A year after India made online filing mandatory for new trade remedy applications, the test for its SETU portal is whether it has made proceedings easier to navigate and scrutinise. Moving submissions out of e-mail inboxes can improve administration. Whether smaller firms can present their cases, and interested parties can examine the evidence against them, will determine how much the reform achieves.
The Directorate General of Trade Remedies (DGTR) made SETU compulsory from October 24, 2025, for applications seeking anti-dumping, countervailing and safeguard investigations, including their respective reviews. Its notice excludes applications filed through other modes, including e-mail, while preserving the earlier procedure for applications already submitted. The change establishes a common filing route for domestic producers and other applicants.
READ | RoDTEP can fix tax distortions, not India’s export problem
SETU, short for System for Ensuring Fair Trade through Unified Platform, offers an opportunity to make trade remedy administration more accountable. That requires attention to the quality of participation as well as the convenience of filing.
Trade remedies require evidence of injury
Trade remedies serve different purposes. Anti-dumping action addresses imports sold below their normal value, usually established by reference to prices in the exporting country’s domestic market. Countervailing measures address subsidised imports that injure domestic industry. Safeguards respond to increased imports causing or threatening serious injury, even where the trade itself is fair. Low prices or rising imports alone do not establish a case for protection. The applicable legal conditions must be met through investigation.
For a domestic producer facing injurious imports, these proceedings offer a means of seeking relief within WTO rules. But manufacturers using imported inputs also have an interest in the outcome. Duties that help an upstream producer can increase costs for downstream businesses, including exporters. An accessible process must allow those businesses to put their evidence on record.
India’s extensive use of anti-dumping measures makes procedural fairness especially important. WTO statistics record 865 measures imposed by India between January 1995 and December 2025, out of 4,918 worldwide, or about 17.6%. India has the highest cumulative total in that table. These figures count measures imposed over the period; they are not a count of measures still in force at its end.
The number of measures cannot, by itself, establish either the prevalence of unfair trade or the merits of individual decisions. Each investigation must determine whether the evidence supports intervention.
Submissions are central to that determination. Production costs and sales data help establish the condition of the domestic industry. Exporters’ responses bear on dumping or subsidy calculations, while importers and users can challenge claims and explain the consequences of a proposed duty. Incomplete records or difficulties accessing submissions can weaken the examination.
READ | Rupee trade gets easier, but the hard part remains
From ARTIS to SETU portal
India’s move towards electronic trade remedy proceedings began before SETU. DGTR’s September 2019 notice introduced ARTIS, following a pilot launched that May. At the time, the system covered original anti-dumping investigations and sunset reviews, with further modules planned. The claim that the earlier platform excluded reviews altogether therefore needs correction.
SETU provides a common platform with broader filing coverage. DGTR’s launch notice also envisaged application and investigation tracking, access to public files and information on registered interested parties. Its public notification page now lists procedural documents, including questionnaires, findings and extensions of deadlines. These facilities can help participants follow proceedings without reconstructing a case from separate communications.
Confidentiality requires particular care. Trade remedy proceedings involve commercially sensitive information, including company costs and prices. Other participants nevertheless need enough disclosure to understand and contest the substance of a claim.
DGTR’s recent investigation notices require confidential submissions to be accompanied by non-confidential summaries containing sufficient detail for a reasonable understanding of the information withheld. They also provide for sharing non-confidential submissions through SETU. A portal can organise access, but the investigating authority must still judge whether the summaries disclose enough to permit a meaningful response.
International systems offer useful reference points. The US Department of Commerce’s ACCESS system allows registered users to file documents and search public documents and public versions of submissions. The European Commission provides interested parties with access to investigation files through TRON.tdi. The relevant lesson is the importance of a usable case record, with clear rules governing access to it.
READ | Trade and sustainable development rules bring forests into FTA strategy
Online access needs practical support
For micro, small and medium enterprises, electronic filing removes some logistical burdens. It does not remove the cost of preparing a defensible application or responding to a detailed questionnaire. A firm must still assemble financial records and explain how the evidence meets the legal tests.
Practical guidance should therefore form part of the service. Worked examples of acceptable submissions, regional-language training and assistance with filing problems would help firms unfamiliar with trade remedy proceedings. DGTR already provides SETU help-desk contacts and organised a workshop before the portal became mandatory. The task is to sustain that support and identify where users encounter difficulty.
The same support should be available to smaller importers and downstream users. Their inability to participate can leave an investigation with an incomplete account of the domestic economic interests involved.
DGTR should also assess the platform through users’ experience. Evidence of fewer rejected filings, quicker acknowledgement of submissions and more reliable access to case records would substantiate claims of improvement. The availability of an online facility alone cannot establish those results.
Make the case record easier to examine
Further development should help participants and researchers understand how cases progress. Searchable summaries organised by product and country, linked to findings and subsequent reviews, would make past decisions easier to examine. Aggregate information on case duration and outcomes would also allow a better assessment of administrative performance.
Any dashboard must distinguish a DGTR recommendation from the government’s decision on imposing a duty. Combining them would obscure an important stage of the process. Notifications should likewise make deadlines and changes to them easy to identify, with a clear procedure for handling documented technical failures.
Trade liberalisation and trade remedies can coexist within WTO disciplines. Remedies can provide relief where the legal tests are satisfied, but they can also become protectionist barriers if those tests are applied loosely. Digital administration does not settle that tension.
SETU should make it easier for a producer to seek justified relief and for an affected user or exporter to challenge an unsupported claim. Its success will depend on whether the evidence receives a fuller examination, including when that examination leads to a decision against imposing a duty.
Murali Kallummal is Professor at Centre for WTO Studies and Head Administration (CRIT), Indian Institute of Foreign Trade (IIFT), New Delhi. Amit Randev is Consultant (Legal) at the Centre for WTO Studies.