Received an exporter questionnaire in a Turkish anti-dumping investigation? Learn how foreign manufacturers and exporters should respond, prepare sales and cost data, protect confidential information, avoid verification problems and reduce anti-dumping duty exposure in Turkey.

Receiving an Exporter/Producer Questionnaire from the Turkish Ministry of Trade is one of the most important stages of an anti-dumping investigation for a foreign manufacturer or exporter selling goods into Turkey. The questionnaire should never be treated as an ordinary commercial survey or a routine request for information. The answers, supporting accounting records, transaction-level sales data, production costs, corporate structure and explanations provided by the exporter can directly affect the dumping calculation and ultimately the anti-dumping measure applicable to exports into Turkey. Current Turkish investigations continue to use detailed exporter/producer questionnaires alongside trader questionnaires, importer questionnaires and other interested-party submissions. For example, Ministry of Trade investigation files published in 2026 for solar glass, dental CNC machines, aluminum frames for photovoltaic panels and other products expressly include exporter/producer questionnaires as part of the investigation record. (https://ticaret.gov.tr)

A foreign exporter should therefore begin preparing its defense immediately after receiving the questionnaire. Waiting until the final days before the response deadline can create serious problems because anti-dumping questionnaires may require data from accounting, sales, production, purchasing, finance, export, logistics and related-company systems simultaneously.

What Is an Anti-Dumping Investigation in Turkey?

An anti-dumping investigation examines whether goods originating in a foreign country are exported to Turkey at dumped prices and whether those imports cause or threaten material injury to the domestic industry under the applicable legal framework.

In simplified terms, dumping concerns exports to Turkey at prices below the relevant normal value determined under the applicable rules.

The Ministry’s materials describe dumping as export pricing below normal value and identify domestic-market prices, third-country export prices and cost information as potentially relevant to the analysis. (https://ticaret.gov.tr)

However, an anti-dumping investigation is considerably more complicated than simply comparing two invoice prices.

Adjustments may be necessary before prices can be compared fairly.

Why Did the Foreign Exporter Receive a Questionnaire?

The Ministry needs company-specific information to investigate the exporter or producer.

The questionnaire can be used to establish matters including the company’s corporate structure, products, domestic sales, exports to Turkey, production costs, related-party transactions and other information relevant to the dumping analysis.

The Ministry’s 2026 investigation files demonstrate that exporter/producer questionnaires remain a central procedural instrument in Turkish trade-remedy investigations. (https://ticaret.gov.tr)

Do Not Ignore the Questionnaire

A company may initially think:

“Turkey represents only 3% of our exports. Why should we spend substantial resources answering this?”

That decision can have significant long-term consequences.

Failure to cooperate can deprive the exporter of the opportunity to establish its position using its own verified company information and can materially weaken its ability to challenge unfavorable findings.

The First Step: Identify the Exact Product Scope

Before preparing thousands of lines of financial information, determine exactly which goods are under investigation.

The investigation notice should be examined carefully.

Product descriptions and tariff classifications must be compared with the company’s actual products.

Do Not Rely Only on the HS or GTIP Code

A tariff classification can help identify the investigation’s scope, but the legal product description is critically important.

A company may export multiple models under the same general tariff heading even though not every model necessarily falls within the investigated product definition.

Prepare a Product Mapping

Create a table such as:

Internal Product Code | Commercial Description | Technical Specification | HS/GTIP | Exported to Turkey? | Domestic Sales? | Investigation Scope?

This becomes extremely useful throughout the investigation.

Determine Whether the Company Is a Producer, Exporter or Trader

The company’s exact role in the supply chain matters.

A manufacturer may produce and directly export the investigated goods.

Another company may manufacture but sell through a related trading company.

A trader may purchase goods from several producers and export them to Turkey.

These structures should be disclosed and explained accurately.

Map the Entire Corporate Structure

Foreign exporters should identify all related companies involved in:

production;

domestic sales;

exports;

distribution;

financing;

raw-material purchases;

intellectual property;

and Turkish sales.

