Trade Remedies Authority Corporate and Business Plan 2023 to 2026
Updated 3 May 2023
© Crown copyright 2023
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This Corporate and Business Plan covers the period 1 April 2023 to 31 March 2026.
It has been prepared in accordance with the Framework Agreement between the Trade Remedies Authority and the Department for Business and Trade.
Copyright: Trade Remedies Authority
This publication is licensed under the Open Government Licence v3.0 except where otherwise stated.
If you require this publication in an alternative format and/or language, or have any questions about its content, please contact us using the details below:
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Foreword
The Trade Remedies Authority exists to defend the UK against unfair international trade practices.
We are approaching our second anniversary as an independent body operating at arm’s length from government. Since our establishment in June 2021, we have laid down solid foundations. We have developed a cadre of around 150 skilled professionals made up of investigators, verifiers, lawyers, analysts, policy experts and supporting corporate functions. We have established a track record of efficient and effective delivery, including through completing reviews of ten trade remedy measures transitioned from the EU to the UK. We are also building an international reputation for the quality of our reports and the way their sophisticated economic analysis takes into account the full impact of potential measures on the UK economy.
This plan sets out how we will build on these foundations over the next three years to March 2026, together with a robust set of key performance indicators against which we can be measured.
By March 2025, we aim to have completed the review of all 43 trade remedy measures
transitioned from the EU. From this point, our pipeline of investigations will come exclusively from UK applicants. We anticipate that developments in the global economy, such as the spread of use of subsidies for selected sectors, are likely to drive increased future demand for investigations by the Trade Remedies Authority.
We want to make sure that everyone who could need our support is aware of the Trade Remedies Authority, and that parties involved in investigations have a high-quality experience interacting with us. So we will continue investing in our Pre-Application Office, which offers free, confidential advice to support businesses interested in making an application, and in improvements to our online platform, the Trade Remedies Service. As part of our commitment to transparency, we will publish all our investigations on a public file so that interested parties can see how we have reached a decision and the evidence that we have used to inform our analysis.
Achieving our vision of being a globally respected trade remedies body relies heavily on the skills, professionalism and commitment of our staff. Our people strategy will focus on building capability and an organisational culture built around our values of transparency, expertise, inclusion and integrity. Our goal is to make the Trade Remedies Authority an expert and innovative place where people enjoy working. We want to be in the top quartile of public sector organisations as measured by our annual staff survey. We are planning to move to new office space in Reading in 2024, reducing our floor space but working with staff to maximise the value of our use of physical space in the hybrid world of work.
There will also be some important changes for the Trade Remedies Authority in the first financial year of this plan. Simon Walker will be standing down as Chair in the summer of 2023 at the end of his term. In addition, the Finance Bill 2023 introduces some significant revisions to the trade remedies legal framework which underpins our work. The changes mean that we will take on new responsibilities for bilateral safeguards investigations and that the government will have greater discretion over how to respond to our recommendations.
The Trade Remedies Authority plays a critical role in the government’s vision of putting trade at the heart of Global Britain. This plan sets out how, over the coming years, we will build on and deploy the independent expertise needed to provide robust advice and recommendations to government in support of the UK’s strategy for prosperity and economic growth.
Oliver Griffiths – Chief Executive
Simon Walker CBE – Chair of the Board
Who we are and what we do
Our mission is to defend UK economic interests against unfair international trade practices.
Imports play a vital role in the UK economy. They can be supplied direct to consumers or be part of the international supply chains of British manufacturers. The UK government is committed to defending free trade and making the world more secure by strengthening supply chains and standing up to protectionism. Free trade operates within important global frameworks and the World Trade Organization (WTO) sets out rules on how WTO Members can defend themselves against dumped and subsidised goods, as well as sharp import surges.
Since the UK left the European Union in 2020, the Trade Remedies Authority has had responsibility for guarding the UK against economic harm caused by unfair trading practices.
The Trade Remedies Authority undertakes investigations into imports to the UK which may be unfair. Drawing on our expert team of investigators, lawyers, verification specialists and economic analysts, we then make evidence-based recommendations to the Secretary of State for Business and Trade on appropriate measures to defend UK economic interests.
