The firm explained that 2009 saw decreased disposable income among consumers which led to a difficult year for the mobile device sector.
It has forecast a year-on-year increase in worldwide sales of nine per cent in 2010.
However, Carolina Milanesa, research director at Gartner, explained that sales in the grey market - products made without valid international mobile equipment identity certification - have boosted figures for the end of this year and could continue to do so through the next 12 months.
She predicted that the market share of Nokia, which has reportedly lost its leading position in the UK, could be impacted the most, but all manufacturers will have to deal with the issue.
"Although the grey market or 'white label' is not a new phenomenon and has been generated by Chinese device manufacturers … today grey-market sales are no longer limited to China," explained Ms Milanesa.
