Foreign Manufacturer Receives an Anti-Dumping Questionnaire from Turkey: How Should It Respond? (2026 Updated Guide)

A foreign manufacturer receives an anti-dumping questionnaire from Turkey. Learn how to respond, organize sales and cost data, protect confidential information, prepare for verification and avoid facts-available risks.

Receiving an anti-dumping questionnaire from Turkish authorities is not an ordinary regulatory information request. The manufacturer’s response may directly affect how its export prices, normal value, production costs and ultimately its potential dumping margin are assessed. A foreign manufacturer should therefore begin work immediately, identify the exact procedural deadlines and establish a coordinated legal, accounting, sales and production team. Fırat Fesih Kaya Law Office advises foreign manufacturers and exporters facing Turkish trade-remedy investigations, while Lawyer Fırat Fesih Kaya assists companies in organizing questionnaire responses, supporting evidence and procedural defenses. The most important practical principle is simple: every significant number submitted should be accurate, internally consistent and capable of being traced back to genuine company records.

Why Has the Foreign Manufacturer Received a Questionnaire?

An anti-dumping investigation examines whether specified goods are being exported to Turkey under conditions constituting dumping and whether the legally required injury and causal relationship exist. The investigating authority therefore requires detailed information from foreign manufacturers and exporters whose goods fall within the investigation.

The questionnaire allows the authority to examine the company’s actual commercial circumstances rather than relying entirely on information obtained from other parties.

Do Not Ignore the Questionnaire

Ignoring the questionnaire can materially damage the manufacturer’s position. If necessary information is not supplied adequately, the investigation may proceed using information otherwise available under the applicable framework.

The company may consequently lose the opportunity to have its actual transaction and cost data properly reflected in the investigation.

Identify Every Deadline Immediately

The company should begin by reviewing the initiation documents, questionnaire and accompanying instructions. Record the deadline for participation, questionnaire submission and any other required procedural steps.

Do not assume that the deadline used in a previous Turkish investigation applies to the present case.

Create an internal deadline several days before the official deadline.

Form an Anti-Dumping Response Team

A questionnaire normally cannot be completed by the legal department alone. Relevant personnel may include lawyers, finance staff, accountants, sales managers, production personnel, logistics teams and information-technology specialists.

One person should coordinate the complete response to prevent contradictory information being submitted by different departments.

Confirm Whether the Product Is Covered

Before producing thousands of records, verify whether the manufacturer’s goods actually fall within the product scope of the investigation.

Compare the investigated product with the manufacturer’s product specifications, composition, dimensions, technical characteristics, intended uses and tariff classification.

If particular models should fall outside the investigation, prepare a detailed product-scope submission supported by technical evidence.

Review the Manufacturer’s Corporate Structure

Prepare an accurate corporate organization chart identifying the manufacturer, parent company, subsidiaries, affiliated producers, related suppliers, related exporters and trading companies.

The authority should understand exactly which entity manufactures the product and which entity sells it to Turkey.

Disclose Related Companies Carefully

Related-party transactions can affect both the investigation methodology and the reliability of submitted information.

Do not omit an affiliate simply because it is located in another country or does not directly invoice the Turkish customer.

Identify the Investigation Period

The questionnaire will generally require information relating to defined periods. Sales, production and cost databases must correspond precisely with the requested period.

Including the wrong accounting period can make otherwise accurate information unusable.

Create a Product Code Mapping

Manufacturers often use internal stock-keeping units, model codes or enterprise-resource-planning identifiers that differ from the product categorization used in an anti-dumping investigation.

Create a mapping explaining how the company’s internal codes correspond with the products reported in the questionnaire.

Prepare Domestic Sales Data

Home-market sales can be central to the dumping analysis. Depending on the questionnaire, the manufacturer may need transaction-level information concerning invoice numbers, dates, customers, product codes, quantities, prices, discounts, rebates, credit terms and delivery conditions.

The database should be derived from genuine sales records.

