WORLD TRADE  
ORGANIZATION  G/SG/N/6/TUR/15 
G/SG/N/7/TUR/3 
G/SG/N/11/TUR/13 
6 May 2009 
 (09-2216) 
Committee on Safeguards Original:   English 
  
 
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 PURSUANT TO ARTICLE 9, FOOTNOTE 2 
OF THE AGREEMENT ON SAFEGUARDS 
 
TURKEY 
 
(Matches
) 
  
 The following communication, dated 4 May 2009, is being circulated at the request of the 
Delegation of Turkey.    
_______________ 
  
We enclose a notification pursuant to Article 12.1(a) of the Agreement on Safeguards, on 
initiation of a safeguard investigati on into imports of matches; a notif ication pursuant to Article 12.4 
of the Agreement on Safeguards, before taking a provisional safeguard measure against imports of 
matches;  and a notification pursuant to Article 9, footnote 2 of the Agreement on Safeguards, on 
taking a decision not to apply the measure to prod ucts originating in developing countries.   
 A. 
NOTIFICATION UNDER ARTICLE 12.1( A) OF THE AGREEMENT ON SAFEGUARDS ON INITIATION 
OF AN INVESTIGATION AND THE REASONS FOR IT  
1. The date when the investigation was initiated 
The investigation was initiated on 2 May 2009 .  The related Communiqué was published in 
the Official Gazette on the same date.   
 
2. The product subject to the investigation 
Matches, other than pyrotechnic articles of h eading 36.04.  The product under investigation is 
currently classified under HS Code 36.05.   
 
3. The reasons for the initiation of investigation 
The investigation was initiated upon an evalua tion of a safeguard petition from the domestic 
industry and on the basis of the evidence and the information contained therein.   G/SG/N/6/TUR/15 
G/SG/N/7/TUR/3 G/SG/N/11/TUR/13 
Page 2 
  
  The information currently available indicates th at there has been a recent, sudden and sharp 
increase in imports of the product concerned both in absolute terms, and relative to domestic 
production.   
 
Imports Unit 2003 2004 2005 2006 2007 2008 
Absolute Tons 80 118 180 354 637 1,229 
Relative to 
Domestic Production Index 100 147 201 405 1,103 5,048* 
*  For January-September.   
 
The information currently availa ble also shows a situation of decreasing production, domestic 
sales, employment, capacity utilization and profitab ility, and an increase in inventories with a 
continuously declining market share for domestic industry.   
 
4. Further information 
Those who fill out and send "Application Form fo r the Interested Party" to the competent 
authority within the period of 20 days after the initia tion of the investigation are accepted as interested 
parties in the investigation.   
 
The competent authority shall provide with a username and a password to each interested 
party.  The username of the interested party sha ll be the e-mail address specified in the "Application 
Form for the Interested Party".  Logging in with th e username and password, the interested parties are 
required to fill out "Online Questionnaire for the Inte rested Party", that is going to be available at 
http://www.dtm.gov.tr/dtmithgozetim/index.cfm, within  the period of 30 days after the initiation of 
the investigation.  Interested parties may ask for the technical assistance of the competent authority 
during filling out "Online Questionnair e for the Interested Party".   
 
Interested parties may state, in the "Applicati on Form for the Interested Party", their request 
to be heard by the competent authority.   
 
"Application Form for the Interested Party" and "Online Questionnaire for the Interested 
Party" are available at the web address below.  Also, the date and venue of the hearing and other 
announcements regarding the investigation will be accessible on the same address.    
http://www.dtm.gov.tr/dtmweb/index.cfm?acti on=detay&yayinID=47&icerikID=132&dil=TR
 
 
The address of the competent authority for correspondence is:  
  Undersecretariat for Foreign Trade 
 Directorate General for Imports, Department of Safeguards 
 Tel:  +90 312 222 65 00 / +90 312 204 77 17  Fax:  +90 312 212 87 65 / +90 312 212 87 11  Web page:  http://www.dtm.gov.tr 
E-mail:  korunma@dtm.gov.tr 
  G/SG/N/6/TUR/15 
 G/SG/N/7/TUR/3 
 G/SG/N/11/TUR/13 
 Page 3 
  
  B. 
NOTIFICATION UNDER ARTICLE 12.4  BEFORE TAKING A PROVISI ONAL SAFEGUARD MEASURE  
1. The product subject to the proposed provisional safeguard measure 
Matches, other than pyrotechnic articles of heading 36.04.  The product subject to the 
proposed provisional safeguard measure is cu rrently classified under HS Code 36.05.   
 
