G/L/1327  
G/SG/N/13/MAR/1  
4 October  2019 
(19-6441) Page: 1/6 
Council for Trade in Goods  
Committee on Safeguards  Original:  French  
 
  
NOTIFICATION UNDER A RTICLE 12.5 OF THE A GREEMENT ON SAFEGUAR DS 
OF THE RESULTS OF A MID-TERM REVIEW  REFERRED TO IN ARTIC LE 7.4  
MOROCCO  
(Paper in Rolls and Paper in Reams)  
The following communication, dated 2 October 2019, is being circulated at the request of the 
delegation of Morocco.  
 
_______________  
 
 
Pursuant to Article 12.5 of the Agreement on Safeguards, Morocco hereby notifies the results of the 
mid-term review of the safeguard measure concerning import s of paper in rolls and  paper in reams.  
1. Specify the measure and the product subject to the measure for which the mid -term 
review was conducted, and provide reference to the WTO document that notified the 
safeguard measure subject to the review.  
Mid-term review of the safeguar d measure concerning import s of paper in rolls and paper in reams, 
classified under the following headings of the Moroccan customs tariff nomenclature : 
‐ 4802.55.90.00 for paper in rolls; and  
‐ 4802.57.90.00 for paper in reams.  
The application of the safeguard measure was notified to the WTO in 
document  G/SG/N/8/MAR/5 - G/SG/N/10/MAR/5 - G/SG/N/11/MAR/5.  
2. Provide the dates of initiation and conclusion of the review.  
The mid -term review of the safeguard measure concerning import s of paper in rolls and  paper in 
reams was initiated on 28 February 2019 and was concluded  on 3 September 2019.  
3. Describe the results of the review, providing some detail on the basis for reaching those 
results.  
(1) Import trends over the safeguard application period  
Imports o f paper in rolls and paper in reams fell by 27.49% and 38.74%, respectively, between 
2016 and 2017, but rose by 12.86% and 6.75% , respectively, between  2017 and 2018.  G/L/1327 • G/SG/N/13/MAR/1  
- 2 - 
  Imports  2016  2017  2018  
Paper in rolls  36,135  26,200  29,570  
Trend  - -27.49%  12.86%  
Paper in reams  11,177  6,847  7,309  
Trend  - -38.74%  6.75%  
Total imports  47,252  33,047  36,879  
Source:  Foreign Exchange Board.  
The leading exporters of  paper in rolls are Finland, Portugal, Poland, Brazil, Germany and Spain.  
 Weight in kilogrammes   
2016  2017  2018  
FINLAND  18,327,973  9,105,063  11,930,108  
PORTUGAL  3,769,297  4,000,900  6,170,044  
POLAND  1,722,104  1,502,496  2,605,828  
BRAZIL  - 1,289,620  2,144,541  
GERMANY  3,560,588  2,428,856  1,802,579  
SPAIN  4,486,689  3,493,898  1,679,250  
SWEDEN  1,149,456  501,037  999,172  
SLOVENIA  23,062  - 969,388  
EGYPT  43,910  - 45,845  
OTHER  3,051,929  3,878,114  772,893  
TOTAL  36,135,009  26,199,984  29,569,647  
Source:  Foreign Exchange Board.  
Data on imports shows that in absolute terms, the overall volume imported rose between 2017 and 
2018, despite the quota established under the safeguard measure for that period. However, the 
volume imported remains below that of 2016 during the investigation period.  
In terms of index  points , imports of paper in rolls in relation to domestic production fell from 100 in 
2016 to 62 in 2017 and 56 in 2018 , while imports of paper in reams  fell from 100 in 2016 to 49 in 
2017 and 40 in 2018. With regard to total imports (paper in rolls plus paper in reams), the share of 
import s in relation to domestic production f ell from 100 index points in 2016 to 59 in 2017 and 52 
in 2018. Despite the decrease in imports relative to domestic production, they continue to represent 
a fairly significant quantity in relation to domestic industry production.  
Index 2016 = 100   2016  2017  2018  
Import  share /production in %  Rolls 100 62 56 
Reams  100 49 40 
Total 100 59 52 
Source:  Foreign Exchange Board and data from the domestic industry.  
(2) Market share taken by imports  
Trend s in the market share taken by imports of paper in rolls and paper in reams show that despite 
a fall during the first few years in which the measure was applied, this share remains dominant if 
not overwhelming in relation to the market share of the domestic industr y.  
Index 2016 = 100   2016  2017  2018  
Market share taken by imports  Rolls 100 96 95 
Reams  100 91 88 
Source:  Foreign Exchange Board and data from the domestic industry.  
(3) Production  
In order to examine the domestic industry 's position since the introduction of the safeguard measure, 
the Ministry has considered the trends in the industry's performance indicators – in particular, G/L/1327 • G/SG/N/13/MAR/1  
- 3 - 
  production, sales, capacity and capacity utilization rate , employment, productivity and profit margin  
- during the 2016 -2018 period.  
Production of paper in rolls and reams rose in the 2016 -2018 period. In 2018, r oll production grew 
by 26% in relation to  2017 and by approximately 47% compared to 2016. Ream production rose by 
