The National Tariff Commission (NTC) has initiated Pakistan’s first safeguard investigation, acting on an application that RIAA Barker Gillette prepared for the domestic industry. The case concerns a surge in imports of vulcanised rubber thread and cord from China. It proceeds under Article 27 of the China-Pakistan Free Trade Agreement (CPFTA), read with the Safeguard Measures Ordinance 2002.
A remedy that had never been used
The CPFTA has been in force since 2007, and its bilateral safeguard clause, Article 27, has always allowed either party to act where preferential imports cause or threaten serious injury to a domestic industry. Yet no application had ever progressed to a formal investigation. The NTC’s public record shows three earlier safeguard applications, and the Commission declined to initiate each one. The notice of initiation, dated 24 July 2026, therefore makes this the first Pakistan safeguard investigation on record.
What the application had to establish
A Pakistan safeguard investigation differs from an anti-dumping or countervailing case. The applicant need not show dumping, subsidisation or any other unfair conduct by foreign exporters, but the threshold is demanding in a different way. It had to show the scale of the surge, serious injury to domestic producers and the causal link between them.
RIAA Barker Gillette developed the application and assembled the supporting record. The team analysed import volumes and trends, the performance of the domestic industry and the economic impact of Chinese imports. It then mapped that evidence onto the injury and causation tests. Alongside that work, the firm advised on how Article 27 interacts with Pakistan’s domestic safeguard framework.
“The safeguard mechanism has been available in Pakistan for more than two decades, but had never been put into operation. Getting the first investigation initiated required us to work through a demanding legal and evidentiary threshold,” said Mazhar Bangash, Partner and Head our International Trade practice.
Why it matters
The NTC has set a period of investigation from July 2022 to March 2026, and a final determination is due within four months, extendable by two. Whatever the outcome, the initiation shows that the CPFTA safeguard is a working remedy, not a treaty provision on paper. As a result, other industries facing preferential imports now have a template for the evidence a Pakistan safeguard investigation requires. It also vindicates Pakistan’s decision to retain a bilateral safeguard when it negotiated the CPFTA.
Mazhar Bangash (Partner – Pakistan) led the matter, assisted by Ayesha Bashir (Associate).
For legal advice on international trade and trade remedies in Pakistan, contact Mazhar Bangash today.
This article is not legal advice; it provides information of general interest about current legal issues.
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RIAA Barker Gillette is Pakistan’s premier law firm, with an on-the-ground presence in three major cities in Pakistan: Karachi, Islamabad and Lahore, and affiliated offices in Dubai (DIFC) and London.
The firm practices in all areas of corporate, commercial and dispute resolution law. Leading international legal directories consistently recognise the firm as a top-tier law firm in Pakistan.
RIAA Barker Gillette is the exclusive member firm in Pakistan for Lex Mundi, the world’s leading network of independent law firms with in-depth experience in over 125 countries worldwide.