2. The proposed provisional safeguard measure 
It is proposed to impose provisional safeguard measure in the form of specific duty that will 
be implemented as 0.64 USD per net kilogram.   
 
3. Entry into force of the proposed  provisional safeguard measure 
The provisional safeguard measure is proposed to enter into force with the publication of the 
approval of the Council of Ministers in the Official Gazette.    4. The expected duration of the provisional safeguard measure 
The provisional safeguard measure is proposed to be in force for two hundred days from the 
date of its introduction.    
5. The basis for: 
(i) Making a preliminary determination, as provided  for in Article 6, that increased imports have 
caused or are threatening to cause serious injury 
The share of developing countries in the world production and exports of matches has 
increased significantly and unexpectedly in the r ecent past depending mainly on the factors like 
proximity to raw materials and markets and the costs of labor and raw materials.  Besides, developed 
countries has lost their weight in the world demand for imports in the same period due to the changes 
in the factors like tobacco products use tende ncies, demographic conditions, development of 
substitute products, etc.    
These changes in the world match market have  affected Turkey's imports of matches 
dramatically.  The increase in the production cap acity, production and exports of matches of 
developing countries that are charact erized with low production costs, and the decline in the share of 
developed countries in world match demand have pu t Turkey, with its population size and tendencies 
of use of tobacco products, in a suitable market pos ition for the relatively low unit priced matches.  
Accordingly, products of Indonesian and Indian orig in constituted 90 per cent of Turkey's imports of 
matches in 2008 while there were no imports fro m these two countries up to 2005.  The substantial 
fall in the unit prices of imports, from 2.61 USD/Kg in  2004 to 1.50 USD/Kg in 2008, is the indicator 
of the effect of unexpected changes on Turkey's imports of matches.   
  I
NCREASE IN IMPORTS  
 
Unit 2003 2004 2005 2006 2007 2008 
Imports 
Tons 80 118 180 354 637 1,229 
 G/SG/N/6/TUR/15 
G/SG/N/7/TUR/3 G/SG/N/11/TUR/13 
Page 4 
  
   Imports of the product concerned have increased in absolute terms consistently throughout the 
period under consideration.  The largest annual increase in imports was recorded in 2006 as 
97 per cent.  Also, having grown by 93 per cent on yearly basis, imports of matches exceeded the 
level of 1,200 tons in 2008.   
 
Unit 2003 2004 2005 2006 2007 2008 
(1-9) 
Imports/ Production % - 
Index 100 147 201 405 1,103 5,048 
 
 The ratio of imports to domestic production has also risen continuously during the period 
under consideration.  The ratio increased by 3 58 per cent in the first 9-month period of 2008 
compared with its value in 2007.   
 
Unit 2003 2004 2005 2006 2007 2008 
(1-9) Market Share of Imports % - 
Index 100 118 161 413 824 1,047 
 
 Also, the market share of the import product has expanded dramatically throughout the period concerned.  Compared with its value in 2003, a nearly tenfold increase in the market share was 
recorded in the first 9-month period of 2008.   
  Based on the figures relating to imports that ar e summarized above, it is concluded that there 
has been a sudden, recent and sharp increase, both in ab solute and relative terms, in the imports of the 
product concerned.  Accordingly, the market pe netration of the import product have increased 
substantially during the period analysed.   
 
 S
ERIOUS INJURY OR THREAT OF SERIOUS INJURY  
 
In order to make a determination of serious in jury or threat thereof to the domestic producer 
of the like product, a preliminary evaluation of all relevant factors of an objective and quantifiable 
nature having a bearing on the situation of the do mestic industry has been undertaken.  In this 
analysis, data submitted by the applicant company,  which constitutes major proportion of domestic 
production, were utilized.  Therefore, in order to maintain the confidentiality of the information 
provided by the applicant company, the figures in this section are shown by indexes.  Information 
below covers the 5-year period from 2003 to 2007 and also the first 9-month period of the years 2007 and 2008, where necessary.   
 
