G/SG/N/8/TUR/18/Suppl.1  
G/SG/N/10/TUR/18/Suppl.1  
G/SG/N/11/TUR/25/Suppl.1  
 
13 December  2023 
(23-8536) Page: 1/8 
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 
Polyethylene Terephthalate Chips  
Supplement  
The following communication, dated and received on 12 December  2023, is being circulated at the 
request of the delegation of Türkiye . 
 
_______________  
 
 
Türkiye  enclose s a notification pursuant to Article 7.2,  12.1(c) and 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 polyethylene terephthalate chips  and non-application of the safeguard measure 
to developing countries. The initial safeguard measure was notified with the document  
G/SG/N/8/TUR/18 -G/SG/N/10/TUR/18 -G/SG/N/11/TUR/25 , dated  16 November 2020 . The initiation 
of a review pursuant to Article 7.2 and 12.1 (A) regar ding the extension of a safeguard measure 
was also notified with the document G/SG/N/6/TUR/27/Suppl.1 , dated  16 May 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 O N 
SAFEGUARDS UPON TAKING A DECISION TO EXTEND A SAFEGUARD MEASURE  
1.1  Evidenc e 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 having a bearing on the situation of the 
domestic industry was undertaken for the investigation period  January 2018 -December 2022, and 
January -June period for the years 2022 and 2023. The data, which w as submitted by the applicant 
company and used  in this analysis, represent s major proportion of the total domestic production of 
the product involved according to the 20 22 figures.  
 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  (i) Consumption  
Unit 2018 2019 2020 2021 2022 2022(6) 2023(6) 
Consumption 
(Indexed)  100 136 173 222 242 100 75 
 
During the investigation period, c onsumption index of the product under investigation  increased 
steadily on annual basis. Index, which was 100 in 2018, increased to 242 points in 2022. Periodically, 
index decreased by 25 points in the first half of 2023 compared to the same period of 2022.  
 
(ii) Production  
Unit 2018 2019 2020 2021 2022 2022(6) 2023(6) 
Production  
(Indexed)  100 131 182 290 301 100 83 
 
Domestic PET chips production  increased steadily on annual basis. Index, which was 100 in 2018, 
increased to  301 points in 2022. On the contrary, periodical production showed a downward trend. 
Index, which was 100 in January -June period of 2022,  decreased to 83 points in the same period 
of 2023.  
 
(iii) Domestic Sales  
Unit  2018 2019 2020 2021 2022 2022(6) 2023(6) 
Domestic Sales  
(Indexed)  100 174 327 551 556 100 94 
 
Domestic sales of the product under investigation increased steadily on annual basis. Index, which 
was 100 in 2018, increased to 556 points  in 2022. Conversely, p eriodical production index, which 
was 100 in the first half of 2022, decreased to 94 points in the same period of 2023.  
 
(iv) Capacity and Capac ity Utilization Ratio (CUR%)  
Unit  2018 2019 2020 2021 2022 2022(6) 2023(6) 
Capacity 
(Indexed)  100 149 292 716 705 100 97 
CUR(%) 
(Indexed)  100 88 62 40 43 100 86 
 
Installed production capacity of the product under investigation increased steadily between 2018 
and 2021. Capacity index, which was 100 in 2018, increased to 716 in 2021. Index decreased to 
705 in 2022 due to the closure of a small production facility wit h old technology in 2022. Related 
with this, periodical capacity index, which was 100 in January -June period of 2022, decreased by 
3 points in the same period of 2023.  
 
Capacity utilisation rate (CUR) in the production of PET chips decreased between 2018 and 2021. 
CUR index, which was 100 in 2018, decreased to 40 in 2021. Index increased to 43 in 2022. 
Periodical index for CUR, which was 100 in the first half of 2022 decreased to 86 in the same period 
of 2023.  
 
(v) Employment  
Number of 
Workers  2018 2019 2020 2021 2022 2022(6) 2023(6) 
Employment 
(Indexed)  100 124 169 213 257 100 106 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  Number of persons employed in PET chips production increased throughout the investigation period. 
Annual employment index, which was 100 in 2018, increased to 257 in 2022. Periodical index, which 
was 100 in January -June period of 2022, increased to 106 in the same period of 2023.  
 
