G/SG/N/8/TUR/17  
G/SG/N/10/TUR/17  
G/SG/N/11/TUR/24  
 
23 October 2019  
(19-6983) Page: 1/7 
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 OF A PROPOSAL TO IMPOSE A  MEASURE ) 
 
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2  
OF THE AGREEMENT ON SAFEGUARDS  
TURKEY 
(Yarns Made of Nylon or Other Polyamides ) 
The following notification, dated 22 October 201 9, is being circulated at the request of the delegation 
of Turkey.  
 
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Concerning imports of yarns made of nylon or other polyamides, Turkey had notified the initiation 
of a safeguard investigation with the WTO Document G/SG/N/6/TUR/25 , dated 4 January 2019.  
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 r eferences and 
sources can be found at the following internet address:  
https://www.resmigazete.gov.tr/eskiler/2019/10/20191022 -10.htm . 
Consistent with Article 12.3 of the  Agreeme nt on Safeguards,  Turkey is prepared to consult with 
those Members having a substantial interest 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 injury or threat thereof to the domestic producers 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 was  undertaken. The data, which were submitted 
by the applicant companies and utilized in this analysis, represent major proportion of the total 
domestic production of the product subject to investigation according to the 2018 figures.   
1. Consumption  
Unit (To ns) 2015  2016  2017  2018  
Consumption (Indexed)  100 112 119 113 G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  Consumption index rose during the period under consideration (PUC). Consumption reached its peak 
in 2017 with a level that is 19% higher than its level in 2015.  
2. Production  
Unit (Tons)  2015  2016  2017  2018  
Production (Indexed)  100 90 88 61 
Production index decreased continuously and significantly during the PUC. Production level 
decreased by 39% from 2015 to 2018.  
3. Domestic Sales  
Unit (Tons)  2015  2016  2017  2018  
Domestic Sales (Indexed)  100 100 85 64 
Domestic sales index was stable from 2015 to 2016, whereas it decreased in the following two years. 
Consequently, the index declined to 64 as its lowest point in 2018.  
4. Capacity and Capacity Utilization Ratio (CUR)  
Unit (Tons)  2015  2016  2017  2018  
Capacity (Indexed)  100 100 100 100 
CUR (%) (Indexed)  100 90 88 61 
Production capacity remained unchanged throughout the period. Capacity utilization ratio (CUR) 
index declined continuously from 100 in 2015 to 61 points in 2018.  
5. Inventories  
Unit (Tons)  2015  2016  2017  2018  
Stocks  (Indexed)  100 56 30 60 
At the end of the investigation period, inventory index decreased to 60 points in 2018. In general, 
the inventory indicator followed a negatively fluctuating course during the PUC. Besides, inventories 
increased significantly at the end of the PUC compared  to the level of the preceding year.  
6. Employment  
Workers  2015  2016  2017  2018  
Employment  (Indexed)  100 111 97 88 
Employment index usually showed a descending pattern throughout the period under consideration 
in line with the production index.  
7. Labor Productivity  
Unit (Tons)  per Worker  2015  2016  2017  2018  
Productivity (Indexed)  100 81 91 70 
Labor productivity index displayed a fluctuating trend of 81 points in 2016 and 91 points in 2017. 
The index declined to 70 points, its lowest level of the period, in 2018.  
8. Profitability  
Net Profit/Total Sales  2015  2016  2017  2018  
Profitability (Indexed) (%)  100 -61 -55 -81 G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  Domestic industry incurred significant losses from sales of the product concerned through 2016 
onwards.  
9. Conclusion  
Domestic industry's production and domestic sales of the product concerned decreased notably 
whereas consumption increased during the PUC. The production capacity of the producers remained 
stable while the capacity utilization decreased gradually. As a res ult, employment decreased 
constantly together with the labor productivity. In addition, domestic industry faced significant losses 
throughout the period analyzed.  
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 no t attributed to increased imports, the 
investigating authority analyzed 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 PUC. In the first 2 
years of the investigation period, the imports increased by 15% from 2015 to 2016 and by 14% 
between 2016 and 2017. From 2017 to 2018, the quantity of impor ts increased by 2%, while the 
increase between the January -June periods of 2018 and 2019 was 4%.  
Likewise, the market share of imports increased significantly between 2015 and 2018. Therefore, it 
is concluded that the increase in imports and the deteriora tion in the economic indicators of the 
domestic industry followed a similar pattern throughout the period analyzed due to the slump of the 
