Commission Implementing Regulation (EU) 2024/2661 of 14 October 2024 imposing a definitive anti-dumping duty on imports of aluminium radiators originating in the People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council

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	2024/2661	15.10.2024

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2016/1036 of the European Parliament and of the Council of 8 June 2016 on protection against dumped imports from countries not members of the European Union (‘the basic Regulation’) ¹, and in particular Article 11(2) thereof,

Whereas:

1. PROCEDURE

1.1.   Previous investigations and measures in force

• (1) By Regulation (EU) No 1039/2012 ², the Council imposed anti-dumping duties on imports of aluminium radiators, originating in the People’s Republic of China (‘the original measures’). The investigation that led to the imposition of the original measures will hereinafter be referred to as ‘the original investigation’.

• (2) By Regulation (EU) 2019/59 ³ the European Commission (‘the Commission’) prolonged the definitive anti-dumping measures on imports of aluminium radiators originating in the People’s Republic of China (‘China’) following an expiry review (the ‘previous expiry review’).

• (3) The anti-dumping duties currently in force are at rates ranging between 12,6 % and 56,2 % on imports from the sampled exporting producers, 21,2 % on the non-sampled cooperating companies and 61,4 % on all other companies in China.

1.2.   Request for an expiry review

• (4) Following the publication of a notice of impending expiry ⁴ the Commission received a request for a review pursuant to Article 11(2) of the basic Regulation.

• (5) The request for review was lodged on 17 October 2023 by the International Association of Aluminium Radiator Manufacturers (‘the applicant’) on behalf of the Union industry of aluminium radiators in the sense of Article 5(4) of the basic Regulation. The request for review was based on the grounds that the expiry of the measures would be likely to result in recurrence of dumping and recurrence of injury to the Union industry.

1.3.   Initiation of an expiry review

• (6) Having determined, after consulting the Committee established by Article 15(1) of the basic Regulation, that sufficient evidence existed for the initiation of an expiry review, on 12 January 2024 the Commission initiated an expiry review with regard to imports into the Union of aluminium radiators originating in China on the basis of Article 11(2) of the basic Regulation. It published a Notice of Initiation in the Official Journal of the European Union (‘the Notice of Initiation’) ⁵.

1.4.   Review investigation period and period considered

• (7) The investigation of continuation or recurrence of dumping covered the period from 1 January 2023 to 31 December 2023 (‘review investigation period’). The examination of trends relevant for the assessment of the likelihood of a continuation or recurrence of injury covered the period from 1 January 2020 to the end of the review investigation period (‘the period considered’).

1.5.   Interested parties

• (8) In the Notice of Initiation, interested parties were invited to contact the Commission in order to participate in the investigation. In addition, the Commission specifically informed the applicant, other known Union producers, the known producers in China, the authorities of China and known importers about the initiation of the expiry and invited them to participate.

• (9) Interested parties had an opportunity to comment on the initiation of the expiry review and to request a hearing with the Commission and/or the Hearing Officer in trade proceedings.

1.6.   Sampling

• (10) In the Notice of Initiation, the Commission stated that it might sample the interested parties in accordance with Article 17 of the basic Regulation.

1.6.1.   Sampling of Union producers

• (11) The Commission stated in the Notice of Initiation that it had provisionally selected a sample of Union producers.

• (12) Pursuant to Article 17(1) of the basic anti-dumping Regulation, the criterion used for the selection of the sample was the representativity in terms of volume of production and sales of the like product in the Union between 1 October 2022 and 30 September 2023.

• (13) This sample consisted of three Union producers, all located in Italy, and accounted for more than 65 % of estimated total production of the like product in the Union.

• (14) The Commission invited interested parties to comment on the provisional sample. Since no comments were received, the Commission confirmed the provisionally selected sample as the definitive sample.

1.6.2.   Sampling of importers

• (15) To decide whether sampling was necessary and, if so, to select a sample, the Commission invited unrelated importers and their representative associations to make themselves known and provide the information specified in the Notice of Initiation. No unrelated importer came forward.

1.6.3.   Sampling of producers in China

• (16) To decide whether sampling was necessary and, if so, to select a sample, the Commission asked all producers in China to provide the information specified in the Notice of Initiation. In addition, the Commission asked the Mission of the People’s Republic of China to identify and/or contact other producers, if any, that could be interested in participating in the investigation. No replies were received.

• (17) Consequently, the Commission informed the authorities of China that in the absence of cooperation it intended to resort to the use of facts available under Article 18 of the basic Regulation when examining the continuation or recurrence of dumping. No response was received.

