Anti-Dumping Investigation Complaint

TO THE CHAIRMAN, NATIONAL TARIFF COMMISSION, ISLAMABAD

COMPLAINT FOR INITIATION OF ANTI-DUMPING INVESTIGATION

Applicant(s): applicant_name, applicant_address, having applicant_capacity in the product_name industry in Pakistan. Respondent(s): respondent_country exporters/producers of product_name, namely respondent_names, whose principal addresses are respondent_addresses.

APPLICATION FOR INITIATION OF ANTI-DUMPING INVESTIGATION UNDER SECTION 11 OF THE ANTI-DUMPING DUTIES ACT 2015

1. The applicant submits this complaint for initiation of anti-dumping investigation against dumped imports of product_name originating from respondent_country into Pakistan, which are causing material injury to the domestic industry in Pakistan. 2. The applicant represents applicant_percentage% of total domestic production of product_name in Pakistan. The domestic industry comprises manufacturers producing product_name with a combined annual production of total_production tonnes/units, of which the applicant produces applicant_production tonnes/units annually. 3. DUMPING: The imports of product_name from respondent_country are being dumped into Pakistan at prices substantially below their normal value. The normal value in the country of origin is USD normal_value per unit, whereas the export price to Pakistan is USD export_price per unit, resulting in a dumping margin of dumping_margin%. 4. MATERIAL INJURY: The dumped imports are causing material injury to the domestic industry as evidenced by: a) Price suppression: Domestic prices have fallen from price_year_1 to price_year_2 (decline of price_decline%) in response to dumped imports. b) Production decline: Domestic production has decreased from production_year_1 to production_year_2 (decline of production_decline%) since dumped imports entered the market. c) Market share loss: The domestic industry's market share has eroded from market_share_year_1% to market_share_year_2% within market_share_period years. d) Inventory accumulation: Unsold inventory has accumulated to inventory_units units, representing inventory_months months of production. e) Employment impact: Employment in the domestic industry has declined from employment_year_1 workers to employment_year_2 workers. 5. CAUSAL LINK: There exists a clear causal link between the dumped imports and the material injury suffered by the domestic industry. The volume and price of dumped imports are the primary factors responsible for injury, not other factors such as domestic demand fluctuations or technical obsolescence. 6. The dumped imports account for import_volume units annually, representing import_market_share% of total market supply. This volume is substantial and has increased significantly since the dumped imports commenced. 7. The domestic industry is solvent and has adequate capacity to supply the market if dumped imports are removed or subject to anti-dumping duties. 8. This complaint is filed in good faith and on the basis of facts and evidence in support thereof.

WHEREFORE, the applicant respectfully prays that this Honourable Commission may be pleased to: (1) Admit this application and issue notice of initiation of anti-dumping investigation against dumped imports of product_name from respondent_country; (2) Call upon the respondent exporters/producers to provide all relevant information regarding production, capacity, costs, prices, and volumes; (3) Conduct a full and fair investigation as provided under the Anti-Dumping Duties Act 2015 and the Anti-Dumping Rules 2016; (4) Make a determination of dumping, material injury, and causal link; (5) Impose provisional anti-dumping duties as deemed appropriate; and (6) Impose definitive anti-dumping duties to eliminate the injury caused by dumped imports.

2. That the National Tariff Commission has the jurisdiction and statutory mandate under the Anti-Dumping Duties Act 2015 to receive complaints from domestic producers, conduct investigation, determine dumping margin, assess material injury, establish causal link, and impose anti-dumping duties.

3. That the present complaint is filed by domestic producers representing more than twenty-five per centum of the total domestic production of the like product, in compliance with Section 14 of the Anti-Dumping Duties Act 2015.

4. That the supporting evidence annexed to this complaint, including export prices, normal values, comparison data, production statistics, and injury indicators, satisfies the threshold for initiation of an investigation under Section 23 of the Act.

PRAYER

It is, therefore, most respectfully prayed that may be pleased to:

(a) Initiate a formal investigation under Section 20 of the Anti-Dumping Duties Act 2015 into the dumping of dumped_product from exporting_country;

(b) Issue a public notice of initiation in the official Gazette and publish the same on the Commission's website;

(c) On preliminary determination of dumping and material injury, impose provisional anti-dumping duties under Section 41 of the Act;

(d) On final determination, impose definitive anti-dumping duties at a level adequate to remove the injury caused to the domestic industry;

(e) Direct the Federal Board of Revenue to collect the anti-dumping duties at the time of import clearance; and

(f) Pass any other or further order as the Commission may deem just and proper in the circumstances of the case.

I, applicant_name, solemnly affirm on oath that the contents of this complaint are true to the best of my knowledge and belief. I further affirm that I am duly authorized to file this complaint on behalf of the applicant.

Deponent applicant_name applicant_designation applicant_organization Date: filing_date