WORLD TRADE  
ORGANIZATION   
G/SG/N/10/TUR/12/Suppl.1
G/SG/N/11/TUR/13/Suppl.222 May 2012 
 
(12-2690) 
Committee on Safeguards Original:   English 
  
 
NOTIFICATION UNDER ARTICLE 12.1(C) OF THE AGREEMENT  
ON SAFEGUARDS ON TAKING A DECISION TO EXTEND  
A SAFEGUARD MEASURE 
 
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2 
OF THE AGREEMENT ON SAFEGUARDS 
 
TURKEY 
 
(Matches) 
 
Supplement 
   The following notification, dated 16 May 2012,  is being circulating at the request of the 
Delegation of Turkey.   
 
_______________ 
 
  Turkey hereby submits its notification pursuant to Article 12.1(c) and Article 9, footnote 2 of 
the Agreement on Safeguards, on taking a decision to extend a safeguard measure that is being 
applied against imports of matches and  non-application of safeguard measure to developing countries.  
The initial safeguard measure was notified w ith the document numbered G/SG/N/8/TUR/12-
G/SG/N/10/TUR/12-G/SG/N/11/TUR/13/S uppl.1 and dated 3 November 2009. 
  Consistent with Article 12.3 of the Agre ement on Safeguards, Turkey is ready to hold 
consultations with those Members having a substan tial interest as exporters of the product concerned. 
 G/SG/N/10/TUR/12/Suppl.1 
G/SG/N/11/TUR/13/Suppl.2 Page 2 
 
 
  A. N
OTIFICATION UNDER ARTICLE 12.1(C)  OF THE AGREEMENT ON SAFEGUARDS UPON TAKING 
A DECISION TO EXTEND A SAFEGUARD MEASURE  
1. Evidence that the safeguard measure continue s to be necessary to prevent or remedy 
serious injury or threat thereof caused by  increased imports and that the industry 
concerned is adjusting. 
 The investigation has been conducted by Turkis h investigating authority.  In the analysis, 
economic indicators of the domestic industry between  the years 2007 and the first two months of 2012 
were examined.  Following figures on economic i ndicators of domestic producers are based on the 
data submitted by 2 domestic producers which produc e whole of total domestic production.  Figures 
relating to domestic production are shown by inde xes in order to protect confidentiality of the 
information provided by the applicants.  The inv estigation period was determined between 2007 and 
2011.  In addition to this, the latest figures relate d to 2012 January-February were also examined by 
comparing the same period of the previous year.  
(i) Consumption 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Domestic consumption 100 94 83 67 51 100 101 
 
 Consumption index which was 100 points in 2007 has steadily dropped in the following years and decreased in 2011 to the half level of 2007.  When periodic consumption figures of the first 
two months of 2011 and 2012 are analyzed, it is seen that consumption index has increased by one point in the first two months of 2012.  
(ii) Capacity 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Capacity 100 100 100 100 100 100 100 
Capacity Utilization 100 38 2 67 62 100 92 
  It is seen that total production capacity of the domestic industry has not changed over the 
investigation period.  However, index on the cap acity utilization rate of the domestic industry 
decreased steadily between 2007 and 2009 and reache d to the lowest level by 2 points in 2009.  
Thanks to the effectiveness of th e safeguard measure, capacity utiliza tion rate of the domestic industry 
increased to 67 points in 2010, and with a little decrease it occurred as 62 points in 2011.  The 
capacity utilization index has decreased to 92 points in the first two months of 2012 compared to the 
100 points of the same period of 2011.  (iii) Production 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Domestic production 100 38 2 67 62 100 92 
 
 Production index of the matches which was 100 points in 2007 decreased to 38 points in 2008 and then to 2 points in 2009, whereas it increased c onsiderably in 2010 by reaching 67 points in this 
year.  In 2011, production index decreased by 5 po ints and occurred as 62 points.  Production index of  G/SG/N/10/TUR/12/Suppl.1 
 G/SG/N/11/TUR/13/Suppl.2  Page 3 
 
 
  the first two months of 2012 has decreased by 8 po ints compared to the same period of 2011 and 
occurred as 92 points.  (iv) Domestic Sales 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Domestic sales 100 71 41 80 60 100 96 
 
