China: An International Trade/WTO: Consultants (PRC Firms) Overview

The New Normal of Trade Remedies Under Multiple Pressures

Trade remedies refer to legally authorised measures adopted by an importing country when its domestic industry suffers injury. Such injury may be caused by unfair competition from imported products, such as dumping or subsidisation, or by a surge in imports. The principal instruments include anti-dumping duties (AD), countervailing duties (CVD), and safeguard investigations (SG).

Looking at the overall landscape of global trade remedy investigations against the imports from China in 2025, trade frictions remained frequent worldwide. Driven by a combination of industrial policy competition, supply-chain security considerations, and domestic employment pressures, jurisdictions and economic blocs continued to treat trade remedies as a “lawful and efficient” policy tool to restrain and manage the impact of import shocks. Compared with prior years, the policy objectives of trade remedies are no longer confined to curbing injury caused by dumped or subsidised imports. They are increasingly linked to broader agendas such as energy transition, critical raw materials security, manufacturing reshoring, and resilience of industrial and supply chains. At the same time, many jurisdictions have intensified the use of procedures such as “sunset reviews” at the expiry stage of existing measures to preserve continuity. Enforcement-oriented mechanisms such as “anti-circumvention” and “anti-evasion” are also being deployed more actively to strengthen implementation, resulting in tighter scrutiny of import channels and origin chains. Taken together, these developments illustrate that trade remedies are operating within a broader policy framework, in which legal instruments and industrial strategy increasingly interact.

Overview of global trade remedy initiations against China in 2025

According to our statistics, trade remedy initiations against China in 2025 displayed three prominent features: broad initiation across multiple regions, high concentration in key industries, and a broader mix of instruments.

In North America (notably the United States and Canada), both the volume of cases and the diversity of instruments were comparatively greater. In addition to traditional anti-dumping and countervailing duty investigations, proceedings were frequently coupled with anti-circumvention and anti-evasion enforcement measures. In Latin America, major economies such as Brazil and Mexico relied primarily on anti-dumping investigations, often conducted at a rapid pace. Product choices have often prioritised the cost-sensitive segments within domestic supply chains and standardised commodity markets. In Europe, the European Union’s cases against China spanned a wide range of industries, with heightened technical thresholds and deep industrial chains. The United Kingdom, meanwhile, demonstrated a superimposed review approach in respect of certain priority products, by running anti-dumping and countervailing duty reviews in parallel and applying both measures side by side where the legal requirements were met. In Asia, India maintained a high case density and showed a clear concentration in chemicals and materials. Japan paid particular attention to steel-related products and key chemical goods, while Thailand stood out for its concentrated use of anti-circumvention instrument. In Oceania (Australia and New Zealand), case volume was relatively limited, but actions were more targeted toward basic industrial products and construction materials. In the Middle East and within the Eurasian Economic Union, overall numbers were not high, but some jurisdictions maintained trade defences against Chinese products through sunset reviews or new investigations targeting specific product categories.

China’s respondent position in the global trade remedy system

Based on the regional data analysed by our Zhong Lun team, China continues to be among the most central and most frequently targeted respondents in the global trade remedy system. Such a “respondent position” is related not only to China’s global supply capacity across a broad range of industrial goods and intermediate inputs, together with its export scale and price competitiveness. It is also linked to the rising concerns in many jurisdictions about import dependence and industry security anxiety in critical materials, foundational manufacturing, and emerging industrial chains. In this context, China’s prominence in global supply chains and its integration into key industrial segments make it more visible in trade remedy proceedings across diverse sectors.

More importantly, case structures in multiple jurisdictions indicate that measures targeting Chinese products are evolving from a “single-instrument approach” to a “combined-tool approach”: situations where a product is simultaneously subject to both anti-dumping and countervailing investigations are increasing, while anti-circumvention and anti-evasion mechanisms extend the enforcement from the “product” level to the “supply chain and compliance pathways” level. This evolution signifies that authorities are broadening the analytical scope of investigations, examining not only pricing and subsidisation issues but also structural trade arrangements and compliance configurations.

Practical challenges and strategic considerations for Chinese companies in 2026

Tool hybridisation and expansion of enforcement boundaries: from “single-procedure compliance” to “systemic compliance”

A defining feature of today’s trade remedy environment is no longer the frequent use of a single instrument, but rather the stacking and cross-application of multiple legal mechanisms. Anti-dumping and countervailing investigations are increasingly co-ordinated with rules of origin, customs enforcement, supply-chain due diligence, sanctions compliance, and even industrial or national security screening. In practice, a case is often no longer assessed solely whether dumping or subsidisation exists. Investigating authorities may simultaneously examine the authenticity of production location, supply-chain traceability, the reasonableness of related-party transactions, and the company’s functional role within global industrial specialisation.

This trend signifies that corporate compliance priorities are shifting from “responding to a single procedure” toward “integrated risk governance”. If Chinese companies continue to rely on a traditional “reactive defence” model, acting only after an investigation is initiated, they may struggle to meet foreign authorities’ expectations for information that is complete, consistent, continuous, and verifiable. A more workable approach going forward is to build, in advance, a compliance framework covering procurement, production, finance, logistics, and related-party transactions. This enables companies to move from passive participation to proactive control of the investigation. Such internal preparedness also facilitates consistency in submissions across parallel proceedings and reduces the risk of inconsistencies that may undermine credibility.

