G/SG/N/6/MDG/10  
G/SG/N/7/MDG/10  
G/SG/N/11/MDG/10  
24 February  2023 
(23-1331) Page: 1/5 
Committee on Safeguards  Original:  French  
 
  
NOTIFICATION UNDER ARTICLE 12.1(A) OF THE AGREEMENT ON SAFEGUARDS  
ON INITIATION OF AN INVESTIGATION AND THE REASONS FOR IT  
 
NOTIFICATION UNDER ARTICLE 12.4 OF THE AGREEMENT ON SAFEGUARDS  
BEFORE TAKING A PROVISIONAL SAFEGUARD MEASURE  
REFERRED TO IN ARTICLE 6  
 
NOTIFICATION UNDER ARTICLE 9, FOOTN OTE 2 ,  
OF THE AGREEMENT ON SAFEGUARDS  
MADAGASCAR  
Flour 
The following communication, dated 22 February 2023 and received on 2 3 February 2 023, is being 
circulated at the request of the delegation of Madagascar.  
 
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In accordance with Articles 12.1(a) and 12.4 of the Agreement on Safeguards, Madagascar hereby  
notifies the Committee on Safeguards of the initiation of an investigation in respect of imports of 
flour and before taking a provisional safeguard measure referred to in Article 6 of the Agreement . 
Madagascar also wishes to notify the Committee, under Article 9, footnote 2, of the Agreement on 
Safeguards, of the decision not to apply the proposed safeguard measure against  imports originating 
in developing countries.  
A. NOTIFICATION UNDER ARTI CLE 12 .1(A) OF THE AGREEMENT ON SAFEGUARDS ON 
INITIATION OF AN INVESTIGATION AND THE REASONS FOR IT  
Faced with imports of flour in such increased quantities as to be detrimental, the domestic flour 
industry has filed a petition with the National Authority for Trade Remedies (ANMCC) requesting the 
implementation of a s afeguard measure pursuant to  Article XIX of the GATT, the WTO Agreement 
on Safeguards a nd Decree No. 2017-695 of 1 6 August 2 017 establishing the procedures applicable 
to trade remedies in Madagascar.  
After being reviewed, the petition was deemed admissible  and the ANMCC decided to initiate a 
safeguard investigation in respect of  imports of flour to Madagascar . The key points relating to   the 
initiation of this investigation are as follows:  
1. Date of initiation  
The investigation was initiated on 1 8 February  2023. 
2. Product concerned  
The product concerned is flour, imported into Madagascar under Harmonized System customs tariff 
code 11010000 entitled "Wheat or meslin flour ". G/SG/N/6/MDG/10 • G/SG/N/7/MDG/10 • G/SG/N/11/MDG/10  
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  3. Exporting countries  
The main countries exporting flour to Madagascar are India, E gypt, Türkiye and the Russian 
Federation.  
4. Reasons for the initiation of the investigation  
The domestic flour industry ha s provided evidence of the serious injury  it has suffered  as a result of 
the considerable increase in flour imports . The increase is evident in both absolute and relative terms 
compared to domestic production during the period from 2020 to 2022 . The situation of the domestic 
industry is of concern in view of the significant and almost universal deterioration  of performance 
indicators, including production, production capacity utilization, sales, market share and, above all, 
profits and losses . It is thus found  that all of the conditions necessary for the initiation of a safeguard 
investigation have been met. 
5. Duration of the investigation  
The investigation will last for a period of 9 months and may be extended up to 12 months.  
6. Further informati on 
Interested parties have 30 days from the date of initiation of the investigation to make themselves 
known to the ANMCC, the investigating authority.  
Pursuant to  Article 3 of the Agreement on Safeguards, any information or comments, as well as 
requests f or questionnaires, should be submitted in writing to the ANMCC at the address below 
within a period of 30 days from the initiation of the investigation.  
Replies to the questionnaire shall be sent to the ANMCC within 30 working days of the initiation of 
the investigation.  
In case of non -response or late response, decisions will be made on the basis of the best information 
available.  
Public hearings may be held, either at the request of the interested parties or at the discretion  of 
the ANMCC, to allow partie s to present  evidence and their views , including  the opportunity to respond 
to the presentations of other parties and to defend their interests.  
B. NOTIFICATION UNDER ARTI CLE 12 .4 OF THE AGREEMENT ON SAFEGUARDS BEFORE 
TAKING A PROVISIONAL SAFEGUARD MEASURE REFERRED TO IN ARTI CLE 6  
1. Products covered by the provisional measure  
The product concerned is flour, imported into Madagascar under Harmonized System customs tariff 
code 11010000 entitled "Wheat or meslin flour ". 
 
