G/SG/N/8/TUR/16  
G/SG/N/10/TUR/16  
G/SG/N/11/T UR/22  
19 October  2017 
(17-5643) Page: 1/6 
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, FOOTNO TE 2 
OF THE AGREEMENT ON SAFEGUARDS  
TURKEY 
(Toothbrushes ) 
The following notification, dated 17 October 2 017, is being circulated at the request of the 
Delegation of Turkey.  
 
_______________  
 
 
 Concerning imports of toothbrushes, Turkey had notified the ini tiation of a safeguard 
investigation with the WTO Document G/SG/N/6/TUR/23, dated 3 May 2017.  
 
 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 public version of the investigation report (in Turkish) together with 
references and sources can be found at the followings internet address  (Tebliğ No:2017/10) . 
 
 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 product concerned.  
 
I. EVIDENCE OF SERIOUS INJ URY OR THREAT THEREO F CAUSED BY INCREASE D 
IMPORTS  
A. EVIDENCE 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 factors of an  objective and quantifiable 
nature having a bearing on the situation of the domestic industry has been undertaken. Data, 
submitted by the applicant companies and utilized in this analysis, represent 97 % share of the 
total domestic production of the product  subject to investigation.  
 
1. Consumption  
Unit 2013  2014  2015  2016  
Consumption (Indexed)  100 122 134 148 
 G/SG/N/8/TUR/16 • G/SG/N/10/TUR/16 • G/SG/N/11/TUR/22  
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  Consumption index has been rising constantly during the period under consideration. 
Consumption reached its peak in 2016 with a level that is 48% higher than its level in 2013.  
 
2. Production  
Unit 2013  2014  2015  2016  
Production (Indexed)  100 142 113 113 
 
 Having risen by 42% in 2014, production index declined significantly in 2015 and kept this 
level in 2016.  
 
3. Domestic Sales  
Unit 2013  2014  2015  2016  
Domestic Sales (Indexed)  100 143 119 112 
 
 Domestic sales index reached to 143 as its highest point in during the period under 
consideration. Consequently, domestic sales decreased dramatically in 2015 and it declined further 
in 2016.  
 
4. Capacity and Capacity Utilization Ratio (CUR)  
Unit 2013  2014  2015  2016  
Capacity (Indexed)  100 100 100 100 
CUR (Indexed) (%)  100 142 113 113 
 
 Production capacity remained unchanged throughout the period. Capacity utilization ratio 
(CUR) index, reached its peak a t 142 points in 2014, declined to 113 points in 2015 and 2016.  
 
5 Stocks  
Unit 2013  2014  2015  2016  
Stocks (Indexed)  0 100 87 144 
 
 At the end of investigation period stocks increased to 144 points in 2016. In general, stocks 
indicator followed a fluctuati ng course during the period under investigation.  
 
6. Employment  
Workers  2013  2014  2015  2016  
Employment (Indexed)  100 116 112 131 
 
 Employment index showed a fluctuating pattern throughout the period under consideration. 
While there was a decline in emplo yment in 2015, the index reached its peak in 2016.  
 
7. Labor Productivity  
Unit/Workers  2013  2014  2015  2016  
Productivity (Indexed)  100 122 101 87 
 
 Labor productivity index displayed a surge of 22 points in 2014 harmoniously with 
production increase. Howe ver, in 2015 productivity ratio started to decrease and declined 
to 87 points in 2016 that is the lowest level of the period.  G/SG/N/8/TUR/16 • G/SG/N/10/TUR/16 • G/SG/N/11/TUR/22  
- 3 - 
  8. Profitability  
 2013  2014  2015  2016  
Profitability (Indexed) (%)  100 63 86 81 
 
 Even if profitability fluctuated throughout the  investigation period, there was a sharp decline 
to 63 points in 2014. The data showed that profitability had a partial recovery in 2015 compared to 
the previous year. However in 2016 index decreased to 81 points.  
 
9. Conclusion  
 Toothbrushes production ha s been decreasing as consumption has been increasing during 
the period under consideration. The production capacity of producers remained stable.  
 
 Furthermore, capacity utilization ratio was 142 and 113 points in 2014 and 2015 
respectively and remained un changed in 2016. Having fluctuated throughout the investigation 
period, domestic sales of the producer reached to 143 points  in 2014 while it decreased to 119 in 
2015 and declined further to 112 in 2016. On the other hand, profitability index has deteriora ted 
significantly in 2014 and 2016.  
 
