Mirror, mirror against the wall, which country has had an investigation for the extension of an antidumping duty launched against it? “Well, the People’s Republic of China, of course,” the mirror replies. The question that you should really be asking is whether it is an ordinary mirror, or a magic mirror. It is said that the greatest trick that the evil queen of Cinderella fame ever pulled off was to provide us with a false memory, for it was not “Mirror, mirror on the wall – whoʼs the fairest of them all?”, but “Magic mirror on the wall, who’s the fairest one of all?”

Which brings us to our story, which is about unframed mirrors. In a Government Gazette of September 22, the International Trade Administration Commission of South Africa (Itac) initiated a sunset review investigation on the antidumping duty on unframed glass mirrors of a thickness of 2 mm or more but not exceeding 6 mm, classifiable under tariff subheading 7009.91 and originating in or imported from China. The deadline for comment is October 23.

The prevailing antidumping duty is 40.22%, but this is not applicable to mirrors manufactured by PT Matahari Silverindo Jaya, which implies that the company has successfully disputed the allegation of dumping that was made against it in an earlier antidumping investigation.

Then there is an antidumping duty of 6.6% against imports from Indonesia, which implies that the earlier antidumping investigation went unopposed by Indonesia companies, resulting in a residual antidumping duty being imposed.

The initiation of the investigation was a consequence of PFG Building Glass, a division of PG Group, which happens to be the only producer of unframed mirrors in the Southern African Customs Union region, having successfully responded to an Itac gazette notice of June 15, 2022. In that gazette, Itac notified interested parties (if one is technical it should read ‘party’) that unless a substantiated request was made indicating that the expiry of the antidumping would likely lead to the continuation or recurrence of dumping and injury (here, too, it should be ‘material injury’), that the antidumping duty would expire on December 12.

According to Itac, PFG Building Glass alleged that the expiry of the antidumping duty would likely lead to the recurrence of dumping and material injury, and the company submitted sufficient evidence and established a prima facie case to enable Itac to arrive at a reasonable conclusion that a Sunset Review investigation should be initiated.

PFG Building Glass’s allegation of recurrence of dumping is based on the comparison between the normal values and the export prices. In calculating the normal value for China, an unnamed independent consultant on behalf of the company obtained a quotation for the domestic selling prices of the unframed glass mirrors in China. (If you want to unmask the ‘unnamed Independent consultant’, simply contact Itac and ask for a ‘nonconfidential version of the application’.) As for the calculation of the export price for China, Itac used audited South African Revenue Service statistics to determine the export price for purposes of initiation. To calculate the export price, import statistics of unframed glass mirrors for the period January 1 to May 31, 2023, were used. This calculation resulted in a dumping margin of 55.94%. On this basis, Itac found that there was prima facie proof of the likelihood of the recurrence of dumping.

As for PFG Building Glass’s allegation of the recurrence of material injury, it alleges that although it is evident from the information submitted that it is not experiencing material injury over the period of investigation, there is a likelihood of a recurrence of material injury should the antidumping duty expire. So, on this basis, Itac found that there was prima facie proof of the recurrence of material injury if the antidumping duty of 40.22% expires.

For Itac to obtain the information that it deems necessary for its investigation, the nonconfidential application and questionnaires were sent to all known importers and exporters and known representative associations. The Chinese trade representative, who undoubtedly attended the fifteenth BRICS summit from 22 to 24, was notified.