2. Proposed provisional safeguard measure  
The provisional safeguard measure consists of an additional ad valore m duty of 12 % of the c.i.f. 
value.  
3. Proposed date of introduction of the provisional safeguard measure  
The provisional safeguard measure will enter into force on 1 March 2 023. 
4. Expected duration of the provisional safeguard measure  
The provisional safe guard measure will be applied for 200 days.  G/SG/N/6/MDG/10 • G/SG/N/7/MDG/10 • G/SG/N/11/MDG/10  
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  5. Basis for application of the provisional safeguard measure  
The decision to  impos e a safeguard measure takes in to account  the critical situation of the domestic 
industry, as provided for by Article 6 of the Agr eement on Safeguards . This situation is evident  from 
the sudden drop in production and sales after only two years of activity, according to the following 
determination : 
I. UNFORESEEN DEVELOPMENTS  
The disruption of international trade in wheat flour as a result of the war in Ukraine, a situation that  
has become profitable for some exporting countries, is an unforeseen circumstance that has helped 
to increase wheat flour imports to Madagascar.  
Moreov er, the increase in flour imports to Madagascar is also explained by the implementation of an 
export promotion policy for wheat flour, as well as the different forms of support for producers and 
processors in the main exporting countries, such as Egypt, Tü rkiye and India, that increase their 
competitiveness.  
II. INCREASE D IMPORTS  
(i) Absolute change in  imports  
Flour imports increased by 12 index points during the period under investigation . The quantity 
imported increased from 165,000 tonnes to 185,000 tonnes between 2020 and 2022 . A considerable 
25-point increase was recorded last year.  
(ii)  Relative change in  imports  
Between 2021 and 2022, imports increased by 17 index points relative to domestic production.  
III. SERIOUS INJURY  
The injury to the domestic industry is determined on the basis of the evolution of the following 
perform ance indicators:  
(i) Rate of increase in imports  
The quantity of flour imported into Madagascar has been far greater than that of domestic production 
in both absolute and relative terms for the past three years . The rate of increase was intensified  
between 2021 and 2022, when it reached more than 25 %. 
(ii)  Market share taken by imports  
The local flour market is dominated by imported products that account for more t han half of total 
consumption during  the investigation period . Still marginal  in 2020, the domestic industry  was able 
to expand  its share  during its growth phase in 2021 . However, this expansion had already  slowed in 
2022 owing to the increase d flour impor ts. 
(iii)  Sales and inventory volumes  
Starting in 2020, c onsumers gradually began to opt for locally produced flour . However,  the sales 
volume decreased by 75 index points in 2022 compared to the previous year . In general, the 
domestic flour industry faces diffi culties in selling its product, leading to a  year-on-year accumulation 
of inventory . 
(iv) Domestic production  
The domestic industry  began  production in 2020 . Its activity only covered  a few months of 2020 
meaning it  is not comparable to activity in 2021. With the resumption of imports, the volume of flour 
production dropped sharply by 68 index points in 2022 compared to the 2021 volume.  G/SG/N/6/MDG/10 • G/SG/N/7/MDG/10 • G/SG/N/11/MDG/10  
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(v) Employment and productivity  
In order to support production, local producers have expanded  their workforces , increas ing from 100 
to 181 index points between 2020 and 2021 . Despite the slowdown in production in 2022 owing to 
the difficulties they faced in disposing of the product on the market, they made efforts to maintain 
the same level of staff . As a result, the domestic industry 's productivity decreased slightly in 2022 
compared to the previous year.  
(vi) Production capacity utilization  
The production capacity utilization rate is far from optimal . It has not been possible to pass the 45 % 
mark during the three years of activity . It was o nly in 2022  that a loss of 68 index points was 
recorded in the utilization of production capacity compared to 2021 . This was a loss on a par with 
the domestic production . 
(vii)  Profits and losses  
The influx of im ports had a significant impact on financial performance . A drop of 40 index points 
was recorded for the period from 2020 to 2022 . Between 2021 and 2022, the domestic industry lost 
57 index points in terms of profitability.  
IV. CAUSAL LINK  
The existence of a causal link between increase d imports and serious injury to the domestic industry 
was established  on the basis of  the following elements:  
(i) Effects of increased imports  
The movement in opposite directions  of imports and of the economic indicators of the domestic 
industry indicates that increase d imports caused the injury to the domestic industry as they have 
led to considerable drops in production, sales and profitability, especially as of 2021.  
(ii) Effects of other factors  
(1) Contraction in demand  
Domestic consumption  grew steadily during the period under consideration . Hence , a contraction in 
domestic demand is excluded from the causes of injury.  
(2) Technology used and product quality  
The domestic industry has effective machinery for producing flour . Moreover, because of the 
similarities between local and imported products it can be said  that these products are of the same 
quality and are produced using the same technologies.  
 
