In brief
The Australian Anti-Dumping Commission (ADC) is currently conducting Investigation Number 691 into the alleged dumping and subsidisation of aluminium windows and doors exported to Australia from China.
This investigation represents a significant development in Australia’s trade remedies landscape. To date, anti‑dumping measures in the aluminium sector have largely been confined to upstream products such as aluminium extrusions. The current investigation signals a potential expansion of enforcement to finished and semi‑finished aluminium goods, increasing risk exposure for importers and downstream participants who may not previously have been subject to dumping duties.
If the ADC ultimately recommends the imposition of anti‑dumping and countervailing duties, affected importers could face material increases in landed costs, including the risk of retrospective duties and securities. Australian manufacturers supporting the application have suggested that duties on Chinese products could be significant, underscoring the potential commercial impact across the building and construction supply chain.
In detail
Goods under consideration
The ADC’s investigation covers aluminium windows and doors, whether fully or partially assembled, including their frames, panels and sashes. The goods may be supplied:
with or without glass
whether or not thermally broken
whether or not incorporating hardware.
The scope includes both complete window or door units and fabricated aluminium assemblies that do not yet constitute a fully functional product.
The following dimensional limits apply:
Window assemblies or partial assemblies (including frames, panels and sashes) - up to and including 3.0 metres in height and 4.0 metres in width
Door assemblies or partial assemblies (including frames, panels and sashes) - up to and including 3.0 metres in height and 7.0 metres in width.
Curtain wall products are expressly excluded from the investigation. All goods within scope are classified under tariff classification 7610.10.00.
In practical terms, the scope captures a broad range of standard residential and commercial aluminium window and door products imported from China, including goods imported as kits or partially fabricated assemblies for further processing or glazing in Australia.
Period under review
The ADC is assessing the alleged dumping, subsidisation and resulting injury over the period commencing 1 July 2021. This means that any measures ultimately imposed could apply to imports made well before the publication of a final decision.
Key investigation milestones
The investigation remains ongoing, with several critical milestones ahead:
25 November 2025 – Application lodged jointly by Ventora Group Pty Ltd and the Australian Glass and Window Association, leading to initiation of the investigation (completed)
2 January 2026 – Initial submissions lodged by other industry participants (completed)
27 January 2026 – Earliest date for an initial preliminary affirmative decision; instead, a 60‑day status report was issued (A PAD has not yet been issued with respect to this matter).
23 September 2026 – Statement of Essential Facts to be published. Interested parties will generally have up to 20 days to respond (upcoming)
25 November 2026 – Final recommendation of the ADC due. The Minister’s decision would typically be expected within 30 days of receiving the recommendation (upcoming).
What importers and exporters should do now
With the investigation progressing and key decision points approaching, this is a critical period for affected businesses to move beyond passive monitoring and actively manage potential dumping duty exposure.
Quantify potential duty exposure
Importers should begin by developing a clear view of their potential exposure. This includes:
identifying all imports of aluminium windows and doors (including partially assembled goods) from 1 July 2021 onwards
confirming the importer of record, exporter, transaction values and volumes
modelling indicative dumping and countervailing duty outcomes under a range of plausible scenarios.
Early quantification allows businesses to assess potential cash‑flow, pricing and balance‑sheet impacts, including the risk of retrospective duties or securities being imposed on future entries.
Engage strategically with the investigation process
Interested parties should consider whether active participation in the investigation is appropriate. This may include:
lodging submissions addressing scope, pricing comparability, market conditions, injury and causal link
assessing whether exporters are prepared to co‑operate fully with the ADC, noting that non‑cooperation can result in the use of adverse facts available and materially higher duty rates
reviewing related‑party pricing and commercial arrangements to ensure they are defensible under anti‑dumping methodologies.
Well‑structured engagement can influence both scope outcomes and individual duty rates, particularly for co‑operating exporters.
Implement forward‑looking mitigation strategies
In parallel, businesses should take steps to reduce risk should measures ultimately be imposed, including:
reviewing supply chains and assessing the feasibility of alternative sourcing or diversification
considering contractual protections such as duty‑exclusive pricing, cost‑pass‑through mechanisms or renegotiation triggers
ensuring customs valuation, tariff classification and origin positions are robust and audit‑ready in anticipation of increased scrutiny.
Early action preserves commercial flexibility and avoids being constrained once measures are in place.
The takeaway
This investigation reflects a broader trend towards the application of dumping and countervailing measures to finished goods, not just upstream inputs. Importers and exporters of aluminium windows and doors from China should not assume that exposure is remote or manageable once a final decision is made.
Proactive assessment, strategic engagement and early risk mitigation will be critical to managing potential cost increases and ensuring business continuity in an increasingly complex trade remedies environment.
Contact us
Paul Cornick
Partner, National Global Trade Leader, PwC Australia
Gary Dutton
Partner, National Global Trade Leader, PwC Australia
Frances Ryan
Director, Global Trade and Excise, PwC Australia
Sarah Macchiavelli
Director, Global Trade and Excise, PwC Australia
Melissa Camilleri
Director, Global Trade and Excise, PwC Australia
Lara Jobling
Director, Global Trade and Excise, PwC Australia
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