 Index on domestic sales, which was 100 poin ts in 2007, occurred as 71 points and 41 points 
in 2008 and 2009 respectively, and increased to 80 point s in 2010.  It decreased again in 2011 to the 
level of 60 points.  In the first two months of  2012, domestic sales index has decreased by 4 points 
compared to the same period of 2011. 
 (v) End of Period Inventories  
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
End of period inventories 100 72 28 36 60 100 110 
 
 Whereas index on end of period inventories was 100 points in 2007, it decreased to 72 points 
in 2008 and decreased to 28 points in 2009, the low est level of the investigation period.  However, 
end of period inventories increased in 2010 and 2011 and occurred as 60 points in 2011.  Also, in the first two months of 2012, there has been 10 poin ts increase compared to the same period of 2011. 
 (vi) Employment 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Employment 100 42 21 81 76 100 54 
 
 Employment index on match production decreased  considerably in 2008 and 2009, whereas it 
increased significantly in 2010 by reaching to the level of 81 points.  Employment index decreased 
slightly in 2011 to 76 points.  Employment index has shown a significant decrease in the first 
two months of 2012.  This situati on is related with the fact that the one of the domestic producers has 
temporarily suspended its production in this period.  (vii) Productivity  
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Productivity 100 89 8 83 82 100 170 
 
 Index on productivity which is calculated as the quantity of production (tons) per person 
decreased considerably in 2009 by decreasing 8 point s in 2009.  However, with the effect of the 
safeguard measure put into force in June 2009, th is index increased to 83 points in 2010 and nearly 
maintained its level in 2011.  There has been a si gnificant increase in the productivity index the first 
two months of 2012 compared to the same period of the previous year. 
 G/SG/N/10/TUR/12/Suppl.1 
G/SG/N/11/TUR/13/Suppl.2 Page 4 
 
 
  (viii) Profitability 
 
Index 2007 2008 2009 2010 2011 2011(2) 2012 (2) 
Profitability 100 55 104 132 117 100 101 
 
 Rate of gross profit of the domestic industr y increased remarkably in 2009 and 2010 due to 
the effect of the safeguard measure, whereas it decreased by 15 points in 2011 compared to the 
previous year.  (ix) Conclusion  
 Within the scope of the WTO Agreement on Safeguards and Turkish Legislation on 
Safeguards, a safeguard measure may be extended pr ovided that the investig ating authority of the 
importing Member have determined that the safegua rd measure continues to be necessary to prevent 
or remedy serious injury and that there is  evidence that the industry is adjusting. 
 
 In this context, relying both on the data  submitted by the domestic industry and on 
determinations made during the i nvestigation regarding the developm ents in domestic industry since 
the imposition of the safeguard measure in June 2009 and taking into account the arguments stated by 
the interested parties, following facts are determined.   In order to reduce costs and increase energy effi ciency one of the producers has completely 
converted its energy system to natural gas.  For th is purpose, a substantial investment compared to the 
company's annual turnover was made for expenses for boiler, infrastructure and other parts.  If the 
measure had not been taken, aside from this investment, the plant had to be scrapped. 
  In order to reduce chemical usage, some studies were made on production development.  In 
this way, besides providing some reduction in th e amount of chemicals used, the company benefited 
in terms of quality and cost.   In order to do increase the productivity, doing the same job with fewer workers, work-time 
efficiency studies were carried out.  For this purpose, objectives were set out for each unit and with new production techniques.  As a result of these studies, productivity has improved and carrying out 
the same work with less labor has achieved. 
  Taking into account new investment incentiv e program which has been announced recently 
by the government, one of the producers is analyz ing the pros and cons to move its facilities to 
another area in which there are incentives and labor a nd raw material cost are more reasonable.  As a 
result of this decision, it is expected to reduce its cost of production due to the decrease in its 
manufacturing overheads particularly on energy, labor and raw materials costs.   One of the domestic producers which had st opped its production and started to import 
because it was not able to compete with the imports before the imposition of the safeguard measure in 
June 2009, has restarted production after the break o ff.  The company is now considering increasing 
its production capacity for export markets if the measure is extended.  During the on-the spot 
verification it has been noticed that the existe nce of the company and the capacity increase are 
contingent upon the continuation of the measure.  It has also been observed that existence of the company and an increase in the production capacity of the company is crucial in terms of employment 
of the local people in that region. 
  G/SG/N/10/TUR/12/Suppl.1 
 G/SG/N/11/TUR/13/Suppl.2  Page 5 
 