We operate the UK trade remedy regime, which is derived from the WTO rules and applies to the whole UK. An important feature of the regime is a requirement for the Trade Remedies Authority to carry out an economic interest test which considers whether implementing a proposed trade remedy measure would be in the wider economic interest of the UK. This means analysing the impacts on producers, downstream manufacturers, importers, consumers and the competitive market. See Appendix 1 for more information on the economic interest test.
Our work underpins the UK government’s vision for putting trade at the heart of Global Britain.
We undertake three main types of trade remedies investigation:
Dumping investigations
Dumping occurs when goods are imported into a country and sold at a price that is below their normal value in the country of export. We assess whether dumping is causing or threatening material injury to UK business.
Subsidy investigations
A subsidy is any financial aid provided by a government or other party to a producer or seller of a good or service that is designed to increase competitiveness. We assess whether subsidised imports are causing or threatening material injury to UK business.
Safeguards investigations
Safeguard measures are defined as emergency actions taken in response to increased imports of particular products. We assess whether an unforeseen surge of imports is causing or threatening serious injury to UK producers. If we find that damage or injury has been or could be caused, we can recommend trade remedies to counter the damage being done. The measures we propose to remedy the impact of unfair competition usually take the form of additional tariffs on imports, and in safeguard cases can also include quotas for import volumes. They are designed to ensure a level playing field for companies competing in the UK market.
Once trade remedy measures are implemented, we can also carry out a variety of types of further review (see Appendix 2 for more information). In addition, we may be asked to provide the Secretary of State with advice, support and assistance relating to the conduct of international trade disputes or other broader trade functions such as trade remedy aspects of trade agreements.
We are carrying out a programme of transition reviews. Since the Trade Remedies Authority was established in June 2021, we have been examining 43 EU trade remedy measures which were carried across into our domestic law when the UK left the EU.
Through these transition reviews, we make recommendations to the Secretary of State about whether existing measures should be maintained, amended or revoked to better meet the needs of the UK domestic economy.
From 2 March 2022, new powers came into force allowing the Secretary of State to ‘call in’ reviews of the transitioned measures. For called-in cases, we still undertake the impartial investigative work and make a report of our findings to the Secretary of State.
We carry out our investigations in accordance with four guiding principles:
Efficiency
Ensure that cases are investigated swiftly and effectively, avoiding placing unnecessary burden on both complainants and the subjects of the complaint
Proportionality
Make recommendations based on clear evidence, targeted at addressing the injury caused and taking into account the interests of domestic producers and other interested parties, including consumers
Impartiality
Be objective and fair to all parties and provide a route for interested parties to appeal decisions
Transparency
Ensure that relevant information about cases is accessible to interested parties while balancing the need to protect commercially confidential data
We welcome applications from any business operating in the UK. Most investigations are likely to be initiated in response to an application from a business which is, or fears it may be, harmed by unfair trading practices.
We understand that trade remedy investigation applications can be complex and time-consuming and that few UK businesses will be familiar with the process. Our handbook and short explainer videos for small and medium-sized businesses provide a comprehensive introduction to the UK trade remedies system and practical advice on how to work with the Trade Remedies Authority.
The typical stages in the lifecycle of an investigation are set out in Appendix 3. Cases are managed through our Trade Remedies Service, a secure IT platform which allows both our case teams and external parties to interact with investigations.
Our Pre-Application Office offers advice and support to all parties considering an application. These discussions are confidential as they may or may not result in a formal application being made. The identity of parties is only made public when we decide to initiate an investigation and publish a Notice of Initiation. We may also initiate investigations on our own behalf where relevant evidence comes to light – for example, of circumvention of a measure.
We publish details and evidence on all our live cases. We encourage interested parties and contributors, such as importers or trade unions, to follow the progress of our investigations and provide contributions and key evidence for us to consider when assessing specific cases.
When we make certain decisions in a trade remedy investigation, we can be asked to reconsider them. At the end of the reconsideration process, we will either uphold the original decision if we are satisfied it was correct, or vary the original decision. Appeals may also be made to the Tax and Chancery Chamber of the UK’s Upper Tribunal.