(vi) Productivity  
Unit per 
Worker  2018 2019  2020 2021  2022  2022(6)  2023(6)  
Productivity 
(Indexed)  100 106 108 136 117 100 79 
 
Productivity, which refers to annual production in tons per employee, increased between 2018 and 
2021, and has decreased since 2022. Index, which was 100 in 2018, increased to 136 in 2021. Index 
decreased to 117 in 2022. Periodical index, which was 100 in the first half of 2022, decreased to 79 
in the same period of 2023  
 
(vii) Stocks  
Unit  2018 2019  2020 2021  2022  2022(6)  2023(6)  
Stocks 
(Indexed)  100 240 328 93 410 100 234 
 
End of period  stocks  index increased between 2018 and 2020 on annual basis. Index, which was 
100 in 2018, increased to 328 in 2020. Stocks index showed a sharp fall in 2021 and decreased to 
93. On the contrary, index showed a sharp increase in 2022 and rose to 410 in 2022. En d of stock 
indicator continued its upward course periodically, and index, which was 100 in the first hal f of 2022 
increased to 234 in the same period of 2023.  
 
(viii)  Profitability  
Net 
Profit/Total 
Sales  2018 2019  2020 2021  2022  2022(6)  2023(6)  
Profitability 
(Indexed) (%)  100 32 72 75 54 100 -18 
 
Profitability, which refers to net profit in total sales showed a fluctuating course in the investigation 
period, while a downward trend has predominated. Annual profitability index, which was 100 in 
2018, decreased to 32 in 2019. Index increased to 72 in 2020, and then to 75 in 2021. Index 
decreased to 54 in 2022. Periodical index, which was 100 in 2018, decreased to -18 in the same 
period of 2023, and marked a negative indicator  (loss)  for the first time in the investigation period.  
 
(ix) Conclusion  
 
During the investigation period, w hile a n improvement was observed in domestic production  and 
domestic sales  until 20 22, some deterioration  was observed in these data in January -June period of 
2023. It has been observed that production reached its highest level in 202 2 following the capacity  
increase in 2021 . While domestic sales increased until 20 22 in parallel to the increase in production , 
it decreased in the first half of 2023. With the effect of the safeguard measure, capacity indicator 
showed a continuous improvement except for the small decrease in 2022 due to the closure of a 
production facility with old technology. In parallel to the i ncrease in capacity, employment data also 
showed a continuous improvement throughout the investigation period, whereas productivity per 
person decreased as of 2022 . End of period stocks, which  increased between 2018 and 2022 except 
for 2021, continue d to increase in January -June period of 2023.  Profitability data showed a 
fluctuating path, while it decreased as of 2022, marking loss in the first half of 2023.  
 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  1.2  Information on imports in absolute term and relative to domestic production  
An analysis of the imports into T ürkiye  of the product concerned both in absolute and relative terms  
are given below.  
 
(i) General View of Imports  
 
Imports  Quantity 
(tons)  Value (thousand 
dollars)  Unit Price 
($/Kg)  Per Cent Change  
Quantity  Value  U.P. 
2018 102.103  126.875  1,24    
2019 123.212  137.190  1,11 21 8 -10 
2020 124.036  102.064  0,82 1 -26 -26 
2021 112.211  123.079  1,10 -10 21 33 
2022 140.130  193.530  1,38 25 57 26 
2022/9  116.487  163.839  1,41       
2023/9  62.515  69.727  1,12 -46 -57 -21 
 
Total imports of the product under investigation tended to increase on annual basis, except for a 
decrease in 2021. Imports, which were at the level of 102.1 tons in 2018, increased in 2019 and 
2020 and reached to 124.2 thousand tons in 2020. Imports, which decreased to 112.2 thousand 
tons in 2021, reached  to 140.1 thousand tons with an increase of 2 5% in 2022. Periodic imports 
decreased by 46%  per cent in the first 9 months of 2023 compared to the same period of the 
previous year, decreasing t o 62.5 thousand tons.  
 