 
   After the imposition of the initial safeguard meas ure in June 2009, the imports have decreased 
significantly by 95% in 2010.  The imports started to increase by 15% in 2011 and 171% in the first two months of 2012 compared to the same period of the previous year.  
 In spite of the fact that there was a gradual decrease in consumption of the product concerned 
throughout the investigation period, domestic pr oduction has increased significantly after the 
imposition of the initial safeguard measure.    In the year of 2010, the economic indicators of the domestic industry such as production, capacity utilization rate, domestic sales, employme nt, productivity and profitability have improved 
thanks to the imposition of the safeguard measure.  
  On the other hand, in parallel to the increase in imports in 2011 and in the first two months 
of 2012, economic indicators of the domestic indu stry such as production, capacity utilization rate, 
domestic sales, inventories and employment have deteriorated.  Taking into account the relation 
between economic indicators of the domestic industry and the surge in imports in the recent period, it 
can be concluded that deteriorati on on the economic indicators of the domestic industry is in parallel 
with the increase in imports and if the measure is removed before the conclusion of the planned 
investments and works by the domestic industry, th e imports will increase sharply by eliminating the 
recovery effects of the measure to prevent the seri ous injury to the domestic industry.  Since the 
domestic industry is still in the process of adjustme nt, removal of the currently applied safeguard 
measure will impair the domestic industry's ability to recover.  
  Consequently, taking into consideration the ar guments put forward by the interested parties 
and the analysis mentioned above, the extension of the existing measure is considered to be necessary 
in order to prevent or remedy serious injury of  the domestic industry.  Therefore, the current 
safeguard measure shall be extended for 3 years. 
 
2. Information on absolute increase in imports 
Imports 2007 2008 2009 2010 2011 2011-2 2012-2
Imports -Kg 637,041 1,228,574 1,660,368 75,676 86,995 8,375 22,690 
Change (%) - 93 35 -95 15 - 171 
Imports/Production (%-index) 100 511 15.184 18 22 100 293 
Market Share of Imports (%-index) 100 204 315 18 27 100 267 
Market Share of Domestic 
Production (%-index) 100 76 50 119 117 100 95 
 
 Imports significantly increased between 2007 an d 2009, dramatically fell in 2010 but again 
increased in 2011 by 15%.  Also, in the first two months of 2012, there has been 171% increase in 
imports compared to the same period of 2011.   Ratio of imports to domestic production signi ficantly increased in 2007-2009 period.  Then, 
that ratio fell back to 18 and 22 points respectivel y in 2011 and 2012.  In the first two months 2012, 
that ratio increased to 293 points.  
 
 Market share of imports was 204 points in 2008 and 315 points in 2009.  That ratio decreased to 18 points in 2010 and again increased to 27 points  in 2011.  That ratio increased by 167 points in 
January-February of 2012 compared to the same pe riod of the previous year due to the increased 
imports in the period concerned. In parallel to th is trend, market share of domestic production which G/SG/N/10/TUR/12/Suppl.1 
G/SG/N/11/TUR/13/Suppl.2 Page 6 
 
 
  diminished till 2009 exceeded the level of 2007 after the imposition of the safeguard measure.  That 
ratio decreased 5 points in January-February 2012 co mpared to the same period of the previous year 
as a result of increase in imports in this period.  
 