We operate as an independent body at arm’s length from government. The Trade Remedies Authority is an independent arm’s length body of the UK’s Department for Business and Trade. We currently employ around 150 staff.
Our Board is responsible for setting and overseeing the strategic direction of the organisation and ensuring we are on track in the delivery of our corporate and business planning priorities. The Board holds the Chief Executive to account and supports him in the discharge of his role as Accounting Officer. As Accounting Officer, the Chief Executive answers personally on matters such as compliance with Managing Public Money and the UK government Functional Standards.
Our Executive Committee advises the Chief Executive in his capacity as Chief Executive and Accounting Officer. More detailed information on our governance arrangements can be found in the Corporate Governance Report section of our upcoming Annual Report and Accounts.
The Secretary of State accounts for the Trade Remedies Authority’s business in Parliament. A Framework Agreement between the Trade Remedies Authority and the Department for Business and Trade was signed in June 2022, setting out all governance, oversight, reporting and funding arrangements. The Department fully funds our operations and applies parliamentary controls as the sponsoring department. More information about our finances is provided in Appendix 4.
Our vision and strategic goals
Our vision is to be a globally respected trade remedies body.
This vision is underpinned by four strategic goals that are designed to maximise our impact.
Cases
We will undertake fair, impartial, rigorous and efficient trade remedy investigations
Drawing on the best available evidence and deploying rigorous analytical techniques, we will ensure timely and cost-effective delivery of our investigations. We will do this consistently, fairly and impartially, following clear processes and procedures that comply with the law.
People
We will develop an expert and innovative organisation where people enjoy working
We will build and maintain an engaged and motivated workforce, where our people embody our values and are committed to our mission and delivering our vision. There will be a strong emphasis on skills and knowledge development and cross-functional team working. We want to be a welcoming, diverse and inclusive place to work, where our people enjoy what they do and are proud to work here.
Digital
We will provide a high-quality experience for end-users through digitally enabled delivery
We will support our investigations work using technology, data and digital tools to optimise our operational performance, information base and the user experience. We will seek and act upon feedback from all users to continuously improve the investigations experience from the customer standpoint.
Reputation
We will be well-known, understood and respected by our domestic and international stakeholders
We aim to be an outward-facing organisation, engaging proactively with our stakeholders both in the UK and overseas, learning from our peers and sharing best practice. We will run ourselves as a model of good governance and will benchmark ourselves against established good practice.
Our values
Everything we do is driven by our values. We are individually and collectively committed to putting these values into practice.
Inclusion
We will build a community of diverse attitudes, ideas and backgrounds
Expertise
We will value strong technical skills in trade remedies disciplines
Transparency
We will be accountable through clear, evidence-based working practices
Integrity
We will deliver on our commitments in an impartial and professional way while holding ourselves to high standards
Our operating environment and key strategic risk areas
Operating environment
We consider the following to be important elements of our operating environment which will influence the delivery of this plan:
- A new and evolving trading relationship between the UK and the EU
- The implementation of new UK trade agreements
- Ongoing legacy impacts of the COVID-19 pandemic on exports and imports
- A challenging outlook for the UK economy
- The UK Government’s plan for decarbonising all sectors of the UK economy and meeting a net zero target
- The Department for Business and Trade’s review of the UK trade remedies framework
- The UK Government’s plan for achieving regionally balanced economic growth
- The push for reform of the international trade landscape and the WTO
- Implications for global trade and energy markets of the war in Ukraine
- Continuing global excess capacity in important sectors such as metals
- Proliferation of international subsidies for selected sectors
- A global economy that is being increasingly transformed by digital technology
Key strategic risk areas
In running our business, we are committed to applying best practice for the identification, evaluation, and cost-effective control of risks. The key areas within which risks can arise and threaten successful delivery of the Trade Remedies Authority’s strategic goals are set out below.
