WORLD TRADE  
ORGANIZATION  G/SG/N/8/TUR/5 
G/SG/N/10/TUR/5 
G/SG/N/11/TUR/5 
12 July 2006 
 (06-3372) 
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 
 
(Salt)
 
  The following notification, dated 11 July 2006, is being circulated at the request of the Delegation of Turkey. 
 
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  In light of the agreed format for notifications (G/SG/W/1, 23 February 1995), Turkey 
provides notification to the Committee on Safeguards of  findings of serious injury or threat thereof 
caused by increased imports and notification of proposed safeguard measures.   On 5 January 2006, Turkey initiated an inves tigation relating to serious injury or threat 
thereof to domestic producers of products like or di rectly competing with the imported product.  The 
initiation of the investigation has been  notified to the Committee on Safeguards.
1  
  Consistent with Article 12.3 of the Agreement on Safeguards , Turkey is prepared to consult 
with those Members having a substantial inte rest as exporters of the product concerned. 
   I. EVIDENCE OF SERIOUS INJURY OR THREAT THEREOF CAUSED BY 
INCREASED IMPORTS 
A. EVIDENCE
 OF SERIOUS  INJURY 
 In order to make a determination of serious in jury to the domestic industry of the like product, 
an evaluation of all relevant factors of an objec tive and quantifiable nature having a bearing on the 
situation of the industry has been undertaken.  Th e petitioner is the only company that produces the 
product under investigation, and accounts for 90% of  the domestic production.  Hence, the following 
evaluation has been based upon data prov ided by the applicant company.   
                                                      
1 G/SG/N/6/TUR/7 G/SG/N/8/TUR/5 
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  1. Consumption 
 2000 2001 2002 2003 2004 2005 
Consumption (Quantity- 
Index: 2000=100) 100 104 122 116 120 114 
 
Consumption index of the produc t concerned fluctuated during the period under investigation. 
The index increased by %14 between the years 2000 and 2005. 
 
2. Capacity and capacity utilization 
 2000 2001 2002 2003 2004 2005 
Capacity  
(Quantity-Index: 2000=100) 100 100 112 112 112 112 
Capacity Utilization 
(%-Index: 2000=100) 100 91 101 98 93 69 
 
Production capacity index of the domestic producer  increased by 12% in 2002.  It remained 
stable in the following years. 
 
Capacity utilization index fell in 2001 from 100 to 91, and then reached 101 in 2002.  The 
index fell from 101 to 69 between the years 2002 and 2005 with a continuous decrease.  Fall in the 
index in 2005 was 25%.   3. Production 
 2000 2001 2002 2003 2004 2005 
Production (Quantity- 
Index: 2000=100) 100 91 112 109 104 78 
 
 Production index fell from 100 to 91 in 2001, and then reached  112 in 2002.  The index fell 
from 112 to 78 between the years 2002 and 2005 with a continuous decrease. The fall was by 25% in 
2005. 
  4. Employment 
 2000 2001 2002 2003 2004 2005 
Employment (End of 
Period-Index: 2000=100) 100 93 97 76 74 63 
 
 Employment index in relation to the product concerned fell by 7% in 2001, and then 
increased by 4% in 2002.  Between the years 2002 and 2005, the index decreased from 97 to 63, the 
lowest level for the period under examination. 
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  5. Domestic sales volume 
 2000 2001 2002 2003 2004 2005 
Domestic Sales (Quantity-
Index: 2000=100) 100 105 120 107 106 97 
 
 Domestic sales index of the product concer ned increased by 5% in 2001 and 14% in 2002.  
However, sales fell by 19% between the years 2002 and 2005.   
 6. Market share 
 2000 2001 2002 2003 2004 2005 
Market Share (%-
Index: 2000=100) 100 101 98 92 88 86 
 
 Domestic producer’s market share index increased slightly in 2001.  Thereafter, it fell by 3%, 6%, and 4% in 2002, 2003and 2004 respectively, as imports increased substantially.  In 2005 the 
index decreased by 2% to reach its lowest  level for the period under examination.  
 