1.7.   Replies to the questionnaire

• (18) Questionnaires for Union producers, as well as those for importers, users and producers in China were made available online on the day of the initiation. ⁶

• (19) The Commission sent a questionnaire concerning the existence of significant distortions in China within the meaning of Article 2(6a)(b) of the basic Regulation to the Government of the People’s Republic of China (‘GOC’).

• (20) Questionnaire replies were received from the three sampled Union producers.

• (21) Neither the GOC nor any producer in China provided a questionnaire reply.

1.8.   Verification

• (22) The Commission sought and verified all the information deemed necessary for the determination of likelihood of continuation or recurrence of dumping and injury and of the Union interest.

• (23) The Commission carried out verification visits pursuant to Article 16 of the basic Regulation at the premises of the three sampled Union producers:

• — Fondital S.p.A, Brescia, Italy;

• — Global di Fardelli Ottorino & Co, S.r.l, Bergamo, Italy;

• — Radiatori 2000 S.p.A, Bergamo, Italy.

1.9.   Subsequent procedure

• (24) On 8 August 2024, the Commission disclosed the essential facts and considerations on the basis of which it intended to maintain the anti-dumping duties in force. All parties were granted a period within which they could make comments on the disclosure.

• (25) The comments made by interested parties were considered by the Commission and taken into account, where appropriate. No parties requested a hearing.

2. PRODUCT UNDER REVIEW AND LIKE PRODUCT

2.1.   Product under review

• (26) The product under review is the same as in in the original investigation and in the previous expiry review, namely aluminium radiators and elements or sections of which such radiator is composed, whether or not such elements are assembled in blocks, excluding radiators and elements and sections thereof of the electrical type, currently falling under CN codes ex 7615 10 10 , ex 7615 10 80 , ex 7616 99 10 and ex 7616 99 90 (TARIC codes 7615 10 10 10, 7615 10 80 10, 7616 99 10 91, 7616 99 90 01 and 7616 99 90 91) (‘the product under review’).

2.2.   Like product

• (27) As established in the original investigation as well as in the previous expiry review, this expiry review investigation confirmed that the following products have the same basic physical and technical characteristics as well as the same basic uses:

• — the product concerned when exported to the Union;

• — the product under review produced and sold on the domestic market of China;

• — the product under review produced and sold by the exporting producers to the rest of the world; and

• — the product under review produced and sold in the Union by the Union industry.

• (28) These products are therefore considered all to be like products within the meaning of Article 1(4) of the basic Regulation.

3. DUMPING

3.1.   Preliminary remarks

• (29) In accordance with Article 11(2) of the basic Regulation, the Commission examined whether dumping was taking place during the review investigation period and whether dumping was likely to continue or recur upon a possible expiry of the measures in force.

• (30) As mentioned in recital (16), none of the producers from China cooperated in the investigation. Therefore, on 21 February 2024 the Commission informed the Chinese authorities and all interested parties that due to the absence of cooperation, the Commission intended to apply Article 18 of the basic Regulation concerning the findings with regard to China. The Commission did not receive any comments nor requests for an intervention of the Hearing Officer in this regard.

• (31) Consequently, in accordance with Article 18 of the basic Regulation, the findings in relation to the likelihood of continuation or recurrence of dumping were based on facts available, in particular information in the request for review, and information obtained from cooperating parties in the course of the review investigation (namely, the applicant) and information from other publicly available sources, in particular the Global Trade Atlas (‘GTA’) ⁷.

3.2.   Procedure for the determination of the normal value under Article 2(6a) of the basic Regulation for the imports of aluminium radiators originating in China

• (32) According to Article 2(1) of the basic Regulation, ‘the normal value shall normally be based on the prices paid or payable, in the ordinary course of trade, by independent customers in the exporting country’.

• (33) However, according to Article 2(6a)(a) of the basic Regulation, ‘in case it is determined […] that it is not appropriate to use domestic prices and costs in the exporting country due to the existence in that country of significant distortions within the meaning of point (b), the normal value shall be constructed exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks’, and ‘shall include an undistorted and reasonable amount of administrative, selling and general costs and for profits’ (‘administrative, selling and general costs’ is refereed hereinafter as ‘SG & A’).

• (34) As further explained below, the Commission concluded in the present investigation that, based on the evidence available, and in view of the lack of cooperation of the GOC and the exporting producers, the application of Article 2(6a) of the basic Regulation was appropriate.

3.3.   Existence of significant distortions

• (35) In recent investigations concerning the aluminium sector in China ⁸, the Commission found that significant distortions in the sense of Article 2(6a)(b) of the basic Regulation were present.