domestic sales of the producer companies within the Turkish market.  
In conclusion, it is inferred that there is a correlation between the increase in imports and the serious 
injury that the domestic industry is exposed to.  
(b) Conditions of Competition  
The product concerned covers a wide scope of yarns that are being used in the manufacturing of 
various products such as n ylon stockings, seamless underwear and home textile. According to the 
information obtained during the investigation, the investigation authority understood that price is 
the most significant criteria for the users of the product under consideration. In thi s respect, it is 
evident that price levels mainly determine the sales volumes of domestic and imported goods within 
Turkish market.  
The figures related to the unit prices of the imported good show that the average unit prices of the 
imported good fell X % below the prices of domestic products. In order to make a comparison 
between sales prices of the imported and domestic goods, the unit prices of the textured yarns 
determined as the most imported product group among the PUC, were obtained from the domestic  
industry and the Turkish Statistical Database for 2019. The import prices of some exporter countries 
and domestic producers can be found on the following table.  G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  Drawn textured yarn made of nylon or other polyamides  Unit Import/Sale Prices  
Chinese Taipei  3,41 $/Kg  
P.R.C.  3,58 $/Kg  
Average of All Imports into Turkey  4,22 $/kg  
Domestic Producers (ex -works)  X $/Kg  
The average import prices of the first two import sources remain significantly lower than total 
average import prices.  In this framework, it is concluded that imported goods undercut the prices of 
the domestic producers during the period concerned.  
(c) Coinciding Trends  
It is understood that there is parallelism between all the relevant factors of an objective and 
quantifiable nature having a bearing on the situation of the domestic industry such as the  decline in 
the profitability, the recent increase in the imports of the product concerned in absolute and relative 
terms  and the increase in the market share of the imports.  
Moreover, the applicant companies could not increase their capacity due to the constraining impacts 
of the imports despite the fact that total consumption increased in the period from 2015 to 2018. 
For instance, while the imports increased significantly, the domestic production decreased 
harmoniously with the capacity utilization ratio in the investigation period.  
Taking into account these evaluations, it is concluded that the surge in the imports of t he product 
concerned and the serious injury on the domestic producers are related.  
(d) Other Factors  
(i) Exports  
The investigating authority concluded that the changes in the level of exports were not a cause of 
serious injury suffered by the domestic producers.  
(ii) Production Technology of the Domestic Producers  
Some parties claimed that the domestic producers could no t compete with imported product in terms 
of quality. However, not only the findings from on the spot investigations but also other documents 
submitted by the interested parties throughout the investigation reveal that the production 
technologies of the dom estic producers are identical with the exporter companies' that allow them 
to produce all qualities of products.  
As a result, it appears that technology did not play a role in the serious injury that the domestic 
industry has been facing.  
2. Conclusion on C ausation  
From 2015 to 2018, the quantities of imports increased significantly at the rate of 33%. In this 
framework, having concluded that there is a correlation between the increase in imports and the 
serious injury that the domestic industry has been fac ing; having examined the effects of other 
known factors and having determined 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 has been exposed to.  G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  II. INFORMATION ON WHETH ER THERE IS AN ABSOL UTE INCREASE IN IMPO RTS OR 
AN INCREASE IN IMPOR TS RELATIVE TO DOMES TIC PRODUCTION  
1. Unforeseen Developments -Developments in Other Markets  
Global Exports of the Main Supplier  Countries  
  2014  2015  2016  2017  2018  2014 -2018  
Country  Tons  Tons  Tons  Tons  Tons  % ∆ 
Chinese Taipei  135.676  118.166  115.075  108.324  98.354  -28% 
P.R.C.  89.171  91.914  114.762  128.894  131.453  47% 
Italy 115.122  108.983  107.805  105.929  101.070  -12% 
Russian Federation  1.387  1.678  1.051  3.096  3.509  153%  
Republic of Korea  35.657  34.485  32.665  31.476  30.864  -13% 
Germany  25.060  22.799  19.862  20.445  16.901  -33% 
Israel  13.682  10.523  14.925  12.502  10.086  -26% 
India 1.967  1.604  1.788  3.242  5.421  176%  
Slovenia  49.259  44.458  43.918  47.086  46.760  -5% 
Indonesia  13.315  13.409  13.153  12.821  12.445  -7% 
 