31% in 2018 in relation to 2017 and by 62% in relation to 2016.  
Index 2016 = 100   2016  2017  2018  
Production (tonnes)  Rolls 100 116 147 
Reams  100 124 162 
Source:  Data from the domestic industry.  
(4) Producti on capacity and capacity utilization  
Between 2016 and 2018 , while  the production capacity of the domestic industry remained stable 
(unchanged) in relation to the initial investigation period, the production capacity utilization rate 
evolved favourably,  rising from 100 to 147 index points for rolls and from 100 to 162 index points 
for reams. This upward trend in capacity utilization was also observed in relation to the initial 
investigation period during which the capacity utilization rate stood , in 2014 and the first half of 
2015, respectively, at seven  and 52 index poin ts for rolls and 14 and 65 index points for reams.  
However , despite positive growth, the utilization rate remains well short of  the optimal rate that 
would allow  the domestic industry to cover its operating expenses.  
Regarding the domestic industry's capac ity to satisfy local demand, the Confederation of European 
Paper Industries (CEPI) , in its comments, expresses the view that even utilizing  its full production 
capacity, the company will not be able to satisfy local demand.  
Index 2016 = 100   2016  2017  2018  
Capacity utilization rate  Rolls 100 116 147 
Reams  100 124 162 
Source:  Data from the domestic industry.  
(5) Sales  
Sales of paper in rolls rose by 12.50% in 2017 compared to 2016, and by 14.35% in 2018 compared 
to 2017. Sales of p aper in reams rose by 22.63% in 2017 compared to 2016, and 25.04% in 2018 
compared to 2017. These results are better than the last four years of the initial investigation period, 
that is since 2012. Sales also grew in volume and value , thus enabling the domestic industry to raise 
its prices between 2016 and 2018 and benefit from a fall in  roll costs from 100 index points in 2016 
to 90.42 points in 2018.  
Index 2016 = 100   2016  2017  2018  
Sales (tonnes)  Rolls 100 113 129 
Reams  100 123 153 
Source:  Data from the domestic industry.  
(6) Inventories  
The domestic industry's progressive recovery of part of the market share resulted in a decline in 
inventories between 2016 and 2017. The increase in inventories in 2018 was due to the delay 
between end-of-year production and the selling of the products concerned in January 2019.  
Index 2016 = 100   2016  2017  2018  
Final inventory (tonnes)  Rolls 100 73 173 
Reams  100 82 129 
Source:  Data from the domestic industry.  G/L/1327 • G/SG/N/13/MAR/1  
- 4 - 
  (7) Production costs and sales price  
Between 2016 and 2018, p roduction costs fell by 9.5% for both paper in rolls and paper in reams. 
Nonetheless, average production costs rose in relation to the initial investigation period. Production 
costs are getting closer and closer to the sales price, which rose by approximately 5.35% during the 
2016-2018 period.  
Index 2016 = 100   2016  2017  2018  
Production costs (MAD/ kg) Rolls 100 91.07  90.42  
Reams  100 91.17  90.52  
Ex-factory price (MAD/ kg) Rolls 100 102.26  105.42  
Reams  100 102.52  105.94  
Source:  Data from the domestic industry.  
(8) Profitability  
In 2018, p rofitability edged up by 77% for paper in rolls and by 79% for paper in reams  in relation 
to 2016,  despite remaining negative throughout the period analy sed.  
Index 2016 = 100   2016  2017  2018  
Profit margin1 (MAD)  Rolls -100 -47.09  -23 
Reams  -100 -46.31  -21 
Source:  Data from the domestic industry.  
(9) Employment  
In 2018, e mployment rose by 7.85% for rolls and by 38.3% for reams  in relation to 2016 . The 
employers' productivity ratio increased by 32.53% for rolls and by 13.49% for reams in the same 
period.  
2016 Index = 100    2016  2017  2018  
Employment  Rolls 100 104 108 
Reams  100 129 142 
Productivity  Rolls 100 113 135 
Reams  100 97 114 
Source:  Data from the domestic industry.  
 (10) Domestic consumption  
Domestic consumption of paper in rolls and paper in reams fell by 26.6% between 2016 and 2017, 
then rose by 15% between 2017 and 2018. It should be noted that consumption of paper in rolls 
accounts for the most significant share of the consumption of paper subject to the investigation  –
from 100 index points in 2016 , it stood at almost 87 points in 2018  – while the consumption of paper 
in reams stood at  100 index points in 2016 , falling  to 75 points in 2018. According to the data 
collect ed from the above -mentioned users concerning their paper -in-roll needs for 2019 and 2020, 
users' needs have tended to increase during this period mainly because of investments made by 
exercise book and envelope manufacturers and certain printing activities.  
                                                
