(Advisory against practices that undermine existing anti-dumping and countervailing measures)
🔎 WHAT IS CIRCUMVENTION?
(Commercial practices designed to bypass existing trade remedies)
Circumvention refers to commercial strategies used by producers or exporters subject to trade remedies (anti-dumping or countervailing duties) in order to avoid paying such duties.
Common forms of circumvention include:
• 🔧 Minor technical modifications to the product to alter its customs classification (HS code)
• 🌍 Misrepresentation of the product’s country of origin
• 🧑🤝🧑 Routing exports through producers/exporters not subject to duties
• 🏗️ Shipping parts/components for assembly in Türkiye to avoid the duty
• 🛠️ Assembling the product in a third country before shipping it to Türkiye
For a case to qualify as circumvention, the following must be demonstrated:
• Injury to domestic industry, or
• A significant undermining of the remedy’s effect on price or quantity, or
• The imported product is still dumped or subsidized
🏛️ INITIATION & REPRESENTATION FOR DOMESTIC INDUSTRY
(Application process to initiate a circumvention investigation in Türkiye)
📊 Preparation and Technical Analysis
• 📈 Analysis of import trends indicating circumvention behavior
• 🧾 Identification of injury and erosion of the remedy’s effectiveness
• 📂 Compilation of evidence in line with WTO legal requirements
🗂️ Filing & Case Follow-up
• 🏛️ Submission of a compliant petition to the Ministry of Trade
• 📬 Timely response to additional requests from the Ministry
• 📢 Presentation of the domestic industry’s position before final decision
🌐 DEFENSE & REPRESENTATION FOR EXPORTERS
(Defense advisory in circumvention investigations initiated in Türkiye or abroad)
🛡️ Defense Strategy Development
• 📄 Legal and technical assessment of circumvention allegations
• 📂 Accurate and consistent completion of investigation questionnaires
• 🧷 Evidentiary support related to assembly, origin claims, and production methods
⚖️ International Representation & Case Management
• 🗣️ Oral and written rebuttals to domestic industry’s claims
• 🧭 Direct liaison with Turkish or foreign investigating authorities
• 📃 Submission of counterarguments and requests for corrections before final findings
📌 WHY CHOOSE US?
ADC Consulting brings over 25 years of experience in handling circumvention investigations both in Türkiye and internationally:
• Preparing strong, well-substantiated petitions on behalf of domestic industry
• Developing strategic defenses for exporters
• Providing effective representation throughout the entire proceeding
