G/SG/N/8/TUR/14  
G/SG/N/10/TUR/14  
G/SG/N/11/TUR/19  
 
24 April 2014  
(14-2490)  Page: 1/13  
Committee on Safeguards 
 Original: English  
 
NOTIFICATION UNDER ARTICLE 12.1(B) OF THE AGREEMENT 
ON SAFEGUARDS ON FINDING A SERIOUS INJURY 
OR THREAT THEREOF CAUSED 
BY INCREASED IMPORTS 
 
NOTIFICATION PURSUANT TO ARTICLE 12.1(C) 
OF THE AGREEMENT ON SAFEGUARDS 
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2, 
OF THE AGREEMENT ON SAFEGUARDS 
TURKEY 
 (Terephthalic acid) 
The following communication, dated 22 April 2014, is being circulated at the request of the 
Delegation of Turkey. 
 
_______________ 
 
 
Concerning imports of terephthalic acid, Turkey had notified the initiation of a safeguard investigation with WTO Document G/SG/N/6/TUR/17, dated 15 January 2013.   
Turkey hereby provides notification to the Committee on Safeguards of findings of serious injury or 
threat thereof caused by increased imports and notification of a proposed definitive safeguard measure. The investigation report (in Turkish) together with references and sources can be found 
at following internet address: 
 http://www.ekonomi.gov.tr/u pload/1C5BA8CE-C240-FDE2-
17ECD917A78D6DF1/PTA_SORUSTURMA%20OZET%20SONUC%20RAPORU.docx  
 
Consistent with Article 12.3 of the Agreement on Safeguards , Turkey is prepared to consult with 
those Members having a substantial interest as exporters of the products concerned. 
 
1  EVIDENCE OF SERIOUS INJURY OR THREAT THEREOF CAUSED BY INCREASED IMPORTS 
1.1  Evidence of threat of serious injury 
In order to make a determination of serious injury or threat thereof to the domestic producer of 
the like product, an evaluation of all relevant fact ors of an objective and quantifiable nature having 
a bearing on the situation of the domestic industry has been undertaken. In this analysis, data 
submitted by the applicant company, which is the on ly domestic producer of the product subject to 
investigation, commercially known as purified terephthalic acid (PTA), were used. Therefore, the figures in this section are shown by indexes, exce pt those that are already publicly available, to 
maintain the confidentiality of the information provided by the applicant company. Since the 
investigation period was extended for 2 months on 8/10/2013 and later for 4 months on 8/12/2013 in line with the domestic regulations, the information below covers the 6-year period G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  from 2008 to 2013 and only relating to the PTA plan t of the domestic producer, which is one of the 
15 plants operating within the company.   1.1.1  Production 
 2008 2009 2010 2011 2012 2013 
Production (Tons) 42.303 60.207 73.668 60.269 28.645 28.112 
Year on Year Change (%) - 42 22 -18 -52 -2 
 
The production which was 42.303 tons in 2008 increased by 42% and 22% respectively in 2009 
and 2010 and reached its peak at 73.668 tons during the period under consideration. Production figure declined 18% in 2011 followed by a huge decline of 52% in 2012. The domestic producer 
ceased production activities in October 2012 until the end of that year. Production facilities 
remained idle during most of 2013 and production further declined by 2% reaching its lowest point in the period under examination with 28.112 tons . Production declined by 34% in 2013 compared 
to 2008 and 62% compared to 2010.   
 
1.1.2  Domestic Sales 
 2008 2009 2010 2011 2012 2013 
Domestic Sales 
(Tons - Indexed) 100 92 154 109 68 54 
 
Domestic sales index fluctuated between 2008 and 2013, reaching its highest point in 2010 with 
54% increase compared to 2008. Domestic sales started to decline in 2011 and this trend continued in 2012 and 2013. Domestic sales reached its lowest point in 2013 in the period under 
examination, and this level corresponds to 54% of what it was in 2008.   
 1.1.3  Capacity and Capacity Utilization Ratio (CUR) 
 2008 2009 2010 2011 2012 2013 
Capacity (Tons) 70.000 70.000 70.000 70.000 70.000 70.000 
CUR (% ) 60 86 105 86 41 40 
 Production capacity remained at 70.000 tons/year throughout the period under consideration. 
Capacity utilization ratio, on the other hand, fluctuated during the investigation period parallel with 
production level. CUR reached 105% of the capacity in 2010 when the highest level of production is also recorded. CUR declined to 86% in 2011 followed by a massive decline to 41% in 2012. CUR 
remained almost the same in 2013 compared to 2012 as production cessations occurred 
throughout the year.    
1.1.4  Stocks 
 2008 2009 2010 2011 2012 2013 
Stocks (Tons -Indexed) 100 165 24 322 4 323 
 