 (i) Consumption  
2003 2004 2005 2006 2007 2007  
(1-9) 2008  
(1-9) 
Consumption   
(Tons – Index)  100 125 139 107 96 82 97 
 
 Having risen by 25 per cent and 12 per cent in 2004 and 2005, respectively, domestic 
consumption of matches reached its peak of pe riod under consideration in 2005.  Thereafter, a 
reversal in the increasing trend started in 2006 a nd the lowest level of consumption was recorded  G/SG/N/6/TUR/15 
 G/SG/N/7/TUR/3 
 G/SG/N/11/TUR/13 
 Page 5 
  
  in 2007.  However, compared with the same peri od in 2007, consumption increased by 18 per cent in 
the first 9-month period of 2008 and exceeded its value in 2007.    
 (ii) Production 
 
2003 2004 2005 2006 2007 2007 
(1-9) 2008 
(1-9) 
Production   
(Tons – Index)  100 100 112 109 72 56 20 
 
 Domestic production of matches remained uncha nged in 2004 and reached its highest value 
in 2005, having grown by 12 per cent in comparis on with 2004.  Match industry saw annual declines 
in production in 2006 and 2007.  Do mestic production further decreased by 64 per cent in the first 9-
month period of 2008 compared with the same period in 2007.     (iii) Capacity and Capacity Utilization Rate (CUR)  
2003 2004 2005 2006 2007 
CUR 
(% – Index)  100 100 112 109 72 
 
 Production capacity of the applicant company re mained stable throughout the years analysed.  
Therefore, capacity utilization ratio figures wholly reflect the changes in the production level.  In this 
regard, after recording its highest value in 2005, th e ratio came down to its lowest value in 2007.   
  (iv) Domestic Sales 
 
2003 2004 2005 2006 2007 2007 
(1-9) 2008 
(1-9) 
Domestic Sales 
(Tons – Index)  100 123 134 89 58 49 47 
 
 Domestic sales of the applicant company have shown a trend that is similar to that of production.  2005 was a peak year for domestic sale s, which fell to its trough level in 2007.  There 
was a slight decrease in domestic sales in the firs t 9-month period of 2008 compared with the same 
period in 2007.   
  (v) Inventories  
2003 2004 2005 2006 2007 2007 
(1-9) 2008 
(1-9) 
End of Period Inventories   
(Tons – Index)  100 84 73 108 184 159 175 
 
 The lowest level of end of period inventories was recorded in 2005.  Starting to rise in 2006, 
inventories reached the highest level at the end of 2007.  End of period inventories increased by 
10 per cent in the first 9-month period of 2008, compared with the same period of 2007.   G/SG/N/6/TUR/15 
G/SG/N/7/TUR/3 G/SG/N/11/TUR/13 
Page 6 
  
  (vi) Employment 
 
2003 2004 2005 2006 2007 2007 
(1-9) 2008 
(1-9) 
Employment  
(Workers – Index)  100 99 101 100 84 89 29 
 
 Employment moved stable from 2003 to 2006 an d decreased by 16 per cent in 2007.  There 
was a dramatic drop by 67 per cent in employme nt in the first 9-month period of 2008.   
  (vii) Productivity  
2003 2004 2005 2006 2007 2007 
(1-9) 2008 
(1-9) 
Productivity  
(Tons/Worker – 
Index)  100 101 110 109 86 63 69 
 
 Labour productivity in the domestic sector reach ed its highest level in 2005.  In 2007, there 
was a fall in productivity, depending, to a large extent , on the sharp decline in production in that same 
year.  Compared with the same period of 2007,  in the first 9-month period of 2008 the domestic 
industry experienced a slight improvement in produc tivity despite the dramatic decrease in production 
in that period.   
  (viii) Profitability  
2003 2004 2005 2006 2007 2008 
(1-9) 
Profitability 
(% – Index)  100 264 129 -92 -131 -31 
 
 Profitability recorded positive values from 2003 to 2005.  However, domestic producer 
incurred losses in 2006, 2007 and 2008.   
  C
AUSATION  
 
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 effects of the following factors were analyzed:    
- Effect of increased imports:   
 
A detailed analysis of the figures relating to impor ts and serious injury reveals that there is a 
parallel trend between the change in  imports of the product concerned and deterioration pattern of the 
applicant company's economic indicators.  The high est annual increase in im ports was recorded in 
2006 with 97 per cent and it is followed by 2008 w ith 93 per cent.  At the same time, during the 
period analysed, negative profits and annual dec lines in production and domestic sales were first 
recorded in 2006.  Also, production, domestic sal es, employment and capacity utilization ratio are 
expected to come down to their lowest levels in 2008.   
  G/SG/N/6/TUR/15 
 G/SG/N/7/TUR/3 
 G/SG/N/11/TUR/13 
 Page 7 
  