7. Price of the like product and undercutting 
 2000 2001 2002 2003 2004 2005 
Price Undercutting (%)  - - - - 3 28 
 
Based on a comparison of average price of dom estic and imported products to consumers, 
domestic prices were undercut by  3% in 2004 and 28% in 2005. 
 
8. Profitability 
 2000 2001 2002 2003 2004 2005 
Net profit/loss (%) 0,89 0,41 0,68 0,16 3,97 -10,19 
 
Yearly profitability ratios of the domestic producer remained under 1 % between 2000 and 
2003.  Despite a profit rate by 3,97% in 2004, year ly profitability ratio sharply fell to –10,19% in 
2005 as a result of decrease in domestic sales of the producer.  G/SG/N/8/TUR/5 
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  9. Stocks 
 
2000 2001 2002 2003 2004 2005 
Closing stocks 
(Quantity-Index: 2000=100) 100 87 80 82 80 65 
  
Stocks level index fell by 13% in 2001 and 8% in 2002. After a slight increase in 2003, it 
decreased again in the following years.  The substant ial fall in the index in 2005 was realized due to 
the fact that the producer had to meet the demands of domestic market from its stocks as its production sharply decreased.  
10. Productivity 
 2000 2001 2002 2003 2004 2005 
Productivity 
(Ton/Employee) 2.071 2.008 2.403 2.975 2.898 2.544 
 
Productivity in relation to the product concerned slightly decreased in 2001.  Thereafter, it 
increased by 20% in 2002 and 24% in 2003. Between  2003 and 2005 it fell by an annual average of 
7%. The productivity in 2005 is 23% more than that in 2000.  
 
11. Conclusion 
 The data shows negative developments for capacity utilization rate, production, domestic 
sales, market share, employment and profitability in the period under consideration. Particularly, 
profitability shows up a drastic downward trend at th e end of the period with a yearly loss over 10%. 
 
 In the period under investigation, imports ha ve increased from 25,733 tons in 2000 to 332,985 
tons in 2005, which means a 1194% increase in the level of imports.  It is noteworthy that the 
domestic sales of the producer decreased by 8.5% , as imports increased by 9% in the year 2005 
compared to the year 2004.  The domestic industry has lost market share, which reached its lowest 
level in 2005.  Moreover, as a result of the downward trend in import prices, domestic prices were 
undercut by 28% in 2005. 
  Taking account of all of these factors investigating authority concludes that the domestic industry has suffered serious injury.    
B. C
AUSATION ANALYSIS  
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 analyzed the effects of the following factors: 
 
1. Analysis of causation factors 
- Effect of increased imports:  G/SG/N/8/TUR/5 
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  Imports have increased from 25.733 tons in  2000 to 332.985 tons in 2005, which means a 
1194% increase in the level of imports.  In addition, the market shares index of imports increased by 
169%, 49% and 15% in 2003, 2004 and 2005, respectively.  As a result of the continuous decrease in 
prices of imported goods, domestic prices were  undercut by 3% in 2004 and 28% in 2005. 
 For the foregoing reasons, the investigating aut hority concludes that there is a correlation 
between the increase in imports and the serious inju ry suffered by the domestic producers, and that the 
increase in low priced imports has had inju rious effects on the domestic producers. 
 
- Other factors 
 
(a)  Effect of changes in consumption:  Demand for the product concerned has not decreased 
over the period under consideration. 
 
(b)  Effects of competition between the domestic  producers:  Competition in domestic market 
has not created an injurious effect.   
(c)  Changes in production technology: Th e production technology used by the domestic 
industry is same with the technology used by foreign producers. 
 
(d)  Alternative products and changes in consum er preferences:  There is no product, which 
will be substitute to the product concerned.  Ther efore changes in user preferences have not been 
identified. 
 
