Whether it is possible to submit documents forgotten in the context of anti-dumping duties is currently a matter for the main customs offices in a large number of proceedings. The introduction of anti-dumping duties on solar modules from China in particular repeatedly opens up these problems in our daily practice.

Commitment invoice and export commitment certificate not submitted

As a rule, the background to this is that under Regulation (EU) 1238/2013 it was simultaneously stipulated for the imposition of an anti-dumping duty on solar modules that company-specific rates of duty could be considered when a declaration of undertaking was made. The anti-dumping duties can then even be eliminated altogether.

As a rule, however, a special commitment invoice and an export commitment certificate must be submitted to the Chinese Chamber of Commerce.

Can the documents be submitted later?

In practice, there is an increase in the number of cases in which these documents were not or not correctly declared in the customs declaration, even though they were present.

Customs is currently of the opinion that the documents cannot be submitted retrospectively, a view that we consider to be at least questionable.

Companies in such a situation should therefore have it checked whether this view of the Federal Finance Directorate North, as it has been represented at the main customs offices up to now, is actually correct.


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Dieser Artikel wurde am 15. August 2018 erstellt. Er wurde am 30. September 2023 aktualisiert. Die fachliche Zweitprüfung hat Rechtsanwalt Dr. Tristan Wegner durchgeführt.

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