GCC Anti-Dumping Duties: How Importers Are Affected and How to Respond

–They add a duty of up to the dumping margin to every import of the product from the named countries, paid at clearance for five years

The GCC Common Law on Antidumping, Countervailing Measures and Safeguard Measures has applied since 1 January 2004. It allows the GCC states to impose duties on imports from outside the GCC that are sold below their normal value and cause injury to a GCC industry. Once a measure is in force, the customs department of each member state collects the duty on every declaration of the product from the named countries.

The importer does not have to be the target of the complaint to be affected. A distributor buying ceramic tiles from India or aluminium sheet from China pays the anti-dumping duty at clearance, in addition to the 5% customs duty. The rate depends on the exporter. A producer that cooperated in the investigation can receive its own lower rate, while all other exporters pay the residual rate.

• The duty follows the product and the origin. It applies to the product under the listed tariff codes from the named countries, whoever the importer is.
• The rate depends on the exporter. Cooperating exporters receive individual rates, and all others pay the higher residual rate.
• Measures last five years. A definitive measure expires after five years unless an expiry review finds that dumping and injury are likely to continue or recur.
• Importers are interested parties. The law lists importers of the product among the parties entitled to take part in the investigation.
• Deadlines are short. A questionnaire must be answered within 40 days of being sent, with one extension of 10 days on a justified request.
• Measures can be challenged. An interested party can seek administrative review within 30 days of publication and then appeal to the GCC Judicial Commission.

Who this applies to

This applies to importers, distributors and trading companies in the UAE that buy goods from outside the GCC, and to manufacturers that import raw materials or components subject to a measure. It concerns buyers in construction supply chains, such as tiles, steel, aluminium and cement, and logistics operators that clear goods on their clients’ behalf.

Our commercial lawyers in Dubai advise importers and foreign exporters on GCC trade remedy investigations, prepare questionnaire responses and submissions, and review supply contracts for duty risk. This article covers anti-dumping investigations and duties. Our guide on importing goods through Dubai customs covers the standard customs duty and clearance.

The legal framework

• The GCC Common Law on Antidumping, Countervailing Measures and Safeguard Measures. The Common Law and its Rules of Implementation entered into force on 1 January 2004. The amended Rules set the procedure for complaints, investigations, measures and reviews. Under Article 2, the law applies to injurious practices in trade from non-member states toward member states.
• The WTO Anti-Dumping Agreement. The GCC law follows the WTO Anti-Dumping Agreement, which sets the rules on dumping margins, injury and the duration of measures for all WTO members.
• The UAE Federal Law on Anti-Dumping, Countervailing and Preventive Measures. The federal law was issued on 16 April 2017 and took effect on 28 April 2017. The current measures discussed in this article were taken under the GCC Common Law.

The administering bodies:

• The Bureau of the Technical Secretariat for Anti-Injurious Practices in International Trade. It is part of the GCC General Secretariat in Riyadh, receives complaints and conducts investigations under Article 10 of the law.
• The Permanent Committee. It decides whether to open an investigation, imposes provisional measures, accepts price undertakings and proposes definitive measures.
• The Ministerial Committee. It approves definitive measures and decides requests for administrative review.
• The customs departments of the member states. In the UAE, local customs departments such as Dubai Customs publish notices and collect the duties.

The supervising courts:

• The GCC Judicial Commission. It hears appeals against decisions on measures after administrative review.

How a GCC anti-dumping investigation starts

An investigation starts with a complaint from GCC producers of the like product. The importer learns of it from the initiation notice, and the clock starts then.

The complaint and standing

Under Article 2 of the Rules, a complaint can be filed by the GCC industry, on its behalf, or by chambers of commerce or producers’ unions. Under Article 6, the Permanent Committee opens an investigation only where the complaint has enough support. Supporting producers must account for more than 50% of the output of producers expressing a view, and for at least 25% of total GCC production of the like product. Producers related to exporters, and producers that are importers themselves, can be excluded from this count.

Evaluation and initiation

The Technical Secretariat evaluates the complaint within 30 working days, and the Permanent Committee decides within 15 working days of the Secretariat’s report. Under Article 9 of the Rules, the initiation notice is published in the GCC Official Gazette within 10 working days of the decision, and the investigation starts on publication. The notice names the product, the tariff codes, the countries and the deadlines for interested parties to make themselves known.

The investigation period

Under Article 23 of the Rules, the investigation must be completed within 12 months of initiation. The Permanent Committee may extend it by up to six months in special circumstances. A preliminary report is due within 180 days of initiation, and parties have 15 days to comment on it.

The importer’s role in the investigation

Importers are interested parties under Article 3 of the law, alongside exporters, foreign producers, the exporting government and GCC producers. The importer’s evidence on prices, demand and the end use of the product can change the outcome.

Making yourself known

The initiation notice sets a deadline for interested parties to register. An importer that misses it may lose the right to receive the questionnaire, comment on the reports and request a hearing.

The questionnaire

Under Article 12 of the Rules, a questionnaire must be answered within 40 days of being sent, and it is treated as received seven days after dispatch. An extension of 10 days may be granted on a justified request made before the original deadline. The importer questionnaire asks for purchase volumes and prices, resale prices, suppliers, stock levels and the use of the product.

Hearings and written submissions

An interested party may request a hearing by the date in the notice. Under Article 15 of the Rules, information given orally counts only if it is submitted in writing within 10 days after the hearing. Importers can use hearings to argue that the GCC industry cannot supply the product, or that injury has other causes.