  It was found that the product concerned competes in the market mainly with its price level.  
Therefore, a summary table regarding the development of unit prices of the domestic and import products is given below.  In the table, IP shows the weighted average unit price of the import product 
whose customs process is finished.  DP1 indicates weighted average ex-factory unit price of the 
domestic product.  DP2 was constructed by adding a r easonable level of profit to the industrial cost of 
the domestic product.    
 Unit 2004 2005 2006 2007 2008 
IP $/Kg 2,61 2,00 1,55 1,78 1,50 
DP1 $/Kg -
Index 100 98 76 84 89 
DP2 $/Kg -
Index 100 113 113 144 147 
Difference 1 
(DP1-IP) $/Kg -
Index -100 19 15 4 84 
Difference 2 
(DP2-IP) $/Kg -
Index -100 -31 8 27 55 
 
Unit price of the import product showed a declin ing trend, except for 2007, during the period 
under consideration.  Unit price of the domestic  product also fell gradually in 2005 and 2006, but 
there were slight increases in 2007 and 2008.  Neve rtheless, unit sales price of the domestic product 
fell by 11 per cent in 2008 compared with its level in 2004.  Meanwhile, the constructed or "target" 
sales price of the domestic product, DP2, increased  substantially in 2007 and reached to a level 
in 2008 that is higher than the level in 2004 by 47 per cent.  Also, IP was below DP1 during the entire period except 2003 and price undercutting reached th e maximum level in 2008.  Therefore, an 
evaluation of these figures reveals that the import products have caused pr ice undercutting and price 
suppression on the domestic products during the period concerned.    
For the foregoing reasons, the preliminary conclu sion is that there is a correlation between the 
increase in imports and the serious injury suffered by  the domestic producers, and that the increase in 
imports has had injurious effects on the domestic i ndustry particularly in terms of downward pressure 
on prices and a reduction in domestic sales and market share of the domestic industry.    
- Other factors:   
 
A preliminary analysis of other factors that ma y have contributed to the serious injury or 
threat of serious injury suffered by dom estic producer has been carried out.   
 
Although consumption of the product concerne d decreased in 2006 and 2007, there was an 
improvement in consumption in the first 9-mont h period of 2008.  Also, taking into account the 
93 per cent increase in imports in 2008, consumption figure for 2008 is expected to improve further.  
Therefore, demand for the product concerned could not have led to an injurious  effect on the domestic 
producer.    
Excess capacity cannot be considered as a factor having an effect on the serious injury since 
the production capacity of the applicant company did not show any change throughout the period 
examined.    G/SG/N/6/TUR/15 
G/SG/N/7/TUR/3 G/SG/N/11/TUR/13 
Page 8 
  
  Labor productivity came down in 2007 due to ma inly the dramatic fall in production in that 
year.  However, an improvement in productivity was recorded in the first 9-month period of 2008 
despite the continuing decline in production.  Therefore, the domestic producer is cannot be 
considered to be suffering problems resulting from productivity.   
 
There has not been any addition to the domestic producers in the match production industry.  
Hence, competition among domestic producers did not create an injurious effect during the period 
analyzed.   
 
Finally, the trend of exports sales and weight of exports sales in total sales indicate that 
exports have not caused injury on the domest ic industry in the period concerned.   
 
According to this preliminary analysis, the serious  injury or threat of serious injury is not 
attributable to the factors other than the increase in imports.   
 
(ii) Determining the existence of critical ci rcumstances where delay would cause damage which 
it would be difficult to repair 
 
The investigating authority has made a prelimin ary determination that critical circumstances 
exist in which delay would cause damage, which it would be difficult to repa ir.  Production, domestic 
sales, market share and employment fell to their trough and end of period inventories reached the maximum level in the first 9-month period of 2008.  The domestic producer has also suffered losses in its sales since 2006.    
The most recent data relating to imports of the product concerned cover the first 2-month 
period of 2009.  Turkey's imports of matches in the first two months of 2009 were 236 tons, which 
indicates to an increase by 531 per cent in co mparison with same period in 2008.   
 
It can be anticipated that without the appli cation of a provisional safeguard measure, imports 
of the product concerned into Turkey will continue to  rise at a high level and particularly as a result of 
the price undercutting, the domestic industry will conti nue to lose its share in the domestic market.   
 