Stocks increased 65% in 2009 compared to 2008 and there was a major decline in 2010 when domestic sales were highest in the period under consideration. Stock index jumped to 322 points 
in 2011 followed by another major fall in 2012 reaching its lowest point in the period under 
consideration. In 2012 when the decline in produc tion was higher than the decline in domestic G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  sales, the applicant used its inventories to meet demand. Stocks reached their highest point in 
2013 when both production and sales were at their lowest.   1.1.5  Employment 
 2008 2009 2010 2011 2012 2013 
Employment (Workers – 
Index) 100 84 88 81 79 73 
 
The employment has been decreasing gradually since 2009 in the period under consideration, except 2010. There was a minor increase in the employment index in 2010 when production was 
at its highest, but employment kept declining during the rest of the period under consideration 
reaching its lowest point in 2013. Compared to the trend in production the decline in employment is moderate.     
1.1.6  Labor Productivity 
 2008 2009 2010 2011 2012 2013 
Productivity 
(Tons/Worker - Indexed) 100 170 199 175 86 90 
 
Labor productivity displayed a massive surge of 70% in 2009 compared to 2008 as production 
increased while employment declined. In 2010 productivity further increased, followed by a mild 
decrease in 2011. In 2012 a major decline was recorded in labor productivity as the production decreased substantially. Productivity improved slightly in 2013, but remained under its level in 
2008. 
 1.1.7  Profitability 
 2008 2009 2010 2011 2012 2013 
Profitability 
(% - Indexed) (-)100 (-)15 16 (-)16 (-)70 (-)108 
 
Profitability remained negative throughout the period under investigation except 2010. There was 
a rapid improvement in the profitability of th e domestic producer between 2008 and 2010. The 
profitability was positive for once in 2010. Following this year, profitability started declining 
between 2011 and 2013. In 2013 profitability reac hed its lowest point in the period under 
examination.     
1.1.8  Consumption  
 2008 2009 2010 2011 2012 2013 
Consumption 
(Tons - Indexed) 100 108 124 120 141 169 
 
The consumption index has been rising constantly du ring the period of investigation, except 2011. 
Following the mild decrease in 2011, consumption increased steadily both in 2012 and 2013. The 
highest increase was recorded in 2013, and consumption reached a level that is 69% higher than 
its level in 2008.   
1.1.9  Conclusion 
Terephthalic acid production in Turkey has been  increasing from 2008 to 2010, in 2010 production 
increased 74% compared to 2008 and capacity utilization ratio reached 105%. The production 
started decreasing in 2011. The decrease in production was drastic in 2012 with a 52% decline 
and production could not recover in 2013 further declining 2%. Capacity utilization ratio was 41% G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  and 40% respectively in 2012 and 2013. The domestic  sales of the producer also decreased in the 
same period, reaching in 2013 to 54% of its level in 2008. Furthermore, profitability and employment levels have both deteriorated between 2012 and 2013.   
Taking account of all of these factors, investigating authority concludes that the domestic industry 
is exposed to serious injury for the product subject to investigation.    
1.2  Causat ıon Analys ıs 
In order to examine the existence of a causal li nk between increased imports and the threat of 
serious injury, and in order to ensure that injury caused by other factors is not attributed to increased imports, the investigating authority analyzed the effects of the following factors: 
 
1.2.1  Analysis of Causation Factors 
a. Effect of Increased Imports 
Imports of the product subject to investigation increased constantly during the period under 
examination. In the first 3 years of the investigation period a gradual increase was recorded and imports increased by 23% from 2009 to 2011. There was a huge increase of 31% in imports from 
2011 to 2012. Imports continued to rise in 2013 and with a 24% advance from 2012 to 2013 
reaching its highest level in the period under examination. Total increase in imports between 2008 and 2013 was 101%. Therefore, it is concluded that  the increase in imports and the deterioration 
in the economic indicators of the domestic industry followed a similar pattern throughout the 
period analyzed. 
 