Prepare All Relevant Exports to Turkey

Create a transaction-level database covering the manufacturer’s relevant Turkish exports during the requested period.

Each transaction should be traceable to supporting documents such as invoices, accounting entries, shipment records and customs documentation.

Export Prices Must Be Reconciled

The price shown on a commercial invoice may not always represent the final economic price relevant to the investigation. Discounts, rebates, commissions, freight, insurance and other adjustments may need to be identified depending on the questionnaire.

Every claimed adjustment should have documentary support.

Related Turkish Importers Require Special Attention

Where the foreign manufacturer and Turkish importer are related, the investigation may require additional information concerning the relationship and subsequent transactions.

Intercompany agreements and transfer-pricing arrangements should be reviewed carefully.

Third-Country Sales May Also Be Requested

Depending on the investigation, sales to markets other than Turkey and the manufacturer’s domestic market may become relevant.

Ensure that the company’s systems can distinguish each sales channel accurately.

Production Data Must Be Consistent

Prepare information concerning production quantities, production capacity, capacity utilization and inventories as required.

The figures should reconcile logically with sales and inventory movements.

Cost of Production Is Often the Most Difficult Section

Manufacturers should begin cost preparation early. Relevant information can include raw materials, direct labor, energy, manufacturing overhead, depreciation and other production expenses.

The methodology used to allocate costs among products should be documented.

Cost Figures Must Connect With the Accounting System

Do not create artificial cost figures solely for the anti-dumping investigation.

The authority should be able to understand how the reported production costs originate from the company’s ordinary accounting records.

Prepare a Cost Reconciliation

The response should explain how reported costs reconcile with financial accounts and relevant ledgers.

Differences caused by accounting classifications, period adjustments or product allocations should be explained transparently.

Raw Material Purchases Should Be Documented

Where raw materials constitute a significant portion of the product’s cost, preserve supplier invoices, purchase records, inventory movements and consumption records.

Related-party raw-material purchases should be identified accurately.

Review Energy and Labor Costs

For energy-intensive or labor-intensive industries, these expenses can materially affect production costs.

The manufacturer should ensure that allocations are based on a defensible methodology rather than estimates created for the investigation.

General Expenses Must Be Allocated Consistently

Administrative, selling and other expenses should be treated according to the applicable questionnaire and methodology.

Document allocation keys and explain why they reasonably reflect the company’s operations.

Discounts and Rebates Need Evidence

If the company claims that invoice prices were reduced through discounts or rebates, preserve contracts, credit notes, accounting records and payment evidence.

Unsubstantiated adjustments may be rejected.

Freight and Insurance Should Be Traceable

Maintain freight invoices, insurance documentation, transport contracts and other records supporting claimed expenses.

The transaction database and supporting documentation should tell the same commercial story.

Payment Terms May Matter

Identify credit periods, financing arrangements and unusual payment conditions where requested.

If different customers receive materially different terms, the reasons should be capable of explanation.

Currency Information Must Be Accurate

Identify the currency used for each sale and the company’s accounting treatment.

Do not select exchange rates merely because they create a more favorable dumping result.

Questionnaire Databases Must Reconcile

One of the most important quality-control exercises is reconciliation between domestic sales, exports, production, inventories and accounting records.

A questionnaire containing individually plausible figures can still fail if the overall datasets contradict one another.

Build an Audit Trail

For every major figure, the manufacturer should be able to answer:

Where did this number come from?

Which accounting system generated it?

Which source document supports it?

How does it reconcile with the financial statements?

This audit trail becomes particularly important during verification.

Do Not Leave Unexplained Blank Answers

If a question does not apply, state why. If requested information does not exist, explain the reason.

An unexplained blank can be interpreted very differently from a properly explained non-applicable item.

Ask for Clarification Early

If a questionnaire question is genuinely unclear, seek clarification through the appropriate procedural mechanism rather than inventing an interpretation.

Do this early enough to complete the response before the deadline.

Can an Extension Be Requested?