1 The profit margin was calculated on the basis of the difference between the ex -factory price and the 
cost price.  G/L/1327 • G/SG/N/13/MAR/1  
- 5 - 
  Index 2016 = 100   2016  2017  2018  
Domestic consumption2 Rolls 100 76 87 
Reams  100 67 75 
Total 100 73 84 
Source:  Foreign Exchange Board and data from the domestic industry.  
In short, following the analysis of data collected throughout the investigation, the Ministry has found 
that domestic industry indicators improved , in relative terms, during the first few years the safeguard 
measure was applied, particularly in terms of production, sales, market share and profitability.  
Yet despite these improvements, the domestic industry was not able to meet the paper needs of 
users. Consequently, users, particularly exercise book manufacturers, continued to procure imported 
products over and above their allotted quotas by paying the addi tional duty instead of purchasing 
from the domestic industry. During the 2016 -2018 analysis period , their purchases from the 
domestic industry amounted to barely 2% of their supply from the international market in 2016, 
0.5% in 2017 and 3.6% in 2018.  
The investigation data also shows a rise in the consumption of paper in roll s in 2017 and 2018, which 
is most notably due to the growing  needs of exercise book manufacturers.  
The mid -term review produced many results, and thanks to the measures taken and the 
restructuring efforts made, there has been a relative improvement in the position of the domestic 
industry, even though the level of the results achieved is not what was anticipated , particularly with 
regard to increasing production  capacity and satisfying domestic needs.  
(11) Conclusion of mid -term review  
In light of the foregoing , it has been decided to:  
- Keep the safeguard measure in force  given that  the domestic industry continues to 
experience difficulty  delivering a profitable outcome due to paper imports;  
- Enhance the liberalization of the safeguard measure by revising the quota for the remaining 
application period upwards by approximately  3,000 tonnes  per year as of 2019 , so as not to 
handicap paper -based industries, i.e. exercise book manufacturers, envelope manufacturers 
and printers. However, the additional duty will not be modified.  
Year Additional ad valorem  
duty Annual quota (in tonnes)  
From 1 January to 31 December 2019  20% 23,500  
From 1 January to 31 December 2020  15.5%  25,500  
Timetable for the liberalization of the safeguard measure.  
In accordance with Article 9.1 of the Agreement on Safeguards, the measure will not be applied to 
imports of paper in rolls and paper in reams originating in the following developing countries or 
customs territories that are Members of the WTO:  
Albania; Angola; Antigua and Barbuda; Argentina; Armenia; Bahrain, Kingdom of ; Bangladesh; 
Barbados; Belize; Benin; Bolivia; Botswana; Brunei Darussalam; Burkina Faso ; Burundi; 
Cabo Verde; Cambodia; Cameroon; Central African Republic; Chad; Chile; China; Colombia; Congo; 
Democratic Republic of the Congo; Costa Rica; Côte d'Ivoire; Cuba; Djibouti; Dominica; 
Dominican  Republic; Egypt; El Salvador; Ecuador; Fiji; Gabon; T he Gambia; Georgia; Ghana; 
Grenada; Guatemala; Guinea; Guinea -Bissau; Guyana; Haiti; Honduras; Hong Kong, China; India; 
Indonesia; Jamaica; Jordan; Kenya; Korea, Republic of ; Kuwait; Kyrgyz Republic; Lao People's 
Democratic Republic; Lesotho; Macao, China;  Madagascar; Malaysia; Malawi; Maldives; Mali; 
Mauritius; Mauritania; Mexico; Moldova, Republic of ; Mongolia; Montenegro; Mozambique; 
Myanmar; Namibia; Nepal; Nicaragua; Niger; Nigeria; Oman; Pakistan; Panama; 
                                                
2 Domestic consumption is estimated according to the following formula: Production + imports ± 
change s in inventories – exports.  G/L/1327 • G/SG/N/13/MAR/1  
- 6 - 
  Papua  New Guinea; Paraguay; Peru; Philippines;  Qatar; Rwanda; Saint Lucia; Saint Kitts and Nevis; 
Saint Vincent and the Grenadines; Samoa; Saudi Arabia, Kingdom of ; Senegal; Sierra Leone; 
Singapore; Solomon Islands; South Africa; Sri Lanka; Suriname; Swaziland; Chinese Taipei; 
Tajikistan; Tanzania; Thailand; The former Yugoslav Republic of Macedonia (FYROM); Togo; Tonga; 
Trinidad and Tobago; Tunisia; Turkey; United Arab Emirates; Uganda; Uruguay; Vanuatu; 
Bolivarian  Republic of Venezuela; Viet  Nam; Yemen; Zambia; and Zimbabwe.  
__________