I. Introduction
Communiqué No. 2026/28 on the Prevention of Unfair Competition in Imports, published in Official Gazette No. 33340 dated 14 August 2026 (the “Communiqué”), announced eleven anti-dumping and countervailing measures whose periods of application will expire during the first half of 2027. Unless an expiry review investigation, known in Turkish as a nihai gözden geçirme soruşturması (“NGGS”), is opened in respect of them, those measures will expire between 15 January and 14 June 2027.
For domestic producers of the listed products, the calendar effectively opens a filing period. The relevant domestic producers, as well as natural or legal persons and organisations able to substantiate that they act on behalf of the domestic industry, may request the opening of an NGGS on the ground that expiry of the measure would lead to the continuation or recurrence of dumping or subsidisation and injury. The application must be supported by sufficient evidence and transmitted to the Ministry of Trade from the applicant’s own registered electronic mail (“KEP”) address no later than three months before the measure expires.
Preparation cannot safely be organised around the final day for transmission. The capacity in which the applicant acts, the matching of the product to the measure in force, the evidence supporting the claim, and the corporate authority for the KEP transmission must all be brought together in the same file. As the earliest filing deadline in the table is 15 October 2026, producers within scope should complete their product-and-measure mapping without delay. An initial screening to match the product with the measure in force, together with the monitoring of NGGS filing deadlines, can be carried out through the ASY Legal Trade Defense Hub.
II. Legal Framework For An NGGS Application
The Five-Year Period And The Effect Of Opening A Review
Article 5 of the Communiqué regulates the duration of definitive measures by reference to Article 35 of the Regulation on the Prevention of Unfair Competition in Imports. A definitive measure expires five years after the date on which it entered into force or the date on which the most recent review covering both dumping or subsidisation and injury was concluded.
That result changes where an NGGS is opened following a valid application. The application is evaluated by the Department of Dumping and Subsidies within the Directorate General for Imports of the Ministry of Trade. If it is considered valid, an investigation is initiated and the measure in force continues to apply until the investigation is concluded. A timely application therefore does not itself extend the measure for another five years; continuation of the existing measure until the investigation is concluded depends on the application being found valid and an NGGS being opened.
Who May Apply And What Must Be Shown
The right to apply belongs to the relevant domestic producers of the products listed in the table and to natural or legal persons and organisations able to substantiate that they act on behalf of the domestic industry. The fact that a product is manufactured in Turkey does not by itself show that the applicant falls within this group. It is therefore important for the file to establish that the applicant is a relevant domestic producer or acts on behalf of the domestic industry concerned.
The Communiqué also defines the substantive case that must be made. The applicant must support with sufficient evidence its claim that expiry of the measure would lead to the continuation or recurrence of dumping or subsidisation and injury. An NGGS file cannot therefore consist only of a request to preserve the existing measure. It must establish an evidence-based connection among the product, the measure, the domestic industry and that claim.
III. The 2026-2027 Filing Calendar
The table under Article 4 of the Communiqué states the expiry date for each measure. The final column below has been calculated by going back three calendar months from each expiry date under the “no later than three months before” rule. These are not dates on which preparation should begin; they are the last dates by which the KEP transmission must have been completed.
| Product or product group | Communiqué | Expiry date | Calculated filing deadline (KEP) |
|---|---|---|---|
| Certain engines under tariff code 8408.90.41.90.00 | 2021/52 | 15 January 2027 | 15 October 2026 |
| Bicycle outer and inner tyres and the wheels listed in the table | 2022/3 | 20 January 2027 | 20 October 2026 |
| Motorcycle outer and inner tyres and the wheels listed in the table | 2022/4 | 20 January 2027 | 20 October 2026 |
| Certain room-type hot and cold air appliances (fan coils) | 2022/1 | 2 February 2027 | 2 November 2026 |
| Sodium formate | 2022/2 | 2 February 2027 | 2 November 2026 |
| Safety glass detailed in the table by tariff code and exclusions | 2022/7 | 23 February 2027 | 23 November 2026 |
| Certain polyester sheets, plates, film, foil and strip | 2022/8 | 6 March 2027 | 6 December 2026 |
| Connection parts for artificial teeth | 2022/12 and 2025/4 | 14 April 2027 | 14 January 2027 |
| Glass lids solely for pots, pans and teapots | 2022/13 | 13 May 2027 | 13 February 2027 |
| Transmission chains and parts listed in the table | 2022/14 | 13 May 2027 | 13 February 2027 |
| Certain chillers for central air-conditioning and process water | 2022/17 | 14 June 2027 | 14 March 2027 |
Of the calculated filing deadlines, 6 December 2026 and 14 March 2027 fall on Sundays, while 13 February 2027 falls on a Saturday. As the Communiqué does not provide a separate extension rule for these cases, the transmission for those files should be completed earlier rather than left until the business day immediately preceding the weekend. This approach does not extend the statutory period; it only leaves a reasonable margin for preparing the KEP message, obtaining the required approval and retaining evidence of transmission.
