A shipment clears customs without an anti-dumping duty. A few months later, the importer could still be asked to pay one.
This can happen when the European Commission makes imports subject to registration during an anti-dumping investigation. Registration itself does not impose a duty. It allows customs to identify the goods if a duty is later collected retroactively.
Which products are affected?
In late October 2026, the Commission introduced registration for:
- Certain pure PVC from China, South Korea, Mexico and Taiwan, from 27 October.
- Certain cellulose ethers from China and South Korea, from 31 October.
Both measures provide for registration for nine months. The exact product description, grade and origin determine whether goods are covered.
Why ordering early may not avoid the duty
When an investigation starts, buyers may bring orders forward to build stock before duties arrive. But if many buyers do this, the resulting surge in imports could help create the conditions for a retroactive duty.
That does not mean one larger order will trigger a duty. The Commission considers the wider increase in imports, its timing and its likely effect, alongside other legal conditions.
Even if a definitive duty is imposed, retroactive collection is not automatic. Under the relevant EU rules, it can apply to eligible registered goods entered for consumption up to 90 days before provisional measures take effect, subject to further conditions.
What should buyers do?
Check the exact product scope and tariff code with your customs representative before ordering. Keep clear records of the manufacturer, as duty rates can differ by producer.
It is also worth agreeing with your supplier in writing how any retroactive duty would be handled. Until the investigation concludes, include the potential cost in your purchasing decision.
At Berg, we check trade defence cases during the quotation process, so these risks can be considered before an order is confirmed.
Sources