G/SG/N/10/TUR/16/Suppl.2  
G/SG/N/11/TUR/22/Suppl.2  
14 January  2021 
(21-0438) Page: 1/7 
Committee on Safeguards  Original:  English  
 
  
NOTIFICATION PURSUANT TO ARTICLE 12.1(C)  
OF THE AGREEMENT ON SAFEGUARDS  
(EXTENSION OF THE EXISTING MEASURE)  
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2  
OF THE AGREEMENT ON SAFEGUARDS  
TURKEY 
Toothbrushes  
Supplement  
The following communication, dated 13 January 2021, is being circulated at the request of the 
delegation of Turkey.  
 
_______________  
 
 
We enclose a  notification pursuant to Article 7.2, 12.1(c) and Article 9, footnote 2 of the Agreement 
on Safeguards, on taking a decisi on to extend a safeguard measure that is being applied against 
imports of toothbrushes  and non-application of the safeguard measure to developing countries . The 
initial safeguard measure was notified with the document s G/SG/N/8/TUR/16, G/SG/N/10/TUR/16  
and G/SG/N/11/TUR/ 22, dated 17 October  2017. The initiation of a review pursuant to Article 7.2 
regarding the extension of a safeguard measure was also notified with the documents 
G/SG/N/ 6/TUR/ 23/Suppl.1 and G/SG/N/14/TUR/11  dated 8 June 2020. 
Consistent with Article 12.3 of the Agreement on Safeguards , Turkey 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), January  2016-June 2020. The data, which were submitted by the applicant 
companies  and used  in this analysis, represent major proportion of the total domestic production of 
the product involved according to the 2019 figures.  
(i) Consumption  
Unit 2016  2017  2018  2019  2019(6)  2020(6)  
Consumption  (Indexed)  100 106 97 104 100 114 G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  Consumption index inc reased by 4 % from 2016 to 2019 . Increase in the index has been 14 % in the 
first 6 months of 2020 compared to the same period of 2019 . 
(ii) Production  
Unit 2016  2017  2018  2019  2019(6)  2020(6)  
Production(Indexed)  100 113 151 193 100 112 
Production index, which increased during the PUC continuously, reached 193 in 2019 . In the first 
6 months of 2020 it expanded by 12 % compared to the same period of 2019 . 
(iii) Domestic Sales   
Unit 2016  2017  2018  2019  2019(6)  2020(6)  
Domestic Sales  
(Indexed)  100 132 169 228 100 110 
Domestic sales indicate annual increase rates of 32 %, 28% and 35 % in 2017, 2018 and 2019, 
respectively . In the first 6 months of 2020, domestic sales increase  went up by 10 %. 
(iv) Capacity and Capacity Utilization  
Unit 2016  2017  2018  2019  2019(6)  2020(6)  
Capacity (Indexed)  100 100 107 129 100 100 
CUR(%) (Indexed)  100 113 140 149 100 112 
Capacity index reached 107 and 129 in 2018 and 2019, respectively . Capacity utilization ratio (CUR) 
index  continuously increased during the PUC and reached 149 in 2019.  
(v) Employment  
Number of Workers  2016  2017  2018  2019  2019(6)  2020(6)  
Employment  (Indexed)  100 107 141 160 100 107 
Employment index reached 160 in 2019 by following a continuous increase during the PUC . The 
number of workers increased by 7 % in the first 6 months of 2020 compared to the same period of 
2019.  
(vi) Productivity  
Unit per Worker  2016  2017  2018  2019  2019(6)  2020(6)  
Productivity  (Indexed)  100 106 107 121 100 105 
Index of labor productivity, which increased during the PUC continuously, escalated to 121 in 2019.  
(vii) Stocks  
Unit 2016  2017  2018  2019  2019(6)  2020(6)  
Stocks  (Indexed)  100 87 137 96 100 93 
The end of period stocks fluctuated during the PUC . In the first 6 months of 2020, the stocks 
decreased by 7 % compared to the same period of 2019.  
(viii)  Profitability  
Net Profit/Total 
Sales  2016  2017  2018  2019  2019(6)  2020(6)  
Profitability  (Indexed)  100 18 20 91 100 151 G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  Profitability index, which dropped by 82% in 2017, increased in the following years ; however, in 
2019 it could not reach its level at the beginning of the PUC yet . In the first 6 months of 2020 it 
increased by 51 % compared to the same period of 2019 . 
(ix) Conclusion  
During the PUC, the domestic consumption expanded  with the exception of the figure in 2018 ; the 
production and the domestic sales increased continuously . While the increase rates of these figures 
are significant in 2019, they indicated more mode st growth in the recent period (the first 6 months 
of 2020) . The stocks fluctuated during the PUC.  