(3) Internal competition  
The two fl our production units are located in two geographically distant locations . In addition, locally 
produced flour still accounts for a lot less than half of domestic demand . Internal competition is 
therefore in no way the cause of the injury suffered by domest ic producers.  
(4) Export performance  
Locally produced wheat flour is destined entirely for the domestic market for the time being . The 
export performance cannot be seen as a cause of the injury to the domestic injury.  
In the light of the foregoing, the aut hority concludes that the cause of injury to the domestic industry 
is increase d imports  alone . The possibility that other factors may be implicated is dismissed  as none 
of these parameters can be considered the cause of injury.  G/SG/N/6/MDG/10 • G/SG/N/7/MDG/10 • G/SG/N/11/MDG/10  
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  6. Offer of consultations under Article 12.4  
Pursuant to  Article 12.4 of the Agreement on Safeguards, Madagascar is prepared to hold 
consultations on the provisional safeguard measure with those Members having a substantial interest 
as exporters of the products concer ned. 
7. Further information  
Requests for further information  and correspondence regarding th e investigation must be sent to: 
Monsieur Le Directeur Général de l'ANMCC  
Enceinte Ex -Conquête Antanimena, Antananarivo 101 - Madagascar  
Email : dg@anmcc.mg  / dg.anmcc@gmail.com  
Website: www.anmcc.mg  
C. NOTIFICATION UNDER  ARTI CLE 9 , FOOTN OTE 2 , OF THE AGREEMENT ON 
SAFEGUARDS  
Below is the list of developing countries excluded from the provisional safeguard measure because 
their exports represent less than 3 % of Madagascar's total imports of flour and collectively account 
for not more than 9 % (Article 9.1 of the Agreement on Safeguards).  
Afghanistan ; Albania ; Angola ; Antigua and Barbuda ; Argentina, Armenia ; Bahrain ; Bangladesh ; 
Barbados ; Belize; Benin; Bolivia, Plurinational State of ; Botswana ; Brazil; Brunei Darussalam ; 
Burkina Faso ; Burundi ; Cabo Verde ; Cambodia ; Cameroon ; Central Afric an Republic ; Chad; Chile; 
Colombia ; Congo; Costa Rica ; Côte d'Ivoire ; Cuba; Democratic Republic of the Congo ; Djibouti ; 
Dominica ; Dominican Republic ; Ecuador ; El Salvador ; Eswatini ; Fiji; Gabon; Gambia ; Georgia ; 
Ghana; Grenada ; Guatemala ; Guinea ; Guinea -Bissau ; Guyana ; Haiti; Honduras ; Indonesia ; Israel; 
Jamaica ; Jordan ; Kazakhstan ; Kenya; Kuwait ; Kyrgyz Republic ; Lao People's  Democratic Republic ; 
Lesotho ; Liberia ; Malawi; Malaysia ; Maldives ; Mali; Mauritania ; Mauritius ; Mexico; Moldova ; 
Mongolia ; Montenegro ; Morocco ; Mozambique ; Myanmar ; Namibia ; Nepal; Nicaragua ; Niger; Oman; 
Pakistan ; Panama ; Papua New Guinea ; Paraguay ; Peru; Philippines ; Qatar; Rwanda ; Saint Kitts and 
Nevis ; Saint Lucia ; Saint Vincent and the Grenadines ; Samoa ; Saudi Arabia ; Senegal ; Seychelles ; 
Sierra Leone ; Solomon Islands ; South Africa ; Sri Lanka ; Suriname ; Tajikistan ; Tanzania ; Thailand ; 
The former Yugoslav Republic of Macedonia ; Togo; Tonga; Trinidad and Tobago ; Tunisia ; Uganda ; 
Ukraine ; United Arab Emirates ; Uruguay ; Vanuatu; Venezuela, Bolivarian Republic of ; Viet Nam ; 
Yemen ; Zambia ; Zimbabwe.  
 
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