According to the International Trade Centre data for the period of 2014 -2018, the share of Chinese 
Taipei, which is Turkey's primary source of imports, in global exports decreased significantly while 
imports from Chinese Taipei into Turkey increased notably at the same period. In addition to this 
fact, China, Russia and India increased the quantity of their global exports by rates of 47%, 153% 
and 176%, respectively. Continuously increasing production quantities in those developing supplier 
countries and their low raw material and labor cost levels have paved the way for increase in imports 
of yarns made of nylon into Turkey. Thus, domestic produc ers, which could once compete with those 
producers in the developed countries, had to face with huge suppliers in a very short span of time.  
 
In the light of the above evaluations, the investigating authority concluded that the unforeseen 
recent developments in the world market had a negative impact on the import trend of Turkey during 
the investigation period.  
2. Increase in Imports  
An analysis of the increase in imports into Turkey of the product concerned both in absolute and 
relative terms was ca rried out over the period from 2015 to January -June of 2019. Imports of the 
product concerned increased considerably, both in absolute terms and relative to domestic 
production, during the period of investigation.  
(a) Absolute Imports  
Imports  
(Tons)  2015  2016  2017  2018  2018  
(1-6) 2019  
(1-6) 
24.986  28.622  32.514  33.174  18.050  18.833  
Imports of the product subject to investigation increased constantly during the period analyzed. 
Imports grew by 4% in the first 6 -month period of 2019 compared with the same period of 2018.  
(b) Relative Imports  
Imports/Production  
 (% – Index)  2015  2016  2017  2018  
100 111 121 150 
Similar to imports in absolute terms, the ratio of imports to domestic production rose dramatically 
throughout the period of investigation.  
(c) Market Share of Imports  
Market Share of Imports  
(% – Index)  2015  2016  2017  2018  
100 102 111 117 
The imports of the product subject to investigation increased its market share significantly in the 
last 4 -year period.  G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  (d) Share of Countries in Turkey's Imports  
Country  2015  2016  2017  2018  
Qty. (%) Qty. (%) Qty. (%) Qty. (%) 
Chinese Taipei  13% 10% 16% 25% 
P.R.C.  13% 17% 22% 17% 
Italy 14% 10% 11% 9% 
Russian Federation  4% 1% 6% 6% 
Republic of Korea  3% 4% 4% 6% 
Germany  9% 7% 8% 6% 
Israel  12% 12% 10% 5% 
India 0% 0% 1% 4% 
Slovenia  4% 2% 1% 3% 
Indonesia  2% 4% 3% 3% 
Thailand  2% 2% 1% 3% 
Poland  1% 2% 2% 2% 
Belarus  0% 0% 1% 2% 
Vietnam  0% 1% 2% 2% 
Croatia  2% 2% 2% 2% 
Czechia  0% 1% 1% 1% 
Belgium  0% 0% 1% 1% 
Spain  3% 1% 1% 1% 
Egypt  0% 1% 1% 1% 
Bulgaria  1% 2% 1% 1% 
Others  17% 22% 4% 2% 
 
