WORLD TRADE  
ORGANIZATION  G/SG/N/8/TUR/8 
G/SG/N/10/TUR/8 
G/SG/N/11/TUR/8 
5 February 2008 
 (08-0530) 
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 
 
(Spectacle Frames
) 
   The following notification, dated 1 February 200 8, is being circulation at the request of the 
Delegation of Turkey.   
 
_______________ 
 
 
 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 11 February 2007, 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 inter est as exporters of the product concerned.   
 
 
 
                                                     
 
1 G/SG/N/6/TUR/11.   G/SG/N/8/TUR/8 
G/SG/N/10/TUR/8 G/SG/N/11/TUR/8 
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  I. EVIDENCE OF SERIOUS INJURY OR THREAT THEREOF CAUSED BY 
INCREASED IMPORTS 
A. E
VIDENCE 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.    1. Consumption 
 2002 2003 2004 2005 2006 2007 (1-7)
Consumption 
(Quantity-Piece) 3.760.000 2.222.000 4.445.000 7.000.000 9.063.000 3.764.000
 
Consumption of the product concerned was est ablished upon the basis of total domestic sales 
made by the domestic producers and total imports  of the product concerned into Turkey.   
 
Consumption increased by 100 per cent, 57 pe r cent and 29 per cent 2004, 2005 and 2006, 
respectively and reached its top level in the year 2006.   
 2. Capacity and capacity utilization 
2002 2003 2004 2005 2006 2007 (1-7)
Capacity  
(Quantity-Piece) 10.215.000 10.800.000 11.210.000 11.306.000 11.442.000 11.262.000
Capacity Utilization 
(%) 7,2 9,1 14,8 17,8 14,2 15,8 
 
Production capacity of the domestic producers incr eased by 6 per cent, 4 per cent, 1 per cent 
and 1 per cent in years 2003, 2004, 2005 and 2006, respectively.   
 
Capacity utilization reaching its highest level in  2005 fell gradually from that point.  It is 
calculated 15,8 in 2007.    3. Production 
 2002 2003 2004 2005 2006 2007* 
Production 
(Quantity- Piece) 737.000 981.000 1.663.000 2.012.000 1.629.000 1.785.000
* Forecasted.   
 
 Production of the domestic producers, on quantity basis, increased by 33  per cent , 70 per 
cent and 21  per cent  in 2003, 2004 and 2005, respectively.  Thereafter, production fell by 19  per 
cent in 2006 and forecasts indicate a slight incr ease in 2007, although still constitutes a lower level 
relative to the production in 2005.   
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  4. Employment 
2002 2003 2004 2005 2006 2007 (1-7)
Employment 
(Number of workers)449 551 534 520 493 453 
 
 Employment in the production increased in 2003.  Thereafter, it started to go down in 2004 by 
3 per cent  and continued its downward trend in 2005, 2006 and 2007 by 3  per cent , 5 per cent  and 
8 per cent .  
 
5. Domestic sales volume 
2002 2003 2004 2005 2006 2007 (1-7)
Domestic Sales 
(Quantity-Piece) 713.000 903.000 1.479.000 1.698.000 1.522.000 1.001.000 
 
 Domestic sales of the product concerned increased by 27  per cent , 64 per cent  and 15  per 
cent in 2003, 2004 and 2005 respectivel y.  However, the domestic sales of the product decreased 
in 2006 by 10  per cent .   
 
6. Market share 
2002 2003 2004 2005 2006 2007 (1-7)
Market Share of 
Domestic Producers 
(%) 19,0 40,6 33,3 24,2 16,8 26,6 
 
 Domestic producers' market share increased in  2003.  However that share could never catch 
that level after this year and fell increasingly in 2004, 2005 and in 2006 it was in the lowest level in 
the investigation period.  The re cent and substantial decrease in market share of the domestic 
producers reflects the simultaneous increase in the market share taken of imports.   
 7. Price of the like product and price undercutting 
 2007 
Unit Prices of Domestic Sales (US $/Pcs) 7,79 
Unit Prices of Comparative Imports (US $/Pcs) 4,76 
Price undercutting (US $/Pcs) 3,03 
 