Institutionalisation and politicisation of trade remedy issues in parallel: legal questions are being embedded in broader governance objectives

As 2026 approaches, trade remedies are no longer viewed merely as technical trade enforcement instruments. They are increasingly used as policy levers to advance industrial security, supply-chain resilience/restructuring, and broader geo-economic strategies. Against this backdrop, the logic behind the application of anti-dumping, countervailing, and anti-circumvention measures is gradually moving beyond the traditional boundaries of trade law and being embedded into macro-level narratives of national security, industrial policy, and economic security. For Chinese companies, this means that even full compliance with existing legal rules may not be sufficient to eliminate external investigative pressure. Trade remedies are shifting from rule-centred legal procedures to governance tools that also reflect policy co-ordination and industrial competition.

Accordingly, Chinese companies need to move beyond traditional case-by-case strategies in responding to trade remedy proceedings. Companies should not only focus on the outcome of specific legal issues but also monitor shifts in broader policy orientation and their long-term implications for industry positioning and global deployment. This calls for more forward-looking mechanisms for risk identification and policy co-ordination at the enterprise level, the industry level, and, where appropriate, the government level. These mechanisms are needed to manage the uncertainties created by the expanding functional scope of trade remedy regimes as their role continues to broaden.

多重压力下的贸易救济新常态

贸易救济是指当国内产业因外国进口产品的不公平竞争行为，如倾销或补贴，或进口激增而遭受损害时，进口国政府依法采取的救济措施，主要包括反倾销税、反补贴税及保障措施调查。

从2025年全球贸易救济调查的总体态势来看，2025年全球贸易摩擦仍然频发，各个国家和经济体在产业政策竞争、供应链安全与国内就业压力等因素叠加下，继续将贸易救济作为“合法、高效”的政策工具来抑制与调控进口冲击带来的影响。与以往相比，贸易救济的政策目标不再仅限于遏制倾销进口或补贴进口造成的损害，而是更频繁地与能源转型、关键原材料安全、制造业回流与产业链安全等议题相连。同时，多国在既有措施到期节点上强化“日落复审”等程序的运用，以维持措施连续性，并通过“反规避/反逃避”等执法型机制补强措施的执行力度，形成对进口渠道与原产地链条的更强监管。

2025年全球对华贸易救济立案数量概览

根据我们的统计，2025 年对华贸易救济立案呈现出明显的“全球范围广泛启动、重点产业高度集中化、执法工具多样化”的特征。

北美地区（尤其美国、加拿大）在案件数量与工具类型上更为活跃，除传统双反外，还显著伴随反规避与反逃避执法；拉美主要经济体（如巴西、墨西哥）则以反倾销为主、调查节奏密集，且产品选择多聚焦本国产业链成本端与通用商品市场；欧洲方面，欧盟对华案件产业覆盖面广、技术门槛与产业链纵深突出，英国则体现出在特定重点产品上“双反并行”的叠加式审查；亚洲地区中，印度案件密度高且明显向化工与材料集中，日本尤其关注钢铁类与关键化工品，泰国则体现出反规避工具的集中使用；大洋洲（澳大利亚、新西兰）案件数量相对有限，但对基础工业与建材相关产品的针对性较强；中东与欧亚经济联盟等地区虽总量不高，但在特定品类上通过日落复审或立案调查维持对华贸易防御。

中国在全球贸易救济体系中的被诉地位

从中伦团队梳理的各区域数据看，中国继续处于全球贸易救济体系中最核心、最高频的被诉对象之一。这一“被诉地位”既与中国在多类工业品与中间投入品上的全球供给能力、出口规模与价格竞争力有关，也与各国在关键材料、基础制造与新兴产业链条中对进口依赖与产业安全焦虑上升有关。更重要的是，多个法域的案件结构显示，针对中国产品的措施正呈现出从“单一税种”向“组合工具”的演进：同一产品被同步置于反倾销与反补贴调查之下的情形增加，而反规避/反逃避等机制使执法范围从“产品”延伸到“供应链与合规路径”。

2026年中国企业应对全球贸易救济环境的现实挑战与策略提示

规则工具的复合化与执法边界的扩张：从“单一合规”走向“系统性合规”

如今全球贸易救济的显著特征将不再是单一工具的频繁使用，而是多种法律机制的叠加运行与交叉适用。反倾销、反补贴调查逐渐与原产地规则、海关执法、供应链审查、制裁合规乃至产业安全审查形成联动。在实践中，一个案件往往不再以“是否构成倾销或补贴”为唯一判断，而是同时围绕生产地真实性、供应链可追溯性、关联交易合理性以及企业在全球产业分工中的功能定位展开。

这种趋势意味着，企业合规的重心正在从“应对单一程序”转向“整体风险治理”。中国企业若仍以传统的“事后应诉”逻辑处理贸易救济问题，将难以及时回应国外调查机关对信息完整性、连续性与可验证性的要求。对于中国企业而言，未来更具可行性的应对路径，是提前构建覆盖采购、生产、财务、物流、关联交易等环节的合规体系，从而在调查程序上由被动转为主动。

贸易救济议题的制度化与政治化并行：法律问题正在被嵌入更宏观的治理目标之中

进入2026年，贸易救济已不再仅被视为技术性的贸易执法工具，而日益成为各国推进产业安全、供应链重构与地缘经济战略的重要政策抓手。在这一背景下，反倾销、反补贴与反规避措施的适用逻辑，正逐步脱离单纯的贸易法范畴，而被嵌入国家安全、产业政策与经济安全的宏观叙事之中。对中国企业而言，这意味着即使企业在合规层面满足既有规则要求，也未必能够完全消解外部调查压力。贸易救济正从以规则为中心的法律程序，转变为兼具政策协调与产业博弈色彩的治理工具。

在此背景下，中国企业的应对策略需要超越传统的案件防御思路，不仅关注具体法律问题的胜负，更要关注宏观政策取向的变化及其对行业布局的长期影响。这要求在企业层面、行业层面乃至政府层面形成更具前瞻性的风险识别与政策协同机制，以应对贸易救济制度功能不断外溢所带来的不确定性。