The domestic industry realized capacity increase s by 7% and 20 % in 2018 and 2019 . In the same 
period , employment figures also went up . During the PUC, capaci ty utilization rate and labor 
productivity increased continuously as a result of new investments and innovation . Developments in 
effectiveness of production brought a bout a significant increase in the profitability 2 019 and the first 
6 months of 2020.  
1.2  Information on imports in absolute term and relative to domestic production  
An analysis of the increase in imports into Turkey of the product concerned both in absolute and 
relative terms was carried out over the period from 2016 to 2019 and January -June 2020. 
(i) General View of Imports  
IMPORTS  Quantity  Value  Unit Price  Change  
Period  Pcs Kg $ ($/Pcs)  ($/Kg)  Pcs Kg $ 
2016  69,727,895  1,331,304  29,089,941  0.42 21.9 - - - 
2017  67,436,631  1,337,251  27,706,978  0.41 20.7 -3% 0% -5% 
2018  44,480,686  838,891  20,125,530  0.45 24.0 -34% -37% -27% 
2019  33,813,414  594,091  17,249,850  0.51 29.0 -24% -29% -14% 
2019(6)  18,515,521  327,894  9,786,555  0.53 29.8 - - - 
2020(6)  20,176,981  366,977  8,599,250  0.43 23.4 9% 12% -12% 
Quanti ty of imports, 69.7  million  pcs in 2016 and 67.4  million  pcs in 2017, decreased significantly 
after the entry into force of the safeguard measure in 2018 . Decrease rates (in pcs) became 34 % 
and 24 % in 2018 and 2019, respectively . During the PUC, import values also continuously 
decre ased.  
On the contrary, the most recent import data shows an increasing trend . In the first 6 months of 
2020, quantity of imports increased by  9% and 12 % in terms of pcs and Kg, respectively, compared 
to the same period of the previous year.  
While unit import price increased in 2018 and 2019 in terms of both $/Pcs and $/Kg, it went down 
in the first 6 months of 2020 under the level of that in 2018.  
(ii) Imports  Relative to Domestic Production  
Imports/Production  2016  2017  2018  2019  2019(6)  2020(6)  
Index  100 86 42 25 100 98 
During the PUC, imports relative to domestic production decreased continuously . The rate of change 
of imports over production in the first 6 months of 2020 was 2 %. 
(iii) Market Share of Imports  
Market Share of 
Imports  2016  2017  2018  2019  2019(6)  2020(6)  
Index  100 91 66 47 100 95 
While the index of market share of imports decreased from 100 in 2016 to 47 in 2019, the rate of 
decrease was 5 % in the first 6 months of 2020.  G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  1.3  Precise description 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 2021.  
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 2 February  2024 
(2 February  2024 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  
(3.2.2021 -2.2.2022)  2nd Period  
(3.2.2022 -2.2.2023)  3rd Period  
(3.2.2023 -2.2.2024)  
9603.21.00.00.19  Others  0.19 USD/Pcs  0.17 USD/Pcs  0.15 USD/Pcs  
1.6  Proposed date of introduction of the measure  
The measure will enter  into force in 3 February  2021 with the publication of the related Presidential 
Decree in the Official Gazette . 
The related Presidential Decree and the Communiqué are expected to be published in the Official 
Gazette . 
1.7  Expected duration of the measure  
The expected duration of the prop osed measure is three years.  
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:  
Following the safeguard measure 's entry into force, the quantity of imports of the product concerned 
decreased and the average unit import price (unit price) increased in 2018 and 2019 . In 2019, the 
unit price hit its highest value during the PUC, 0.51 $/Pcs and 29 $/Kg . In this period , while the 
share of Viet  Nam among major exporters (to Turkey) decreased to 6 %, the share of China increased 
to 55 %. The economic figures of the domestic indust ry recovered to some extent, particularly in 
2019.  
On the other hand, import figures of the recent period point out a reverse trend . Compared to the 
first 6 month s of 2019, the quantity of imports increased and the unit price significantly decreased G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  to 0.4 3 $/Pcs and 23.4 $/Kg in the first 6 months of 2020 . These figures show that the imported 
products started to strengthen their position  in the domest ic market in the recent period.  
The trend of the unit prices of the products concerned having China and Viet Nam origin states that 
there exists a harsh price competition between these products and the domestic products . 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 2019 to X  % in the first 6 
months of 2020 . The unit price of the products having China origin converged to the level of the unit 
price of the domestic products in the recent period . Indeed, the data from International Trade Center 
(ITC) show 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 5  billion  pcs and the unit price 
about 0.12 $/Pcs . These figures point out a high probability for imports from China and Viet Nam to 
Turkey to increase soon in case the application period of the measure is not extended.  
In the first two years in which the measure was appl ied, the domestic industry made  investment 
plans to improve competitiveness and realized some of them . Unless t he measure is extended, there 
may be a risk for a number of investment plans not to be accomplished.  
