MILE Thesis - Anti-Circumvention Practices: Balanced Approach to Address Loopholes in Anti-Dumping Agreement

Sep 12, 2026

The thesis explores a balanced approach to reducing anti-dumping circumvention practices by introducing a “pre-emptive anti-circumvention mechanism” at the earliest stage of initial investigation. It proposes specific adjustments to current anti-dumping questionnaire templates to improve detection and prevention of exporters’ circumvention methods during that initial phase. It further analyzes how voluntary price undertakings and public interest inquiries can limit circumvention. Finally, it outlines an interaction framework between competent authorities and the general public, including how to establish or extend such interaction.

LanguageEnglish

CategoryPaper Templates

FormatPDF

Pages121

Reading Time42 min

AccessFree to download

Declaration

Abstract

Acknowledgements

Abbreviations and Acronyms

List of Annexes

Introduction

Chapter 1. The Concept of Circumvention in Anti-Dumping

History of Anti-Circumvention

Definition of Circumvention and Types of Circumvention Activities Based on the Practice of the EU and the USA

Forces Behind the Decision of Exporters to Circumvent

Voluntary Price Undertakings as a Mean to Reduce Circumvention Practices

Chapter 2. Anti-Circumvention Inquiries and «Pre-emptive» Mechanism to Alleviate Circumvention

Procedural Aspects of Anti-Circumvention Inquiries

Toolkits to Address Circumvention at the Stage of Anti-Dumping Investigations

Chapter 3. Other Methods to Prevent Circumvention in Anti-Dumping

The Role of Enforcement of Anti-Dumping Orders

MILE Thesis Advanced Master Programme in International Law and Economics| 2018-19 Anti-Circumvention Practices: Balanced Approach to Address Loopholes in AntiDumping Agreement Student: Kucheriava Yuliia Supervisor: Edwin Vermulst Declaration “I hereby declare that I have written this work independently and that it is my own unaided work. The ideas and opinions expressed in this paper are made independently, represent my own views and are based on my own research. I have used no other sources than the ones I have specified. All sections that include direct or indirect sources have been properly acknowledged as references. I am aware that this thesis can be examined for the use of unauthorized aid and whether the thesis as a whole or parts incorporated in it may be deemed as plagiarism. I understand that failing to meet these requirements will result in a failing grade of ‘0’ and that the Senate of the University of Bern (pursuant to UniG Art. 36, para. 1, section r. of 5. September 1996 and Art. 69 of the UniSt of 7. June 2011) has the right to withdraw the conferred title. For the purposes of assessment and compliance concerning plagiarism, I grant the University of Bern the right to enter my work into a database where it shall also remain after examination, to enable comparison with future theses submitted. I understand that my thesis will be made available in the World Trade Institute library”. October 29, Bern, Switzerland Yuliia Kucheriava Abstract The thesis gives a fresh perspective of how the circumvention practices could be effectively reduced upon implementation of the “pre-emptive anti-circumvention mechanism” at the stage of initial anti-dumping investigation. First, it offers a list of adjustments to the current anti-dumping questionnaire templates to ensure the detection and prevention of possible means of exporters to circumvent at the stage of initial anti-dumping investigation. Second, it discusses the application of the voluntary price undertakings and the public interest inquiry as conceivable means to reduce the occurrence of circumvention practices. Last but not least, the thesis proposes interaction framework between the competent authorities and general public and submits how such interaction could be established or extended. Acknowledgements Taking this opportunity, I would like to express my sincere gratitude to my supervisor, Mr. Edwin Vermulst for his thoughtful and helpful comments as well as endless support and encouragement. I would like to extend my gratitude to the WTI administration and the MILE fellows for all the assistance provided during this year. My special thanks goes to Mr. Rodrigo Polanco for his indispensable personal support throughout the MILE Programme. This thesis is dedicated to my constant source of inspiration and loving-kindness, to my family. Table of Contents DECLARATION ........................................................................................................................................................................ 1 ABSTRACT ................................................................................................................................................................................ 2 ACKNOWLEDGEMENTS....................................................................................................................................................... 3 ABBREVIATIONS AND ACRONYMS .................................................................................................................................. 5 LIST OF ANNEXES .................................................................................................................................................................. 6 INTRODUCTION ...................................................................................................................................................................... 7 CHAPTER 1. THE CONCEPT

FAQs

What is the core proposal of the thesis regarding circumvention?

It proposes a “pre-emptive anti-circumvention mechanism” implemented at the stage of initial anti-dumping investigation to effectively reduce circumvention practices.

How does the thesis suggest improving anti-dumping questionnaires?

It provides a list of adjustments to current anti-dumping questionnaire templates to ensure the detection and prevention of exporters’ possible circumvention methods during the initial investigation stage.

Which additional instruments does the thesis consider to reduce circumvention?

It discusses voluntary price undertakings and the public interest inquiry as conceivable means to reduce the occurrence of circumvention practices.

Sep 12, 2026

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