
Sweden  273 194 204 236 143 346 234 155 168 174 108 241 
Italy 427 133 106 114 57 76 269 127 102 102 52 88 
USA 557 1.107  387 93 54 21 520 1.092  342 104 66 32 
Other Countries  73 30 25 5 1 3 37 24 16 7 3 6 
Total  33.813  41.268  33.704  30.517  17.871  11.683  17.250  20.812  12.701  12.157  6.145  5.887  
The main exporter to T ürkiye  for the product concerned is China which had 40% share in total 
imports (in terms of pcs) in 20 22. The quantity share of Viet  Nam, with the lowest unit price among 
all the countries  increased to 31% in 2022.  
ii. The exporting Members to which the measure does not apply for any reason other than 
the application of Article 9.1:  
Not applicable.  G/SG/N/10/TUR/16/Suppl.4 • G/SG/N/11/TUR/22/Suppl.4  
 
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  1.13  Members are encouraged to attach, in an electronic form, publicly available 
document(s) containing the relevant decision(s) made by the competent authority.   
The official documents regarding the investigation and th e final decision are available in  the link 
below.  
https://ticaret.gov.tr/ithalat/ticaret -politikasi -savunma -araclari/korunma -onlemleri/yururlukteki -
onlemler   
2  NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2 OF THE AGREEMENT ON 
SAFEGUARDS  
2.1  The measure  
It is proposed to impose safeguard measure as described  in Section  1.5. 
2.2  The product subject to the measure  
The measure is applied to the product  described in Section 1. 3. 
2.3  Developing countries to which the measure is not applied under article 9.1 of the 
Agreement on Safeguards.  
The developing countries which are excluded from the measure as they export in quantities less than 
3 per cent of imports  to Türkiye  are listed below.  
Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Azerbaijan, Bangladesh,  
Barbados, Belarus, Belize,  Benin, Bolivia, Bosnia and Herzegovin a, Botswana, Brazil, Burkina Faso, 
Burundi, Bhutan , Cambodia, Cameroon, Cape Verde, Central African Republic, Chad, Chile, 
Colombia, Comoros, Congo, Cook Islands, Costa Rica, Côte d'Ivoire, Cuba, Democratic People 's 
Republic of Korea, Democratic Republic of the Congo, Djibouti, Dominica, Dominican Republic, 
Ecuador, Egypt, El Salvador, Equatorial Guinea , Eritrea, Ethiopia, Fiji, French Pol ynesia, Gambia, 
Georgia, Gabon, Ghana, Grenada, Guatemala, Guinea, Guinea -Bissau, Guyana, Haiti, Honduras, 
Iraq, Iran, Indonesia, Jamaica, Jordan, Kazakhstan, Kenya, Kiribati, Kosovo, Kyrgyzstan, Lao 
People's Democratic Republic, Lebanon, Lesotho, Liberia,  Libya, Macedonia, Madagascar, Malawi, 
Malaysia, Maldives, Mali, Marshall Islands, Mauritania, Mauritius, Mexico, Micronesia (Federated 
States of), Moldova, Mongolia, Montenegro, Montserrat, Morocco, Mozambique, Myanmar, Namibia, 
Nauru, Nepal, Nicaragua, Niger, Nigeria, Niue,  Oman, Pakistan, Palau, Palestine, Panama, Papua 
New Guinea, Paraguay, Peru, Philippines, Russian Federation, Rwanda, Samoa, Sao Tome and 
Principe, Senegal, Serbia,  Seychelles,  Sierra Leone, Solomon Islands, Somalia, South A frica, South 
Sudan, Sri Lanka, St. Kitts and Nevis, St.  Lucia, St.  Vincent and Grenadines, Sudan, Surinam, 
Eswatini , Tajikistan, Tanzania, Thailand, Timor -Leste, Togo, Tonga, Trinidad and Tobago, Tunisia, 
Turkmenistan, Tuvalu, Uganda, Ukraine, Uruguay, Uzbekistan, Vanuatu, Venezuela, Yemen, Zambia , 
Zimbabwe.  
 
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