For Over 33 Years

Anti Dumping - Submission of documents possible?

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.

We will examine your import tax bill and the possibility of submitting additional documents. You can always reach us by phone on 040 / 3696150.

For companies: 15 minutes free initial consultation+49 40 369615-0or send an e-mail


Attorney Dr. Tristan Wegner

Ihr Ansprechpartner

More interesting articles on this topic

How to handle (long-term) vendor declarations (LTVDs)

The vendor’s declaration (VDs) is one of the most frequently issued commercial documents in ...

Brexit and customs – companies need to know this now

On the roadshow “Brexit und Zoll“, customs informed the economy about changes in the upc...

Anti-dumping duty on Chinese solar modules – this must be taken into account

Since 2013 there has been an anti-dumping duty on crystalline silicon photovoltaic modules and key c...

Call directly and get advice 040 - 36 96 15 0