In the calculation of price undercutting, the fina l sale prices of the importers and the domestic 
producers have been included.  The prices of impor ts has been collected from the actual invoices and 
trade documents verified by the importers.  It  was prominent according to the results of the G/SG/N/8/TUR/8 
G/SG/N/10/TUR/8 G/SG/N/11/TUR/8 
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  investigation that the imported products were be ing sold under the price of those of domestic 
producers by at least 3 US Dollars per piece.    
8. Profitability 
2002 2003 2004 2005 2006 2007 (1-7)
Net profit/loss (%) 11,5 -0,9 5,3 -6,6 -2,8 -0,5 
 
The profitability of the domestic producers' has been observed as being negative for the past 
two years and currently it stays as it was in that period.  Although the domestic producers seems to 
have made a profit at the end of year 2004, that profit apparently turned into a loss of 6.6 per cent in 2005 and 2,8 in 2006.    9. Stocks 
 
2002 2003 2004 2005 2006 2007 (1-7)
Stocks (Quantity-
Piece) 39.379 84.422 234.107 521.001 593.998 620.712 
 
Stocks of the domestic producers have increased  throughout the investigation period reaching 
its highest level in 2007.  The latest increase in stoc ks can be attributed to the fall in sales volume and 
relevant increase in the production.   
 
10. Productivity 
 2002 2003 2004 2005 2006 2007 (1-7)
Productivity 
(Pieces/Employee) 1.642 1.780 3.114 3.869 3.304 3.064 
 
Productivity in relation to the product concerne d increased by 8 per cent, 75 per cent and 
24 per cent in years 2003, 2004 and 2005.  In 2006, it decreased by 15 per cent from 3.869 pieces/employee in 2005 to 3. 304 pieces/employee in 2006 and co ntinued further to decrease to 
3.064 pieces/employee in 2007.   
 11. Conclusion 
The data show negative developments for capac ity utilization rate, production, domestic sales, 
market share, employment and profitability in th e period under consideration.  Stocks increased 
constantly in the period under examination period  reaching its highest level ever in 2007.   
 
 Imports have indicated a sharp and substan tial increase most remarkably in 2004, 2005 
and 2006, 125 per cent, 79 per cent and 42 per cent, respectively.     Taking account of all of these factors, inves tigating authority concludes that the domestic 
industry has suffered serious injury.  No other factors that could have contributed to the injury apart  G/SG/N/8/TUR/8 
 G/SG/N/10/TUR/8 
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  from the increase in imports were identified.  Theref ore, it is concluded that there is a genuine and 
substantial link between increased  imports and serious injury to the domestic industry.   
 
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 th e effects of the following factors.   
 
1. Analysis of causation factors 
- Effect of increased imports: 
Imports have been on an increasing trend in th e period under examination, most prominently 
in years 2004 and 2005 with increase rates of 125 per cent and 79 per cent.  Additionally, at the same 
time, the increase in imports caused a reduction in the market shares of the domestic producers and 
deteriorations in their main economic indicators.   
 
After having experienced a demand shock as explai ned in the determination of the existence 
of unforeseen development in section II of this report , imports were quick to gain the considerable 
share of market and to secure long term purchasing c ontracts with its apparent advantage in cost of 
products offered, availability of larg e volume of stocks and availabilit y of long term payment plans.   
 
The investigating authority concluded that th ere is a causal link between the increase in 
imports and the serious injury suffered by the domes tic industry, and that the increase in imports has 
had injurious effects.   
 
- Other Factors 
 
(a) Effect of changes in consumption:  Demand for the product concerned has not 
decreased throughout the period under consideration.   
 
(b) Effect of competition between the domest ic producers:  Competition in the domestic 
market has not created an injurious effect.   
 
(c) Changes in production technology:  The production technology used by the domestic 
industry is the same with the technology used by foreign producers.   
 
(d) Alternative products and changes in cons umer preferences:  There is no product, 
which can be a substitute for the product concerne d.  Therefore, changes in user preferences 
have not been identified.   
 
