South Africa's Trade Remedy Pipeline: Windscreen Circumvention Duties, New PET and Cement Probes, and a Paper Sector Review

• Windscreens, country hopping (4 September): final duties on Chinese windscreens routed via Malaysia: 12.92% for one selected exporter, 129.15% for all others.

• Windscreens, tariff hopping (7 September): duties extended to windscreens declared as vehicle parts (8708.22.10): 12.92% and 28.39% for selected exporters, 129.15% residual.

• PET (Notice 4152 of 2026): anti-dumping investigation into virgin PET from Egypt, Oman and China, the China leg limited to the Jiangsu Sanfangxiang Group previously excluded as de minimis, on Safripol's application.

• Portland cement: investigation into imports from Vietnam and Mozambique, on application by Afrimat, Intercement and Dangote Cement SA. Preliminary margins are 37.04% (Vietnam) and 90.51% (Mozambique).

• Paper review (17 September): tariffs, trade remedies and possible import surveillance for headings 48.01–48.05, 48.11, 48.18 and 48.23, requested by Minister Parks Tau. No duty proposals are listed yet.

• Deadlines: paper comments by 15 October 2026; PET and cement submissions by 18 October 2026.

South Africa already imposes anti-dumping duties on vehicle windscreens from China, under tariff subheading 7007.21.20 (laminated safety glass). ITAC found that importers were avoiding those duties in two ways, and on 7 March 2025 it opened two anti-circumvention investigations. SARS implemented the final duties in September 2026.

What the two cases mean.

• Country hopping is transhipment or minor processing in a third country to disguise origin. The duties now apply to windscreens coming through Malaysia unless they come from the exporter that cooperated and obtained its own rate.

• Tariff hopping is misclassification to a tariff line not covered by the original duty. By extending the duty to subheading 8708.22.10, SARS closes that route.

The residual rate is the key number. At 129.15%, the residual duty is designed to make uncooperative or unidentified suppliers commercially unviable, which is the standard effect of a residual rate in trade-remedy practice. Importers sourcing from anyone other than the named exporters will pay more than double the value of the goods in duty.

PET from China, Egypt and Oman (ITAC Notice 4152 of 2026)

The China leg is unusual. Jiangsu Sanfangxiang was excluded from South Africa's earlier anti-dumping duties on Chinese PET because its dumping margin was found to be de minimis. ITAC has decided that this exclusion does not bar a fresh investigation based on new facts and a new investigation period. The case targets a single producer that previously escaped duties.

Portland cement from Vietnam and Mozambique

Deadline for both cases. Interested parties, including foreign producers, exporters, importers and users, must submit questionnaire responses and representations within 30 days of publication or receipt of the questionnaire. For most parties that means 18 October 2026.

What happens next. ITAC will verify submissions and make a preliminary determination, which can lead to provisional anti-dumping duties, before a final determination. No duties are payable yet. But importers should note that provisional duties can be imposed during the investigation.

What ITAC launched. At the request of the Minister of Trade, Industry and Competition, Parks Tau, ITAC invited comment on a sector-wide review covering three things for paper and paper products:

1. the tariff structure;

2. the relevant trade remedy measures; and

3. the possible introduction of an import surveillance system.

Products in scope: tariff headings 48.01 to 48.05 (newsprint, uncoated paper, tissue stock, kraft and other uncoated papers and paperboard), 48.11 (coated and treated paper), 48.18 (toilet paper, tissues, towels and similar household and sanitary products) and 48.23 (other cut paper and paperboard articles).

Why now. The Minister's request cites:

An open-ended review. Unlike the steel review, the paper gazette does not list proposed duty changes. ITAC is gathering evidence first. Interested parties must respond using the questionnaire on ITAC's website by 15 October 2026. ITAC has said it will keep evaluating existing applications for tariff amendments and trade measures in the sector in the meantime.

The likely pattern. If the steel review is a guide, a paper review could lead to higher duties on products South Africa makes in adequate quantities, rebates for grades it does not, possible import permits, and support for new trade-remedy applications. Because the gazette sets no specific proposals, the evidence submitted now will shape what ITAC recommends.

1. Anti-circumvention: filling a gap in WTO law

The WTO Anti-Dumping Agreement contains no detailed anti-circumvention rules; negotiators could not agree on them. Members therefore rely on domestic law, and South Africa's anti-dumping regulations provide for circumvention investigations. The windscreen cases show the two classic forms:

• Country hopping, or transhipment, which raises a rules-of-origin question: whether the goods were genuinely produced in Malaysia or merely passed through it.

• Tariff hopping, or misclassification, which raises a classification question: whether goods declared under a parts heading are in substance windscreens covered by the original duty.

Because circumvention rules lack express WTO guidance, they are a frequent source of trade friction. Rates for cooperating exporters (12.92% and 28.39%) show ITAC calculated individual margins where firms engaged. A residual rate such as 129.15% typically reflects the use of "facts available" for those that did not, a method the Anti-Dumping Agreement permits but subjects to safeguards on how the evidence is used.

2. Reopening a de minimis exporter (PET)

Under the Anti-Dumping Agreement, an exporter whose dumping margin is de minimis (below 2%) must be excluded from duties. WTO case law has limited attempts to pull such exporters back into an existing order through later reviews. ITAC has taken a different route: a new investigation with a new period of investigation and new facts. That is legally cleaner than a review, but Jiangsu Sanfangxiang can be expected to scrutinise whether the evidence of dumping and injury in the new period genuinely stands on its own.