IV. Matching Product Scope To The Measure In Force
The table in the Communiqué identifies not only the expiry dates, but also the tariff position used when the measure was published, the product description, the Official Gazette date and number, and the number of the relevant communiqué. Those elements must be read together. An apparent match between a company’s products and a GTİP or GTP number does not by itself establish that the product falls within the measure. Technical product descriptions, parenthetical limitations and express exclusions in the table form an integral part of the assessment.
This distinction is particularly visible for engines, tyre and wheel components, safety glass and chiller products. The engine entry, for example, excludes water-cooled engines and engines with more than one cylinder. The safety-glass and chiller entries also contain limitations based on technical use or product type. The assessment must therefore use technical specifications, tariff classification and the scope stated in the relevant measure communiqué, rather than the company’s commercial product name.
A second mapping exercise is also required during preparation. The entry in Communiqué No. 2026/28 must be compared with the earlier measure communiqué identified in that entry, while the measure’s country, exporter or producer coverage, rate and any subsequent changes must be verified against the original measure communiqué and later official acts. Those elements cannot be derived from the calendar table and directly determine the import and market data on which the NGGS claim should be built.
V. Evidence File, KEP Transmission And Corporate Preparation
Building The Application File
Although the Communiqué requires the application to be supported by sufficient evidence, it does not enumerate every category of evidence. The file should show both that the applicant is a domestic producer or acts on behalf of the domestic industry and that there is sufficient evidence for the continuation-or-recurrence claim. The data period, company records, industry information and other supporting documents should be organised around these two questions.
The application form is available on the Ministry of Trade website through the “Trade Policy Defence Instruments”, “Dumping and Subsidies”, and “Application and Questionnaire Forms” sections. Rather than completing the form during the final week, a working version should be opened after product scope and internal data owners have been identified. This allows requests for missing information to be directed to the correct business units. The data supplied by sales, finance, production, customs and legal teams should use the same product definition and the same period.
KEP Transmission And The Internal Approval Chain
The written application must be sent from the applicant’s own KEP address to the Ministry of Trade’s KEP address. The transmission channel is a procedural requirement separate from the substantive requirements governing the application. Access rights to the company’s KEP account, the signature and approval chain, naming of the final attachments, and retention of the transmission evidence should be checked before the calculated filing deadline.
The corporate timetable should also be built backwards from the calculated filing deadline. Product-and-measure mapping and the applicant’s standing should be established first, followed by completion of the evidence and data set, and then management approval, finalisation of the application form and attachments, and KEP transmission.
Monitoring For Importers And Foreign Producers
Although the right to apply is based on domestic-producer status or representation of the domestic industry, the calendar also has commercial consequences for importers, foreign producers and exporters. If an NGGS is opened following a valid application, the existing measure remains in force until the investigation is concluded. Their supply contracts, pricing assumptions and 2027 budgets should therefore not assume that the measure will automatically expire on the date shown in the calendar.
The role of those parties differs from preparation of the domestic industry’s application. Their priorities are to determine product and supplier coverage accurately, monitor the opening of any NGGS, and preserve the commercial data required for participation if an investigation is initiated. That workstream should remain separate from the filing right granted to domestic producers.
VI. General Assessment
Communiqué No. 2026/28 does more than announce measures due to expire during the first half of 2027. It establishes a concrete filing calendar for domestic producers, beginning with a deadline of 15 October 2026. A sound application depends on correctly matching the product to the measure, establishing domestic-producer status or domestic-industry representation, supporting the continuation-or-recurrence claim with sufficient evidence, and completing the KEP transmission on time.
Producers subject to the earliest expiry dates should first complete their review of product scope and the prior measure. Companies subject to later dates should likewise not defer preparation until 2027; the data period, internal responsibilities and any industry-level representation work should be completed before the final transmission date. Importers, foreign producers and exporters should reflect in their supply and pricing plans that an NGGS, if opened, will keep the existing measure in force until the investigation is concluded.
