Category Archives: Uncategorized

Trade Remedies and Freeports

MTRA has submitted comments in response to the government consultation on freeports.  The comments related to questions 13 & 14 on the application of trade remedies in the context of freeports.  The consultation document stated the HMG position that “freeports should not undermine the effectiveness of the UK’s trade remedies system” and the MTRA comments highlighted potential issues in relation to different scenarios and the possibilities for circumvention.

Freeports – MTRA submission

MTRA calls on Trade Minister for improvements in UK trade remedies

Following a meeting with the Rt Hon Greg Hands, Minister for International Trade, the MTRA has written to Minister Hands raising concerns in relation to the Trade Bill and other aspects of the newly established UK trade remedy system.

In terms of the trade bill, the letter emphasises the importance of ensuring that non-executive members of the TRA board do not have an ideological bias.  It also requests more specificity on what should be contained in the TRA’s annual report.

Other issues raised included a request for the government to take another look at ways in which UK trade remedies could be strengthened in light of continued support for British manufacturers during the Covid-19 crisis.  Particularly highlighted was the issue of using provisions already contained in the UK legislation relating to China and problems caused by significant state distortions and unfair subsidies, the need for a more flexible approach on transition reviews, and the need to take into account of imminent regulatory costs in injury margin calculations.

Letter to Minister Hands (12 June 2020)

Non-specialist briefing on the importance of trade remedies

MTRA has produced a 2 page non-specialist briefing on the importance of trade remedies, summarising the key issues for UK manufacturers.  The briefing covers the types of trade remedy and the critical need for remedies against unfair pricing practices and global state distortions.  It also summarises key issues around the treatment of China in trade remedy investigations and in relation to the transition reviews that will consider the current EU measures to be continued by the UK.

MTRA – importance of trade remedies (May 20) (PDF)


MTRA letter to Secretary of State

8 January 2020

Rt Hon Liz Truss MPSecretary of State
Department for International Trade
3 Whitehall Place
London SW1A 2HP

Dear Secretary of State,

We look forward to working with you as you continue in the role of Secretary of State for International Trade.

As you will be aware the Manufacturing Trade Remedy Alliance (MTRA) has worked cross-party to ensure that the UK has a fit for purpose trade remedies system. The election of a new government is an opportunity to reflect on the approach that has been previously adopted in relation to key issues. In this regard, it seems the right time to remind you that the regime, in its current form, falls short of the protections required to ensure that UK industry has a robust, transparent remedies system to protect against unfair trade post Brexit. MTRA has played an active role in helping to develop recent modernisation of the EU system and the UK regime falls short of the EU’s protection. We are committed to ensuring transparency, scrutiny and co-operation towards achieving a UK trade remedies system which serves our country, its industries and workers well. We call for the following essential changes to be made to the UK trade remedies system:

  • The UK system should provide the same level of protection for UK jobs in manufacturing as the EU system does for its Member States from dumping and unfair trade practices, especially by non-market economies such as China.
  • China should be treated as a non-market economy as provided for by the China WTO Accession Protocol.
  • When selecting data to use in place of state distorted costs in the calculation of constructed normal value, preference should be given for data from countries meeting ILO conventions.
  • The lesser duty rule should not be compulsory in every case so that it can be ensured that remedies on dumped and subsidised imports are adequate to remove the problem.
  • Future environmental, regulatory and labour costs should be fully taken into account when calculating injury to an industry.
  • The economic interest test should be a ‘sense check’ which includes an adequate presumption in favour of the adoption of measures when dumping or subsidies are found, rather than novel tests which could lead to no remedies being applied in situations where protection from the unfair trade is needed. No other major global trade remedy authorities use this approach and it raises concerns that UK trade remedies will not be adequate to rectify situations of unfair trade.
  • For the transition reviews, a strong link should be maintained with the original EU measures. The focus of the analysis should be whether the measure was justified when it was adopted rather than current data. The TRA/TRID has the discretion not to recalculate the dumping/subsidy margin and guidance should be provided for this discretion to be used to ensure that resources are allocated to the cases where there is a strong case for the level of measures to be amended.
  • UK customs should be robust when the UK has an independent trade policy, not least to ensure that any UK specific trade remedies are enforceable. This should include the situation where 3rd country imports subject to UK trade remedies have entered the UK through the Ireland/Northern Ireland border.
  • The government should ensure that HMRC is able to provide adequate data to ensure that import trends can be monitored.
  • The TRA must have manufacturing employers and trade unions represented as non-executive members to ensure the concerns of working people and manufacturing are properly addressed.

We are keen to continue engaging both with you and the officials at your department to ensure the above and other issues are addressed, particularly in relation to implementation and operation of the UK system by the TRA/TRID and trade remedy issues in any FTAs we are developing as a country.

We would welcome an opportunity to meet with you in January to further explore these issues at this critical time.

Yours sincerely

Laura Cohen MBE
Chair, Manufacturing Trade Remedies Alliance

Distribution to (by e-mail):
DIT: Amanda Brooks, Graham Zebedee, Gaynor Jeffery
TRID: Claire Bassett
BEIS: Rt Hon Andrea Leadsom MP
Angus MacNeil MP
Barry Gardiner MP
Lord Purvis of Tweed
Stewart Hosie MP

MTRA comments on Brexit and UK/Ireland border issues

The MTRA has today submitted comments to the Prosperity UK/Alternative Arrangements Commission consultation on their interim report “Alternative Arrangements for the Irish Border‘.

