Safeguard Investigation on Certain Paper and Paperboard Imports – Initiation of Investigation (Communiqué No: 2026/3, Türkiye)
Why this matters for importers and exporters of paper and paperboard to Türkiye and compliance teams:
The initiation of this safeguard investigation signals a material trade policy risk for companies importing or exporting paper and paperboard under GTP 4810.29 and 4810.92 to Türkiye. Safeguard proceedings are origin-neutral and can lead to additional duties, quotas, or tariff-rate quotas if serious injury (or threat thereof) is established. Even before any measure is imposed, the investigation itself introduces pricing uncertainty, supply planning constraints, and contractual risk, particularly for businesses with high import dependence or long-term supply agreements.
From a compliance perspective, the process places immediate emphasis on data accuracy, timely submissions, and strategic engagement. Importers and exporters must be prepared to substantiate historical volumes, pricing trends, and market behavior within strict procedural timelines and Turkish-language submission requirements. Failure to participate—or participation with incomplete or inconsistent data—can result in adverse determinations based on facts available, materially increasing the likelihood of restrictive outcomes and long-term cost impact.
Executive Summary
With Communiqué No: 2026/3, published in the Official Gazette dated 31 December 2025, the Turkish Ministry of Trade has initiated a safeguard investigation concerning imports of certain paper and paperboard products classified under GTP 4810.29 and 4810.92. The investigation aims to assess whether the recent increase in imports has caused or threatens to cause serious injury to the domestic industry, potentially leading to the imposition of safeguard measures.
Scope
The investigation covers the following products under the Turkish Customs Tariff Schedule (TGTC):
- GTP 4810.29 – Paper and paperboard used for writing, printing or other graphic purposes: Other
- GTP 4810.92 – Other paper and paperboard: Multilayer
These products are examined irrespective of country of origin, in line with safeguard principles.
Initiation and Preliminary Findings
Based on an application submitted by domestic producers, the Ministry conducted a preliminary review and identified:
- A significant increase in imports, both in absolute and relative terms
- Sustained and rising import market share during the period under review
- Deterioration in key economic indicators of the domestic industry, including production, domestic sales, profitability, productivity, capacity utilization rates, and end-period inventories
These findings were deemed sufficient to justify the initiation of a formal safeguard investigation.
Investigation Process
The investigation will be conducted by the Import General Directorate under the framework of the Regulation on Safeguard Measures on Imports.
Interested Parties
- Domestic interested parties must submit questionnaire responses and views via their official KEP (Registered Electronic Mail) addresses to:ticaretbakanligi@hs01.kep.tr
- Foreign interested parties must submit responses and views via email to:korunma@ticaret.gov.tr
Questionnaires and Submissions
- Questionnaires and the non-confidential summary of the application are available on the Ministry’s website under:Imports → Trade Policy Defense Instruments → Safeguard Measures / Investigations
- All submissions must be made within 30 days from the date of publication of the Communiqué.
- All communications and documents must be submitted in Turkish. Submissions in other languages will not be considered.
Confidentiality and Verification
- Confidential information must be accompanied by a non-confidential summary allowing reasonable understanding.
- Failure to provide requested information on time, obstruction of the investigation, or submission of misleading data may result in conclusions being drawn on the basis of facts available.
Duration of the Investigation
- The investigation will be completed within nine months, with a possible extension of up to six additional months if deemed necessary.
Enforcement and Compliance Risk
Importers, exporters, and other stakeholders dealing in the products concerned should closely monitor the investigation. Depending on the findings, safeguard measures such as additional duties, quotas, or tariff-rate quotas may be imposed, which could significantly impact cost structures and supply planning.
Compliance Assessment
From a trade compliance perspective, companies importing paper and paperboard under GTP 4810.29 and 4810.92 should:
- Review historical and ongoing import volumes and pricing
- Prepare accurate and consistent data for questionnaire responses
- Assess contractual and pricing flexibility in case safeguard measures are introduced
- Engage proactively in the investigation process to mitigate potential adverse outcomes
Early preparation and strategic participation are critical to managing both regulatory risk and commercial impact.
Entry into Force
The Communiqué entered into force on the date of its publication, 31 December 2025.
Other legislation updates
- Türkiye – Amendment to Customs General Communiqué No. 16: Clarification on Simplified Procedure for OKSB Holders
- Türkiye – Anti-Dumping Measures Expiring in 2026: Official Notice under Communiqué No. 2026/4
- Türkiye – Amendment to the Free Zones Implementation Regulation: Licensing, Accounting Separation and Superstructure Regime
- Amendment to the Minimum Fee Tariff for Customs Brokers and Authorized Customs Brokers (Türkiye – Regulatory Update)
- Imposition of Definitive Anti-Dumping Measures on Tin-Coated Flat-Rolled Steel Products Originating in Germany, China, Korea, Japan and Serbia