The Anti-Dumping Commission (ADC) has initiated Investigation 691, examining alleged dumping and subsidisation of aluminium windows and doors exported from China to Australia.
This investigation marks a significant shift in the ADC’s focus in the aluminium industry. For over a decade, anti-dumping measures have applied to raw aluminium extrusions. Previously, finished goods such as fully assembled windows and doors were considered ‘downstream products’ and were effectively exempt from these anti-dumping and subsidy duties (Duties).
This may no longer be the case in the future as Investigation 691 specifically targets these previously exempt finished goods. Curtain walls are ostensibly excluded from the investigation and the application of the Duties.
If readers or their customers are currently importing aluminium windows or doors from China, or have future projects relying on these supply chains, they face significant commercial risk depending on the outcomes of this investigation.
If the ADC issues a Preliminary Affirmative Determination (PAD), securities or interim duties could be imposed as early as late January 2026.
This has critical retrospective cost implications, particularly for projects with fixed-price contracts signed prior to this investigation. Should Duties be imposed, the importers will be liable for the additional cost, which could erode project margins.
Furthermore, the potential imposition of duties could significantly alter the viability of current Chinese suppliers, leading to potential supply chain disruption.
Key deadlines
The timelines for this investigation are tight, and missing a deadline may result in the loss of the right to participate fully and influence the outcome (although some of these deadlines may be subject to extension of time). Some key deadlines are:
- 9 December 2025: Preliminary Information Request (PIR) response due from Chinese suppliers.
- 02 January 2026: submissions due (initial responses to the investigation).
- 27 January 2026: earliest date for a PAD.
We note that active participation in the investigation is the best way for affected parties to potentially influence the outcome in a favourable way. Cooperating exporters may be able to secure a specific and potentially lower dumping duty rate rather than having the punitive ‘all other exporters’ rate imposed, which is often significantly higher.
Furthermore, engagement with the ADC allows affected parties to argue whether their specific product technically falls within the goods description, and whether the Australian injury has suffered material injury. For importers with locked-in contracts, understanding the likely quantum of duties as soon as possible will allow for better contingency planning and contract renegotiation where possible.
Any readers requiring assistance may contact us to assist with assessing their potential exposure and determining the best strategy for navigating Investigation 691.
Contact us
If you would like to discuss the implications of Investigation 691 on your imports, please contact a member of our Custom & Trade group.
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