Depending on the applicable procedure and circumstances, an extension request may potentially be considered. It should be submitted promptly, properly justified and before expiration of the relevant deadline.

The manufacturer should continue preparing the response while waiting for any decision.

Do Not Assume an Extension Will Be Granted

A pending extension request is not permission to stop working.

Maintain the original preparation schedule unless and until the procedural position changes.

Confidentiality Is Critical

Anti-dumping questionnaires can contain highly sensitive commercial information, including individual prices, customer identities, production costs and supplier data.

The manufacturer should identify confidential material carefully and follow the applicable confidentiality procedure.

Prepare Non-Confidential Material Properly

Where the procedure requires non-confidential versions or summaries, these should be meaningful while still protecting legitimately sensitive commercial information.

Do not simply mark every page “confidential” without considering the procedural requirements.

Keep Confidential and Public Versions Consistent

The two versions should correspond with each other. Differences should result from legitimate confidentiality treatment rather than substantive inconsistencies.

Do Not Fabricate Missing Documents

If a historical document cannot be found, explain the problem and investigate whether another genuine business record can establish the same fact.

Never create an invoice, production record, contract or accounting entry and present it as historical evidence.

Correct Mistakes Transparently

Large questionnaire responses can contain errors. If a material error is discovered after submission, determine promptly how it should be corrected within the applicable procedure.

Concealing a known discrepancy can create a greater problem than the original mistake.

What Does “Facts Available” Risk Mean?

If the manufacturer fails to provide necessary, usable information, authorities may proceed using other information available under the applicable framework.

For the foreign manufacturer, this can be commercially significant because its actual sales and cost records may no longer form the complete basis of the analysis.

Incomplete Cooperation Can Affect the Dumping Result

Sending thousands of pages does not necessarily constitute effective cooperation.

The important question is whether the requested information is complete, timely, internally consistent and verifiable.

Prepare for Supplemental Questions

The initial questionnaire response may generate further questions.

Keep the response team active and preserve all working files after the first submission.

Supplemental Requests Should Receive the Same Attention

A supplemental questionnaire is not a minor administrative request. It may identify areas where the authority believes the original response is unclear or incomplete.

Respond precisely to each identified issue.

Verification Preparation Should Start Before Submission

The company should not wait until verification is announced before checking its records.

During questionnaire preparation, create reconciliation schedules showing how each important database connects with source records.

What Happens During Verification?

The authority may seek to determine whether information submitted in the questionnaire corresponds with genuine business records.

The company should therefore be prepared to demonstrate transaction samples, accounting entries, invoices, production information and the methodology used to create submitted databases.

Train the Verification Team

Employees participating in verification should understand the submitted questionnaire and their own responsibilities.

They should answer accurately rather than speculate about matters outside their knowledge.

Keep All Working Files

Preserve spreadsheets, extraction methodologies, reconciliation schedules and explanations used to produce the final response.

These records may be essential months later.

Product Scope Arguments Should Be Supported Technically

If the manufacturer believes one or more products should be excluded, prepare detailed technical evidence.

Useful information can include composition, production method, physical characteristics, performance, use and customer segment, depending on the specific investigation.

Dumping Is Not the Only Issue

An anti-dumping investigation also involves injury to the domestic industry and causation.

Foreign manufacturers may therefore have reason to respond to allegations concerning import volumes, prices, market share and effects on Turkish producers.

Examine Other Causes of Injury

If domestic producers face declining profitability or sales, determine whether other factors may explain those developments.

Possible issues include declining demand, raw-material prices, energy costs, domestic overcapacity, technological changes or imports from other countries.

Coordinate With the Turkish Importer

The Turkish importer may possess customs declarations, resale information, market evidence and transaction records relevant to the manufacturer’s response.

Differences between importer and exporter records should be resolved before they are submitted.

Review Existing Contracts

An anti-dumping investigation can change the economics of ongoing supply arrangements.

Review clauses concerning taxes, duties, price adjustment, delivery terms, regulatory changes and termination.

