Anti-Dumping Verification Visit in Turkey: Compliance Guide for Foreign Exporters – 2026 Legal Guide

Turkish Anti-Dumping Verification Visit | Foreign Exporter Guide

Learn how foreign exporters should prepare for an anti-dumping verification visit in Turkey, protect their data and avoid adverse dumping-margin findings.

An anti-dumping verification visit in Turkey is one of the most important stages of an investigation. Turkish authorities may use the visit to test whether the information submitted by a foreign exporter is accurate, complete and supported by original business records.

A successful verification can protect the exporter’s individual dumping margin. Poor preparation, inconsistent records or restricted access to evidence may lead to rejection of data and the use of adverse facts available.

What Is an Anti-Dumping Verification Visit?

A verification visit is a review of the information submitted in the anti-dumping questionnaire. Officials may examine the exporter’s sales, production, accounting, cost, inventory, logistics and corporate records.

The visit may involve:

• Review of original invoices and sales contracts;
• Examination of accounting ledgers;
• Testing of selected export transactions;
• Review of production and inventory records;
• Inspection of manufacturing facilities;
• Analysis of related-party transactions;
• Examination of freight, insurance and commission expenses;
• Interviews with responsible employees;
• Reconciliation of questionnaire data with audited accounts.

The visit is not merely an informal meeting. It is an evidentiary control process that can directly affect the final dumping margin.

Turkey’s anti-dumping investigations are conducted under Law No. 3577 and related implementing legislation. The Ministry of Trade’s official anti-dumping page provides information about investigations, measures and the applicable legal framework.

Does a Verification Visit Mean That Dumping Has Been Proven?

No. A verification visit does not mean that the exporter has already been found to be dumping. It gives the authority an opportunity to verify the submissions and determine whether the information can be used.

The final assessment generally considers:

• Export price;
• Normal value;
• Dumping margin;
• Injury to the Turkish domestic industry;
• Causation between dumped imports and alleged injury.

The exporter should therefore use the visit to correct misunderstandings, explain accounting methods and demonstrate that the submitted information is reliable.

What Should a Foreign Exporter Do Immediately?

The first step is to appoint a coordinated legal and technical team. The team should include Turkish trade-remedies counsel, international anti-dumping counsel, finance personnel, production managers, sales staff, logistics specialists and IT representatives.

The exporter should also:

• Review the investigation notice;
• Confirm the verification dates;
• Identify the officials attending;
• Request an agenda;
• Confirm the products and periods covered;
• Review confidentiality arrangements;
• Prepare an employee responsibility chart;
• Preserve all relevant records;
• Create a secure document room.

Lawyer Fırat Fesih Kaya and the Fırat Fesih Kaya Law Office can assist foreign exporters with Turkish anti-dumping proceedings, verification preparation, customs consequences and administrative or judicial remedies.

Create a Verification Master File

A verification master file should contain the final questionnaire response and every supporting record used to prepare it.

The file should include:

• The submitted questionnaire;
• All annexes and calculation sheets;
• Sales ledgers;
• General ledgers;
• Trial balances;
• Audited financial statements;
• Product-cost calculations;
• Production records;
• Inventory reports;
• Freight and insurance invoices;
• Export declarations;
• Bank records;
• Customer contracts;
• Related-party agreements;
• Corporate ownership documents;
• Reconciliation schedules;
• Confidentiality explanations.

Each figure reported to the authority should be traceable to a source document. The company should be able to explain who created the record, when it was created and how it was used in the questionnaire.

Reconcile Questionnaire Data With Accounting Records

The most common verification problem is a mismatch between questionnaire figures and the company’s accounting system.

Before the visit, the exporter should reconcile:

• Total export sales to Turkey;
• Total home-market sales;
• Product quantities;
• Invoice values;
• Discounts and rebates;
• Freight expenses;
• Production costs;
• Inventory movements;
• Currency conversions;
• Related-party purchases;
• Financial-statement totals.

If a difference exists, it should be identified and explained before the authority discovers it. Differences may result from accounting cut-off dates, returns, cancelled sales, currency translation, intercompany eliminations or different product classifications.

An unexplained discrepancy may cause the authority to question the reliability of the entire response.

Prepare Selected Transaction Files

Officials may select individual transactions for detailed testing. The exporter should prepare a complete file for each likely sample transaction.

A transaction file may include:

• Purchase order;
• Sales contract;
• Commercial invoice;
• Packing list;
• Transport document;
• Export declaration;
• Insurance document;
• Freight invoice;
• Payment evidence;
• Credit note;
• Rebate record;
• Customer correspondence;
• Accounting entry;
• Bank receipt.

The price shown in the invoice should reconcile with the sales ledger, shipment record and payment received. If the customer received a later discount or credit, the exporter should explain the commercial reason and provide documentary support.