The unit prices of imported and domestic products  are compared in the table below. Price of the 
imported product is calculated by adding 2% cost of handling and customs clearance to the 
weighted average unit price of the imported product. To be able to compare the actual prices that users of the terephthalic acid face when domestically produced or imported terephthalic acid reach 
their production premises, domestic product price 1 is calculated by adding the difference in freight 
between the domestic and imported products to the weighted average unit price of the domestic product.   
Taking into account that the domestic producer had negative profitability throughout the 
investigation period except 2010, domestic product price 2 was constructed, by adding a reasonable level of profit and the aforementioned  freight difference to the commercial cost of the 
domestic producer.  
 
 2008 2009 2010 2011 2012 2013 
Imported Product Price (TL/Kg) 1,415 1,343 1,505 2,330 2,187 2,261  
Domestic Product Price 1 (TL/Kg) 1,408 1,375 1,457 2,261 2,264 2,353  
Domestic Product Price 2 (TL/Kg) 1,697 1,471 1,465 2,387 2,580 2,862  
Price Undercutting (%) -0,5 2,4 -3,2 -2,9 3,5 4,1  
Price Suppression (%) 19,9 9,6 -2,7 2,5 18,0 26,6  
 As seen from the price undercutting line of the table above, the imported product undercut the 
actual sales price of the domestic product except in 2008, 2010 and 2011. Price undercutting 
which was 3,5% in 2012, reached 4,1% in 2013. The imported product undercut the domestic product 2 price by larger margins. Price suppression  is 26,6% in 2013. Therefore, an evaluation of 
these figures reveals that the imported product has caused price undercutting and price 
suppression on the domestic product during the period concerned.    
 G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  b. Coinciding trends 
It is understood that there is parallelism between  the decline in the production, domestic sales, 
capacity utilization ratio, productivity, and the increase in the stocks of the domestic producer and the recent increase in the imports of the product concerned in absolute and relative terms and the 
increase in the market share of the imports. Becaus e of these evaluations, it is concluded that the 
surge in the imports of the concerned product and the threat of serious injury on its domestic 
producers are simultaneous.  
 
c. Other Factors 
i. Exports 
 2008 2009 2010 2011 2012 2013 
Exports (Tons - Indexed) 100 292 180 145 111 22 
Exports/Total Sales (%) 17 39 19 21 25 8 
 
Exports increased 192% in 2009 compared to 2008. Between 2010 and 2012 exports decreased 
steadily but in 2012 exports were  still higher than their level in  2008. In 2013 foreign sales were 
at their lowest in the period under consideration, and they were only 22% of their level in 2008  
 When the ratio of exports to total sales of the ap plicant company is analyzed, a different trend is 
visible. In 2009 exports to total sales ratio is doubled to 39% from 17% in 2008 but declined to 
19% in 2010 resembling the trend in export volume. However, in 2011 and 2012, exports to total 
sales ratio increased contrary to declining export volume. The domestic producer increased its exports relatively while struggling in the domestic market. Only in 2013 when the production and 
total sales were at their lowest point, export to total sales also dropped to its lowest level. Still the 
decrease in this ratio is lower than that the decrease in exports. Furthermore, profitability of the domestic producer was negative when its relative exports were highest in 2009 with 39%, but in 
2010 when exports to total sales were at 19%, the domestic producer had positive profits.  
 
Therefore, despite claims by some of the interested  parties, it is concluded that the changes in the 
level of exports were not a cause of the serious injury suffered by the domestic producer, and the 
decline in exports in 2013 both in absolute and relative terms is a result of the overall 
deterioration in its economic situation.   
ii. Paraxylene Sales 
It is claimed by some parties that the domestic producer decreased its PTA sales deliberately in 
order to increase its paraxylene (PX) sales, as it is more profitable. Table below provides figures 
relating to PX production of the domestic prod ucer. Figures are shown again by indexes, except 
those that are already publicly available, to maintain the confidentiality of the information provided by the applicant company. 
 2008 2009 2010 2011 2012 2013 
Capacity (Tons) 140.000 140.000 140.000 140.000 140.000 140.000  
Production (Tons) 109.102 130.706 140.167 106.935 144.684 122.544  
CUR (%) 78 93 100 76 103 88 
Total Sales (Tons - Indexed) 100 99 108 77 136 123 
Total Sales/Production (% - Indexed) 100 83 84 78 103 109 
Unit Price (TL - Indexed) 100 79 89 137 125 129 G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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PX production and sales fluctuated in the peri od under examination while capacity remained 
stable. Production and sales both reached their maximum points in 2012 when the PTA production was lower than any other year except 2013. However, in 2010 when PX production was over 
capacity on paper as it was in 2012, ratio of PX sales to production was lower than that of 2012. 
Reason for this is that the domestic producer had no difficulty selling the PTA that it produced in 2010. PTA sales were at their maximum point in 2010, therefore domestic producer did not opt to 
sell PX instead. 
  Likewise, PX sales to production ratio were at their lowest in 2011 despite unit price of PX was at its highest during the investigation period. 2011 was a year that capacity utilisation ratio in PTA 
plant was also high. The domestic producer again chose to use PX as feedstock in PTA production 
instead of selling it as a final product even when its price was high. This is reasonable as PTA price is calculated using a formula where PX price is the main component.    
 
