Article 14 of the Saudi Trade Remedies Law

This article sets out the circumvention practices which, if carried out by an exporter or producer when the investigation begins or before or after provisional or final measures are imposed, mean that the circumvention practice is considered established:

1. Limited modification of the product so as to bring it under a different customs classification. The modification is shown to be limited where the modified product essentially has the same production methods, the same raw materials and the same apparent specifications, or where it is a substitute for the product subject to the measure.
2. Shipping through non-subject countries: exporting, transferring or shipping the product or its parts to the Kingdom through countries not subject to the measure.
3. Manipulating documents: commercial or shipping documents by the importer, the exporter or both, by showing information that does not reflect reality regarding value, origin or customs item.
4. Reorganizing sales channels in the country subject to the measure so as to export through another exporter or producer that benefits from a better measure.
5. Absorption of the measure, with the cases defined by the Implementing Regulations.
6. Simple assembly or production operation inside the Kingdom or in a non-subject country, under two conditions together: (a) the operation begins, or increases substantially, as soon as the investigation begins or during it or while measures are in place, and the parts are imported from a subject country; (b) the value added does not exceed 25% of the value of production, unless the conversion operation is substantial. Value added is calculated on the basis of the direct and indirect cost of the production operation only, excluding general and administrative costs, selling, packaging and profit.
7. Any other form aimed at circumventing the measures.

Article 13 shows that proof of one of these practices is used together with other conditions for circumvention to be considered established, and for the resulting widening of the scope or raising of the level of the measures. Article 15 follows, regulating anti-circumvention review and enforcement and fine procedures. Anyone planning assembly or modification operations for products subject to measures may consult a lawyer specialized in international matters and foreign investment.