(ii) Evidence that the industry concerned is adjusting:  
After the safeguard measure 's entry into force in 2018, the domestic industry increased its 
production, domestic sales and the capacity utilization rate (CUR) . CUR Index (100 in 2016) 
increased to 140 in 2018 and 149 in 2019 . Indeed, the domestic industry increased the labor 
productivi ty in this period . Productivity index (100 in 2016) increased to 12 1 in 2019 . The trend of 
unit commercial cost of the domestic industry  at the same period confirms  improvement of the 
domestic industry which utilized the capacity more efficiently and worke d with higher productivity . 
Starting from 2018, the unit commercial cost decreased in each period.  
Improvements in economic situation of the domestic industry started in 2018 . In 2019, this positive 
outlook was reflected to profitability that enabled the i ndustry to make new investment plans and 
to accelerate the innovation activities towards adjustment.  
The domestic industry started to establish a more firm and widespread marketing network after 
2018 to be able to more competitive with the global companies  active in Turkish market . Among the 
domestic producers, company X allocated a larger budget to new advertisement and marketing 
activities after 2018 and made an investment in this field amounting X  million  Turkish Lira in the 
last three years . Furthermore , company X invested into new machinery after 2018 for the production 
of toothbrushes in premium segment . Thanks to this investment, the company managed to increase 
the share of the premium products in its total production X times in the first 6 months of 2020, 
compared to the same period of the previous year.  
Consequently , in the period following the start of application of the measure, the domestic industry 
increased its capacity, made new investments in production and marketing fields and focused on 
production in premium segment more . These developments brought about an increase in efficiency 
and productivity in production, 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/1 1/TUR/22 , dated 17 October  2017. 
(iv) Duration of the measure from initial application till the date at which it will be extended:  
The safeguard measure was initiated on  3 February  2018 and will be in force till 2 February  2021. 
Turkey now intends to extend the  safeguard measure until 2 February  2024. G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  (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 the Council of Ministers Decision published in the Official Gazette dated  
3 February  2018, no. 30321 . The levels of duty  are demonstrated  in the table below.  
Turkish Customs 
Tariff Code*  Description of 
The Product*  1st Period  
(3.2.2018 -2.2.2019)  2nd Period 
(3.2.2019 -2.2.2020)  3rd Period  
(3.2.2020 -2.2.2021)  
9603.21.00.00.00  Toothbrushes  0.23 USD/Pcs  0.22 USD/Pcs  0.21 USD/Pcs  
 * Stated in accordance with Turkish Customs Tariff Schedule of 2018.  
1.12  Information relating to exporting members  
(i) The major exporting Members of the product concerned to Turkey:  
 Quantity (000 pcs)  Value (000 $)  
Countries  2016  2017  2018  2019  2019  
(6) 2020  
(6) 2016  2017  2018  2019  2019  
(6) 2020  
(6) 
China  25.211  22.864  16.349  18.445  9.767  9.685  9.203  9.609  7.515  8.615  5.165  2.150  
Ireland  7.104  8.844  8.126  4.660  2.329  3.680  6.470  7.557  4.689  3.224  1.654  2.677  
India 6.317  6.583  4.712  4.548  2.631  3.536  2.263  930 1.513  2.153  1.120  1.782  
Viet Nam 20.960  17.216  6.814  2.169  1.624  1.520  1.931  1.651  663 232 175 161 
Germany  3.073  1.561  844 1.102  498 236 4.620  1.133  905 780 365 310 
Other  7.063  10.369  7.636  2.888  1.666  1.520  4.603  6.827  4.841  2.246  1.308  1.519  
Total  69.728  67.437  44.481  33.813  18.516  20.177  29.090  27.707  20.126  17.250  9.787  8.599  
The main exporter to Turkey for the product concerned is China which had 55 % share in total imports 
(in terms of pcs) in 2019.  
(ii) The exporting Members to which the measure does not apply for any reason other than the 
application of Article 9.1:  
Not applicable.  
1.13  Members are encour aged 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 count ries 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 Turkey are listed below.  G/SG/N/10/TUR /16/Suppl.2 • G/SG/N/11/TUR/22/Suppl.2  
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  Afghanistan, Al bania, 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, Cote 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, Kyrgyzst an, Lao 
People's Democratic Republic, Lebanon, Lesotho, Liberia, Libya, North Macedonia, Madagascar, 
Malawi, Malaysia, Maldives, Mali, Marshall Islands, Mauritania, Mauritius, Mexico, Micronesia 
(Federated States of), Moldova, Mongolia, Montenegro, Montser rat, 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 
Africa, South Sudan, Sri Lanka, St.Kitts and Nevis, St.Lucia, St.Vincent and the 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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