Related Companies Can Affect the Investigation

Suppose:

Factory A manufactures the goods.

Trading Company B purchases them from Factory A.

Company C handles international invoicing.

Turkish Company D imports them.

If these entities are related, the Ministry may need information concerning more than one company.

Do Not Hide Related Companies

Attempting to simplify the response by omitting a related entity can create serious credibility and verification problems later.

The corporate structure should be disclosed consistently with accounting and corporate records.

Create an Anti-Dumping Response Team Immediately

A questionnaire response usually cannot be prepared by one employee.

The company may need:

legal counsel;

finance personnel;

cost accountants;

sales staff;

IT personnel;

production management;

export department;

and senior management.

Appoint One Internal Coordinator

One person should control document collection and communications.

Without centralized coordination, different departments may provide inconsistent data.

Establish a Document Preservation Notice

Relevant records should not be deleted during the investigation.

This includes emails, accounting exports, sales databases, cost calculations and production records.

Identify the Investigation Period

The questionnaire normally identifies the period for which information must be reported.

All datasets should be prepared consistently for that period.

Do Not Mix Financial Years

A common problem occurs when the investigation period does not correspond exactly with the company’s fiscal year.

The company must carefully reconcile the requested period with its accounting system.

Domestic Sales Data Can Be Critical

The Ministry may require detailed information concerning sales of the like product in the exporter’s domestic market.

This can involve transaction-level information.

Prepare Domestic Sales Transaction Data

Depending on the questionnaire, relevant fields may include:

invoice date;

invoice number;

customer;

customer relationship;

product code;

quantity;

gross price;

discounts;

rebates;

freight;

insurance;

commissions;

credit terms;

and net price.

Export Sales to Turkey Must Also Be Reconstructed

Every relevant transaction to Turkey during the requested period should be identified.

The company’s export database should be reconciled with invoices and accounting records.

Reconcile Export Sales With Customs Records

The company should compare:

sales database → commercial invoice → export declaration → shipping document → payment → accounting entry.

Inconsistencies should be investigated before submission.

Do Not Submit Raw ERP Data Without Reviewing It

ERP systems frequently contain fields that do not mean what outsiders assume they mean.

For example, “invoice date” may actually be posting date.

“Customer” may represent the distributor rather than final buyer.

“Freight” may be allocated automatically.

Every important field should be understood.

Prepare a Data Dictionary

For each field explain:

what it means;

where it comes from;

how it is calculated;

and which accounting or ERP module produces it.

This can significantly improve the reliability of the response.

Product Control Numbers Can Become Extremely Important

Anti-dumping calculations often require comparison between products with similar physical characteristics.

The questionnaire may establish product characteristics or product-control criteria.

The exporter should classify products carefully.

Incorrect Product Coding Can Distort the Dumping Margin

Suppose premium industrial machinery is incorrectly compared with a basic model.

The resulting price comparison may become commercially meaningless.

Technical personnel should therefore participate in product classification.

Cost of Production Is Often One of the Hardest Sections

Manufacturers may be required to provide detailed production-cost information.

This can include:

raw materials;

direct labor;

energy;

factory overhead;

depreciation;

administrative expenses;

selling expenses;

and other relevant cost components.

Cost Data Must Reconcile With Accounting Records

A cost spreadsheet prepared solely for the anti-dumping response without connection to audited or ordinary accounting records can create serious verification difficulties.

The Ministry should be able to understand how the submitted figures connect to the company’s normal accounting system.

Build a Reconciliation Trail

A strong cost response should ideally allow the reviewer to move from:

audited financial statements → trial balance → cost accounts → production records → product-specific costs.

Raw Material Costs Require Attention

If raw materials represent 70% of production cost, the Ministry may examine them closely.

Large fluctuations or related-party purchases should be explainable.

Related-Party Raw Material Purchases

If important inputs are purchased from affiliated companies, the exporter should prepare evidence explaining the pricing structure.

