Circumvention is a mechanism used by companies to avoid applicable anti-dumping duties on merchandise they seek to ship (David W. Leebron, An Overview of the Uruguay Round Results, 34 COLUM. J. TRANSNAT’L L. 11, 20 (1995)). Companies can use different means to ‘circumvent’ an order, including minor alterations, transshipment, or by shipping parts not subject to the order for assembly in either the final destination country or a third country (ibid.). This has the effect of changing the country of origin for the merchandise, resulting in circumvention of the order.
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