The distribution of imports among supplying countries changed notably during the period concerned. 
Particularly, the share of products originated in Chinese Taipei, that are characterized with relatively 
low unit price levels, expanded dramatically in 2017  and 2018 whereas products of Italian, Israeli 
and German origin lost their position in the composition of imports.  
III. PRECISE DESCRIPTION OF THE PRODUCT INVOL VED 
The subject product is classified under Turkish Customs Codes 5402.31, 5402.32.00.00.00, 5402.4 5, 
5402.51 and 5402.61 in Turkish Customs Tariff Schedule of 2019. It includes DTY (Drawn Textured 
Yarn), FDY (Fully Drawn Yarn), POY (Partially Oriented Yarn) and other yarns made of Nylon or other 
Polyamides.  
IV. DESCRIPTION OF THE P ROPOSED MEASURE  
The impos ition of a definitive safeguard measure is proposed in the form of specific duty per 
kilogram, which will be implemented as shown in the table below.  
Customs Tariff 
Statistics Code  Definiton  Proposed Measure  
1st Year 2nd Year 3rd Year 
5402.31  Of nylon or other polyamides, measuring 
per single yarn not more than 50 tex  
0,30 USD/Kg  0,29 
USD/Kg  0,28 
USD/Kg  5402.32.00.00.00  Of nylon or other polyamides, measuring 
per single yarn more than 50 tex  
5402.51  Of nylon or other polyamides  
5402.61  Of nylon or other polyamides  
5402.45  Other, of nylon or other polyamides  0,10 USD/Kg  0,09 
USD/Kg  0,08 
USD/Kg  
Below is the list of developing countries excluded from the measure, according to Article 9.1 of the 
Agreement on Safeguards,  as they  constitute less than 3% individually and 9% collectively of 
imports of Turkey. The exemption will be applied in the form of tariff quotas. To that end, each 
country will be granted, for each period, a tariff quota of 995 tons, the amount that represents 3 % 
of imports of Turkey of the product concerned in the year 2018. Overall, total amount of tariff quota 
shall not exceed 2.986 tons, 9% of total imports of Turkey in 2018.  
Afghanistan, Albania, Algeria, Angola, Antigua And Barbuda, Argentina, Azerbaijan - Nakhichevan, 
Bangladesh, Barbados, Belarus, Belize, Benin, Bhutan, Bolivia, Bosnia and Herzegovina, Botswana, G/SG/N/8/TUR/17 • G/SG/N/10/TUR/17 • G/SG/N/11/TUR/24  
 
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  Brazil, Burkina Faso, Burundi, Cambodia, Cameroon, Cape Verde, Central African Republic, Chad, 
Chile, Colombia, Comoros, Congo, Congo Dem. Republ ic, Cook Islands, Costa Rica, Cuba, Djibouti, 
Dominica, Dominican Republic, East Timor, Egypt, El Salvador, Equator, Equatorial Guinea, Eritrea, 
Ethiopia, Fiji, Financial, French Polynesia, Gabon, Gambia, Georgia, Ghana, Grenada, Guatemala, 
Guinea, Guinea -Bissau,, Guyana, Haiti, Honduras, Iran, Iraq, Ivory Coast, Jamaica, Jordan, 
Kazakhstan, Kenya, Kirghizstan, Kiribati, Kosovo, Laos, Lebanon, Lesotho, Liberia, Libya, Macedonia, 
Madagascar, Malawi, Malaysia, Maldives, Marshall Islands, Mauritania, Mauritius , Mexico, Micronesia, 
Moldova, Mongolia, Montenegro, Montserrat, Morocco, Mozambique, Myanmar, Namibia, Nauru, 
Nepal, Nicaragua, Niger, Nigeria, Niue, North Korea, Oman, Pakistan, Palau, Palestine, Panama, 
Papua New Guinea, Paraguay, Peru, Philippines, Rwa nda, Samoa, Sao Tome and Principe, Senegal, 
Serbia, Seychelles, Sierra Leone, Solomon Islands, Somalia, South Africa, South Sudan, Sri Lanka, 
St. Vincent and the Grenadines, St. Kitts and Nevis, St. Lucia, Sudan, Suriname, Swaziland, 
Tajikistan, Tanzania, Thailand, Togo, Tonga, Trinidad and Tobago, Tunisia, Turkmenistan, Tuvalu, 
Uganda, Uruguay, Uzbekistan, Vanuatu, Venezuela, Vietnam, Yemen, Zambia, Zimbabwe.  
V. PROPOSED DATE OF INTRODUCTION OF THE MEASURE  
The measure will enter into force on 21/11/2019. The related Presidential Decree was published in 
the Official Gazette on 22/10/2019 . 
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 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 progress ively the necessary restructuring and adjustment programs. The 
proposed measure is to be progressively liberalized as indicated in item IV above.  
IX. INFORMATION RELATING TO THE EXTENSION OF A SAFEGUARD MEASURE  
Not applicable.  
 
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