Energy Costs

Energy-intensive industries should reconcile electricity, natural gas and other energy costs with invoices and production records.

Allocation Methodologies Must Be Defensible

Many companies produce multiple products in the same factory.

Shared expenses therefore need allocation.

Possible allocation keys may include:

production volume;

machine hours;

labor hours;

turnover;

material consumption;

or another commercially reasonable basis.

The methodology should correspond with the company’s actual accounting practices wherever possible.

Do Not Change Cost Allocation Merely to Improve the Result

An artificial methodology created after the investigation begins can attract significant scrutiny.

Consistency with ordinary accounting practices is important.

Selling, General and Administrative Expenses

SG&A expenses can materially affect calculations.

The company should determine how these expenses are recorded and allocated.

Financial Expenses

Interest and financing items may also require careful classification depending on the questionnaire and applicable methodology.

Domestic Sales Below Cost

Where relevant under the applicable anti-dumping methodology, the authority may examine whether domestic sales occurred at prices below cost.

This makes cost reporting especially important.

Discounts and Rebates Must Be Documented

The exporter should identify all discounts affecting domestic and Turkish export prices.

Examples include:

volume discounts;

early-payment discounts;

annual rebates;

promotional discounts;

customer-specific rebates;

and credit notes.

Do Not Net Discounts Without Evidence

The company should be able to connect claimed adjustments with invoices, contracts or accounting records.

Freight and Transportation Adjustments

Transportation costs can affect price comparability.

The exporter should determine whether prices are:

EXW;

FOB;

CIF;

CFR;

DDP;

or another Incoterm.

Inland Freight

Transportation from the factory to the export port may need to be identified separately.

International Freight

Ocean, road, rail or air freight should be supported by logistics records.

Insurance

Where separately identifiable, insurance costs should be documented.

Handling and Port Charges

Export-related handling and terminal charges may also require reporting depending on the questionnaire.

Commissions

Sales commissions paid to agents or related companies should be identified accurately.

Credit Expenses

Different payment periods can affect price comparability.

The company should preserve payment terms and actual payment information.

Currency Conversion

Foreign exporters selling in multiple currencies should carefully review the applicable currency and exchange-rate methodology used in the questionnaire response.

Domestic and Export Sales Should Be Compared Carefully

Do not assume that a EUR 100 domestic sale and EUR 90 export sale automatically establish a 10% dumping margin.

Differences in commercial circumstances may require adjustments under the applicable methodology.

Customer Level Can Matter

A domestic sale to a retailer may not be commercially equivalent to an export sale to a national distributor purchasing container quantities.

Quantity Differences Can Matter

Large Turkish customers may receive lower unit prices because they purchase substantially greater quantities.

Document the commercial policy.

Product Differences Can Matter

Different grades, dimensions, specifications and performance characteristics can explain price differences.

Related Turkish Importers

If the exporter sells to a related company in Turkey, the sales structure requires particular attention.

The authority may examine the relationship and subsequent resale structure.

Prepare Turkish Resale Information Where Relevant

The Turkish affiliate may need to cooperate closely with the foreign exporter.

Do not wait until late in the investigation to involve it.

Confidentiality Is Extremely Important

Anti-dumping questionnaires can require commercially sensitive information.

This may include:

customer names;

individual sales prices;

production costs;

profit margins;

supplier information;

and internal pricing policies.

Companies should follow the applicable confidentiality procedures carefully.

Confidential and Non-Confidential Versions

Trade-remedy proceedings generally require appropriate handling of confidential submissions and non-confidential summaries.

Ministry materials expressly contemplate both confidential submissions and non-confidential summaries in the investigation process. (https://ticaret.gov.tr)

Do Not Simply Mark Everything “Confidential”

Confidentiality should be properly claimed and supported where required.

The non-confidential version should still provide meaningful information without revealing protected business secrets.

Never Accidentally Disclose Customer-Level Prices

Before submitting the non-confidential version, perform a separate confidentiality review.