Unit prices for total imports decreased in 2019 and 2020 compared to previous years, and increased 
starting from 2021. Import unit price, which was 1.24 $/kg in 2018  increased to 1.38 $/kg in 2022. 
Periodic unit prices decreased by 2 1% in the first 9 months of 2023 compared to the same period 
of the previous year and came to the level of  1.12 $/kg. 
 
(ii) Imports Relative to Domestic Production  
 
Imports/  
Production   2018 2019 2020 2021 2022 2022(6) 2023(6) 
Production  
(Indexed)  100 92 67 38 46 100 56 
 
During the period under investigation, the ratio of imports to domestic production decreased on an 
annual basis until 2022, and index , which was 100 in 2018, decreased to 38 in 2021.  Conversely,  
index increased to 46 in 2022. Periodical index,  which was 100 in the first 6 months of 2022, 
decreased to 56 in the same period of 2023.  
 
1.3  Precise description of the product involved  
The product involved is classified under Customs Code  3907.69.00.00.00 in Turkish Customs Tariff 
Schedule of 202 3. 
 
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 12 December 2026 
(12 December  2026 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  2nd Period  3rd Period  
(13.12.2023 -
12.12.2024)  (13.12.2024 -
12.12.2025)  (13.12.2025 -
12.12.2026)  
3907.69.00.00.00  Others  0,054 USD/Kg  0,052 USD/Kg  0,050 USD/Kg  
 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  1.6  Proposed date of introduction of the measure  
The measure enters  into force on 13 December  2023 according to the provisions of the related 
Presidential Decree published in the Official Gazette .  
 
The date of entry into force of the related Presidential Decree  and the Communiqué  is 
13 December  2023.  
 
1.7  Expected duration of the measure  
The expected duration of the proposed 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:  
 
Domestic consumption of the product under investigation increased continuously on annual basis , 
while periodical consumption decreased slightly in 2023. Alt hough PET chips imports decreased in 
2021 with the effect of the safeguard measure put into force in December 2020,  it increased in 2022  
on both quantitative and value basis.  Imports  decreased in the first 9 months of 2023. While s hare 
of imports in domest ic market  decreased between 2018 and 2022, it re -increased in 2022. Relative 
imports (imports relative to domestic production) also increased in 2022. Unit prices for imports 
decreased in the first half of 2023.   
 
Deteriorations  have occurred  in domestic p roducers ' profitability indicators since 2022,  while there 
has also been deterioration  in the producers ' production and domestic sales indicators in the first 
half of 2023.  End-of-period stock s indicator has been deteriorated over the investigation period,  
except for 2021. While  domestic sales price of the domestic producer remained above the  import  
unit prices throughout investigation  period ( except for 2018 ), the reasonable sales price of the 
producer, which w as created by adding a reasonable profit  to producers ' unit production cost , was 
above the import unit prices in January -June period of  2023. In this context, domestic sales 
reasonable price was suppressed by import unit prices in the first half of 2023. Consequently,  the 
deterioration in the ec onomic indicators of the domestic produc er which started to occur 
simultaneously with the re -increase in imports  in 2022 , continue d in the first half of 2023.  
 
On the other hand, global  PET chips exports have increased since 2021 . Exports originating from 
People 's Republic of China (China) , which ranks  first in global  exports  of PET chips, also increased 
continuously  between 2018 and 2022 ( except for 2020, when the effects of the global epidemic were 
intense ). Share of Chinese exports in total PET chips  exports became 20% in 2022.  Türkiye ranked  
fourth  in China 's PET chips export markets  in 2022. Between 2018 and 2022, China 's exports to 
Türkiye  increased continuously, except for 2020, and the increase rate was 11 8% in 2022 . In this  
regard,  PET chips  imports to Türkiye, mainly originating from Far Eastern countries, will likely to 
further increase, in case the  current safeguard measure is not ext ended at the end of the 
implementation period . 
 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  (ii) Evidence that the industry concerned is adjusting:   
 
It was confirmed during the on -spot investigations that the  applicant domestic producer  made a 
capacity growth investment with the most -recent product ion technology. Production under this 
facility began just after the safeguard measure was put into force, which provided domestic producer 
to gain advantages in production costs. The applicant domestic producer is  also making a new 
investment to  enlarge its  established PET  chips production capacity, which is planned to start 
production in 2024. Following the completion of capacity increase plans, domestic producer  plans to 
focus on the production of specialty products.   
 