(e) Lack of production capacity:  The dom estic 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 in jury suffered by the domestic industry.   
 
(g) Effect of changes in export performance:  The effect of variations in the level of 
exports has also been examined.  Since domes tic sales constituted major proportion of total G/SG/N/8/TUR/8 
G/SG/N/10/TUR/8 G/SG/N/11/TUR/8 
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  sales during the period under examination, it is  concluded that there is no link between the 
changes in exports and 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 causal 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.     The imported spectacle frames have been sold not directly to the final customers, but to the optical goods businesses (retailer opticians).  On ce the optical experts in those businesses sell 
spectacle frames to customers, the public social security institutions are then paying the bill for each 
customer under social security system.  So in  practical, retail businesses mostly supply spectacle 
frames to the social security institu tions.  Those sales that are being paid in social security system 
constitute a major portion in the tota l sales of spectacle frames.   
 
 Since each spectacle frame billed in the social security system is being paid to the opticians 
later in the same social security system, opticians te nd to consider the cost of  spectacle frames in their 
purchases as their main equipment they can use in or der to increase their profit those in those sales.  
For this reason, the purchasing decisions of the retail er opticians plays a major role in determining the 
price, sale and marketing conditions in the spectacle frame market.    
 There are approximately 4 000 retailer opticians in  Turkey.  Slightly more than half of this 
number was opened after the Law on Optometry in 2004.   More recently, approximately 1 300 of total 
4 000 retailer opticians got their licenses and en tered into business in 2006 causing a total 1 500 000 
of additional demand coming in with newly opened bu sinesses.  In addition, in 2005 the Ministry of 
Health made a change of its "green card" regime providing the needy their spectacle frames to be paid 
by the medical aid system.  This change contri buted to the demand of spectacle frames with an 
additional 423 000 pieces in 2006.  Together with the additional stocks demand from newly opened 
businesses, they approximately constitute a quarter of the total consumption.  The new comers in the 
retail sector demanded the products w ith lowest cost possible, the quickest way to get their requests of 
large amounts and with the most ease in payments in  order to reduce their in itial investment costs.  
Only importers were able to meet this demand with conditions requested in payment and prices, 
leading long-term purchasing agreements between the importers and retailer op ticians and restricting 
the market share of the domestic producers by crowdi ng out.  This recent development in the market 
has been identified as an unforeseen development.    G/SG/N/8/TUR/8 
 G/SG/N/10/TUR/8 
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  1. Volume of imports 
2002 2003 2004 2005 2006 2007 (1-9) 
Imports 
(Pcs) 3.048.053 1.319.012 2.965.462 5.302.739 7.540.903 3.735.585 
 
Turkey has investigated whether the product c oncerned is imported into Turkey in such 
increased quantities, absolute or re lative to total production, and/or on such terms or conditions as to 
cause, or threaten to cause, serious  injury to the domestic producers.   In this respect, Turkey has 
focused on imports of the product concerned in the mo st recent period for which data are available.  
The table shows the development of imports for the years 2002-2006 and the first 9-month period 
of 2007.  
Volume of imports decreased by 57 per cent in 20 03 compared to level of imports in 2002.  In 
the following year, imports increased by 125 per cent.   The rates of increase were 79 per cent in 2005 
and 42 per cent in 2006.  The volume of imports in creased by 148 per cent in the period of 2000-
2005.  This reflects the fact that imports increased in absolute terms and the increase in imports is 
recent and substantial.    
 2002 2003 2004 2005 2006 2007 (1-7) 
Imports/ 
Production (%) 413,4 134,5 178,3 263,6 463,0 359,4 
 
 Relative to total domestic production, impor ts decreased from 413,4 per cent in 2002 to 
134,5 per cent in 2003.  The ratio then increased in 2004 to 178,3 per cent, 263,6 per cent in 2005 and 463 per cent in 2006.  Although it decreased in the sev en-month period in 2007, it still stayed in high 
ratio of 359,4 per cent.    
2. Market share of imports 
 2002 2003 2004 2005 2006 2007 (1-7) 
Market Share of 
Imports (%-Index) 81,0 59,4 66,7 75,8 83,2 73,4 
 