3. A regional neighbour in the dock (cement)

Mozambique is a fellow SADC member and part of the SADC Free Trade Area, under which most goods trade duty-free. The SADC Protocol on Trade still allows members to apply anti-dumping measures to dumped imports from each other, so the investigation is lawful. But a preliminary margin of 90.51% against a neighbour is politically sensitive, and remedies against regional partners tend to draw closer scrutiny. Vietnam has no trade agreement with SACU, so ordinary WTO rules apply.

4. Sector-wide reviews as industrial policy

The paper review follows the steel template: a ministerial request, a sector-wide look at tariffs, trade remedies and import surveillance, and a structured questionnaire process. Duty increases are lawful within South Africa's WTO bound rates. Surveillance systems are acceptable if they are transparent and do not restrict imports more than necessary. These reviews are effectively industrial-policy exercises, using trade tools to stabilise sectors under pressure from imports, input costs and weak demand.

5. SACU-wide effects

ITAC administers tariffs and trade remedies for the Southern African Customs Union. Whatever is decided on windscreens, PET, cement and paper applies equally to imports into Botswana, Lesotho, Namibia and Eswatini.

Windscreens

Auto-glass importers, distributors and fitment centres. Duties now apply whether Chinese windscreens are declared as glass or as vehicle parts, and whether they come direct or via Malaysia. Unless the supplier is one of the named exporters with an individual rate, the duty is 129.15%. Importers should verify the manufacturer behind every invoice, check classification, and re-cost supply. Stock bought from non-named Malaysian or Chinese suppliers will become far more expensive.

Motorists and insurers. Replacement windscreens from non-named sources will cost more, and insurers may see higher claims costs for glass replacement. Local and non-Chinese suppliers, and named exporters, gain market share.

The SACU windscreen industry. The circumvention rulings restore the protection the original duty was meant to provide, and show that ITAC will act on evasion.

PET

Safripol and local PET producers. If the investigation succeeds, it would extend protection to Egyptian, Omani and the remaining Chinese competition, including the previously excluded Jiangsu Sanfangxiang Group.

Beverage, food and packaging companies. PET resin is a core input for bottles and food packaging. Possible duties could raise packaging costs for soft-drink, water and food brands. Users should file representations by 18 October showing the impact on downstream industry and the availability of local supply.

Jiangsu Sanfangxiang, Egyptian and Omani exporters. Cooperation is critical. Exporters that answer ITAC's questionnaires and allow verification can obtain individual margins. Those that do not face facts-available rates, which tend to be much higher.

Recyclers. Duties on virgin PET could make recycled PET more competitive, which links this case to South Africa's packaging recycling and extended producer responsibility goals.

Cement

Local cement producers (Afrimat, Intercement, Dangote Cement SA/Sephaku). A successful case would curb competition from Vietnamese and Mozambican imports, which ITAC preliminarily found to be suppressing and undercutting local prices.

Construction companies, developers and government infrastructure programmes. Cement is a major building cost. Anti-dumping duties at margins of 37% to 91% would push up prices for imported cement and could allow local prices to rise. Contractors on long projects should review price-escalation clauses.

Mozambican exporters and the Mozambican government. Mozambique faces the highest preliminary margin, 90.51%. Exporters should participate fully, and the government may raise the case in SADC forums.

Cement importers and traders. Imports may face provisional duties during the investigation. Importers should plan purchases with that risk in mind.

Paper

Pulp and paper producers and forestry communities. The review is an opportunity to secure tariff and trade-remedy support, and to protect rural employment tied to forestry and fibre. Producers should file comprehensive evidence of import injury, capacity and investment.

Printers, publishers, packaging converters and tissue makers. Higher duties on paper inputs would raise their costs. They should identify grades not made locally and argue for rebates, as downstream steel users have done.

Retailers and consumers. Tissue, toilet paper, packaging and printed products could become more expensive if protection rises.

Across all cases

Trade lawyers and customs advisers. Three deadlines fall close together: paper review comments by 15 October, and PET and cement submissions by 18 October. Advisers will also be busy with origin and classification checks for windscreen importers.

SACU neighbours. Every measure applies across Botswana, Lesotho, Namibia and Eswatini, affecting their importers and consumers too.

What duties now apply to Chinese windscreens imported via Malaysia? 12.92% for one selected exporter and 129.15% for all others, effective 4 September 2026.

What changed for Chinese windscreens declared as vehicle parts? From 7 September 2026, the anti-dumping duty applies to windscreens under both 7007.21.20 and 8708.22.10: 12.92% and 28.39% for two selected exporters and 129.15% for all others.

Which PET imports are under investigation? Virgin PET (3907.6) from Egypt and Oman, and from China only where made by the Jiangsu Sanfangxiang Group, following an application by Safripol.

What are the preliminary dumping margins on cement? 37.04% for Vietnam and 90.51% for Mozambique. These are not yet duties; ITAC must complete its investigation first.

What does the paper review cover? Tariffs, trade remedies and a possible import surveillance system for paper and paper products under headings 48.01–48.05, 48.11, 48.18 and 48.23. Comments are due by 15 October 2026.