3. Precise description of the product involved 
 The Harmonized System (HS) Codes within Turkish Customs Tariff Schedule and description 
of the product subject to the safeguard measure are listed in the table below.  
    
 
4. Description of any part of the imported pr oduct that will no longer be subject to the 
measure in the extension 
 The initial safeguard measure covers the product stat ed in Title 3.  For the extension there is 
no change on the scope of the product.   
5. Precise description of the proposed measure 
 It is proposed to impose a definitive safeguard measure in the form of a variable duty, which 
will be implemented against imports having CIF unit pri ce lower than the relevant threshold level.  If 
imports are undertaken at a CIF unit price equal to or above the relevant th reshold level established, 
the imports will not be subject to the proposed me asure.  If imports are undertaken at a lower unit 
price, the difference between the threshold level and the actual value will be paid. In addition to this, 
the amount of duty will not exceed a certain maximum level of duty as specified in the table below.    
HS Code Threshold/Maximum Level of Duty 
(USD per net kilogram) 1st Period 
(6/6/2012-
5/6/2013) 2nd Period 
(6/6/2013-
5/6/2014) 3rd Period 
(6/6/2014-
5/6/2015) 
3605.00.00.00.00 Threshold Level of Duty 2.95 2.90 2.85 
Maximum Level of Duty 0.85 0.80 0.75 
 
6. Proposed date of introduction of the measure 
 The measure will come into effect with the publication of the approval of the Council of 
Ministers after the procedures are concluded.  7. Expected duration of the measure 
 The expected duration of the proposed measure is three years. 
 
8. Proposed date for the review  
 Not applicable. 
 HS Code Description of the Product 
3605.00.00.00.00 Matches, other than pyrotechnic articles of heading 36.04  G/SG/N/10/TUR/12/Suppl.1 
 G/SG/N/11/TUR/13/Suppl.2  Page 7 
 
 
  9. Expected timetable for progressive liberalization of the measure 
 The measure is proposed to be liberalized as stated in the Title 5. 
 
10. If the notification relates only to a finding of serious injury or threat thereof, and does 
not relate to a decision to appl y or extend a safeguard measure: 
 Not applicable. 
 
11. Information relating to the extension of a safeguard measure 
(i) Evidence that the industry  concerned is adjusting and that the safeguard measure continues to 
be necessary to prevent or remedy serious injury is provided in Title 1. 
 
(ii) Reference to the WTO document that notifie d the initial application of the measure 
 
 The introduction of the definitive safeguard measure was notified in the document numbered 
G/SG/N/8/TUR/12-G/SG/N/10/TUR/12-G/SG/N/ 11/TUR/13/Suppl.1 dated 3 November 2009. 
 (iii) Duration of the measure from initial applicati on till the date at whic h it will be extended. 
 
 The initial safeguard measure was applied from 6 June 2009 to 5 June  2012.  Turkey now 
intends to extend the safeguard measure until 5 June 2015. 
 
(iv) Precise description of the measure in place prior to the date of extension 
 
 The initial safeguard measure was imposed in the form a variable duty, which was 
implemented against imports having CIF unit price lower than the relevant threshold level.  If imports 
were undertaken at a CIF unit price equal to or ab ove the relevant threshold level established, the 
imports would not be subject to the proposed measure.   If imports are undertaken at a lower unit price, 
the difference between the threshold level and the act ual value will be paid.  In addition to this, the 
amount of duty would not exceed a certain maximum level of duty as specified in the table below.    
*  Periods in the table imply the co nsecutive one year terms starting from 6/6/2009 when the Decision of 
Council of Ministers numbered 2009/15014 regarding the Implementation of a Provisional Safeguard Measure 
on Imports of Matches, came into force.   
 