Taking into account all these factors, it is concluded that the domestic industry as a whole is 
exposed to serious injury for the product subject to investigation.  
 
B. Causatıon Analysıs  
In order to examine the existence of a causal link between increased imports and the 
serious injury and in order to ensure that injury caused by other factors is not attributed to 
increased imports, the investigating authority analy sed the effects of the following factors:  
 
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 2 years of the investigation peri od, a gradual increase was recorded and 
imports increased by 16 % from 2013 to 2014. It continued to increase by about 19 % between 
2014 and 2015. The increase by 14 % was seen in imports from 2015 and 2016. So the total 
imports of toothbrushes rose significa ntly by 58 % from the beginning to the end of the period 
under consideration.  
 
 Besides, market share of imports was about 77,8 %-83,22 % between 2013 and 2016. 
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 analy zed. Also 
the pattern of the increase in imports coincided with the deterioration in the economic indicators . 
 
On the other hand, the unit prices of imported and domestic  products are compared with a 
view to assess the conditions of competition in the domestic market.  
 
 2013  2014  2015  2016  
Price Undercutting (Indexed) (%)  100 33 28 67 
Price Suppression (Indexed) (%)  100 27 19 42 
 
 As can be seen from the table above, th e imported product undercut the sales price of the 
domestic product constantly during the period  analy zed. The indexed price undercu tting which was 
100 in 2013, reached to the level at 33 points in 2014. It is seen that the unit prices of imported 
products  continued to undercut the unit prices of domestic products. Therefore, an evaluation of 
these figures reveals that the imported products have caused price undercutting on the domestic 
products during the period concerned.  G/SG/N/8/TUR/16 • G/SG/N/10/TUR/16 • G/SG/N/11/TUR/22  
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   Besides, when the indexed price suppression was taken into account, it is seen that the 
index was 100 in 2013 and fluctuated in the following years under examination. In the last year of 
period under examination, the indexed price suppression stood at 42 points.  
 
For the foregoing reason s, it is concluded that there is a correlation between the increase in 
imports and the serious injury that the domestic industry is exposed to.  
(b) Coinciding Trends  
It is understood that there is parallelism between the all relevant factors of an objectiv e and 
quantifiable nature having a bearing on the situation of the domestic industry such as the  decline 
in the profitability, the increase in the stocks of the domestic producer and the evaluations of the 
recent increase in the imports of the product conc erned in absolute and relative terms and the 
increase in the market share of the imports.  
Moreover, the applicant companies could not increase its capacity due to the constraining 
imports despite the fact that there was a capacity stability in the period o f 2013 and 2016. For 
instance, while the imports increased significantly, the production decreased harmoniously with 
the capacity utilization ratio in the investigation period.  
Because of these evaluations, it is concluded that the surge in the imports of the concerned 
product and the serious injury on its domestic producers are simultaneous.  
(c) Other Factors  
(i) Exports  
Unit 2013  2014  2015  2016  
Exports (Indexed)  100 97 143 106 
 
Exports increased 43 % in 2015 compared to 2013. Between 2015 and 2016 export s 
decreased but when the general trend is taken into consideration, export level slightly increased 
as 6% in comparison with the base year of 2013.  
 
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 serious injury suffered by the domestic producer.  
 
(ii) Production Technology of Domestic Producer  
Some parties claimed that the domestic producers could not compete with imported 
products in terms of quality. However, on spo t investigation showed that the machines that have 
been used by applicant company in the process of the production are identical with the machines 
of the exporter companies and also that the applicant company has the recent technology that it is 
sufficient  for producing all qualities of toothbrushes. Also, the quality of the products of domestic 
producer is confirmed by national and especially global -scale firms which examine frequently the 
quality of products every year.  
 
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.  
 
2. Conclusion on Causation  
 As seen from the non -confidential summary of the application, due to the increasing imports 
and price suppression, most of the  economic indicators like sales, market share, share of import in 
domestic production have progress in negative way.  
 
Considering the market size rates of increase and quantities reveals that significant increase 
in imports in the last four years of the in vestigation period 2013 and 2016 that reached  58%. 
 G/SG/N/8/TUR/16 • G/SG/N/10/TUR/16 • G/SG/N/11/TUR/22  
- 5 - 
   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 det ermined that no injurious effects resulted from these; the investigating authority 
reached to the conclusion that there is a causal link between increased imports and serious injury 
that the domestic industry is exposed to.  
 