As a result, it is concluded that domestic producer does not see PX as an alternative to PTA, and it is not reasonable to claim that it deliberate ly lowered PTA production to sell more PX.  
 
iii. Costs 
 2008 2009 2010 2011 2012 2013 
Industrial Cost  
(TL/Kg - Indexed) 100 90 92 151 158 163 
 
It is claimed by some parties that not the surge in imports but rising costs are the reason behind 
serious injury faced by the domestic producer. It is true that industrial cost of the producer increased overall by 63% during the period under consideration. Largest increase in costs were recorded in 2011, this was a result of the increase in crude oil prices. Crude oil is the primary raw 
material for the petrochemical industry and its prices have a direct effect on the costs of 
petrochemical product producers. In the case of terephthalic acid, its feedstock paraxylene is produced using naphtha, which is one of the materials that are produced when crude oil is 
cracked. Table below shows the price of the crude oil from 2008 to 2013. 
 
 2008 2009 2010 2011 2012 2013 
Crude Oil Price 
(US Dollar/Barrel) 97 62 79 104 105 104 
Year on Year Change 
(%) - -36 28 32 1 -1 
 
From 2009 to 2010 the price of oil increased 28% to 79 USD/Barrel following a 36% decline from 
2008 to 2009. The price of oil further increased 32% from 2010 to 2011 and was steady at this 
level in 2012 and 2013. The increase in oil prices which started from late 2010 and continued 
during 2011 was reflected in the cost of the domestic producer in 2011, but the increase in cost 
was limited in 2012 and 2013.   It is concluded that the rise in oil prices are the main reason of the increase in domestic producer's 
costs. On the other hand, PTA prices are calculated worldwide by adding a spread to 67% of 
paraxylene price, as it is the amount of PX needed to produce terephthalic acid. Therefore, the cost of PTA is closely related to price of PX and crude oil, and increase in one of them affects the 
costs of not only the domestic producer but all PTA producers worldwide.  
 
iv. Production Technology of Domestic Producer  
Some parties claimed that it was the old technology of the domestic producer that caused serious 
injury and not the surge in imports. The production  plant of the domestic producer was established 
in 1987, improvements were made to increase productivity and decrease costs before and during the period under examination. On the other hand, the domestic producer was able to produce PTA 
at maximum capacity and market its product co mpetitively in 2010 using the same technology. 
Besides, some of its competitors in the market that are also interested parties are using their G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  production facilities that were established in 1969 and 1991. As a result, it is concluded that the 
technology of the domestic producer did not play a part in the serious injury that it is facing.   
 
v. Capacity 
The capacity of the domestic producer remained stable throughout the investigation period. 
Capacity utilisation ratio declined significantly despite substantial increase in demand. Therefore it is concluded that capacity is not a factor that can be attributed to the serious injury faced by the 
domestic producer.  
 1.2.2  Conclusion on Causation 
Having concluded that there is a correlation between the increase in imports and the serious injury 
that the domestic industry is facing; having examined the effects of other known factors and 
having determined that no injurious effects resulted from these; the investigating authority 
reached the conclusion that there is a genuine and substantial causal link between increased 
imports and serious injury that the domestic industry is exposed to. 
 2  INFORMATION ON WHETHER THERE IS AN ABSOLUTE INCREASE IN IMPORTS OR AN 
INCREASE IN IMPORTS RELATIVE TO DOMESTIC PRODUCTION  
2.1  Unforeseen developments This analysis on unforeseen development is carried out during the investigation to find out which 
issues, that were unforeseen while the concessions at the WTO were made, have caused a sharp 
and significant increase in the imports. The bo und tariffs of the product concerned are 13% for 
Turkey and the maximum applied rate is 6.5%. The applied tariffs on this product are significantly low and will be lower than the bound tariffs even with the imposition of the proposed measure.  
 