(e)  Lack of production capacity:  The domestic industry has adequate production capacity to 
meet domestic demand.  
 (f)  Changes in financial costs:  The investig ating authority determined that changes in 
financial costs did not contribute to the injury suffered by the domestic industry. 
 
(g)  Effects of changes in export performance:  Th e effect of variations in the level of exports 
has also been examined.  
 
 2000 2001 2002 2003 2004 2005 
Exports (Quantity-
Index: 2000=100) 100 37 85 124 49 49 
 
The index of domestic producers’ exports fluctu ated during the period under investigation. 
Although the index increased by 24% between th e years of 2000 and 2003, it decreased to 49 in 2004 
and remained stable in the following year. However, as the exports have a minor share in total sales of 
domestic producers, this fall has negligible effects on the injury indicators.  Hence, there is no link 
between the changes in exports a nd the injurious effects observed. 
 2. Conclusion on causation 
 After having examined the injurious effects of the other known factors, the investigating 
authority has reached the conclusion that there is  a genuine and substantial link between increased 
imports and serious injury to the domestic industry. No  other factors that could have contributed to the G/SG/N/8/TUR/5 
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  injury apart from the increase in im ports were identified.  Therefore, it is concluded that there is a 
genuine and substantial link between  increased imports and serious injury to the domestic industry. 
 
 
II. INFORMATION ON WHETHER THERE IS AN ABSOLUTE INCREASE IN 
IMPORTS OR AN INCREASE IN IMPORTS RELATIVE TO DOMESTIC PRODUCTION 
The investigation was conducted in accordance w ith the requirements of Turkish Legislation 
on Safeguard Measures and the procedures prescrib ed by the WTO Agreement on Safeguards and 
Article XIX of GATT 1994, i.e. determination of th e existence of unforeseen developments and effect 
of obligations, including tariff concessions which le d to the increased imports and resulting injury to 
the domestic producers.    
Although these circumstances need not be demonstrated for the reason that the product 
concerned is not the subject of any tariff concessi on granted by Turkey under the WTO Agreement, 
current investigation was governed by the national legislation and the term s and conditions of the 
Agreement on Safeguards and Article XIX of GATT 1994. 
  The investigating authority found that the New Turkish Lira appreciated unexpectedly since 
2001. According to the data circulated by the Central Bank of the Republic of Turkey, the New 
Turkish Lira appreciated by 47% in real terms in 2005 compared to the year 2001.  The real value gain of the New Turkish Lira speeded up the imports and lessened the competitive power and 
profitability of the domestic industry.  The incr eased imports in significant quantities consequently 
eroded the domestic producers’ market share.   
 
Another factor influencing the competitive power  of the domestic producers and the market 
prices of the product concerned is the significant in crease in world crude oil prices in the period under 
investigation.  World crude oil prices increased by 112% in 2005 compared to the year 2000.  Cost of 
road transportation, which constitutes a consider able part in the price of the domestic product 
concerned, is influential in consumers’ preference s between domestic and imported products.  Within 
this framework, the rise in world crude oil prices ha d influence on road transportation prices and thus 
brought about a price disadvantage of domestic produc t in the market. In this  circumstance, imports 
consistently increased, as the competitive pow er of domestic product was weakened. 
 1. Volume of imports 
An examination has been undertaken based on da ta for the period 2000 to 2005, focusing on 
imports in the most recent period for which reliabl e data are available, to establish whether the 
product concerned is imported into Turkey in such greatly increased quantities, absolute or relative to 
total domestic production, and/or on su ch terms or conditions as to cause, or threaten to cause, serious 
injury to the domestic industry.  The table belo w shows the development of imports for the years 
2000-2005.   
 
