Trade Remedies

A foreign exporter defends a Turkish anti-dumping investigation by making itself known within the period set in the initiation communiqué, answering the questionnaire within the 30 days allowed (questionnaires are deemed received one week after dispatch), and contesting the dumping margin, injury and causation in written submissions and hearings. Under Law No. 3577 the duty is levied up to the dumping margin, or at a lower rate where that is enough to remove the injury, so the exporter's own verified sales and cost data are its main defence, while a party that does not cooperate may be assessed on the facts available. We act for foreign exporters in anti-dumping, anti-subsidy and safeguard matters and in later reviews, and for domestic producers seeking protection against unfair imports.

Av. Onur ÇalışıcıIstanbul Bar reg. no 83426 · Updated October 2026

In brief

  1. Anti-dumping and anti-subsidy measures rest on Law No. 3577 on the Prevention of Unfair Competition in Importation and its implementing regulation, administered by the Ministry of Trade with a dedicated Board.
  2. There are three instruments: anti-dumping duty (on dumped imports), countervailing duty (on subsidised imports) and safeguard measures (against increased imports that cause or threaten serious injury). All three are designed to be WTO-consistent.
  3. An anti-dumping investigation is usually opened on a complaint from the domestic industry alleging dumped or subsidised imports and resulting injury; the Directorate General of Imports may also act on its own initiative.
  4. To impose a duty, the authority must establish three things: a dumping margin, material injury (or a threat of it) to the domestic industry, and a causal link between the two.
  5. Foreign exporters that answer the questionnaire in time and cooperate can obtain an individual duty rate calculated from their own data; a party that does not cooperate may be assessed on the facts available, with a less favourable result.
  6. Measures are not permanent: a definitive measure expires five years after it enters into force unless an expiry review is opened, and interim and newcomer reviews are also available.

Turkish trade-remedy law gives the state three tools to respond to unfair or damaging imports, and gives the businesses on either side of an import flow a formal process in which to be heard. The framework rests on Law No. 3577 on the Prevention of Unfair Competition in Importation and its implementing regulation, administered by the Ministry of Trade through the Directorate General of Imports and a dedicated Board. For a foreign exporter, an anti-dumping investigation can mean a duty that reshapes the economics of selling into Türkiye; for a domestic producer, the same process is the principal legal route to protection against dumped or subsidised competition. We act on both sides.

Anti-dumping and anti-subsidy measures sit within Law No. 3577 and its regulation. The Ministry of Trade runs investigations through the Directorate General of Imports, and a dedicated body, the İthalatta Haksız Rekabeti Değerlendirme Kurulu (Board for the Evaluation of Unfair Competition in Importation), assesses the findings and decides on measures, subject to the Ministry’s approval. Safeguard measures rest on separate legislation, the Regulation on Safeguard Measures in Imports. All three instruments are built to be WTO-consistent, mirroring the WTO Anti-Dumping, Subsidies and Safeguards agreements, which matters both for how they are argued domestically and for how they interact with the wider import and export regime.

Read the full section

Trade remedies are distinct from ordinary import charges. A dumping duty is not a general tariff set in the annual Import Regime Decree; it is a targeted measure tied to a specific product, origin and often a specific exporter, which is why the way goods are classified and cleared at the border, a customs-law question, interacts closely with the remedy itself.

What are the three trade-remedy instruments?

The three measures answer different problems, and confusing them is a common early mistake.

Read the full section
InstrumentTargetsTriggerNature
Anti-dumping dutyImports sold below normal valueComplaint by domestic industry, or ex officioProduct- and often exporter-specific
Countervailing dutyImports benefiting from a foreign subsidyComplaint by domestic industry, or ex officioOffsets the subsidy amount
Safeguard measureIncreased imports causing or threatening serious injuryWritten application by interested persons or their trade bodies, or ex officioTemporary, applied regardless of fault

Anti-dumping and countervailing duties address unfair trade: pricing below normal value, or state subsidisation. A safeguard is different. It responds to imports in increased quantities, even fairly traded ones, that cause or threaten serious injury to domestic producers of like or directly competitive goods, and it is temporary by design: including any provisional measure it may not exceed four years unless extended after a fresh investigation, and for imports from WTO members the total may not exceed ten years (Regulation on Safeguard Measures in Imports, article 11).

