I. Introduction
The Ministry of Trade has opened two expiry reviews of existing antidumping measures. The Communiqué on the Prevention of Unfair Competition in Imports (Communiqué No. 2026/25), published in the Official Gazette dated 3 July 2026 and numbered 33299, concerns only suspension-type polyvinyl chloride (PVC-S) originating in Germany and the United States. Communiqué No. 2026/26, published in the Official Gazette dated 4 July 2026 and numbered 33300, concerns specified plastic ball-point pens and sets containing those pens originating in the People’s Republic of China.
Both communiqués entered into force on publication, and each review is deemed to have commenced on its publication date. Opening an expiry review does not determine whether the measure will continue, change or expire. It begins the Ministry’s examination of whether the expiry of the measure would be likely to lead to the continuation or recurrence of dumping and injury.
The existing measures remain in force until the reviews are concluded. Exporters, foreign producers and Turkish importers should therefore base current customs and pricing decisions on the measures still in force, while establishing the precise product scope, origin and participation period applicable to their position.
II. Existing Measures and Opening Decisions
For PVC-S, the existing measure was most recently continued by Communiqué No. 2021/29, published in the Official Gazette dated 14 July 2021 and numbered 31541. The measure is 7.93% of the CIF value for covered PVC-S originating in either Germany or the United States. Communiqué No. 2026/25 records the domestic industry’s application and the authority’s conclusion that sufficient information, documents and evidence existed to open a further expiry review. This is a procedural threshold for opening the review, not a final finding on whether dumping or injury would continue or recur.
For plastic ball-point pens, Communiqué No. 2021/37, published in the Official Gazette dated 15 July 2021 and numbered 31542, continued the existing measure at USD 0.066 per unit for the covered Chinese-origin products. Communiqué No. 2026/26 followed an application by Pensan Kalem ve Kağıt San. ve Tic. A.Ş., supported by three other domestic producers, and similarly records that sufficient information, documents and evidence existed to open the review.
The 7.93% rate and the USD 0.066 per-unit amount are the existing antidumping measures; they are not dumping margins determined in the newly opened reviews. Both opening communiqués expressly provide that the relevant measure will remain in force until the review is concluded. Because the reviews have been opened, expiry of the five-year period does not, by itself, end the current measures.
III. Product and Country Scope
Communiqué No. 2026/25 covers only suspension-type polyvinyl chloride (PVC-S) originating in Germany or the United States. It identifies Turkish customs tariff statistical position (GTİP) 3904.10.00.00.19 for information, but states that this classification is not binding. The product description determines the scope, and later changes to the tariff position or description do not prevent the communiqué from being applied.
Communiqué No. 2026/26 covers three Chinese-origin categories: liquid-ink ball-point pens made of plastic under GTİP 9608.10.10.10.00; “other” pens, limited to gel-ink ball-point pens made of plastic, under GTİP 9608.10.99.00.00; and “articles made of plastic” under GTİP 9608.50.00.10.00 in sets containing either of those two types of pen. These tariff positions are also stated to be informative rather than binding.
The tariff code does not replace a product-scope review. Technical specifications, materials, ink type, set composition, commercial descriptions and origin records should be examined together. Any distinction between covered and non-covered goods should also be reflected consistently in catalogues, contracts, invoices, packing lists, customs declarations and product master data.
IV. Interested Parties, Participation Periods and Submissions
The communiqués identify exporters, foreign producers, importers, trade associations whose members mainly consist of those parties, exporting-country governments, Turkish producers of the like product, and trade associations whose members mainly consist of those producers as interested parties. To be taken into account as an interested party in the review, a party must identify itself to the competent authority by submitting its questionnaire response or views within the applicable period.
Article 11 of Communiqué No. 2026/25 and Article 12 of Communiqué No. 2026/26 establish two different starting events for the 37-day period. For parties to whom an opening notification is sent, the questionnaire-response period is 37 days from the date of dispatch, including postal time. Parties to whom the notification could not be sent must submit their questionnaire responses and views within a separate 37-day period beginning on publication of the relevant communiqué. There is therefore no single calendar deadline that applies to every participant.
Both reviews are conducted by the General Directorate of Imports of the Ministry of Trade. Written and oral communications in the investigations must be in Turkish, subject to the exception stated for questionnaire responses. Where an overseas party acts through a legal representative, the power of attorney must meet the signature, Turkish or English translation, and apostille or consular authentication requirements set out in the relevant communiqué.
Information submitted as confidential must be accompanied by a non-confidential summary that permits a reasonable understanding of its substance. If information cannot exceptionally be summarised, the reasons must be explained.
A party that fails to provide the requested information within the prescribed period and form, refuses access, obstructs the investigation, or supplies false or misleading information may be treated as non-cooperating. Provisional or final determinations may then be made on the facts available, and the outcome may be less favourable than it would have been had the party cooperated.
Communiqué No. 2026/26 contains an additional rule for producers established in China. A producer seeking market-economy treatment must establish, within the applicable period and with sufficient evidence, that the criteria in Additional Article 1 of the Regulation are met. Article 5 of the Regulation then applies to the determination of normal value; otherwise, Article 7 applies. Where Article 7 is applied, the communiqué envisages Turkey as the analogue country.
V. Commercial Implications for Exporters and Importers
Import-cost calculations should continue to include the applicable antidumping measure. Exporters and Turkish importers should review customs treatment together with invoices, delivery terms, price-adjustment provisions and clauses allocating the burden of trade-remedy duties. If the contract does not state clearly which party bears that burden, a customs payment can give rise to a separate commercial dispute between the parties.
Consistent product records are equally important. For PVC-S, technical specifications, origin evidence and invoice descriptions should correspond to the covered product description. For pens, company records should distinguish liquid-ink pens, gel-ink pens, other writing instruments and goods sold in sets. Conflicting descriptions across catalogues, contracts, packing lists and customs documents may complicate both customs treatment and the presentation of evidence in the review.
Internal assessments and customer communications should reflect the same current legal position without predicting the result. A company may state that the review is pending and the existing measure remains in force, but should not state that the measure will necessarily be removed, continued or changed. Different pricing outcomes may be modelled internally while external statements remain limited to the present legal status.
The two reviews also require separate factual records. They use the same expiry-review mechanism, but concern different products, countries, measures and evidence; the Chinese proceeding also includes the market-economy issue described above. The same internal team may monitor both matters, but the data sets, supporting documents and legal positions should remain separate.
VI. Conclusion
Communiqués No. 2026/25 and 2026/26 have opened expiry reviews for the covered PVC-S and plastic ball-point-pen measures, while keeping the existing measures in force until the proceedings are concluded. Affected companies should first determine the products and transactions within scope, whether an opening notification was received, which participation period applies, and who holds the data required for a response.
Notification status determines when the relevant 37-day period begins. Exporters, foreign producers and Turkish importers intending to participate should therefore organise their evidence, representation documents, confidential submissions and non-confidential summaries by reference to their own procedural position. Until the Ministry reaches its determinations, commercial planning should continue to reflect the measures currently in force.
