The EU’s New Agenda: Why Has Anti-Circumvention Become So Important?
Over the last few years, the axis of the foreign trade world has been shifting completely. Countries no longer focus only on the price of the products they import; where those products are actually manufactured, which raw materials they are shaped by, and which country’s supply chain they are fundamentally connected to have become much more important. In particular, the concept of "Anti-Circumvention," which the European Union has repeatedly emphasized in recent years, lies exactly at the centre of this sensitivity.
So, what is anti-circumvention? Why is the EU showing such a high level of sensitivity on this issue, and more importantly, why does this situation closely concern exporters in Türkiye?
What Is Anti-Circumvention?
The logic behind it is actually quite straightforward. When a country imposes anti-dumping duties, additional financial duties, quotas, or safeguard measures against another country in order to protect its domestic producers, some manufacturers and intermediaries begin looking for creative and alternative ways to avoid these measures.
For example, let us consider a product originating from China. Since this product would face significant duties if exported directly to the EU, it may first be shipped to a third country . Without creating significant added value there, it may be subjected only to a minor process or repackaging and then exported to the EU as if it were originating from that country in order to gain a tax advantage. This is exactly the type of process that has attracted the EU’s attention and that it seeks to prevent. Brussels is no longer satisfied with asking, “Which country did this product come from?”; it is now pursuing the question, “Where was the real added value behind this product created?”
Why Is the EU So Sensitive Now?
The biggest reason behind this strict approach is, as one might expect, China’s enormous and aggressive production capacity. Today, China has become the world’s manufacturing hub in almost every critical sector, ranging from steel and aluminium to electric vehicles, batteries and solar panels, and from industrial machinery to electronics. Moreover, this massive volume is offered to global markets through highly aggressive pricing policies.
Europe believes that this situation has brought the continent’s industrial infrastructure and domestic producers to the brink of being undermined. This is also why the term “China-driven overcapacity” has appeared so frequently in recent European media reports and analyses. Therefore, the EU now recognizes that it cannot protect its borders merely by introducing new duties; it also wants to monitor much more closely whether these duties are being circumvented.
Where Does Türkiye Stand in This Process? Are We Close to a Risk or an Opportunity?
Türkiye stands right at the centre of this equation due to its geographical location and industrial strength. Its Customs Union relationship with the EU, strong manufacturing infrastructure and logistical proximity to Europe make Türkiye an excellent supply partner for European buyers looking for alternatives to China. This represents a tremendous opportunity for our country.
However, there is also a other side to the coin. EU authorities suspect that some Chinese-origin inputs or products are entering the European market through certain countries by “changing their origin.” If a similar perception or concrete suspicion emerges regarding the export corridor from Türkiye, even honest Turkish companies may find themselves involved in intensive and exhausting trade defence investigations. Sectors such as steel, aluminium, solar panels, automotive supply industries, and electrical and electronic products are currently under Brussels’ close watch.
It Is No Longer Enough Simply to Obtain a Certificate of Origin
In traditional foreign trade practices, a properly issued certificate of origin or, where applicable, a movement certificate was generally sufficient to pass through customs procedures. However, those days are now behind us. EU customs and trade inspectors now look beyond the ink on the document. They examine in great detail the exporter’s actual production capacity, the origin of the raw materials used in the factory, who the suppliers are, and even the level of technical added value created during the production process.
Ultimately, customs authorities are seeking answers to the following questions: “Is there truly a production process carried out from scratch here, or is it merely a simple assembly or joining of parts? Has the product genuinely undergone the economic transformation required by the legislation?”
What Awaits Exporting Companies in the New Era?
In the coming period, three main topics will be critical on the agenda of companies that wish to maintain their position in the EU market and avoid customs barriers:
End-to-End Supply Chain Transparency: Companies will need to be able to explain the entire journey of their products, from raw materials to finished goods, with verifiable data. They must always be prepared to answer questions such as: “Who supplied the raw material, where was it processed, and in which factory was the added value created?”
Flawless HS Code and Origin Management: The use of incorrect or inaccurate HS Code (Tariff Classification) can no longer be considered merely a risk of local tax penalties; it can become a trigger for an anti-circumvention investigation. Therefore, tariff classification and origin acquisition analyses must be conducted with engineering-level precision.
A New Era of Compliance in Carbon, Origin and Trade: With the Carbon Border Adjustment Mechanism (CBAM), foreign trade now has a two-dimensional nature. The EU will look not only at where a product is manufactured, but also at the amount of carbon footprint generated during its production. In the near future, origin management, carbon data, and production methods will be examined together as a single package.
In Summary
The rules of foreign trade are being rewritten, and the motto of the new era is very clear: “Selling inexpensive products alone is no longer enough to stay in the game.” To remain competitive in the new world order, companies need reliable supply chains, genuine production, transparent data, sustainability, and sound customs strategies.
Türkiye has the potential to turn Europe’s search for alternatives to China into an advantage through the right strategic moves. However, for this process to become a lasting advantage, our companies need to learn not only how to manufacture goods but also how to transparently manage their entire supply chains under international trade rules and defend them whenever necessary.