Spreadsheet hidden columns, formulas, comments and metadata should also be checked.

Excel Files Require Special Attention

Anti-dumping investigations frequently involve extensive spreadsheets.

Do not convert everything into PDF if the questionnaire requires editable Excel information.

At the same time, check formulas carefully.

Formula Errors Can Be Expensive

A single incorrect spreadsheet formula can affect thousands of transactions.

Perform independent checks before submission.

Use Control Totals

For every dataset calculate totals for:

quantity;

sales value;

discounts;

freight;

and other material fields.

Then reconcile those totals against accounting records.

Document Every Reconciliation

If questionnaire sales total EUR 22.8 million but financial statements show EUR 24 million, explain the EUR 1.2 million difference.

For example:

EUR 700,000 unrelated products;

EUR 300,000 domestic services;

EUR 200,000 outside investigation period.

Unexplained differences create problems.

The Questionnaire Response Should Tell One Consistent Story

Corporate structure, accounting records, sales databases and cost data must all fit together.

Contradictions are dangerous.

Example of an Inconsistency

Corporate response:

“We have no related Turkish customers.”

Accounting records:

“Receivable from Turkish Subsidiary A.”

Such discrepancies can seriously damage credibility.

Prepare for Verification From Day One

Foreign exporters should assume that important information may be tested against underlying company records.

Therefore, never submit a number that cannot be traced back to its source.

Build a Verification File

For every important figure preserve:

source document;

ERP report;

accounting account;

calculation;

and explanation.

Test Individual Transactions

Select sample domestic and Turkish sales and trace them from beginning to end.

For example:

purchase order → invoice → delivery → payment → accounting record.

If your own team cannot trace the transaction, investigators may have the same difficulty.

Test Production Costs

Select several products and trace their costs back through material consumption, labor, overhead and accounting records.

Language Issues Should Be Managed Early

The foreign company’s accounting documents may be in Chinese, Korean, German, Italian or another language.

Determine which documents may require translation and prepare them early.

Never Translate Accounting Terminology Inconsistently

Create a terminology table for important accounts and cost categories.

Deadline Management Is Critical

The exporter should immediately identify the response deadline stated in the investigation documents or questionnaire and calculate the internal timetable backward from that date.

Do not assume that an extension will automatically be available.

Ask for an Extension Early If Necessary

If the questionnaire cannot reasonably be completed within the applicable period, any extension request should be considered as early as possible and supported with concrete reasons.

Do not wait until the final hours.

Internal Deadline Should Be Earlier

If the official deadline is Day 30, management should aim to complete the substantive response several days earlier.

That allows time for reconciliation and confidentiality review.

What Happens If the Exporter Does Not Cooperate?

Non-cooperation can significantly weaken the company’s position.

The exporter may lose the practical benefit of having the authority rely on complete company-specific information.

Partial Cooperation Can Also Be Dangerous

Submitting only easy sections while ignoring difficult cost or sales questions may not solve the problem.

The response should be assessed as a complete evidentiary package.

Never Guess

If information does not exist, explain why.

Do not manufacture data.

Never Alter Historical Accounting Records

If the ERP contains an error, preserve the original information and explain any correction transparently.

Never Create Backdated Contracts

This can turn an ordinary trade-remedy problem into a serious credibility issue.

Never Hide Affiliate Transactions

Related-party structures can often be identified through corporate databases, financial statements and import records.

Disclosure and explanation are usually safer than concealment.

Can the Exporter Challenge the Investigation?

Yes, foreign exporters can participate in the investigation and present arguments concerning dumping calculations, product scope, methodology, injury, causation and other relevant issues depending on the procedural stage.

Product Scope Arguments Can Be Important

A company may argue that particular products should not fall within the investigation because of significant differences in technical or commercial characteristics.

Such arguments should be supported by technical evidence.

Injury Arguments

Anti-dumping measures do not depend solely on identifying dumping.