12. Information relating to exporting members 
(i) The major exporting Members of imports of the product involved. 
  The main exporter to Turkey for the product concerned is the EU.  The EU has 98% import 
share in 2011.  HS Code Threshold/Maximum Level of Duty 
(USD per net kilogram) 1st Period 2nd Period 3rd Period 
3605.00.00.00.00 Threshold Level of Duty 3.10 3.05 3.00 
Maximum Level of Duty 1.00 0.95 0.90 G/SG/N/10/TUR/12/Suppl.1 
G/SG/N/11/TUR/13/Suppl.2 Page 8 
 
 
  (ii) There are no exporting Members to which th e measure does not apply for any reason other 
than the application of Article 9.1 
 
13. Members are encouraged to attach, in an electronic form, publicly available 
document(s) containing the relevant decision (s) made by the competent authority.   
 The official documents regarding the investiga tion and the final decision are available at the 
link below.   http://www.tpsa.gov.tr/index.cfm?sayfa =DBACB8EF-F104-D01B-A976146B3A9A1EAC  
 
B. NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2 OF THE AGREEMENT ON SAFEGUARDS  
1. The measure 
 It is proposed to impose safeguard  measure as described in Title 5. 
 2. The product subject to the measure 
 The measure is applied to the product described in Title 3. 
 
3. Developing countries to which the measure is not applied under article 9.1 of the 
Agreement on Safeguards. 
 The developing countries which are excluded from the measure as they export less than 3 per 
cent of imports to Turkey are listed below.  
 Afghanistan; Albania; Algeria; Antigua and Barbuda ; Angola; Argentina; American Samoa; Anguilla;  
Antarctica; Aruba; Azerbaijan; Barbados; Banglad esh; Burkina Faso; Bahrain, Kingdom of; Burundi; 
Benin;  Brunei Darussalam; Bolivia, Plurinationa l State of; 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; Egypt; Eritrea; Ethiopia; Fiji; 
Federated States of Micronesia; Falkland Islands; Fr ench Polynesia; French Southern Territories; 
Gabon;  Grenada; Ghana; Gambia; Georgia; Green land; Guinea; Equatorial Guinea; Guatemala; 
Guinea-Bissau; Guyana; Gibraltar; Guam; Honduras;  Haiti; Heard Island and Mc Donald Islands; Iraq; 
Iran (Islamic Republic of); Jamaica; Jordan; K azakhstan; Kenya; Cambodia; Kiribati; Comoros; 
St Kitts and Nevis; Kuwait; Kyrgyzstan; Laos; Leba non; St Lucia; Sri Lanka; Liberia; Lesotho; 
Libya;  Morocco; Madagascar; Marshall Islands; Mali; Moldova; Mongolia; Mauritania; Mauritius; 
Malaysia;  Maldives; Malawi; Mozambique; Macao; Mayotte; Mexico; Montserrat; Namibia; Niger; 
Nigeria;  Nicaragua; Nepal; Nauru; Nether lands Antilles; New Caledonia; Niue Island; 
Norfolk Island;  Northern Mariana Islands; Oman ; Panama; Peru; Papua New Guinea; Philippines; 
Pakistan; Palau;  Paraguay; Pitcairn; Qa tar; Russian Federation; Rwanda; Samoa; 
Saudi Arabia, Kingdom of; Solomon Islands; Seyche lles; Sudan; Sierra Leone; Senegal; Somalia; 
Suriname; Sao Tomé and Principe; El Salvador; Syrian Arab Republic; Swaziland; South Africa; 
South Georgia and South Sandwich Islands; St Helena a nd dependencies; St Pierre and Miquelon; 
Tajikistan; Thailand; Togo; Tunisia; Tonga; East Ti mor; Trinidad and Tobago; Turkmenistan; Tuvalu; 
Tanzania; Tokelau; Turks and Caic os Islands; Ukraine; United Arab  Emirates; United States Minor 
outlying islands; Uganda; Uruguay; Uzbekistan; St  Vincent; Venezuela, Bolivarian Republic of; 
Vietnam; Vanuatu; Virgin Islands of US; Wallis a nd Futuna Islands; Yemen; Zambia and Zimbabwe. 
__________