Prepare the Production and Cost Verification

Cost verification is essential when the authority examines normal value or constructed value.

The exporter should be prepared to explain:

• Raw-material purchases;
• Labour costs;
• Energy expenses;
• Factory overhead;
• Depreciation;
• Production yields;
• Scrap and wastage;
• Work-in-progress;
• Finished-goods inventory;
• Cost-allocation methods;
• Product-specific profitability;
• Research and development costs;
• Selling, general and administrative expenses.

The production team should understand the product-control numbers used in the questionnaire. Technical differences between models, grades, sizes or functions must be explained consistently by the sales, engineering and accounting departments.

Product Matching Must Be Consistent

Product matching errors can significantly distort the dumping margin. The exporter should prepare a clear product-control-number dictionary showing how internal model codes correspond to the codes used in the investigation.

The verification team should be able to explain differences involving:

• Dimensions;
• Weight;
• Material;
• Grade;
• Quality;
• Technology;
• Capacity;
• Function;
• End use;
• Brand;
• Warranty;
• Packaging;
• Customer segment.

Catalogues, technical drawings, test certificates, photographs and product specifications can help demonstrate that apparently similar products are commercially different.

Explain Export Price Adjustments

Officials may examine every claimed adjustment to the export price. The exporter should prepare written explanations for:

• Inland transportation;
• International freight;
• Insurance;
• Port handling;
• Packing;
• Commissions;
• Credit costs;
• Discounts;
• Rebates;
• Warranty expenses;
• Technical services;
• Currency conversion;
• After-sales costs.

Each adjustment should be supported by invoices, contracts, accounting entries or a consistent allocation methodology.

A general statement that an expense “relates to exports” may not be enough. The company should show how the amount was calculated and allocated to the relevant transaction.

Prepare Home-Market Sales Evidence

Where normal value is based on domestic sales, the exporter should prepare evidence showing:

• Domestic customers;
• Sales channels;
• Quantities;
• Payment terms;
• Domestic taxes;
• Discounts;
• Delivery costs;
• Product comparability;
• Profitability;
• Below-cost sales;
• Related-party sales.

If the company has no home-market sales of a comparable product, it should provide a clear explanation and supporting cost information. It should not leave gaps in the questionnaire response.

Related-Party Transactions Require Special Care

Affiliated companies may be examined in detail. The exporter should prepare:

• Group structure charts;
• Shareholding records;
• Intercompany contracts;
• Transfer-pricing policies;
• Management-service agreements;
• Loan and financing documents;
• Royalty or licence agreements;
• Intercompany invoices;
• Payment records;
• Consolidation schedules.

The authority may question whether transactions between related companies were conducted on commercial terms. The exporter should provide a coherent explanation supported by ordinary-course business evidence.

Confidentiality During the Verification Visit

The exporter must protect sensitive information without appearing to obstruct the investigation.

A practical approach is to:

• Prepare a confidentiality schedule;
• Mark documents accurately;
• Provide non-confidential summaries;
• Use a secure data room;
• Limit access to unrelated information;
• Explain the commercial harm caused by disclosure;
• Obtain consent before sharing third-party data;
• Keep a record of documents provided.

Confidentiality should not be claimed for every page. Excessive or unjustified confidentiality claims may damage credibility and prevent interested parties from understanding the evidence.

Employee Preparation and Interview Protocol

Employees who may meet the verification team should receive a short factual briefing. They should know:

• The investigation period;
• The products involved;
• The submitted figures;
• Their own area of responsibility;
• The location of supporting documents;
• Which person should answer legal questions;
• How to handle uncertain questions.

Employees should answer accurately and avoid speculation. If an employee does not know the answer, the correct response is to say that the issue will be checked and answered through the designated team.

No employee should create a new explanation that conflicts with the questionnaire response.

Factory Inspection and On-Site Compliance

If the verification includes a factory inspection, the exporter should prepare:

• Production-line maps;
• Capacity information;
• Machine lists;
• Raw-material storage records;
• Inventory locations;
• Quality-control procedures;
• Production orders;
• Scrap records;
• Health and safety arrangements;
• Visitor access procedures.

The physical facility should correspond to the production and cost information submitted. Significant differences between reported capacity and actual production records may attract additional questions.

What If the Authority Finds a Discrepancy?

A discrepancy should be addressed immediately and in writing. The exporter should:

1. Identify the exact difference;
2. Explain its cause;
3. Provide corrected calculations where necessary;
4. Submit additional supporting records;
5. Explain whether the difference affects the dumping margin;
6. Preserve the right to make further legal submissions.

Minor clerical errors can often be explained. Concealed, repeated or material inconsistencies may result in rejection of the affected data.

Consequences of Failing to Cooperate

If the exporter refuses access, misses the verification, provides incomplete records or prevents the authority from testing the data, the authority may use facts available.