The investigation also examines injury to the domestic industry and the causal relationship between dumped imports and that injury.

Other Causes of Injury

Depending on the facts, relevant factors may include:

declining domestic demand;

raw-material increases;

energy costs;

currency movements;

domestic capacity problems;

imports from other countries;

technological change;

or the domestic industry’s own commercial decisions.

Do Not Focus Only on the Dumping Margin

A comprehensive defense may address both dumping and injury.

Final Disclosure Stage

Before a final determination, exporters should carefully examine the authority’s disclosed findings and identify factual or methodological errors within the applicable procedural framework.

Check the Company’s Own Data

Common errors can include:

incorrect currency;

wrong product matching;

duplicate transactions;

incorrect quantities;

misallocated freight;

or misunderstood accounting fields.

Calculate Your Own Expected Margin

The exporter should not wait for the authority to perform every calculation.

Where possible, the company should model potential dumping outcomes using its submitted data.

Scenario Analysis

Calculate how the result changes if:

certain domestic sales are excluded;

different product matching is used;

cost adjustments are made;

or particular allowances are rejected.

This helps management understand commercial exposure.

Commercial Impact Analysis

An anti-dumping measure can fundamentally alter the viability of the Turkish market.

The company should model possible duty scenarios.

For example:

5% duty → manageable

20% duty → substantial margin pressure

40% duty → distribution model may require restructuring

Do Not Restructure Trade Flows Artificially

After an anti-dumping measure is imposed, routing goods through another country without genuine transformation can create separate circumvention risks.

Turkish Importers Should Be Coordinated

Foreign exporters should communicate with their Turkish importers because the measure ultimately affects import costs and market access.

However, all participants should maintain consistent factual positions.

2026 Turkish Anti-Dumping Environment

Anti-dumping and related trade-remedy investigations remain active in Turkey. Ministry records show that 2026 proceedings continue to involve detailed questionnaires for exporters/producers, traders, importers and domestic producers. Recent files include investigations concerning solar glass from China, Malaysia and Vietnam and completed proceedings involving Chinese and Korean flat-steel products, Chinese aluminum frames for photovoltaic panels and Chinese dental CNC machines. (https://ticaret.gov.tr)

For foreign manufacturers exporting significant volumes into Turkey, trade-remedy compliance should therefore form part of market-access planning rather than being treated only as emergency litigation after an investigation begins.

What Should the Exporter Do in the First 24 Hours?

Immediately secure the questionnaire and opening notice, identify the response deadline, determine the investigation period, identify the product scope, notify senior management and establish an internal investigation-response team.

Do not begin filling spreadsheets before understanding the scope.

What Should the Exporter Do Within the First 72 Hours?

Map all relevant products and related companies, identify domestic and Turkish sales databases, locate cost-accounting records, determine whether Turkish importers are related and begin building reconciliations.

The legal and accounting teams should also identify potential weaknesses early.

What Should Be Done During the First Week?

Prepare preliminary domestic and export sales datasets, construct product-control mapping, reconcile sales with financial accounts, test production-cost data, identify necessary adjustments and establish confidential/non-confidential document procedures.

Internal Red-Flag Review

Before submitting anything, ask whether the data reveals:

very low Turkish prices;

domestic sales below cost;

large related-party transactions;

unusual rebates;

unexplained credit notes;

large year-end adjustments;

inconsistent product coding;

or unreconciled accounting differences.

These issues should be understood before the authority identifies them.