 2000 2001 2002 2003 2004 2005 
Imports 
(Ton)  25.733 11.072 78.051 198.633 306.882 332.985 
  G/SG/N/8/TUR/5 
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  Volume of imports in 2001 decreased by %57 compar ed to level of imports in 2000 due to the 
macro-economic crisis occurred in Turkey in that year. In the following year, the imports increased by 
605% and reached 78.051 tons.  The rate of increase was 155% in 2003, 55% in 2004 and 9% in 
2005.  The volume of imports increased by 1194% in the period of 2000-2005.  This reflects the fact 
that imports increased in absolute terms.  
 2000 2001 2002 2003 2004 2005 
Imports/ 
Production (%-Index: 2000=100) 100 47 270 706 1.146 1.664 
 
 The index of the ratio of imports to tota l domestic production decreased from 100 to 47 in 
2001.  Afterwards, it increased to 270 in 2002, 706 in 2003 and 1.146 in 2004.  As domestic 
production continued to its downwar d movement in 2005, the index increased by 45% and reached to 
its highest level (1.664) in the period under examination. 
  Imports below the average price of domestic product (35 USD/ton) in 2005 are given below 
table.  As is seen in the table, the imports under average domestic sales price increased during the investigation period.   
 2000 2001 2002 2003 2004 2005 
Ton 4.963 2.242 57.268 139.224 251.077 249.494 
Share in general 
imports 19,29% 20,25% 73,37% 70,09% 81,82% 74,93% 
 
2. Market share of imports 
 2000 2001 2002 2003 2004 2005 
Market share of 
imports (%-Index: 2000=100) 100 41 248 667 992 1.140 
 
 The market share index of imports decreased by 59% in 2001; however, imports continuously 
increased its market share from 2001 until the end of  the period under investigation.  The index 
increased from 100 in 2000 to 1.140 in 2005.  3. Import prices 
 2000 2001 2002 2003 2004 2005 
PriceUSD/ton  166 179 35 35 31 27 
 
The average price of the total imports increased  by 8% in 2001.  The average import price, 
which was 179 USD/ton in 2001, fell to the level of 27 USD/ton in 2005.  The decrease between the 
years 2000 and 2005 occurred by 84%. 
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  III. PRECISE DESCRIPTION OF THE PRODUCT INVOLVED 
 The product concerned which is salt and pure sodium chloride (except sea water and salt 
liquors; and the salt suitable for human consumption) is classified within the Turkish Customs Tariff 
Schedule under the 12-digit headings of 2501.00.31.00.00, 2501.00.51.00.00, 2501.00.99.10.00, 
2501.00.99.90.11, 2501.00.99.90.12 and 2501.00.99.90.13.   
IV. DESCRIPTION OF THE PROPOSED MEASURE 
 It is proposed to impose definitive safeguard measu re in the form of variable duty that will be 
implemented for the imports under the CIF price of 35 USD per ton.  Application of the measure on 
products under a this threshold price is proposed, since it was found that the injury suffered by the domestic producers has mainly been caused by low-pr iced imports.  Hence, th e type and magnitude of 
the measure were determined in consistent with th e aim of preventing serious injury to the domestic 
industry.  In determining this threshold, the aver age price of domestic product in 2005 and the average 
CIF price (plus customs duty and other cost s) were taken into consideration.  
 
If imports are undertaken at a CIF price equal to or above the relevant threshold level 
established (35 USD per ton), the imports will not be subject to the proposed measure.  If imports are 
undertaken at a lower price, a duty as much as the difference between the CIF price and the threshold 
price established (35 USD per ton) will be charged.   
 
