What happens to the anti-dumping security after 15 October 2026, and how does an importer get a refund?

A security taken at the border under investigation 691 into aluminium windows and doors from China is not a duty and it is not final. It sits at the start of a chain that runs through the Minister's decision, a conversion or cancellation step, and then a duty assessment that can return part or all of what was paid. Each stage has its own decision-maker, its own document and, at the end, a deadline that turns interim duty into final duty if nobody acts.

What the security is, and what it is not

A security under section 42 of the Customs Act 1901 is an undertaking to pay, required by the Commonwealth while an investigation is still running. Trade Remedies Notice (TRN) 2026/147 states that securities will be taken for goods exported from China and entered for home consumption on or after 15 October 2026. The dumping commodity register describes it the same way: an undertaking or promise to pay should the Minister decide to impose measures at the end of the investigation.

Two consequences follow. A security is not a duty, a tariff or a customs charge, and it does not appear in the rate tables as a final liability. And the exposure is capped. Section 12 of the Customs Tariff (Anti-Dumping) Act 1975 provides that where the interim duty that would otherwise be payable exceeds the security taken, the interim duty payable equals the security. Conversion cannot cost more than the undertaking that secured it.

Stage one: the decision, and the two things it can do

The Commissioner of the Australian Trade Remedies Commission (ATRC) must report to the Minister with final recommendations on or before 16 December 2026. Submissions on the statement of essential facts closed on 3 November 2026, twenty days after publication on 14 October 2026. Once the Minister receives the recommendation, section 269TLA of the Customs Act requires a decision within 30 days, unless the Minister considers there are special circumstances and gives public notice of a longer period.

The decision has two shapes, and they lead in opposite directions. If the Minister decides not to publish a dumping duty notice or a countervailing duty notice, the securities are cancelled. If a notice is published, the securities may be converted to interim dumping duty at the rate in that notice, capped at the amount taken.

Conversion is not automatic across everything that was secured. Australian Customs Dumping Notice (ACDN) 2012/02 sets out the rule: securities convert only for goods the subject of the notice that were exported to Australia on or after the date the preliminary affirmative determination was made. Securities for goods entered after the securities date but exported before the determination are not converted to interim duty and are cancelled.

The register says the same thing in one line and adds the detail that matters. Securities will be either cancelled or converted to interim duty, and the Australian Border Force will contact each affected importer or broker with instructions for each consignment. There is no portfolio-level conversion event, so ten containers can produce ten separate outcomes.

Stage two: what a duty notice changes for goods already moving

Two questions get mixed together at this point, and they have different answers. The first is whether a security still has to be lodged. The second is which rate applies to goods already on the water when the decision landed.

On the first, once a duty notice is published, securities are no longer required on entry for home consumption. The register also provides a route for shipments that left before the securities began: a Goods on the Water Dumping Specification Number removes the Security ID requirement, on a bill of lading showing a shipped on board date before the securities date, plus the tariff and statistical codes.

On the second, the Australian Border Force states the rule directly. If goods leave the export country before publication of a duty notice but enter Australia after publication, the duty rate is the rate that applied on the date of export, and the importer must provide evidence of that date. For a shipment that sailed in October and berths in December, the bill of lading decides the rate, not the arrival date.

There is a third mechanism the notice flags but does not apply. Section 269TN of the Customs Act allows a duty notice to reach goods already entered for home consumption, provided a security was taken and has not been cancelled. Trade Remedies Notice 2026/147 records that if retrospective notices are imposed on the goods, the duty notice will also include the duties imposed retrospectively. Whether that happens in investigation 691 is a matter for the Minister's decision, and nothing in the public record for this investigation applies it.

Stage three: the assessment, and the deadline that makes it final

Interim duty is the amount paid at the border on the way in. Final duty is the amount actually owed. The interim figure is set from estimated variable factors; the final figure is worked out on the actual export price, normal value, countervailable subsidy and non-injurious price for the consignments concerned. That difference is why the assessment exists.

Division 4 of Part XVB of the Customs Act 1901 provides the route. Any importer of goods on which interim dumping duty or interim countervailing duty has been paid may apply under section 269V for an assessment of the final duty payable, using Form ATRC2 and the duty assessment calculation spreadsheet published with it. The application must be lodged no later than six months after the end of the importation period in which the goods were entered for home consumption. Where securities have been taken, the importation period may run differently from the standard six months, and the register lists the periods that apply.

The possible outcomes are more favourable than most importers expect. If the final duty payable is less than the total interim duty paid, the government repays the difference. If it is more, the government waives the balance and the importer is not required to pay any extra. If the importer does not apply within the time limits, the interim duty paid on the goods is taken to be the final duty payable. That last sentence is worth diarising. The default is not a fresh assessment later; the default is that the interim number becomes the final number, and the chance to recover an overpayment is gone.

Once an application is lodged, the clock is long. The Commission has 155 days to examine it and make a recommendation, a period that can be extended, and the Commissioner then has 30 days to order repayment or waiver. An incomplete application must be rejected within 20 days. The application must cover all consignments imported during the period, from all exporters, with the interim duty paid on each and evidence for the variable factors. Much of that evidence comes from the exporter, so that conversation starts before the form does.

Where the money sits at each stage

At the security stage the Commonwealth holds an undertaking, and the importer has either paid a deposit or arranged a guarantee. At conversion the undertaking becomes interim duty for the consignments that qualify, still capped at the amount secured, and is released for the rest. At the duty notice stage the interim duty is collected or confirmed as the working liability. At assessment it is recalculated on actual figures, and the difference is repaid to the importer or waived by the Commonwealth. A reader who only watches the rate table will miss the step where the money is actually settled.

One timing detail sits across all four stages. The rates published in October are the rates for the securities, not a commitment to the final measure. The Minister can publish a notice at a different level, and an assessment can land at a different level again. Planning a 2027 project on the October figure is planning on an interim position.

What to do with this, in order

For a container entered on or after 15 October 2026 and exported on or after the date of the preliminary determination, the working assumption should be conversion if a notice is published. Keep the import declaration, the bill of lading and the security documentation together, because the Border Force instruction is issued against the consignment, not the company.

For a container entered after 15 October 2026 but exported before the determination, the working assumption is cancellation. The bill of lading showing the shipped on board date is the evidence that supports it, and it is worth retrieving before anyone needs it.

For any importer that has paid interim duty, note the end of the importation period and the six-month application window in the same place. The window is legislated, and missing it converts an estimate into a final figure.

For a project being priced now, the rates in the register are the current position rather than the final one. The Minister's decision, and any assessment that follows it, can both move the number.

The determination in investigation 691 is preliminary, and this article is general information rather than legal, customs or financial advice.