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The UK’s trade remedies body, the Trade Remedies Authority (“TRA”) announced on 22 February that it has begun a reconsideration of its recommendation in Case AD0012, concerning imports of certain aluminium extrusions originating in China (here). Notably, this was the TRA’s first anti-dumping investigation in response to an application from UK industry. A reconsideration application is a request for the TRA to review its findings in a concluded investigation.  

The applicant, a UK producer in Case AD0012, alleges that the TRA erred in its evaluation of the facts and in the application of UK anti-dumping law (here).The applicant seeks an increase in the level of all of the dumping margins found; imposing dumping margins on Shandong Nanshan, a co-operating overseas exporter; and the inclusion of certain large aluminium extrusions originating in China in the product scope so that anti-dumping duties will apply to these as well. 

Reconsideration Application 

In its Final Determination, the TRA concluded that aluminium extrusions originating in China were being dumped on the UK market causing injury to the domestic UK industry and that it was in the UK’s economic interests to impose measures. However, in the TRA’s Negative Determination, it concluded that certain large sized extrusions should be excluded from the scope of the measures. 

The grounds of the reconsideration application also turn on the fact that the applicant considers that the dumping margins of sampled co-operating overseas exporters were incorrect and therefore, if the correct dumping margins were applied, the result would be that the dumping duties would be uplifted. 

Next Steps

At the end of the reconsideration process, the TRA will reach a reconsidered decision either upholding or varying its recommendation and will notify this to the Secretary of State for Business and Trade.

If you would be interested in receiving updates on this reconsideration application, or further information in respect of the UK TRA, please get in touch with our team. 


Jennifer Revis is a partner in Baker McKenzie's London office and co-leads our EMEA Customs Team.
Jennifer focuses her practice on the public regulation of international trade, particularly in a wide range of customs compliance issues. She regularly advises clients on import matters, including customs valuation, rules of origin, and classification. She has worked with clients designing and implementing their compliance programs, policies, procedures and risk assessments, and assisting them in customs audits. She has significant experience in managing global customs projects and disputes, particularly in the area of customs valuation (transfer pricing; assists; royalties). Jennifer also advises on FTAs and trade remedies matters.
Jennifer has been consistently recognised as a "Leading Individual" for Customs & Excise and “Next Generation Partner” for Trade, WTO Anti-Dumping And Customs. Clients describe her as "an outstanding customs lawyer and litigator with fantastic experience. She is also easy to work with and leads her team with aplomb", "without a doubt, one of the best customs lawyers in the business (…) with an exceptionally deep knowledge of customs valuation concepts, as well as considerable experience applying those concepts in a variety of jurisdictions."
Jennifer has been on secondment to the UK customs authorities (Her Majesty's Revenue and Customs) in their tax and excise litigation department and to the Firm's European Law Centre in Brussels.


Rini joined Baker McKenzie after six years with the Canadian government, having worked on Brexit policy, as well in trade and tax litigation. She obtained her legal training with the Canadian government with the Trade Law Bureau and the Department of Justice. Her background in trade matters spans legal advisory, litigation and policy, having worked on free trade agreements, WTO litigation on market access and trade remedies issues. Prior to joining the Canadian government, she was a government affairs associate at one of Canada's most recognizable brands.


Courtney is an associate in the Competition, Trade and Foreign Investment practice group, with a focus on trade and foreign investment matters across a range of sectors. She joined Baker McKenzie in 2022 from another large international law firm where she also advised on a range of international trade matters, including a three year secondment to the trading entity of a global energy major. During her training, Courtney also spent six months on secondment at a multinational FMCG company where she advised on a range of matters concerning household brands, including in respect of commercial contracts, protection of intellectual property, product regulation and competition law.


Sven Bates is Of Counsel for International Trade at Baker McKenzie. He has spent the majority of his career at the Firm's London office, focusing on international trade compliance, trade remedies and anti-bribery. He has also practiced in Amsterdam and has previously worked for the European Commission and the Shadow Attorney General. Sven has extensive experience in particular in the financial services sector, and has undertaken secondments at a Tier 1 UK bank and the Lloyd's insurance market.

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