There exists a critical situation in which any delay in the adoption of a provisional safeguard 
measure would cause damage, which it w ould be difficult to repair.   
 6. Offer of consultations under Article 12.4 
Consistent with Article 12.4 of the Agreement on Safeguards, Turkey is prepared to consult 
on the provisional safeguard measure with those Memb ers having a substantial interest as exporters of 
the product concerned at any time after 2 May 2009.    C. N
OTIFICATION UNDER ARTICLE 9, FOOTNOTE 2 UPON TAKING A DECISION NOT TO APPLY 
THE PROVISIONAL SAFEGUARD MEASURE TO CERTAIN PRODUCTS ORIGINATING IN 
DEVELOPING COUNTRIES  
1. The measure 
It is proposed to impose provisional safegua rd measure in the form of specific duty as 
described in the notification under Article 12.4 above.   
  G/SG/N/6/TUR/15 
 G/SG/N/7/TUR/3 
 G/SG/N/11/TUR/13 
 Page 9 
  
  2. The product subject to the measure 
The measure applies to the products described  in paragraph 1 of the notification under 
Article 12.4 above.   
 
3. The developing countries to which the measure is not applied under Article 9.1 of the 
Agreement on Safeguards  
The developing countries in the list below are excluded from the measure as they export less 
than 3 per cent of imports to Turkey.   
 
Afghanistan;  Albania;  Algeria;  Anti gua and Barbuda;  Angola;  Argentina;  
American Samoa;  Anguilla;  Antarctica;  Aruba;  Azerbaijan;  Barbados;  Bangladesh;  Burkina Faso;  
Bahrain;  Burundi;  Benin;  Bolivarian Republic of Venezuela;  Brunei Darussalam;  Bolivia;  Brazil;  
Bahamas;  Bhutan;  Botswana;  Belize;  Berm uda;  Bouvet Island;  Br itish Virgin Islands;  
British Indian Ocean Territory;  Democratic Republic  of Congo;  Central African Republic;  Congo;  
Côte d'Ivoire;  Cameroon;  Chad;  Colombia;  Cost a Rica;  Cuba;  Cape Verde;  Cayman Islands;  
Chile;  Christmas Islands;  Cocos Islands;  Cook Is lands;  Djibouti;  Dominica; Dominican Republic;  
Ecuador;  Egypt;  Eritrea;  Ethiopia;  Fiji;  Fede rated States of Micronesia;  Falkland Islands;  
French Polynesia;  French Southern Territories;  Gabon;  Grenada;  Ghana;   Gambia;  Georgia;  
Greenland;  Guinea;  Equatorial Guinea;  Guatemal a;  Guinea-Bissau;  Guyana;  Gibraltar;  Guam;  
Honduras;  Haiti;  Heard Island and Mc Donald Islands;  Iraq;  Iran (Isla mic Republic of);  Jamaica;  
Jordan;  Kazakhstan;  Kenya;  Cambodia;  Kiriba ti;  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;  
Malaysia;  Maldives;  Malawi;  Mozambique;  Maca o;  Mayotte;  Mexico;  Montserrat;  Namibia;  
Niger;  Nigeria;  Nicaragua;  Nepal;  Nauru;  Ne therlands Antilles;  New Caledonia;  Niue Island;  
Norfolk Island;  Northern Mariana Islands; Oman;  Panama;  Peru;  Papua New Guinea;  Philippines;  
Pakistan;  Palau;  Paraguay;  Pitcairn;  Qatar;  Ru ssian Federation;  Rwanda;  Samoa;  Saudi Arabia;  
Solomon Islands;  Seychelles;  Sudan;  Sierra Le one;  Senegal;  Somalia;  Suriname;  Sao Tomé and 
Principe;  El Salvador;  Syrian Arab Republic;  Swaziland;  South Africa;  South Georgia and South 
Sandwich Islands;  St Hele na and dependencies;  St Pierre and Miquelon;  Tajikistan;  Thailand;  
Togo;  Tunisia;  Tonga;  East Timor;  Trinidad and Tobago;  Turkmenistan;  Tuvalu;  Tanzania;  
Tokelau;  Turks and Caicos Islands;  Ukraine;  United Arab Emirates;  United States Minor outlying 
islands;  Uganda;  Uruguay;  Uzbekistan;  St Vincen t;  Vietnam;  Vanuatu;  Virgin Islands of US;  
Wallis and Futuna Islands;  Yemen;   Zambia;  and Zimbabwe.   
 
 
 
__________