Leadership
Setting a clear strategic direction for the organisation and successfully engaging and motivating staff
Capacity & capability
Attracting, retaining and developing the staff resources needed to deliver our programmes of work
Profile & reputation
Raising awareness, understanding and credibility among UK and international businesses and other interested parties
Accessibility
Ensuring the applications process and digital case platform is accessible, secure and reliable for use by external users
Timeliness
Delivering recommendations within an optimal timeframe for measures to be effective and reduce harm to UK economic interests
Quality
Delivering investigations to appropriate quality standards and making well-evidenced and legally defensible recommendations
Value for money
Running the business in an economic, efficient and effective manner with high standards of governance, transparency and accountability
More detailed information on our risk management framework can be found in the Corporate Governance Report section of our upcoming Annual Report and Accounts
Our corporate and business planning priorities for 2023 to 2026
We set out below our corporate and business planning priorities for the next three years, which we have aligned with the main strategic goals to which they relate.
Since our set up in June 2021, we have been in the ‘establish’ phase of our corporate strategy. The three financial years to which this plan relates can broadly be considered as covering the ‘develop’, ‘evaluate’ and ‘consolidate’ phases of that strategy.
Cases
We will undertake fair, impartial, rigorous and efficient trade remedy investigation
- Complete reviews of all 43 transitioned measures
- Ensure a flexible and responsive process is in place that allows us to deal efficiently and effectively with reconsiderations and appeals
- Establish and develop a programme of work aimed at monitoring and evaluating the impact of our trade remedies recommendations
- Successfully implement the necessary changes to our work resulting from the Department for Business and Trade’s review of the UK trade remedies framework
- Take on responsibility and establish a robust and efficient process for conducting investigations of bilateral safeguards linked to trade agreements
People
We will develop an expert and innovative organisation where people enjoy working
- Develop a community of trade remedy specialists and implement programmes for external secondments to enhance individual career development and performance
- Review and refresh all core HR policies in order that they fully align with business needs and give us the solid foundations of a mature employment framework
- Embed our values and desired ‘DNA’ behaviours into recruitment, development, and performance management activities
- Secure and move to a new and accessible office location, which is designed to be a great place to work, support hybrid working and deliver value for money and improved environmental performance
- Undertake a staff workplace experience survey and make further changes to the office floorplate where appropriate and necessary to optimise alignment with business need and ensure value for money
Digital
We will provide a high-quality experience for end-users through digitally enabled delivery
- Establish and optimise access to key data sources, including with HMRC and commercial data suppliers, to maximise the insights available to our investigation teams
- Improve the offering of the TRS system by responding effectively to user feedback on any identified system weaknesses, barriers and inefficiencies
- Fully meet our cyber security assurance framework and implement any actions agreed with internal audit
- Carry out the work necessary to achieve Cyber Essentials certification
- Progress our digital vision roadmap and associated capabilities, including project management and enhanced management information to underpin effective decision-making
Reputation
We will be well-known, understood and respected by our domestic and international stakeholders
- Deepen our key UK stakeholder relationships and broaden our audience outreach and awareness raising work
- Expand our engagement and networking with peer trade remedies bodies across the world to share learning and good practice and enhance the collective impact of our work
- Respond effectively to public spending pressures, through developing a better understanding of what value for money and success means for the Trade Remedies Authority and optimising our future operating model
- Progress to an advanced level of maturity in the working relationship between the Trade Remedies Authority and our sponsoring department, the Department for Business and Trade
- Implement a sustainability policy, establish baseline sustainability measures and develop a broader plan to minimise our environmental impact
Our planned programme of investigations for 2023-24
Our core business is conducting trade remedies investigations. The table below lists all active and planned investigations cases as of 31 March 2023. Throughout the coming year, we will keep our programme under review, taking account of the evolving external environment, strategic risks, our corporate and business planning priorities, and the context of our own resourcing. We will maintain sufficient flexibility so that we can respond swiftly and effectively to applications for initiating new investigations.
We will initiate new investigations or reviews in response to applications as they arise. While we cannot predict what those will be nor when they may arise, our interactions with various parties suggest that we can expect applications for new anti-dumping and/or anti-subsidy cases, and for new exporter reviews, in the coming months.