Possible consequences include:

• A higher dumping margin;
• Rejection of claimed adjustments;
• Loss of an individual exporter rate;
• Application of a residual or country-wide rate;
• Adverse conclusions about product scope;
• Increased duties for Turkish importers;
• Greater anti-circumvention scrutiny;
• Weaker prospects in future reviews.

The exporter should therefore cooperate while preserving objections concerning scope, methodology, confidentiality and procedural fairness.

Can the Verification Result Be Challenged?

Potential remedies depend on the investigation stage and the legal form of the decision. The exporter may be able to:

• Submit written comments;
• Request a hearing;
• Respond to preliminary findings;
• Challenge the final determination;
• Apply for an interim review;
• Request a new-exporter review;
• Seek an expiry or sunset review;
• Challenge scope findings;
• Contest anti-circumvention measures;
• Bring an annulment action before the administrative courts;
• Request suspension of execution.

A court action does not automatically suspend the collection of anti-dumping duties. Deadlines depend on the notification or publication of the specific decision and must be calculated immediately.

2026 Compliance Priorities

In 2026, foreign exporters should prioritise data integrity and rapid verification readiness. Authorities are increasingly likely to focus on transaction-level evidence, product matching, related-party sales, origin records, transfer-pricing adjustments and supply-chain routing.

Manufacturers should also review risks involving:

• Transshipment through third countries;
• Minor processing intended to change origin;
• Incorrect certificates of origin;
• Indirect sales through distributors;
• Product modifications after the investigation period;
• Unreported affiliated companies;
• Inconsistent customs and accounting records.

The Ministry’s official questionnaire and application page should be monitored for current forms, notices and procedural updates. Current legislation should be checked through the Official Turkish Legislation Portal.

Verification Visit Checklist

Before the visit, the foreign exporter should confirm that:

• The questionnaire response is final and internally approved;
• All data reconciles to accounting records;
• Sample transactions are fully documented;
• Product codes are consistently explained;
• Cost calculations are reproducible;
• Related parties are disclosed;
• Confidentiality claims are justified;
• Non-confidential summaries are ready;
• Employees have been briefed;
• Translators are available if required;
• The data room is secure;
• Original records can be produced;
• Meeting notes will be maintained;
• Legal objections are preserved in writing.

Frequently Asked Questions (FAQ)

1. Is an anti-dumping verification visit mandatory?

If the authority schedules a verification, the exporter should cooperate fully. Failure to cooperate may lead to rejection of submitted data and the use of adverse facts available.

2. Can the exporter refuse access to confidential records?

The exporter may request confidential treatment and controlled access, but an unexplained refusal may be treated as non-cooperation. A secure data room and non-confidential summaries are usually safer solutions.

3. What happens if the company’s accounting figures do not match the questionnaire?

The difference should be identified, reconciled and explained immediately. The exporter should provide corrected schedules and supporting documents where necessary.

4. Can the verification team inspect the factory?

Yes, where the verification arrangements include a facility inspection. Production capacity, inventory, machinery and manufacturing records may be reviewed.

5. What if an employee gives an incorrect answer?

The exporter should correct the information promptly through the designated legal team and provide a written explanation. Delayed correction may create credibility problems.

6. Are Turkish importers involved in the verification visit?

Importers may provide transaction and market information, but the foreign exporter is generally responsible for production, cost and exporter-side sales data.

7. Can a verification visit change the dumping margin?

Yes. Verified corrections, rejected adjustments or revised product matching can increase or reduce the calculated dumping margin.

8. What if records are unavailable because of an old computer system?

The exporter should explain the limitation, describe its document search and provide alternative evidence or a transparent estimation method.

9. Can the final anti-dumping duty be challenged after verification?

Potentially, yes. Administrative submissions, review applications and court proceedings may be available, depending on the decision and applicable deadlines.

10. When should a foreign exporter hire a Turkish lawyer?

Counsel should be engaged as soon as the investigation or verification notice is received. Early legal review protects deadlines, confidentiality, evidence and future appeal rights.

Legal Disclaimer

The information provided in this article is for general informational purposes only and does not constitute legal advice. Laws and regulations may change, and each case depends on its specific facts. For advice regarding your situation, consult a qualified lawyer.

This article is intended for general informational purposes only. To avoid any loss of rights, we recommend consulting your lawyer regarding your specific circumstances.

Expert Legal Support

Specialist legal support is essential to prevent loss of rights during an anti-dumping verification visit in Turkey. Fırat Fesih Kaya Law Office assists foreign manufacturers and exporters with questionnaire responses, verification preparation, dumping-margin calculations, customs disputes and administrative court proceedings.

Lawyer Fırat Fesih Kaya provides professional assistance to international companies facing Turkish trade-remedy investigations.

Office: +90 312 434 22 22
Mobile / WhatsApp: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, 06520 Balgat, Çankaya, Ankara, Turkey

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