Plan for Possible Measures

The manufacturer should model the commercial effect of different anti-dumping outcomes on landed cost and customer pricing.

Do not wait until a measure is imposed to determine who bears the cost.

Avoid Artificial Supply-Chain Changes

Routing goods through another country, changing invoicing entities or making superficial processing changes solely to avoid an investigation can create serious anti-circumvention and origin risks.

Any restructuring should reflect genuine commercial and manufacturing reality.

Maintain Accurate Origin Information

The country of export, country of dispatch and country of origin are different concepts.

Questionnaire and customs information should remain consistent with the actual manufacturing chain.

Review the Authority’s Findings Carefully

When findings or disclosures become available under the applicable procedure, compare them with the company’s submitted information.

Identify factual mistakes, calculation problems, unsupported assumptions and evidence that may have been misunderstood.

Respond With Specific Evidence

A useful response should identify the disputed finding, explain the error and point to supporting evidence already submitted or properly introduced under the procedure.

General statements that the calculation is unfair are rarely sufficient.

Preserve the Administrative Record

Keep every questionnaire, supplemental response, confidential version, non-confidential version, attachment, authority communication and verification record.

The complete administrative record can become essential if the final measure is later challenged.

Immediate Response Checklist

A foreign manufacturer receiving a Turkish anti-dumping questionnaire should immediately identify all deadlines, establish a response team, confirm product scope, map related companies, preserve accounting records, prepare domestic and Turkish sales databases, organize production and cost information, reconcile every major dataset, prepare confidentiality materials, coordinate with the Turkish importer, anticipate supplemental questions and prepare for verification from the beginning.

Frequently Asked Questions

Should a foreign manufacturer answer a Turkish anti-dumping questionnaire?

Participation can be critically important if the manufacturer wants its own sales, costs and commercial circumstances considered in the investigation.

What happens if the company ignores the questionnaire?

Authorities may proceed on the basis of other information available under the applicable framework, potentially producing a less favorable outcome for the manufacturer.

What information may be requested?

Depending on the investigation, information may include corporate structure, domestic sales, Turkish exports, third-country sales, production, capacity, inventories, costs, related parties and accounting records.

Can confidential business information be protected?

Confidential treatment may be available subject to the applicable procedural requirements. Appropriate non-confidential material may also need to be provided.

What if the manufacturer cannot answer one question?

The company should explain why the information is unavailable and determine whether reliable alternative evidence can be provided rather than leaving the issue unexplained.

Can the questionnaire deadline be extended?

An extension may potentially be available depending on the applicable procedure and circumstances, but it should never be assumed. Any request should be made promptly and properly justified.

Will the manufacturer’s records be verified?

Verification can be an important part of anti-dumping proceedings. The company should prepare every significant dataset so that it can be traced to genuine source records.

Can the company correct an error after submitting its response?

Potentially, depending on the procedural stage and circumstances. A discovered material error should be addressed transparently and promptly.

Should the Turkish importer be involved?

Yes. Customs and transaction information held by the importer can be important, and importer and manufacturer records should remain consistent.

What is the biggest mistake a foreign manufacturer can make?

Treating the questionnaire as a simple form-filling exercise. A strong response requires legal analysis, accounting reconciliation, transaction-level evidence, confidentiality management and verification preparation from the first day.

Client-Focused Legal Support for Turkish Anti-Dumping Questionnaires

A Turkish anti-dumping questionnaire can determine how a foreign manufacturer’s export prices, normal value, production costs, related-party transactions and potential dumping margin are assessed. Fırat Fesih Kaya Law Office assists foreign manufacturers, international exporters and Turkish importers participating in Turkish anti-dumping and other trade-remedy investigations. Lawyer Fırat Fesih Kaya provides legal assistance in reviewing investigation documents, preparing questionnaire responses, coordinating accounting and transaction evidence, managing confidentiality and verification issues, responding to supplemental requests and evaluating legal remedies arising from final anti-dumping measures.

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+90 312 434 22 22

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+90 532 769 22 22

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