Ukraine Initiates Three Anti-circumvention Investigations on Imports from Malaysia

On 16 April 2025, the Interdepartmental Commission on International Trade of Ukraine (“Commission”) initiated three anti-dumping investigations into the suspected evasion of anti-dumping duties on Chinese-origin products that are being re-exported to Ukraine via Malaysia. These investigations target the following subject merchandise, all of which were previously subject to anti-dumping duties when directly imported from China; 
  1. Steel Fasteners1 classified under Ukraine classification codes 7318 15 69 90, 7318 15 81 90, 7318 15 89 90, 7318 15 90 90, 7318 16 91 90 and 7318 16 99 90;
  2. Silicon-Manganese Steel Wire2 classified under Ukraine classification code 7229 20 00 00; and
  3. Coated Flat-Rolled Carbon-Steel Products3 classified under Ukraine classification codes 7210 70,  7210 90 and 7212 40, 
(collectively “subject merchandise”).
 
The investigations were prompted by complaints from Ukrainian manufacturers: PrJSC Druzhkiv Metal Products Plant in the case concerning Steel Fasteners; LLC PLAZMATEK in the case concerning Silicon-Manganese Steel Wire; and a joint complaint by LLC HEAVY METAL and LLC MODUL-UKRAINE in the case concerning Coated Flat-Rolled Carbon-Steel Products.
 
Each complaint presented evidence of a notable shift in import patterns namely, a sharp decline in imports from China accompanied by a surge in imports from Malaysia, raising concerns over possible circumvention of anti-dumping duties and undervaluation at customs. As a precautionary measure, the Commission has required suppliers of the subject merchandise originating from Malaysia to place advance deposits equivalent to the applicable anti-dumping duties and VAT, commencing from 28 April 2025.
 
Interested parties are invited to submit factual information and register within 20 days from the effective date of the Commission’s decision, and to provide written comments within 30 days. Submissions must comply with Ukrainian language requirements and, where applicable, be accompanied by both confidential and non-confidential versions.
 
Please contact Ms. Lim Koon Huan (Partner), Mr. Manshan Singh (Partner), Ms. Ho Pui Yan (Associate) or Ms. Lim Shu Yi (Associate) of our Anti-Dumping and Trade Remedies Practice Group for further information.
 

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