2.1.1  PTA Supply and Demand in the European Market 
Financial and economic crisis that broke out in 2008 affected European economy. A slowdown has 
been visible in European Union countries and in European economy as a whole. The slowdown 
which is still palpable has also affected the PTA market.  
 
 The graph above shows the PTA supply and demand in Western Europe. Production, which was 
2,4 million tons in 2007 declined to 1,9 million tons in 2008, and continued to decline in 2009. In 
2010, production returned to its level in 2007 and remained at that level in throughout 2011 and 2012.   
On the other hand, Western Europe PTA consumpt ion which was 2 million tons in 2007 declined 
steadily between 2008 and 2011 regressing to 1,65 million tons. Consumption recovered a bit in 2012 reaching 1,7 million tons, but could not reach its level in 2007 or 2008.  05001000150020002500300035004000
2007 2008 2009 2010 2011 2012Thousand Tons
YearsPTA Supply and Demand in Western Europe
Net Exports
Total Capacity
Production
ConsumptionG/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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Capacity in Western Europe, advanced between 2007-2012 except 2009, increasing 17,7% in 2012 reaching 3,7 million tons. Net exports which were relatively low between 2008 and 2009, increased 920% in 2010 reaching 735 thousand tons when domestic consumption was at its lowest 
point. Exports reached their maximum point in 2011 with 928 thousand tons, only declining 
slightly in 2012 to 872 thousand tons.   
In the table below, data relating to exports of te rephthalic acid and its salts which are classified 
under 2917.36.00 combined nomenclature code from European Union is shown. The table has data for 2008-2012 period, as there is no data on EUROSTAT for the year of 2013.   
2917.36.00 – EU27 Exports (By Importing Country) (Tons) 
2008 2009 2010 2011 2012 
EU 27 Total Exports 59.302  42.355  101.869  358.363 726.816  
Oman 41.933 236.930  
Turkey 37.988  40.218  56.339  144.953 211.862  
Russia 4.026  35.820 114.634  
UAE 35  17.016 75.290  
China 43  24 27.039 23.010  
Belarus 1.560  33.626  15.808 22.427  
India 0  0 2.024 11.352  
Others 13.244  624 7.909  71.775 31.340  
  
EU27 Exports 
Year on Year Change (%) -68  -29 141 252 103  
EU27 Exports to Turkey  
Year on Year Change (%) -71  6 40 157 46  
Exports to Turkey  /EU27 Exports (%) 64
 95 55 40 29  
 
EU27 exports which declined 28% from 2008 to 2009, increased 141% from 2009 to 2010, 252% 
from 2010 to 2011 and 103% from 2011 to 2012. As a result, exports which were 59 thousand tons in 2008 reached 727 thousand tons in 2012 with a total increase of 1125%. During 2010-
2012 exports to Turkey increased by 40%, 157% and 46% respectively. Share of exports to 
Turkey in total EU27 exports were 40% in 2011 and 29% in 2012, making Turkey EU27's largest 
export market in 2011-2012 combined.  
As a result, it is concluded that difference between production and consumption got bigger 
between 2008 and 2010 and producers increased th eir exports following 2010, and Turkey was the 
primary market that these exports were channe lled when 2011 and 2012 are considered together. 
 