A fourth measure is frequently met alongside these but belongs to a different family. Import surveillance (gözetim) imposes no duty at all: it conditions clearance on a surveillance document where the declared unit value falls below the threshold named in a product-specific communiqué, and the communiqué itself states that the figure is not a basis for applying the customs-value provisions of Law No. 4458. How that threshold operates, and the objection route that follows, is set out in our note on import surveillance and reference prices.

What must the authority prove, and where can an exporter push back?

An investigation is usually set in motion by a complaint from the domestic industry. Once opened, the authority works to establish three things, and each is a distinct battleground:

Show the 3 points
  • Dumping margin: the amount by which the product’s normal value (broadly, its price in the exporting country’s home market) exceeds its export price to Türkiye. The methodology, the comparison period and the treatment of costs all shape the number.
  • Material injury: harm to the domestic industry, or a threat of it, evidenced by indicators such as price undercutting, lost sales and market share, idle capacity and falling profitability.
  • Causal link: proof that the dumped imports, rather than other factors, caused that injury.

A duty may be imposed up to the dumping margin, or at a lower rate where that is enough to remove the injury. Each element is contestable: an exporter may attack the normal-value calculation or the causation analysis, while a domestic producer builds the injury record that supports a measure. The stages, time limits and negligible-margin thresholds of an investigation are explained step by step in our guide to anti-dumping duties in Türkiye.

Deadlines in these proceedings are short and strict. An exporter that does not supply the necessary information in time is treated as non-cooperating and may be assessed on the “facts available”, and a domestic producer that files a thin complaint risks no investigation at all. The record you build in the first weeks tends to define the outcome.

How does a foreign exporter defend its duty rate?

The heart of the process is the questionnaire. For an exporter it captures cost, sales and pricing data; for a domestic producer it documents the injury picture. This is also where the single most important commercial point for exporters arises: participation.

Read the full section

An exporter that files a complete response and cooperates can be assigned an individual duty rate derived from its own figures, rather than the rate set for exporters that stay silent. Alongside the questionnaire, interested parties can request hearings, comment on the authority’s disclosures and its provisional determination, and rebut the claims of opposing parties. Getting the technical submissions right at this stage is what separates a defensible individual rate from an unfavourable one.

Two further tools matter for exporters. Where the investigation is limited to a sample, an exporter or producer that was not selected but supplies the necessary information in time is given its own dumping margin, unless there are so many of them that examining each separately would prevent the investigation being completed in time (implementing Regulation, article 27). An exporter may also offer a price undertaking, on its own initiative or at the Board’s suggestion, to remove the injurious effect of its imports; if the Board accepts it, the investigation can be suspended or concluded without provisional or definitive measures (Law No. 3577, article 11), although an undertaking can be proposed or accepted only once preliminary determinations of dumping and injury have been made (Regulation, article 32).

Can an exporter have a duty reviewed or removed later?

A measure is not the end of the story. A definitive anti-dumping or countervailing duty expires five years after it enters into force, or after the most recent review covering both dumping or subsidisation and injury, unless an expiry review is opened; domestic producers can apply for one no later than three months before expiry, and the review asks whether dumping and injury would likely continue or recur if the duty lapsed (implementing Regulation, article 35). Once a measure has been in force for one year, an interim review can be sought on evidence that the measure is no longer needed or no longer sufficient (article 34), and a newcomer review lets an exporter that did not export during the original investigation period, is not related to the exporters subject to the duty, and has exported to Türkiye after that period or entered into an irrevocable contractual obligation to export a significant quantity, obtain its own margin (article 36).