Should we receive fewer applications than we anticipate, we may seek to initiate transition review cases ahead of the dates by which we are obliged to initiate them.
| Commodity | Country | Case type | Start date |
|---|---|---|---|
| Welded Tubes and Pipes | The Republic of Belarus, the People’s Republic of China and the Russian Federation | Reconsideration of transition antidumping review | Feb 2020 |
| Aluminium Extrusions | People’s Republic of China | Reconsideration of transition anti-dumping review | Jun 2021 |
| Certain Aluminium Road Wheels | People’s Republic of China | Transition anti-dumping review | Oct 2021 |
| Heavy Plate | People’s Republic of China | Transition anti-dumping review | Jan 2022 |
| Hot Rolled Flat and Coil | People’s Republic of China | Transition anti-dumping review | Apr 2022 |
| Hot Rolled Flat and Coil | People’s Republic of China | Transition anti-subsidy review | Apr 2022 |
| Ironing Boards | Republic of Turkey | Anti-subsidy investigation | Apr 2022 |
| Optical fibre cables | People’s Republic of China | Anti-dumping investigation | Apr 2022 |
| Optical fibre cables | People’s Republic of China | Anti-subsidy investigation | Apr 2022 |
| Stainless steel bars and rods | Republic of India | Transition anti-subsidy review | Jun 2022 |
| Hot-rolled Flat and Coil | Russia, Ukraine, Brazil and Iran | Transition anti-dumping review | Jun 2022 |
| Ceramic Tiles | People’s Republic of China | Transition anti-dumping review | Sep 2022 |
| Certain Bicycle Parts(1) | People’s Republic of China Circumvention exemption review | Oct 2022 | |
| Cast Iron Articles | People’s Republic of China | Transition anti-dumping review | Nov 2022 |
| Steel Products | Developing countries | Tariff rate quota review | Jan 2023 |
| Corrosion Resistant Steels | People’s Republic of China | Transition anti-dumping review | Feb 2023 |
| Certain Bicycle Parts(2) | People’s Republic of China | Circumvention exemption review | Feb 2023 |
| Hot Rolled Flat and Coil | Ukraine | Suspension extension review | Mar 2023 |
| Steel Ropes and Cables | People’s Republic of China | Transition anti-dumping review | Mar 2023 |
| Tyres | People’s Republic of China | Transition anti-dumping review | TBC |
| Tyres | People’s Republic of China | Transition anti-subsidy review | TBC |
| Bicycles (electric) | People’s Republic of China | Transition anti-dumping review | TBC |
| Bicycles (electric) | People’s Republic of China | Transition anti-subsidy review | TBC |
| Biodiesel | Argentina | Transition anti-subsidy review | TBC |
| Chamois leather | People’s Republic of China | Transition anti-dumping review | TBC |
Measuring and reporting on our performance
Over the course of this plan, we will use a combination of quantitative and qualitative methods to measure, report and reflect on our performance, value for money and risks, and to seek evidence on the impact of our work. This includes regular reporting to our Executive Committee and Board on progress made on delivering our planned programme of investigations and business improvement priorities, and achieving our key performance indictor (KPI) targets. It will also include internal audit reports to our Executive Committee and Audit and Risk Assurance Committee.
For each of our strategic goals, we have identified a small number of high-level KPIs that will help us to measure progress made towards delivering our overall vision. These KPI targets have been developed with reference to current levels of performance and appropriate external benchmarks, to ensure alignment with our overall vision and strategic goals.
We will report on our performance externally through our Annual Report and Accounts. It should be noted that our KPIs are a subset of a broader set of operational and corporate performance indicators, many of which are also reported on externally in our Annual Report and Accounts, including within the Financial Statements,
Sustainability Report and Staff Report sections. As a relatively new organisation, we will be building our staffing capabilities over the period of this corporate plan and will measure our progress through an annual people survey and other workforce metrics.
We will also conduct a biennial survey to measure both the effectiveness of our relationships with stakeholders and how far we are valued as an essential part of the UK’s independent trade policy architecture.
