Global trade measures are evolving rapidly, with significant implications for UK importers, manufacturers and supply chains. In this edition, we examine the latest developments from the Trade Remedies Authority, including landmark appeals, steel safeguard decisions and emerging regulatory risks for businesses trading internationally.
Aaron & Partners appeals to Upper Tribunal on behalf of LiuGong
We have launched a landmark Upper Tribunal appeal on behalf of LiuGong over how electric excavators are classified under UK trade tariffs.
LiuGong, a manufacturer and distributor of construction equipment, has launched a legal challenge over the inclusion of electric excavators within UK anti-dumping duties on imports from China. The case follows a Trade Remedies Authority investigation, prompted by JCB, into imported excavators from the People’s Republic of China.
The appeal – the first of its kind since Brexit – questions whether zero-emission machinery should be treated in the same way as conventional fossil fuel equipment under the current trade remedies regime. LiuGong argues that electric excavators are technologically and environmentally distinct, and were not previously imported when the original measures were introduced.
The outcome could have significant implications for the future treatment of green construction technology in the UK.
TRA makes final decisions in steel quota reviews
The Trade Remedies Authority (TRA) has published its final decisions on three tariff rate quota (TRQ) reviews relating to the UK’s steel safeguard measures, with changes taking effect from 1 April 2026. TRQs operate under World Trade Organization rules and allow a fixed volume of steel imports to enter the UK at normal duty rates, after which a higher safeguard tariff applies.
- In review TQ0077, covering metallic coated sheet and non-alloy and other alloy quarto plates, the TRA decided to retain the existing quotas to avoid harming UK producers who make competing products.
- Review TQ0078 amended the quota for alloy merchant bars and light sections by removing three commodity codes where no UK production was found, easing restrictions on those imports.
- In TQ0085, the TRA reviewed Turkey’s developing country exemption and recommended a country-specific quota for category 4 steel after import volumes exceeded the permitted threshold.
In simple terms, these decisions determine how much steel can be imported before a safeguard tariff applies. The impact is that some importers may face higher costs or stricter limits depending on the product and country of origin.
TRA proposes new measure on South Korean hot rolled steel plate
The TRA has also proposed a new anti-dumping measure on imports of hot rolled steel plate from South Korea, following interim findings in its investigation. The TRA’s initial view is that South Korean producers have been selling these products into the UK at unfairly low prices, resulting in trade protection.
The TRA’s preferred option is to apply the measure only to narrower plates (over 600mm but less than 2500mm wide), where it found consistent UK production. It decided against applying duties to wider plates because UK industries like renewable energy, defence and shipbuilding depend on imports for these products and could face supply shortages or higher costs. In simple terms, this would protect UK steelmakers where domestic supply exists, while avoiding disruption to key industries that rely on wider imported plates.
If adopted, duties on narrow plates would range from 7.04% to 22.27%, raising costs for importers of those products. Businesses affected can comment on the proposal by 21 May 2026 before the TRA makes its final recommendation.
TRA updates import trends monitor
The TRA has also published its latest UK Import Trends Monitor (covering imports up to February 2026), which analyses HMRC data to identify unusual spikes in import volumes and sharp falls in prices that could indicate potential market distortion. The report flags a broad range of commodities across sectors such as base metals, chemicals, machinery and textiles, using statistical thresholds to highlight changes that are significantly outside normal trends. However, it emphasises that these findings are not determinative of unfair trade, but rather an initial screening tool to identify areas that may require further investigation or industry engagement.
For importers, the key implication is that products highlighted in the Monitor may be more likely to come under scrutiny and could form the basis for future trade remedy investigations, potentially leading to the imposition of anti-dumping or safeguard measures. Importers of affected goods should therefore be alert to increased regulatory risk, including possible duties, supply chain disruption, or heightened reporting requirements, and may wish to engage early in any resulting investigations to protect their position.
TRA publishes its Corporate Plan 2026-2027
The TRA has published its Corporate Plan 2026–2029, which signals a more assertive and proactive approach to trade defence. The Plan confirms a shift away from legacy EU transition reviews towards a greater focus on new investigations, supported by enhanced monitoring tools and earlier risk identification. It emphasises faster, more agile and more accessible investigations, alongside increased use of data, digital systems and intelligence to identify potential harm to UK industries at an earlier stage.
For importers, the direction of travel is clear: the TRA is likely to initiate more investigations, and to do so more quickly, particularly in sectors where there are signals of import surges or price suppression. This increases the risk of new anti-dumping, countervailing or safeguard measures being imposed. Importers should therefore be prepared for heightened scrutiny and shorter timelines, and may benefit from early engagement in investigations and monitoring of at-risk product categories to mitigate potential cost and supply chain impacts.
How Aaron & Partners Can Help
We are one of the few UK firms with live experience in dealing with Trade Remedies Authority matters, TRA investigations in the UK are still extremely rare. Since the legislation came into force, only a handful of cases have been pursued; we are actively involved in one of those cases. We can assist you whether you are responding to an investigation as an interested party or are wishing to instigate an investigation within your industry.
We can guide you through each step of the investigation, offering our expertise and knowledge in order to help your business secure the best outcome.
Engaging early and constructively in a TRA investigation can make a real difference. Where affected businesses participate and provide evidence, this can influence the scope of a measure, support exclusions, or result in a lower, company-specific tariff being applied rather than a higher residual rate. Our team works closely with clients to protect their commercial position and minimise disruption to supply chains.
Get in Touch
Layla Barke-Jones
Dispute Resolution Partner
Layla is actively working on TRA investigations and has worked for clients in many industries including warehousing, aviation, hospitality, property and freight.
Lucy Harrison
Dispute Resolution Solicitor
Lucy works closely with Layla to support clients who are under investigation by the TRA. She is recognised for her excellent attention to detail and works across multiple sectors.