3. Unforeseen Developments -Deve lopments in Other Markets  
In many eastern and far eastern countries with high population and low income, there have 
been significant increases in income levels in recent years. This includes dental care, personal 
care, etc. It has been emphasized that the countries concerned have increased both consumption 
and production capacity very seriously.  
 
As a result of that, it has been claimed that multi -national global companies which had once 
been producing toothbrushes in high -income countries started to either  produce in or supply from 
those above -mentioned countries in order to benefit from both cheap cost level and easy access to 
the markets with high demand.  
 
Considering the fact that continuously increasing production in developing supplier countries 
and th eir low raw material and labor cost levels have paved the way for increase in imports of 
toothbrushes into Turkey; thus domestic producers which could once compete with those 
producers in developed countries had to face with huge suppliers in a very short span of time.  
 
In the light of the above evaluations, it is considered that the unforeseen recent 
developments in world market have negatively affected the import trend of toothbrushes into 
Turkey in the investigation period.  
 
II. PRECISE DESCRIPTION OF TH E PRODUCT INVOLVED  
The subject goods are classified under Turkish Customs Codes 9603.21.00.00.00 with the 
definition of "Tooth Brushes, Including Dental -plate Brushes" in Turkish Customs Tariff Schedule 
of 2017.  
 
III. DESCRIPTION OF THE P ROPOSED MEASURE  
The imposition of a definitive safeguard measure is proposed in the form of specific duty per 
unit, which will be implemented as shown in the table below.  
 
Customs Tariff 
Statistics Code  Product  
Description  PROPOSED MEASURE  
1st Period  2nd Period  3rd Perio d 
9603.21.00.00.00  Toothbrushes  0.23 
US$ / per unit  0.22 
US$ / per unit  0.21 
US$ / per unit  
 
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 tari ff quota, which will be in 
effect during the duration of the safeguard measure, will be determined later and will be published 
together with the Decision of the Council of Ministers regarding the safeguard measure.  
 
Below is the list of Developing Countrie s excluded from the measures as they export less 
than 3% of imports to Turkey.  
 
Afghanistan, Albania, Angola, Bangladesh, Benin, Bolivia, Bosnia and Herzegovina, Burkina 
Faso, Burundi, Butane, Cambodia, Cape Verde, Central African Republic, Chad, Chile, Co moros, 
Cook Islands, Cote d'Ivoire, Djibouti, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Gambia, Georgia, 
Ghana, Guinea, Guinea -Bissau, Haiti, Indonesia, Jordan, Kenya, Kiribati, Kongo, Kongo Democratic 
Republic, Kosovo, Kyrgyzstan, Lao People's Democrat ic Republic, Lesotho, Liberia, Macedonia, 
Madagascar, Malawi, Malaysia, Mauritania, Mauritius, Micronesia (Federated States of), Moldova, 
Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Nauru, Nepal, Niger, Nigeria, Niue, 
Pakistan, Paraguay, Philippine s, Rwanda, Samoa, Sao Tome ve Principe, Senegal, Serbia, Sierra G/SG/N/8/TUR/16 • G/SG/N/10/TUR/16 • G/SG/N/11/TUR/22  
- 6 - 
  Leone, Solomon Islands, Somalia, South Sudan, Sri Lanka, Sudan, Swaziland, Tajikistan, 
Tanzania, Timor -Leste, Togo, Tonga, Tunisia, Tuvalu, Uganda, Ukr aine, Uzbekistan, Vanuatu, 
West Bank and Gaza Strip, Yemen, Zambia  
 
IV. PROPOSED DATE OF INT RODUCTION OF THE MEA SURE  
 The measure will take effect with the approval of the Council of Ministers. The date of 
introduction of the measure will be provided in the Decision of the Council of Ministers wh ich will 
be the published after all legal procedures are completed.  
 
V. EXPECTED DURATION OF  THE MEASURE  
 The expected duration of the proposed measure is three years.  
 
VI. PROPOSED DATE FOR TH E REVIEW  
 Not applicable.  
 
VII. EXPECTED TIMETABLE F OR PROGRESS IVE LIBERALIZATION O F 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 prog ressively the necessary restructuring and adjustment programs. The 
proposed measure is to be progressively liberalized as indicated in item III above.  
 
VIII.  INFORMATION RELATING  TO THE EXTENSION OF A SAFEGUARD MEASURE  
 Not applicable.  
 
__________