Confidentiality

Under Article 12 of the law, confidential information may not be disclosed without the written permission of the party that provided it. Article 13 sets a fine of up to SAR 500,000 for breaches. Each party must file a non-confidential summary of confidential submissions, and information that is not properly supported can be disregarded.

Non-cooperation

Under Article 26 of the Rules, where a party refuses to provide information or does not provide it in time, determinations may be based on the information available. For an exporter, that means the residual rate. For an importer, it means the investigation proceeds without its evidence on price, demand and supply.

Provisional and definitive duties

A measure can apply before the investigation ends. The importer should plan for duty from the date of the preliminary findings.

Provisional measures

Under Article 6(2) of the law, provisional measures may take the form of customs duties, price undertakings or security by cash deposit or bond, and they may not exceed the provisional dumping margin. They cannot be imposed in the first 60 days after initiation and are limited in duration. Where the final duty is lower than the provisional one, the difference is refunded or the security released.

Definitive duties

Under Article 6(1) of the law, a definitive duty may not exceed the dumping margin. The Ministerial Committee approves it on the proposal of the Permanent Committee, and the public notice states its form, level and duration. The duty is calculated as a percentage of the CIF value, and the customs department of the member state collects it with the standard customs duty.

Recent measures

In 2025 the GCC imposed duties on aluminium alloy sheets, plates and strips from China at rates between 7.1% and 20% of the CIF value, depending on the producer. Dubai Customs implemented them by notice, according to PwC Middle East. Duties on ceramic and porcelain tiles from China and India were extended for a further five years in May 2026, after an expiry review. Duties on starter batteries from China and Malaysia took effect in January 2026.

Reviews, refunds and undertakings

A measure is not fixed for its five years. The Rules give importers and exporters several routes to change or end it.

Expiry review

A measure expires five years after it is imposed, or five years after its last review. The GCC industry can request an expiry review before that date, and the measure stays in force while the review proceeds. The tiles review shows the effect: the duties continued while the review was pending and were then extended.

Interim review

An interested party can request an interim review where circumstances have changed, for example where the exporter’s prices have risen or the GCC industry has stopped producing the product. The review can reduce, increase or remove the duty.

New exporter review

A foreign producer that did not export during the investigation period can request its own review to obtain an individual rate. An importer buying from a new supplier should ask whether that supplier has applied.

Refunds

Where an importer shows that the duty collected exceeds the actual dumping margin, it can request a refund. The request must be supported by evidence on the exporter’s prices and normal value, which the importer must obtain from the exporter.

Price undertakings

An exporter can offer to raise its prices to remove the injurious dumping, in place of a duty. An undertaking can be accepted only after a preliminary finding of dumping and injury. Where it is accepted, the importer pays the higher price instead of the duty.

Appealing a measure

Under Article 11(1) of the law, an interested party can ask the Ministerial Committee for administrative review within 30 days of publication of the decision. The Committee decides within 60 days, and a request not decided within that period is treated as rejected. Under Article 11(2), the party can then appeal to the GCC Judicial Commission within 30 days of notification of the rejection.

The appeal concerns the measure itself. A dispute with customs about the classification or valuation of a particular shipment follows the customs appeal route instead. Our article on appealing Dubai customs decisions covers that route.

Common mistakes by importers

Ignoring the initiation notice. An importer that does not register as an interested party loses its voice in the case, and the measure is decided on the evidence of others.

Assuming the exporter will defend the case. The exporter defends its own margin, and the importer’s arguments on supply shortages and demand may not be made at all.

Missing the questionnaire deadline. A late response without an extension requested before the deadline can be disregarded.

Signing supply contracts without a duty clause. A contract that does not allocate anti-dumping duty leaves the importer bearing the cost of a measure imposed during the contract.

Changing the declared origin or classification. Routing goods through a third country or declaring them under a different code to avoid the duty can lead to a customs violation or smuggling case. Our article on Dubai customs post-clearance audits covers how customs checks past declarations.

Not checking the exporter’s individual rate. Buying from an exporter without an individual rate means paying the residual rate, which can be several times higher.

What importers should do next

• Monitor initiation notices. Track the GCC Official Gazette and customs notices for investigations on the products you import.
• Register as an interested party. Make yourself known by the date in the notice and request the questionnaire.
• Prepare the questionnaire response early. Collect purchase, resale and stock data, and request any extension before the original deadline.
• Coordinate with exporters. Agree on the evidence each party will provide, and check whether your supplier will seek an individual rate or offer an undertaking.
• Review supply contracts. Add clauses that allocate anti-dumping duty and allow price renegotiation or termination if a measure is imposed.
• Check alternative sources. Identify suppliers from countries outside the measure, without changing the declared origin of goods already sourced.
• Diary review and appeal dates. Note the 30-day period for administrative review and the date when the measure is due to expire.

How should importers respond to a GCC anti-dumping investigation?

A GCC anti-dumping investigation is decided on the evidence filed within the deadlines in the Rules and the initiation notice. Importers are interested parties, and an importer that registers, answers the questionnaire within 40 days and takes part in the hearing can influence whether a duty is imposed and at what level.

The main risk is cost over time. A duty of up to the dumping margin applies to every shipment for five years and can be extended after an expiry review. A measure on a core product therefore changes the importer’s pricing and sourcing.

The commercial consequence is that importers who prepare early have options. They can support lower individual rates, request interim or new exporter reviews, seek refunds and challenge the measure within 30 days. Importers who wait until the duty appears on a customs declaration have fewer of those options left.

For importers and foreign exporters, our corporate and commercial team advises on GCC anti-dumping investigations, questionnaire responses and supply contracts that allocate trade remedy risk.