I. Introduction
The Communiqué on the Prevention of Unfair Competition in Imports (Communiqué No. 2026/31) (the “Communiqué”), published in Official Gazette No. 33400 of 14 October 2026, provides for anti-dumping duty on imports of sodium gluconate originating in the People’s Republic of China at rates ranging from 22.56% to 32.96% depending on the company.
The Communiqué took effect on publication and provides no transition period or exemption for orders already placed or goods already in transit. Importers should therefore promptly review the costs not only of new orders but also of shipments in transit or still going through customs.
II. Duty Rates and the Person Liable
There is no single rate for all Chinese-origin sodium gluconate: the Communiqué’s definitive measure table sets 24.43% for Shandong Fuyang Bio-Tech. Co., Ltd., 22.56% for Weifang Jianbao Biotechnology Co., Ltd. and 32.96% for all other companies. The rates are expressed as a percentage of the CIF value, which according to the Communiqué means the delivered value including costs, insurance and freight.
According to the Communiqué, customs authorities will collect the duty, subject to other legislation, on imports under the release-for-free-circulation procedure. Law No. 3577 on the Prevention of Unfair Competition in Imports (the “Law”) determines that the person liable for the duty is the natural person or legal entity importing the goods and also provides for the duty to be collected separately from the other taxes levied on import.
The Communiqué does not separately address how the company-specific rates apply to imports made through a trader. According to the disclosure report annexed to the Communiqué (the “Report”), the two traders handling Weifang Jianbao’s sales to Turkey, Qingdao Reayou Chemical Co., Ltd. and Qingdao Abel Technology Co., Ltd., also cooperated in the investigation, but as traders unrelated to Weifang Jianbao they were not made the subject of a separate margin calculation, and neither trader appears in the table.
III. Product and Origin Scope
The Communiqué’s definitive measure table identifies the goods to which the measure applies by Chinese origin, tariff code 2918.16.00.00.13 and the description “sodium gluconate”, and it makes no distinction by the product’s end use. The Communiqué also states that the descriptions of the product in the Report are general and that what governs application is the tariff code in the current Turkish Customs Tariff Schedule together with the description in the table, and it provides that later changes to the tariff position or description do not prevent the measure from applying.
IV. Duration of the Measure
The Communiqué states that the measures will lapse five years after their effective date, but provides that if an expiry review investigation is initiated before that date, the measures will remain in force until the investigation concludes.
V. Conclusion
Because the Communiqué sets company-specific rates rather than a single rate for Chinese-origin sodium gluconate, the duty an importer pays will depend on who the producer and exporter are. For purchases made through a trader in particular, the producer and exporter should therefore be identified from the transaction documents rather than from the supplier’s trading name, and total import cost should be recalculated at the verified rate. Although the Communiqué provides for no separate sanction, unpaid duty will be collected from the importer under Article 15 of the Law in accordance with Law No. 6183 on the Collection Procedure for Public Receivables, so supply contracts should state clearly which party bears the duty.