Read the full section

Separately, a final determination is an administrative act and can, on legal grounds, be challenged before the administrative courts within the applicable time limit. Choosing between a court challenge and a review, and sequencing them, is a strategic decision we take with the client.

Our Approach

We advise across the full trade-remedy lifecycle. For foreign exporters and importers, we assess exposure when an investigation opens, prepare questionnaire responses aimed at the lowest defensible individual rate, appear at hearings, and pursue reviews or court challenges where the measure is vulnerable. For domestic producers, we help build and file complaints and sustain the injury case through the investigation. Because a remedy sits on top of the ordinary import framework, we coordinate this work with a client’s customs and duty-relief planning and, for inbound businesses, with their wider investment and market-entry strategy. Contact us to discuss an investigation or a complaint.


Show the 4 points

Key figures

No. 3577
Law on the Prevention of Unfair Competition in Importation
3
Instruments: anti-dumping, countervailing and safeguard
5 yrs
Life of a definitive measure unless an expiry review is opened
WTO
All three measures are designed to be WTO-consistent

Related tool Customs duty and A.TR

How we handle a trade-remedy matter

  1. Assess exposure

    We review the initiation notice, the product scope and the GTİP codes involved, identify whether you are named or covered as an exporter or an interested domestic producer, and map the deadlines and the strategic options.

  2. Questionnaire and defence

    We prepare the questionnaire response (cost, sales and normal-value data for exporters, or injury and market evidence for producers), assembling the record needed to argue for an individual rate or for the measure itself.

  3. Hearings and submissions

    We attend hearings before the authority, comment on disclosures and the provisional determination, respond to other parties' claims and file legal submissions on dumping, injury and causation.

  4. Duty determination

    We argue for the most favourable outcome on the final measure, such as a lower individual duty, a narrower product scope or a negative finding, and advise on how the resulting duty affects your import costs.

  5. Reviews and appeals

    We pursue interim, newcomer and expiry reviews to change or end a measure, and challenge determinations before the administrative courts where grounds exist.

Frequently asked questions

What are trade remedies, and what are the three instruments?

Trade remedies (ticaret politikası savunma araçları) are measures a state may apply against unfairly traded or increasing imports. Turkish law provides three. An anti-dumping duty targets imports sold below their normal value; a countervailing duty targets imports that benefit from a foreign subsidy; and a safeguard measure is a temporary response to imports in increased quantities that cause or threaten serious injury to domestic producers of like or directly competitive goods, regardless of fault. Anti-dumping and anti-subsidy measures rest on Law No. 3577, while safeguards rest on separate legislation, the Regulation on Safeguard Measures in Imports; all three are designed to comply with the WTO agreements.

Who can start an anti-dumping investigation in Türkiye?

An investigation is usually triggered by a complaint from the domestic industry: producers who make the like product and consider they are being injured by dumped or subsidised imports, or persons acting on their behalf. The Directorate General of Imports at the Ministry of Trade can also examine a case on its own initiative (Law No. 3577, article 4). It completes its examination within at most 45 days and proposes to the İthalatta Haksız Rekabeti Değerlendirme Kurulu (the Board) whether an investigation should be opened; an investigation requires sufficient evidence of dumping or subsidisation and of resulting injury (implementing Regulation, article 20). The Board decides on opening the investigation and on measures, and provisional and definitive measures take effect with the Ministry's approval (Law No. 3577, articles 6, 12 and 13).

What must the authority prove before imposing an anti-dumping duty?

Three elements. First, a dumping margin: the amount by which the product's normal value (broadly, its price in the exporting country) exceeds its export price to Türkiye. Second, material injury to the domestic industry, a threat of material injury, or material retardation of the establishment of an industry, shown through indicators such as lost sales, price undercutting, falling market share and reduced profitability. Third, a causal link connecting the dumped imports to that injury. A duty may be imposed up to the dumping margin; if any of the three elements is missing, the investigation is closed without a measure.

We are a foreign exporter named in an investigation. Should we respond?