 In the investigation period, the market shar e of imports increased continually from 59,4 per 
cent in 2003 to 83,2 per cent in 2006.  The market sh are taken by imports is still 73,4 per cent, much 
bigger than the share of the domestic producers in the first seven-month period of 2007.    III. PRECISE DESCRIPTION OF THE PRODUCT INVOLVED 
 The products concerned are spectacle frames th at are currently classified within the Turkish 
Customs Tariff Schedule 9003.11 and 9003.19.    G/SG/N/8/TUR/8 
G/SG/N/10/TUR/8 G/SG/N/11/TUR/8 
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  IV. DESCRIPTION OF THE PROPOSED MEASURE 
 It is proposed to impose definitive safeguard me asure in the form of duty of 3 US Dollars per 
piece.   
 
Below is the list of Developing Countries excl uded from the measures as they export less 
than 3 per cent 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;  Brunei Darussalam;  Bolivia;  Brazil;  Bahamas;  
Bhutan;  Botswana;  Belize;  Bermuda;  Bouvet Isla nd;  British Virgin Islands;  British Indian Ocean 
Territory;  Democratic Republic of Congo;  Cent ral African Republic;  Congo;  Côte d'Ivoire;  
Cameroon;  Chad;  Colombia;  Costa Rica;  Cuba;  Cape Verde;  Cayman Islands;  Chile;  Christmas 
Islands;  Cocos Islands;  Cook Islands;  Djibouti;   Dominica;  Dominican Republic;  Algeria;  
Ecuador;  Egypt;  Eritrea;  Ethiopia;  Fiji;  Federate d States of Micronesia;  Falkland Islands;  French 
Polynesia;  French Southern Territories;  Gabon;  Gr enada;  Ghana;  Gambia;  Georgia;  Greenland;  
Guinea;  Equatorial Guinea;  Guatemala;  Guinea- Bissau;  Guyana;  Gibraltar;  Guam;  Honduras;  
Haiti;  Heard Island and McDonald Is lands;  India;  Indonesia;  Iraq;   Iran (Islamic Republic of);  
Jamaica;  Jordan;  Kazakhstan;  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 ;  Papua New Guinea;  Philippines;  Pakistan;  
Palau;  Paraguay;  Pitcairn;  Qatar;  Russian Fe deration;  Rwanda; Samoa;  Saudi Arabia;  Solomon 
Islands;  Seychelles;  Sudan;  Sierra Leone;  Sene gal;  Somalia;  Suriname;  Sao Tomé and Principe;  
El Salvador;  Syrian Arab Republic;  Swaziland;   South Georgia and S outh Sandwich Islands;  
St Helena and dependencies;  St Pi erre and Miquelon;  Tajikistan;  Th ailand;  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 Vincent;  Vietnam;  Vanuatu;  Virg in Islands of USA;  Wa llis and Futuna Islands;  
Yemen;  South Africa;  Zambia;  Zimbab we;  Indonesia;  Malaysia and Mexico.   
 
V. PROPOSED DATE OF INTRODUCTION OF THE MEASURE 
The investigation report was published in the Tu rkish Official Gazette on 30 January 2008.  
Application of the measure is pending ap proval of the Council of Ministers.   
 
VI. EXPECTED DURATION OF THE MEASURE 
 The expected duration of the proposed measure is three years.   
 
VII. PROPOSED DATE FOR THE REVIEW  
 Not applicable.   
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  VIII.  EXPECTED TIMETABLE FOR PROGRESSIVE LIBERALIZATION OF THE 
MEASURE 
 In order to facilitate adjustment, the proposed  measure will be subject to liberalization on a 
regular basis following its imposition, thereby en suring that there is an 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 3.00 US $ per piece 
2nd year 2.85 US $ per piece 
3rd year 2.70 US $ per piece 
 
IX. INFORMATION RELATING TO THE EXTENSION OF A SAFEGUARD MEASURE 
 Not applicable.   
 
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