2.1.2  Developments in Chinese PTA Market 
PTA producers in China have been expanding their capacity rapidly as PTA demand was increasing 
together with increasing profits. Capacity which was 19 million tons in 2011 increased to 26 million 
tons in 2012. It is predicted that Chinese PTA supply will increase to 39 million tons in 2015 doubling what it was in 2011.     
Chinese imports of PTA which was 5,4 million tons fell to 4,2 million tons in 2012 due to 
impressive increase in domestic PTA capacity in the last years, especially in 2012. The decline in Chinese PTA imports continued in 2013 as imports fell down to 2,1 million tons. The table below 
provides data on Chinese PTA imports between 2008 and 2013. G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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PTA Imports of China (Tons) 
 2008 2009 2010 2011 2012 2013 2013 
(%) 
World 4.978.084 5.080.298 5.402.249 5.377.463 4.194.897 2.136.533 100  
South Korea 2.403.268 2.153.798 2.038.747 1.920.066 1.581.648 1.213.156 56,78  
Chinese Taipei 1.725.905 1.902.173 2.501.133 2.686.742 1.785.041 415.691 19,46  
Thailand 588.273 626.451 630.968 575.827 552.602 233.984 10,95  
Malaysia 22.869 37.374 7.541 5.707 88.022 109.237 5,11  
Japan 117.221 178.211 182.623 119.923 86.520 104.321 4,88  
Indonesia 10.355 19.160 20.976 32.802 52.165 39.359 1,84  
Poland 0 0 0 5.914 38.984 12.364 0,58  
Iran  52.085 9.800 2.000 1.000 680 3.558 0,17  
India 0 36 187 143 0 3.454 0,16  
UAE 0 0 0 0 0 1.000 0,05  
Brazil 0 0 0 0 0 220 0,01  
Saudi Arabia 41.257 95.191 6.300 426 381 178 0,01  
Belgium 0 4.425 0 0 78 9 0,00  
 
In 2013, China's PTA imports decreased to the lowest level observed in the investigation period. 
On the other hand, in 2013, 87% of China's PTA imports came from South Korea, Taiwan and Thailand. Within the last six years, EU's PTA exports to China remained at notably low levels. In 
the last column, each supplier's imports is rated to China's overall imports. Imports from two 
European countries that are listed comprise less than 1% of all Chinese PTA imports. While imports Poland comprises less than 0,6% of China's total imports, Belgium exports to China are near-zero.  
 
On the other hand, although Poland's share in China's total imports is less than 1% in 2012, Poland's PTA exports to China, which was about 39 thousand tons in 2012, decreased to 12 thousand tons in 2013. In the same period, Turkey's PTA imports of Poland origin increased 
from 36 thousand tons in 2012 to 41 thousand tons in 2013. 
 In the light of this data, the argument that the European companies has diverged to Turkish 
market due to the market shrinkage and increasing ca pacity in China, is regarded as acceptable to 
some extent.  
2.1.3  PTA Plants Established in Portugal and Poland 
Plants in Portugal and Poland have started PTA production in March 2012 and May 2011, 
respectively. The construction of the mentioned facilities in Portugal and Poland had started in March 2008 and July 2008. The investment decision of the facility in Poland had been made in 
2003, and at that time the investor company had anticipated that the demand of PTA in Europe 
would increase approximately by 6% annually between 2003 and 2010. Increase in demand for 
PET bottles in Poland is also regarded as one of the reasons for the launch of this facility. Plant in 
Portugal was planned to export 95% of its product. 
  T h e  s t a r t  o f  i n v e s t m e n t  o f  b o t h  f a c i l i t i e s  f e l l  o n  a  t i m e  o f  d e c r e a s e  i n  P T A  d e m a n d  i n  E u r o p e ,  
especially the one in Portugal had to begin its PTA production when European PTA and PET 
demand fell, and it was speculated by analysts that it "could not have picked a worse time to come on-stream" and "is desperately looking for customers."  
The table below shows PTA exports of EU broken do wn by member states. As there is no data on 
EUROSTAT for the year of 2013, the table has da ta from 2008 to 2012. As can be seen from the 
table, exportation from Poland and Portugal has star ted right after the activation of the facilities in 
those countries. Polish firm's exports to Turkey constituted 26% of its total sales in 2011 and 40% 
of its total sales in 2012. G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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As being located relatively close to Turkey, these two PTA facilities in Portugal and Poland with 
700.000 ton/year and 600.000 ton/year capacities respectively have assisted to the surge in PTA 
exports from Europe to Turkey.   2.1.4  Increase in Turkish PTA Demand  
There has been a significant demand increase in downstream products in which PTA is used as 
feedstock. Increase in demand is generally favourable for the domestic producer. But the domestic producer could not benefit from the increasing demand in 2012 and 2013, demand was met by 
increasing imports and the producer had to cease operation several times during these two years. 
Market share of imports were close to its level in 2008 between 2009 and 2011, but have increased by 14% and 19% in 2012 and 2013 respectively.   
 