In most cases it is important to engage. Exporters that file a complete questionnaire response in time and cooperate can be assigned an individual duty rate calculated from their own data, rather than the rate set for exporters that do not participate. A party that does not supply the necessary information within the time allowed is treated as non-cooperating, determinations may then be made on the facts available, and the outcome may be less favourable than if it had cooperated (implementing Regulation, article 26). Responding also preserves your ability to comment at hearings and to seek later reviews. We can prepare the response and represent you through the proceeding.

How long do anti-dumping and countervailing measures last?

They are not permanent. A definitive measure expires five years after it enters into force, or after the conclusion of the most recent review covering both dumping or subsidisation and injury, unless an expiry review is opened. Domestic producers may apply for that review no later than three months before expiry, and the measure stays in force while the review runs; the question is whether dumping and injury would be likely to continue or recur if the measure lapsed (implementing Regulation, article 35). Once a measure has been in force for one year, an exporter, importer or domestic producer may seek an interim review supported by evidence (article 34), and an exporter that did not export during the investigation period, is not related to the exporters subject to the measure, and has exported to Türkiye after the investigation period or entered into an irrevocable contractual obligation to export a significant quantity may seek a newcomer review to obtain its own margin (article 36). A measure can be maintained, amended or terminated depending on the outcome.

Can a trade-remedy decision be challenged?

Yes. A final determination is an administrative act and can, on legal grounds, be challenged before the administrative courts within the applicable time limit, for example on procedural defects or on how dumping, injury or causation was assessed. In parallel, the review mechanisms under Law No. 3577 and its regulation (interim, newcomer and expiry reviews) offer a route to revisit a measure on the merits. We advise on which avenue fits your situation and on the interaction between a court challenge and a review.

How can a foreign exporter defend against an anti-dumping investigation in Türkiye?

The initiation communiqué in the Official Gazette sets the period within which interested parties may make themselves known to the Directorate General of Imports (implementing Regulation, article 20). Questionnaires are deemed received one week after dispatch and must be answered within 30 days, extendable on a reasoned request (article 21). The exporter can submit views, request a hearing in writing and is notified of the essential facts and findings before the final determination (articles 24 and 25). A party that does not supply the necessary information in time is treated as non-cooperating and may be assessed on the facts available (article 26). An interim review may be sought once a measure has been in force for one year (article 34).

This page is general information, not legal advice. For advice on your specific situation, speak with a lawyer.

Av. Onur Çalışıcı

The lawyer on your file

Av. Onur Çalışıcı

Founding Attorney · Istanbul Bar Association · Bar reg. no 83426

Lex lata is Latin for “the law as it is”. The office was founded by Av. Onur Çalışıcı, and you deal with Av. Çalışıcı directly from the first meeting to the end of the matter. With foreign clients we write in English and explain what each Turkish document says.

Write to us with what happened and which documents you have. We will read it and get back to you. You can write in English or Turkish.

Last reviewed: October 2026 · LinkedIn: linkedin.com/in/onurcalisici

OfficeKarataş Sk. No:6, SNS Plaza Kat:3, Kağıthane, Istanbul

On screen

Beyaz TV · Beyaz Ana Haber · September 2026 · In Turkish

Evicting a tenant who disturbs the neighbours

Why a tenant's unbearable conduct has to be shown with concrete evidence, and the exceptional cases in which the 30-day period may not be required.

Office and events

Gürsel Mah., Karataş Sk. No:6, SNS Plaza Kat:3, Kağıthane / İstanbul · Address and directions

The Lex Lata office in Kağıthane, Istanbul: desks and wall screens showing the Lex Lata logo
The office · Kağıthane, Istanbul
Av. Onur Çalışıcı on the blockchain law panel at Blockchain Expo World, Istanbul, July 2024
Blockchain law panel · Blockchain Expo World, Istanbul · July 2024
A meeting around the table in the Lex Lata meeting room
Meeting room · Kağıthane, Istanbul

SNS Plaza, Kağıthane, IstanbulContact page