Domestic producer also com menced an investment on production of the main raw material of PET 
chips: PTA ( Terephtalic acid) in the period safeguard measure was in force. PTA production is also 
planned to start in 2024. The applicant producer also completed the territory acquisition to establish 
facilities for production of main petro -chemical row materials  and polymer s in Adana , Türkiye. In an  
effort to reduce production costs, the installation of Solar Energy System (SPP) was installed in 
producers ' main facilities buildings in the Adana, Türkiye, which is planned to be put into operation 
in 2024. In addition, another solar power installation is planned to be put into operation in Gaziantep , 
Türkiye  in 2024.  
 
As a result, with new investment decisions, new production and product deve lopment processes, 
raw material production to reduce production costs and the implementation of improved production 
technology in new facilities , the applicant producer  started to increase its competitiveness in the 
domestic market during the period safegu ard measure was implemented . In this regard, it has been 
determined that there is evidence showing that domestic producers are adapting to market 
conditions.  
 
(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/18 -G/SG/N/10/TUR/18 -G/SG/N/11/TUR/25 , dated 16 November  2020. 
 
(iv) Duration of the measure from initial application till the date at which it will  be 
extended:  
 
The safeguard measure was initiated on 13 December 2020  and will be in force until 
12 December  2023 (12 December is included) . Türkiye  now intends to extend the safeguard 
measure until 12 December 2 026. 
 
(v) Precise description of the measure in place prior to the date of extension:  
 
The measure in place prior to the date of extension is a specific duty, which was put into force on 
imports of polyethylene terephthalate chips  by the Presidential  Decision numbered 3192 and 
published in th e Official Gazette dated 13 November  2020, no. 31303 . The levels of duty  are 
demonstrated in the table below.   
 
Turkish 
Customs  
Tariff Code  Description of the 
Product  1st Period  2nd Period  3rd Period  
3907.69.00.00.00  Others  0,060 USD/Kg  0,058 USD/Kg  0,056 USD/Kg  
*Stated in accordance with Turkish Customs Tariff Schedule of 2023.  
 
1.12  Information relating to exporting members  
(i) The major exporting Members of the product concerned to Türkiye:  
 
Countries  Quantity (tons)  
Year 2018  2019  2020  2021  2022  2022 -9 2023 -9 
China  8.545  23.148  19.382  19.843  59.942  46.612  32.464  
Malaysia  13.585  28.497  42.060  36.306  28.916  25.972  15.074  
Korea, Republic of  50.845  39.377  23.589  22.237  19.712  19.263  3.612  
Indonesia  5.380  7.360  6.780  4.540  4.111  3.788  3.260  G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  Countries  Quantity (tons)  
Çorlu-Europe Free Zone 
of Türkiye  1.742  1.889  2.785  5.175  7.902  4.536  2.609  
Thailand  1.019  2.860  1.482  1.020  1.127  1.120  1.102  
Germany  9.676  9.797  8.022  7.764  5.715  4.419  853 
Algeria  0 0 0 0 332 232 650 
Spain  0 1 8 94 364 180 509 
Uganda  0 0 0 24 2.112  1.799  482 
Other  11.310  10.283  19.928  15.207  9.898  8.566  1.901  
Total  102.103  123.212  124.036  112.211  140.130  116.487  62.515  
 