2026 Legal Strategy for Foreign Exporters Receiving an Anti-Dumping Questionnaire in Turkey

A foreign exporter receiving an anti-dumping questionnaire from Turkish authorities should treat the response as a major legal, accounting and commercial project. The company should first analyze the investigation notice, product scope, investigation period and procedural deadline. It should then map the corporate structure and identify every producer, exporter, trader and related Turkish importer involved in the investigated goods. Domestic sales, Turkish export sales and production-cost data should be extracted from ordinary company systems and reconciled with accounting records. Product characteristics should be mapped accurately to avoid distorted comparisons. Discounts, freight, commissions, credit costs and other potential adjustments should be supported by contemporaneous documents. Confidential information should be separated properly from the non-confidential version. Every material number should have a verification trail back to source records. The company should simultaneously analyze injury and causation arguments rather than concentrating solely on price calculations. Before submission, independent reconciliation and spreadsheet checks should be completed. The practical strategy is therefore: analyze the opening notice → identify the product scope → confirm the deadline and investigation period → establish the response team → map related companies → preserve documents → extract domestic sales → extract Turkish export sales → prepare cost data → reconcile everything with accounting records → classify products accurately → document adjustments → prepare confidentiality treatment → perform internal verification → calculate potential dumping scenarios → prepare injury and causation arguments → submit a complete and consistent response → prepare for verification → review final disclosure findings → challenge factual or methodological errors within the applicable procedures.

Frequently Asked Questions

1. Should a foreign exporter respond to a Turkish anti-dumping questionnaire?

Where the company wants its own information and arguments properly considered in the investigation, active and timely cooperation is extremely important. Failure to provide requested information can materially weaken the exporter’s position.

2. What information may an exporter questionnaire require?

Depending on the investigation, questionnaires can require information concerning corporate structure, investigated products, domestic sales, exports to Turkey, production costs, related companies and numerous price-comparison adjustments. Turkish Ministry investigation files routinely publish dedicated exporter/producer questionnaires. (https://ticaret.gov.tr)

3. Does the exporter have to disclose confidential prices and costs?

Detailed commercial information may be required, but applicable confidentiality procedures should be used. Companies should carefully prepare confidential submissions and meaningful non-confidential versions or summaries where required.

4. What happens if the company’s accounting records do not match the questionnaire tables?

The difference should be reconciled and explained before submission. Unexplained discrepancies between sales databases, questionnaire figures and financial records can create serious verification problems.

5. Can a foreign exporter request additional time to answer?

Any possibility of an extension depends on the applicable investigation and procedural requirements. If additional time is genuinely required, the issue should be raised early rather than assuming an extension will automatically be granted.

6. Can Turkish authorities examine the exporter’s production costs?

Yes. Production-cost information can be highly relevant to dumping calculations, particularly where the authority needs to examine normal value and the reliability of domestic sales information.

7. Can the exporter challenge which products are included in the investigation?

Product-scope issues can potentially be raised during the investigation. Technical distinctions should be supported by detailed product specifications, production information and commercial evidence.

8. Can related-party sales affect an anti-dumping investigation?

Yes. Sales involving related producers, exporters, traders or Turkish importers can require additional analysis. The entire corporate and sales structure should therefore be disclosed accurately.

9. Should the exporter prepare for verification before submitting the questionnaire?

Yes. Every significant figure should ideally be traceable to underlying accounting, sales and production records. Building the verification file while preparing the questionnaire is considerably safer than reconstructing it later.

10. Can an anti-dumping investigation result in company-specific treatment?

The outcome depends on the investigation, applicable legal framework and degree of cooperation. This is one reason a foreign producer/exporter should carefully evaluate the strategic importance of submitting complete company-specific information rather than remaining passive.

Legal Support for Foreign Exporters in Turkish Anti-Dumping Investigations

An anti-dumping questionnaire can require foreign exporters to disclose and reconcile extensive sales, pricing, production-cost, accounting, related-party and corporate information. Errors or incomplete responses can materially affect the company’s position and its future access to the Turkish market.

Fırat Fesih Kaya Law Office provides legal assistance to foreign manufacturers, exporters, multinational companies and international corporate groups involved in anti-dumping and trade-remedy investigations in Turkey.

Fırat Fesih Kaya can assist with investigation-opening analysis, product-scope assessment, exporter questionnaire preparation, sales and cost-data review, confidential submissions, related-company structures, dumping and injury arguments, verification preparation, final disclosure responses and the applicable administrative and judicial processes.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey