South African consumers should not be asked to continue paying the price for trade protection that is no longer justified by the evidence, the Association of Meat Importers and Exporters (AMIE) says in its submission to the sunset review of anti-dumping duties on frozen bone-in chicken imports from Germany, the Netherlands and the United Kingdom.
The sunset review will determine whether the existing duties should expire or remain in place. The South African Poultry Association (SAPA) has asked for them to be extended for a further five years and substantially increased. The duties were first imposed in 2015/16 and extended in 2021. If SAPA’s application succeeds, the protection could remain in place for more than 15 years.
Kherina Narotam, trade attorney at Commodity Trade Observer (CTO), which prepared AMIE’s submission, said the legal starting point for the review was important.
“The law presumes these duties expire. A sunset review is a fresh test of current evidence, not an automatic renewal. The burden is on the applicant to demonstrate, with positive evidence, that allowing the duties to expire would probably lead to the continuation or recurrence of both dumping and material injury.”
Chicken accounts for around 60% of meat consumed in South Africa, making its affordability particularly important for lower-income households. Research by the South African Reserve Bank (SARB), cited in AMIE’s submission, estimated that tariffs, anti-dumping duties and safeguard measures increased the retail price of frozen chicken by 16.2% between 2012 and 2021 above what prices would otherwise have been.
The same research found that rising protection disproportionately affects poorer consumers, with higher prices for frozen chicken, frozen chips and pasta reducing welfare by the equivalent of around 2.1% of food expenditure for the poorest households.
Paul Matthew, CEO of AMIE, said South Africa should not frame the debate as a choice between domestic production and imports. “South Africa needs a strong, competitive and growing domestic poultry industry. It also needs responsible imports to supplement local production, strengthen food security and provide consumers with choice.”
“The challenge is to find the right balance. Where trade protection is necessary to address genuine unfair trade, it has an important role. But those measures also have consequences for consumers, so there must be clear evidence to justify extending them, particularly where extended and significantly higher duties are being proposed.”
In its submission, SAPA calculates new dumping margins of 425.64% for Germany, 32.48% for the Netherlands and 61.84% for the UK, and has asked ITAC to increase the existing duties accordingly. AMIE argues that the calculations do not make fair like-for-like comparisons and, particularly in the cases of Germany and the UK, rely on data that is not representative of the products actually under review.
One of AMIE’s concerns relates to Germany. Because there were no German exports of the product under review to the Southern African Customs Union during the investigation period, SAPA used German exports to Ghana to construct an export price.
AMIE’s analysis found that 88% of the Ghana volume used in that calculation falls under a tariff category that ITAC itself excluded from the product covered by the original investigation. Removing that product more than halves the calculated German dumping margin before any other adjustments are made.
“When decisions can affect the price and availability of an important food staple, it is critical that they are based on robust and representative evidence,” Matthew said. “Our submission asks ITAC to interrogate these calculations carefully and determine whether the legal threshold for extending the duties has in fact been met.”
In the submission, AMIE argues that European market conditions have changed significantly since the protective tariffs were introduced. Germany remains affected by avian influenza restrictions and its poultry production has declined; the UK is itself a net importer whose domestic production meets only around 80% of its requirements; and Dutch poultry is increasingly supplying demand within Europe. These factors, AMIE argues, need to be considered in assessing how likely it is that significant volumes would be redirected to South Africa if the duties expire.
AMIE’s submission also points to the improved performance of South Africa’s poultry industry as an important part of the assessment. In a sunset review dumping must also have the characteristic of being injurious.
Sales, production, employment and profitability among domestic producers have strengthened considerably. Rainbow Chicken’s earnings more than doubled in the six months to December 2025, while Astral reported that operating profit for the six months to March 2026 increased 348% to R1.2 billion. South Africa has also been ranked in BFAP’s 2025 Competitiveness Benchmark, produced with Wageningen University, as the world’s second-most competitive poultry producer, behind Brazil and ahead of European producers.
This relative competitiveness is significant, AMIE says, because it calls into question the contention that imports from European producers would necessarily expose the South African industry to material injury if the duties expire.
In the Terms of Reference for its Poultry Market Inquiry, published in September 2025, the Competition Commission raised concerns about concentration and competition in the South African poultry value chain and has acknowledged the role imports play in closing the gap between domestic production and consumption. The Competition Commission also observed that producers had not passed lower feed prices through to chicken meat prices.
AMIE says the stronger performance of the domestic industry is a positive development and demonstrates the progress made by local producers. It should also form part of ITAC’s assessment of whether expiry of the duties is likely to result in material injury.
“A stronger and more competitive domestic poultry industry is good for South Africa,” Matthew said. “The question for this review is whether the evidence shows that these particular duties are still required for another five years and at the substantially higher levels being sought. Careful consideration also needs to be given to the impact of ongoing duties on consumers, especially the most vulnerable. Duties are essentially another tax on consumers.”
AMIE argues that this reinforces the need to consider the poultry market as a whole, including domestic production, imports, competition, food security and affordability, rather than any one element in isolation.
AMIE has asked ITAC to find that the evidence does not establish that expiry of the duties is likely to result in a recurrence of injurious dumping and to allow the existing duties to expire.
“This is ultimately about getting the balance right,” Matthew said. “South Africa needs domestic producers to thrive, it needs secure and diverse sources of supply, and it needs chicken to remain affordable for consumers.
“A trade policy that achieves those objectives together will be better for the poultry sector, consumers and the South African economy.”