Countries  Value (000 $)  
Year 2018  2019  2020  2021  2022  2022 -9 2023 -9 
China  10.897  26.106  18.957  22.549  82.797  65.480  36.711  
Malaysia  15.842  29.096  31.797  40.498  42.023  38.395  16.202  
Korea, Republic of  62.607  45.474  19.333  22.342  29.005  28.403  4.449  
Indonesia  6.440  7.716  5.347  4.971  6.232  5.800  3.480  
Çorlu-Europe Free Zone 
of Türkiye  2.192  1.799  2.001  5.793  8.620  5.169  2.453  
Thailand  1.459  4.415  2.151  1.686  1.947  1.924  1.450  
Germany  13.573  12.249  8.253  9.960  9.852  7.453  2.099  
Algeria  0 0 0 0 135 106 192 
Spain  0 1 41 92 355 269 388 
Uganda  0 0 0 20 1.682  1.435  327 
Other  7.786  3.376  7.397  10.753  3.697  2.987  615 
Total  126.875  137.190  102.064  123.079  193.530  163.839  69.727  
 
In the quantity -based ranking made according to the PET chips imports to Türkiye in 
January  September period  of 2023, it is seen that the countries with the largest share in imports 
since 2022 are China, Malaysia and South Korea, respectively. While more than half of the imports 
originated from the China  in 2023, share of Malaysia and South Korea in imports was 24% and 6% 
respectively. PET chips imports from China has increased continuously during the investigation 
period, except for 2020, and the share of the said country in  Türkiye 's imports increased from 4 3% 
in 2022 to 5 2% in the first 9 months of 2023.  
 
(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 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 the 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.  
 G/SG/N/8/TUR/18/Suppl.1 • G/SG/N/10/TUR/18/Suppl.1 • G/SG/N/11/TUR/25/Suppl.1  
 
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  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% of imports to T ürkiye are listed below.  
 
Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Azerbaijan, Bangladesh, 
Barbados, Belarus, Belize, Benin, Bhutan, Bolivia , Bosnia and Herzegovina, Botswana, Brazil, 
Burkina Faso, Burma (Burmese/Myanmar), Burund i, Cabo Verde, Cambodia, Cameroon, 
Central  African Republic, Chile, Colombia, Cook Islands, Costa Rica, Cuba, Democratic Republic of 
the Congo, Djibouti, Dominican Republic, Dominica, East Timor, Egypt, El Salvador, Eritrea, Ethiopia, 
Equatorial Guinea, Fe deral Republic of Nigeria, French Polynesia, Gabon, Gambia, Georgia, Ghana, 
Grenada, Guatemala, Guinea, Guinea -Bissau, Guyana, Haiti, Honduras, Independent State of 
Samoa, Iraq, Iran, Ivory Coast, Jamaica, Jordan, Kazakhstan, Kenya, Kingdom of Eswatini, Ki ngdom 
of Tonga, Kiribati, Kosovo, Kyrgyzstan, Laos, Lebanon, Lesotho, Liberia, Libya, Madagascar, Malawi, 
Maldives, Mali, Marshall Islands, Mauritania, Mauritius, Mexico, Micronesia, Mongolia, Moldova, 
Montenegro, Montserrat, Morocco, Mozambique, Namibia, Nauru, Nepal, Nicaragua, Niger, Niue, 
North Korea, North Macedonia, Oman, Pakistan, Palau, Palestine, Panama, Papua New Guinea, 
Paraguay, Peru, Philippines, Republic of Chad , Republic of Congo, Republic of Ecuador, Republic of 
Fiji, Russian Federation, Rwa nda, Sao Tome and Principe, Senegal, Seychelles, Serbia, Sierra Leone, 
Solomon Islands, Somalia, South Africa, South Sudan, Sri Lanka, St.  Kitts and Nevis, St.  Lucia, 
St. Vincent and the Grenadines, Sudan, Suriname, Tajikistan, Tanzania, Thailand, Togo, Tr inidad 
and Tobago, Tunisia, Turkmenistan, Tuvalu, Uganda, Union of Comoros, Uruguay, Uzbekistan, 
Vanuatu, Venezuela, Viet  Nam, Yemen, Zambia, Zimbabwe.  
 
__________