Our key performance indicators
Cases
| Indicator | Description | Target for 2023-24 |
|---|---|---|
| Timeliness – applications | Proportion of new applications assessed within recommended timeframes | 100% |
| Timeliness – investigations | Proportion of recommendations submitted to the Secretary of State within required timelines | 90% |
| Completed transition reviews | Number of transition reviews completed (out of a total of 43) | 22 |
People
| Indicator | Description | Target for 2023-24 |
|---|---|---|
| Recruitment and retention | Proportion of posts filled | 91% |
| Employee engagement | Percent positive annual staff survey engagement index score (aligned with that for the Civil Service People Survey) | 70% |
Digital
| Indicator | Description | Target for 2023-24 |
|---|---|---|
| TRS external user satisfaction | Proportion of Trade Remedies System (TRS) external users that give a positive satisfaction score | 85% |
| Cyber security | Progress made towards meeting the Cyber Essentials accreditation requirements | 100% by March 2024 |
Reputation
| Indicator | Description | Target for 2023-24 |
|---|---|---|
| Credibility | Proportion of stakeholders that said they believe the Trade Remedies Authority undertakes fair, impartial and rigorous investigations | 50% |
| Financial management | Level of variance in expenditure from that set out in our agreed budget for the financial year | Within 1% |
| Sustainability | Total CO2 equivalent emissions resulting from our business activities | Establish baseline |
Appendix 1: The Economic Interest Test
An important and novel feature of the UK trade remedies system is the Economic Interest Test, which considers whether implementing a proposed trade measure would be in the wider economic interest of the UK.
Key considerations:
- The injury caused to UK industry by the imports we are investigating and the benefits to that industry of removing the injury
- The economic significance of affected UK industries and consumers
- The likely effect on wider UK industries and on consumers
- Other matters that we consider relevant
- The likely consequences for the competitive environment and the structure of UK markets for these goods
- The likely effect on particular geographic areas or demographic groups within the UK
Appendix 2: Further reviews that we can undertake
Once trade remedy measures are implemented, we can carry out a variety of types of further review:
- Absorption reviews if we find evidence of companies absorbing an anti-dumping duty
- Circumvention reviews if we identify a change in trade flows and have reason to believe this is caused by an attempt to circumvent a measure
- Exemption reviews where we assess whether an importer or overseas exporter should be exempted from particular measures
- Repayment investigations when an importer of goods believes that the level of additional duty is incorrect
- Tariff rate quota reviews which assess whether the exceptions for imports of particular products need to be amended
- Scope reviews if it emerges that other products which are being imported under similar circumstances may need to be covered by a measure, or that products which are currently covered by a measure may need to be removed from the description of the goods
- New exporter reviews of overseas exporters that have started or will soon start to export goods into the UK which are subject to existing anti-dumping or countervailing measures
- Suspension investigations when market conditions temporarily change
- Interim reviews when there has been a change in circumstances which is of a lasting nature
- Expiry and extension reviews when measures previously put in place by the Secretary of State expire (usually after five years)
Appendix 4: Our finances
The Chief Executive of the Trade Remedies Authority, in his role as Accounting Officer, is accountable for the use, including the regularity and propriety, of the funding received.
The Board reviews our financial performance each time it meets throughout the year. On a bimonthly basis, our Executive Committee considers a risk assessment of our financial health with a view to ensuring value for money and a year-end outturn within budget.
The Secretary of State scrutinises our use of resources, including through consideration of this plan and our Annual Report and Accounts. In addition, the Comptroller and Auditor General examines, certifies and reports on our annual statements of accounts, which are then laid before Parliament.
The Secretary of State for Business and Trade provides the Trade Remedies Authority’s funding. The Departmental Group’s financial statements consolidate the balances of the Department for Business and Trade and the Trade Remedies Authority.
Our indicative budget allocation for 2023-24 is shown below. Our precise grant-in-aid allocation during this period will be set through discussions with the Department for Business and Trade.
Total budget allocation 2023-24: £18.8 million
Estates: £3.2m Pay: £10.3m Other costs: £2.6m Digital and IT: £1.7m Outsourced contracts: £0.5m Learning and development: £0.3m Travel and subsistence: £0.2m
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