2.1.5  Conclusion on Unforeseen Developments 
In the light of evaluations above, it is conclude d that the sharp, sudden, significant and recent 
increase in imports of PTA during the investigation period resulted from unforeseen developments 
in the last three years. These developments were: increasing production capacity in Europe and 
decreasing consumption despite predictions on the contrary; the search for export markets of newly established plants in Europe, some of which were planned to meet domestic demand 
originally, that were struggling in the domestic market; the decline in European exports to Chinese 
market as PTA imports of China declined; the 7 fold increase in European exports from 2010 to 2012; Turkey, as a close market and with large PTA demand, becoming the main target in for the 
European exports that increased 7 times as taking  40% and 29% of these exports respectively in 
2011 and 2012.   2.2  ıncrease ın ımports 
An analysis of the increase in imports of the product concerned to Turkey both in absolute and 
relative terms has been carried out over the period from 2008 to 2013. Imports of the product concerned increased considerably, both in absolute terms and relative to domestic production, 
during the period of investigation. 
 2.2.1  Absolute Imports 
 2008 2009 2010 2011 2012 2013 
Imports (Tons) 143.769 161.387 166.752 177.169 231.921 288.717 
Year on Year Change (%) - 12 3 6 31 24 
 
Imports of the product subject to investigation increased constantly during the period under 
examination. The imports which were 143.769 tons in 2008, gradually increased by 12%, 3% and 2917.36.00 -  EU27 Exports (By Exporting Member) (Tons) 
2008 2009 2010 2011 2012 
EU 27 Total Exports 59.302  42.355  101.869  358.363 726.816  
Belgium 245.097 369.525  
Poland 21 88.476 194.787  
Portugal 106.340  
UK 13.948  5.903  25.729  21.679 48.104  
Lithuania 43  13.428  3.085 7.669  
Germany 1  1 25 391  
Others 45.354  36.408  62.691    G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  6% between 2009 and 2011 reaching to 177.169 tons in 2011. From 2011 to 2012 the imports 
surged significantly with a 31% increase reaching 231.921 tons. Escalated rate of increase in imports continued in 2013 with 24% increase from 2012 to 2013, bringing imports to its highest level with 288.717 tons. Total increase in im ports between 2008 and 2013 is 101% during the 
period under examination, and 63% of this in crease was recorded in 2012 and 2013 together 
compared to 2011.  
2.2.2  Relative Imports 
 2008 2009 2010 2011 2012 2013 
Imports/Production (%) 340 268 226 294 810 1.027 
 
Imports have been at least twice the amount of production throughout the period under 
consideration. Between 2008 and 2010 the ratio of imports to domestic production declined as the 
production quantity of the domestic producer increased while imports rose mildly. Starting with 
2011 this trend changed course as imports to domestic production ratio started increasing. In 2012 when the highest increase in imports and deterioration in domestic production was recorded, 
there was a massive increase in imports relative to domestic production with this figure reaching 
810%. This trend continued in 2013 as well, imports to domestic production ratio was at its highest point in the period under examination as imports were 10 times the amount of domestic 
production. 
 2.2.3  Market Share of Imports 
 2008 2009 2010 2011 2012 2013 
Market Share of Imports 
(% – Indexed) 100 104 93 103 114 119 
 
In 2008 imports were already taking a large share of the domestic market. Between 2008 and 
2010 there was a mild increase in the market shar e of the domestic producer, as production was 
over capacity and domestic sales increased. Star ting with 2011 imported products increased their 
market share reaching above their level in 2008. Upward trend in market share of imports 
continued in 2012 and 2013, compared with its value in 2008, the market share index of imports rose almost 19% in 6 years. 
 
2.2.4  Share of Main Exporters 
The share of imports from the main exporters to the Turkish market is shown at the table below. 
The countries are sorted according to their share in imports in 2013.  
 