MTRA has significant concerns that issues relating  to the enforcement of differential tariffs (including trade remedies) are underestimated in the report.  While MTRA welcomes the report as contributing to the debate on possible solutions to the UK/Ireland border issue, the system proposed is unprecedented and experimental.  It is not clear that such an ambitious system could work meaning that there would be grave risks of circumvention of trade remedies and other differential UK and EU trade measures.

MTRA reponse to AAC consultation (final)


British manufacturing sounds alarm bells at zero tariffs

20th February 2019

Business leaders and trade unions are warning Government to stop gambling with Britain’s world-leading manufacturing sectors, and dismiss talk of zero tariffs.

The Manufacturing Trade Remedies Alliance, (MTRA) made up of eight national trade associations three trade unions and the TUC, is calling on politicians to rethink plans for a wholesale reduction in import tariffs.

In the event of a no-deal, politicians are considering zero most favoured nation tariffs to lower prices on consumer goods, but the move could ruin the home market for many sectors. Increased imports would flood the market, jeopardising tens of thousands of jobs and fundamentally changing the British economy.

Ian Cranshaw, Head of International Trade at the Chemical Industries Association (CIA) said: “The idea of a new tariff regime is something which should be subject to proper consultation. With less than 40 days to Brexit British manufacturers already dealing with Brexit uncertainties are now having to assess how their business might be impacted by an increase in non-EU competition should the government remove MFN tariffs on key chemical products.

Jude Brimble, GMB National Secretary, said: “Zero tariffs in the event of a no-deal Brexit is a short-sighted move. While it may lower prices in the short term, it will ultimately put thousands of British manufacturing jobs at risk.

“Manufacturers are often based in the heart of their communities and supporting many more indirect and supply chain jobs.
“Zero tariffs could destroy the proud history of making and manufacturing in Britain.”

Laura Cohen, Chief Executive of the British Ceramic Confederation and Chair of the Manufacturing Trade Remedies Alliance, said: “Government needs to consult properly with businesses and trade unions. Jobs, communities and the economy are at stake. This cuts to the heart of the sort of country we want.

“Our domestic market would be jeopardised at the same time as our export markets would be subject to additional tariffs, for example 12% on tableware going into Europe, where previously it would have been zero.

“No tariffs makes the UK’s emerging trade remedies system ineffective from the outset by lowering the duty paid on dumped imports.

“MTRA member companies and unions are asking Government to act to secure this vital part of the economy, in the event of a no-deal Brexit and reconsider zero-tariffs.”

Frances O’Grady, general secretary of the TUC, said: “Ending all tariffs in a no deal Brexit would be a further hammer blow to our manufacturing industries and the communities they support.

“Government must not show such reckless disregard for people’s jobs.

“The Prime Minister must act now to rule out a no-deal Brexit and ditch her destructive red lines, which threaten working people’s jobs and rights.”



Notes to Editors

About Us

The Manufacturing Trade Remedies Alliance (MTRA) is made up of the following organisations:

Agricultural Industries Confederation; British Ceramic Confederation; British Glass; Chemical Industries Association; Confederation of Paper Industries; Mineral Products Association; Renewable Energy Association; UK Steel; Community; GMB; TUC; and Unite

For further information please contact: 

Ciara Jagger, Publicity and Project Officer, c/o British Ceramic Confederation, Federation House, Station Road, Stoke-on-Trent, ST4 2SA.

Tel:  01782 572851 M: 07535 084055

MTRA members give evidence to International Trade Committee on TRA


Laura Cohen, Cliff Stevenson and Rosa Crawford give evidence to the International Trade Committee

Laura Cohen, Chief Executive, British Ceramic Confederation, Cliff Stevenson, Consultant to Trade Remedies Alliance, and Rosa Crawford, Policy Officer, EU International Relations, TUC today gave evidence on the TRA to the International Trade Committee.

This included an overview of the EU’s trade defence system from perspective of business and trade unions, TRA decision-making and governance, concerns over economic interest and public interest tests, role of Secretary of State, lack of detail in primary legislation and concerns over secondary legislation.

Link to video
Link to transcript

MTRA submits written evidence on TRA to International Trade Committee

Evidence submitted included the structure and functions of TRA, the balance between primary and secondary legislation, TRA decision-making, membership of the TRA, reporting to Parliament, appointments to the TRA, Secretary of State guidance, complicated decision-making around economic interest and public interest tests, staffing and other functions, and appeals.

MTRA Written Evidence

MTRA members give evidence on the Taxation (Cross-Border Trade) Bill

Gareth Stace, Laura Cohen, Ian Cranshaw

MTRA members gave evidence on the Taxation (Cross-Border Trade) Bill.  This included an outline of the EU trade remedy system, difference between strong trade remedies and protectionism, concerns with proposed UK trade remedy system, balance between primary and secondary legislation, transition of existing EU measures, proposed public and economic interests, lesser duty rule, state distortions and dumping methodology, timescales, engagement with DIT.

Trade Union Members of the MTRA also gave evidence at the same session (Kathleen Walker Shaw (GMB), Ben Richards (Unite the Union) and Rosa Crawford (TUC)).

Video (Trade Association Members of MTRA)
Video (Union Members of MTRA)