Two anti-dumping investigations initiated: Alu Alu Foil and Ibuprofen
The National Tariff Commission has initiated two anti-dumping investigations under section 23 of the Anti-Dumping Duties Act, 2015. Both arise from applications filed on 30 June 2026 under section 20.
Alu Alu Foil (Cold Forming Foil and Tropical Foil) — A.D.C. No. 76/NTC/2026/AAF. Applicant: M/s Zenith Packages Industries (Pvt) Ltd, Lahore. Alleged dumped imports originating in and/or exported from the People's Republic of China. PCT headings 7607.1990 and 7607.2000. Notice signed 23 July 2026.
Ibuprofen — A.D.C. No. 78/2026/NTC/Ibuprofen. Applicant: M/s Zenith Chemical Industries (Pvt) Ltd, Lahore. Alleged dumped imports originating in and/or exported from the People's Republic of China and the United States of America. PCT heading 2916.3910. Notice signed 25 July 2026. The application alleges both material injury and threat of material injury.
In both, the period of investigation for dumping is 1 April 2025 to 31 March 2026, and for injury 1 April 2023 to 31 March 2026.
Who is affected
Importers and distributors of aluminium foil falling under the two headings in the first investigation, and of ibuprofen under heading 2916.3910 in the second. Chinese exporters and producers of both products, and US exporters and producers of ibuprofen. Pharmaceutical manufacturers using imported ibuprofen as an input, and packaging converters using Alu Alu foil, whose landed cost is directly exposed.
Duty, if imposed, is paid at the border by the importer, in addition to ordinary customs duty. Provisional measures take the form of a cash deposit and may be imposed no earlier than sixty days from initiation.
On the ten-day period in the notices
Both notices ask interested parties to identify themselves within ten days of publication in the press. That period has now passed on any likely publication date, and parties who did not register in it may assume they are shut out. In our view that assumption is wrong, and it is worth being clear why.
The ten-day period is administrative, not statutory. Nothing in the Anti-Dumping Duties Act, 2015 requires an interested party to register within ten days of initiation. The period appears in the notice as a matter of the Commission's own practice in scheduling the investigation. It is not a limitation prescribed by the Act.
A self-imposed period is a weak basis for exclusion. Refusing to admit a party to a quasi-judicial proceeding — with a direct pecuniary interest in its outcome — solely because it did not respond within a period the Commission set for its own convenience raises an obvious question under Article 10A of the Constitution and the ordinary principles governing quasi-judicial process.
What the Commission can properly say is different. It is entitled to insist that a late entrant does not derail the investigation timetable, and submissions arriving so late that they cannot be evaluated within the statutory periods may be difficult to accommodate. But that is a question of where the investigation has actually reached, not of a calendar rule.
These investigations are early. Both were initiated in late July. Preliminary determination cannot come earlier than sixty days from initiation, and the forty-five-day window for views, comments and evidence remains open on both. A party registering now, and filing within that window, is not asking the Commission to disturb anything.
What registration provides
Registration as an interested party under section 2(j) is what converts an importer or exporter from a bystander into a participant.
The public file
Under rule 7 of the Anti-Dumping Duties Rules, 2022, the Commission maintains a public file open to interested parties for review and copying — in these investigations, Monday to Thursday between 1100 and 1300. That file contains the non-confidential application and the material on the record. Without registration, a party first learns what was alleged, on what data, when the determination is published and the duty is in force.
Product scope
The description of the investigated product is settled during the investigation. A party whose goods differ in specification, grade or use has its realistic opportunity to say so now. Scope arguments run much harder once a determination has fixed the description and the headings.
The rate
The Commission must determine an individual dumping margin for each known exporter (section 14(1)), and must do so even outside a sample for an exporter who volunteers the necessary information in time (section 14(4)), with individual duties applied accordingly (section 51(5)). Exporters not known to the Commission at final determination receive the residual rate (section 51(6)). An importer with a commercial interest in a particular supplier has reason to ensure that supplier participates, because the difference between an individual rate and the residual rate is borne at the border for five years and, on sunset review, potentially longer.
The record for appeal
On appeal under section 70, the Tribunal assesses whether the Commission's establishment of the facts was proper and its evaluation unbiased and objective, on the official record and the documents relied on. An argument never placed on the record during the investigation is largely unavailable afterwards. The investigation is where the material for any later challenge is created.
Filing
Alu Alu Foil: submissions to the Director (Investigation-II/B), National Tariff Commission, State Life Building No. 5, Blue Area, Islamabad. Ibuprofen: to the Secretary at the same address. Confidential submissions must be marked accordingly and, under section 31, accompanied by a non-confidential summary for the public file.
Deadlines run from publication in the press, which is not the date on the notice. Verify the publication date before calculating any period.
This note is general commentary and not legal advice. Time limits and procedural positions should be verified against the governing instruments and the documents in your own matter. Please read our full disclaimer.