The European Commission may also decide to register imports at some stage during the first 8 months of the investigation if there is a danger that imports coming into the EU during the investigation would undermine the effectiveness of any measures. For instance, if there is a risk of stockpiling, registration is done through the publication of a regulation instructing customs authorities to register imports of the product under investigation. If there is prior registration, the European Commission has to decide at the definitive stage whether or not anti-dumping and anti-subsidy duties should be collected retroactively, that is, normally as of 90 days prior to the imposition of provisional measures.

In cases of circumvention proceedings (i.e. proceedings investigating if existing duties are being circumvented, for example. by trans-shipment through other countries), imports are registered from the date of initiation of the proceeding. Where the final decision confirms the circumvention, the duties can be levied from this date, that is, retroactively from the date of initiation of the proceeding.

Source: “TDI Trade defence instruments, Anti-dumping & Anti-subsidy - A Guide for Small and Medium-Sized Businesses” by the European Commission