Countries (%) 2008 2009 2010 2011 2012 2013 
Spain 34 34  37 39 24 22  
Belgium 9 30  37 33 27 21  
South Korea 4 9  3 3 1 19  
Portugal 0 0  0 0 16 17  
Poland 0 0  0 13 16 14  
Thailand 11 17  12 4 6 3  
Brazil 0 0  0 0 0 1  
UK 6 6  10 3 8 1  G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  Countries (%) 2008 2009 2010 2011 2012 2013 
Iran 0 0  0 0 0 1  
Others 37 5  0 4 2 1  
 
Spain has been the biggest supplier of the Turkish market during the investigation period, except 
2010 when Belgium was the first provider. These countries together accounted for close to half of 
the market throughout the 6 year span while surpassing 50% share in some years. Saudi Arabia and the US who had together close to 35% share in imports in 2008 lost their market share in the 
following years. Poland and Portugal, who had zero shares among imports until 2011 and 2012 
respectively, accrued significant shares following their entrance into the Turkish market. Portugal's market share was 17% Poland's was 14% in 2013. South Korea had a rather small market share 
between 2008 and 2012. With the entry into force of the Turkey-South Korea free trade 
agreement in 2013, imports from this country increased significantly, resulting with a share of 19% among imports. Thailand and the UK who ha ve been traditional suppliers between 2008 and 
2012 lost their market shares in 2013. 
   
3  PRECISE DESCRIPTION OF THE PRODUCT INVOLVED 
The product involved is "terephthalic acid." The pr oduct subject to measure is currently classified 
under 2917.36.00.00.11 tariff code in the Turkish Customs Tariff Schedule. 
 4  DESCRIPTION OF THE PROPOSED MEASURE 
The imposition of a definitive safeguard measure is  proposed in the form of a variable duty, which 
will be implemented as shown in the table below. 
 
Turkish Customs Tariff Code Description Of The Product 1st Period 2nd Period 
2917.36.00.00.11 Terephthalic acid 4% 3,75% 
 
On the other hand, implementation of a tariff quota is considered to allow imports of a certain level 
exempt from the safeguard measure. The quantity of the tariff quota, which will be in effect during 
the duration of the safeguard measure, will be dete rmined later and will be published together with 
the Decision of the Council of Ministers regarding the safeguard measure. 
 
Below is the list of Developing Countries excluded from the measures as they export less than 3% 
of imports to Turkey. 
 Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Azerbaijan, Bangladesh, 
Barbados, Belarus, Belize, Benin,  Bhutan, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, 
Burkina Faso, Burundi, Cambodia, Cameroon, Cape Verde, Central African Republic, Chad, Chile, 
China, Colombia, Comoros, Congo,  Cook Islands, Costa Rica, Cote d'Ivoire, Cuba, Democratic 
People's Republic of Korea, Democratic Republic of Congo, Djibouti, Dominica, Dominican Republic, 
Ecuador, Egypt, El Salvador, Equatorial Guinea, Eritrea, Ethiopia, Fiji, Gabon, Gambia, Georgia, 
Ghana, Grenada, Guatemala, Guinea, Guinea-Bissa u, Guyana, Haiti, Honduras, India, Indonesia, 
Iran, Iraq, 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, Morocco, Mozambique, Myanmar, Namibia, Nauru, Nepal, Nicaragua, Niger, Nigeria, Niue, 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, So malia, South Africa, South Sudan, Sri Lanka, 
St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Sudan, Suriname, Swaziland, 
Tajikistan, Tanzania, Thailand, Timor Leste, Togo, Tonga, Trinidad and Tobago, Tunisia, 
Turkmenistan, Tuvalu, Uganda, Ukraine, Uruguay, Uzbekistan, Vanuatu, Venezuela, Vietnam, West 
Bank and Gaza Strip, Yemen, Zambia, Zimbabwe. 
 G/SG/N/8/TUR/14 • G/SG/N/10/TUR/14 • G/SG/N/11/TUR/19 
 
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  5  PROPOSED DATE OF INTRODUCTION OF THE MEASURE 
The measure will come into effect after the appr oval of the Council of Ministers. The date of 
introduction of the measure will be provided in the Decision of the Council of Ministers which will be the published after all legal procedures are completed. 
 
6  EXPECTED DURATION OF THE MEASURE 
The expected duration of the proposed measure is two years. 
  
7  PROPOSED DATE FOR THE REVIEW  
Not applicable. 
 
8  EXPECTED TIMETABLE FOR PROGRESSIVE LIBERALIZATION OF THE MEASURE 
In order to induce adjustment, the proposed measure will be subject to liberalization on a regular 
basis following its imposition, thereby ensuring that there is a strong incentive for domestic 
producers to undertake progressively the necessa ry restructuring and adjustment programs. The 
proposed measure is to be progressively liberalized as indicated in item 4 above.  
9  INFORMATION RELATING TO THE EXTENSION OF A SAFEGUARD MEASURE 
Not applicable. 
  
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