Below is the list of Developing Countries exclude d from the measures as they export less than 
3% of imports to Turkey (Article 9.1 of the Agreement on Safeguards ) 
 
 Afghanistan; Antigua and Barbuda; Angola;  Argentina; American Samoa; Anguilla; 
Antarctica; Aruba; Azerbaijan; Barbados; Banglad esh; Burkina Faso; Bahrain; Burundi; Benin; 
Belarus; Bolivarian Republic of Venezuela; Br unei Darussalam; Bolivia; Brazil; Bahamas; Bhutan; 
Botswana; Belize; Bermuda; Bouvet Island; British Virgin Islands; British Indian Ocean Territory; 
Democratic Republic of Congo; Central African Re public; Congo; Côte d'Ivoire; Cameroon; Chad; 
Colombia; Costa Rica; Cuba; Cape Verde; Cayman  Islands; Chile; Christmas Islands; Cocos Islands; 
Cook Islands; Djibouti; Dominica; Dominican Repub lic; Ecuador; Eritrea; Ethiopia; Fiji; Federated 
States of Micronesia; Falkland Islands; French Polynesia; French Southern Territories; Gabon; 
Grenada; Ghana; Gambia; Georgia; Greenland; Guinea; Equatorial Guin ea; Guatemala; Guinea-
Bissau; Guyana; Gibraltar; Guam; Honduras; Haiti; H eard Island and McDonald Islands; India; Iraq; 
Iran (Islamic Republic of); Jamaica; Jordan; Kazakhs tan; Kenya, Cambodia, Kiribati, Comoros, St 
Kitts and Nevis, Kuwait, Kyrgyzstan; Laos; Lebanon; St Lucia; Sri Lanka; Liberia; Lesotho; Libyan 
Arab Jamahiriya; Morocco; Madagascar; Marshall Islands; Mali; Moldova; Mongolia; Mauritania; 
Mauritius; Maldives; Malawi; Mozambique; Macao ; Mayotte; Montserrat; Namibia; Niger; Nigeria; 
Nicaragua; Nepal; Nauru; Netherlands Antilles; New Caledonia; Niue Island; Norfolk Island; 
Northern Mariana Islands; Oman; Panama; Peru; Pa pua New Guinea; Philippines; Pakistan; Palau; 
Paraguay; People’s Republic of China; Pitcairn; Qa tar; Russian Federation;  Rwanda; Samoa; Saudi 
Arabia; Solomon Islands; Seychelles; Sudan; Sie rra Leone; Senegal; Somalia; Suriname; Sao Tomé 
and Principe; El Salvador; Syrian Arab Repub lic; Swaziland; South Georgia and South Sandwich 
Islands; St Helena and de pendencies; St Pierre and Miquelon; Tajikistan; Thailand; Togo; Tunisia; 
Tonga; East Timor; Trinidad and Tobago; Turkme nistan; Tuvalu; Tanzania; Tokelau; Turks and 
Caicos Islands; Ukraine; United Arab Emirates;  United States Minor outlying islands; Uganda; 
Uruguay; Uzbekhistan; St Vincent; Vietnam; Vanuatu ; Virgin Islands of USA; Wallis and Futuna 
Islands; Yemen; South Africa; Zambia; Zi mbabwe; Indonesia; Malaysia and Mexico.  
  G/SG/N/8/TUR/5 
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  V. PROPOSED DATE OF INTRODUCTION OF THE MEASURE 
The date of introduction of the pr oposed measure is 10 August 2006. 
 VI. EXPECTED DURATION OF THE MEASURE 
 The expected duration of the proposed measure is three years. 
 
VII. PROPOSED DATE FOR THE REVIEW  
 Not applicable. 
 
VIII.  EXPECTED TIMETABLE FOR PROGRESSIVE LIBERALIZATION OF THE 
MEASURE 
In order to induce adjustment, the proposed m easure will be subject to liberalization on a 
regular basis following its imposition, thereby ensuri ng that there is a strong incentive for domestic 
producers to progressively undertake the necessary rest ructuring and adjustment.  The timetable for 
progressive liberalization of the prop osed measure is shown below.  
 
Period Threshold Level 
1st year  35 US $ per ton 
2nd year  33 US $ per ton 
3rd year  31 US $ per ton 
 
IX. INFORMATION RELATING TO THE EXTENSION OF A SAFEGUARD MEASURE 
 Not applicable. 
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