• (36) In those investigations, the Commission found that there is substantial government intervention in China resulting in a distortion of the effective allocation of resources in line with market principles ⁹. In particular, the Commission concluded that in the aluminium sector, not only does a substantial degree of ownership by the GOC persist in the sense of Article 2(6a)(b), first indent of the basic Regulation ¹⁰, but the GOC is also in a position to interfere with prices and costs through State presence in firms within the meaning of Article 2(6a)(b), second indent of the basic Regulation ¹¹. The Commission further found that the State’s presence and intervention in the financial markets, as well as in the provision of raw materials and inputs have an additional distorting effect on the market. Indeed, overall, the system of planning in China results in resources being concentrated in sectors designated as strategic or otherwise politically important by the GOC, rather than being allocated in line with market forces ¹². Moreover, the Commission concluded that the Chinese bankruptcy and property laws do not work properly in the sense of Article 2(6a)(b), fourth indent of the basic Regulation, thus generating distortions in particular when maintaining insolvent firms afloat and when allocating land use rights in China ¹³. In the same vein, the Commission found distortions of wage costs in the steel sector according to Article 2(6a)(b), fifth indent of the basic Regulation ¹⁴, as well as distortions in the financial markets in the sense of Article 2(6a)(b), sixth indent of the basic Regulation, in particular concerning access to capital for corporate actors in China ¹⁵.

• (37) Like in previous investigations concerning the aluminium sector in China, the Commission examined in the present investigation whether it was appropriate or not to use domestic prices and costs in China, due to the existence of significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation. The Commission did so on the basis of the evidence available on the file, including the evidence contained in the request, and in the Commission Staff Working Document on Significant Distortions in the Economy of the People’s Republic of China for the Purposes of Trade Defence Investigations ¹⁶ (‘Report’) as well as in its updated version (‘updated Report’) ¹⁷, which relies on publicly available sources. That analysis covered the examination of the substantial government interventions in China’s economy in general, but also the specific market situation in the relevant sector including the product under review.

• (38) The request alleged that due to the existence of significant distortions in China, domestic prices and costs of the Chinese aluminium industry cannot be used in the present case. To support its position, the applicant referred to the Report, especially the sections concerning the aluminium sector ¹⁸, to previous Commission investigations of aluminium and downstream products ¹⁹, to Chinese legislation, as well as to additional studies.

• (39) In particular, the applicant commissioned a study, ‘China Household Aluminum Radiators Industry Market Research Report’ (‘the Study’), updated as of October 2023. The Study showed that China is not only the world’s largest producer of bauxite, the main source of aluminium, but also the world’s largest producer of aluminium, and ‘[a]ccording to the data released by the International Aluminum Association and the International Energy Deployment, in 2020, China’s aluminum production increased by 5 % year-on-year, while the rest of the world only increased by 0,3 %, and even the production of aluminum in some regions declined. China accounts for 57,2 percent of global aluminium production. Overall, China’s aluminum production has shown an upward trend. China’s 2022 aluminum production reached 40 million tons, once again accounting for more than half of global aluminum production. China is also one of the world’s largest consumers of aluminum’.

• (40) The applicant furthermore sustained that the boom that the aluminium industry experienced in China was led by favorable government policies encouraging SOEs to enter the primary aluminum production sector and private owned enterprises to enter the aluminum manufacturing sectors.

• (41) More specifically, the request pointed out that significant regional state aid initiatives by China government also confirm the distortive nature of the China government interventions, supporting the aluminium sector in the provinces as follows:

• — in Zhejiang, i) strengthen the implementation of the national tax reduction policy; ii) increase employment stability support; iii) increase support for epidemic prevention; iv) increase financing services; and v) increase support for stabilization;

• — in Shanghai, i) support the innovative development of small and medium sized enterprises; ii) assist small and medium sized enterprises in their digital transformation; iii) create an integrated development ecosystem for large, medium and small enterprises; iv) strengthen financial empowerment services for small and medium sized enterprises; v) increase efforts to rescue small and medium sized enterprises; and vi) strengthen precise services for small and medium sized enterprises;

• — in Shandong, i) further increase the financial support for relief efforts; ii) further promote tax and fee reductions; iii) further strengthen financing support; iv) further alleviating the pressure of rising costs; v) further optimize scientific electricity management; and vi) further expand market space.

• (42) In conclusion, the request took the position that prices or costs are not the result of free market forces because they are affected by substantial government intervention within the meaning of Article 2(6a)(b) of the Basic Regulation. On that basis, according to the request, it is not appropriate to use domestic prices and costs to establish normal value in this case.

• (43) The GOC did not comment or provide evidence supporting or rebutting the existing evidence on the case file, including the Report and the additional evidence provided by the applicant, on the existence of significant distortions and/or appropriateness of the application of Article 2(6a) of the basic Regulation in the case at hand.

• (44) Consequently, when examining in the present investigation whether it was appropriate or not to use domestic prices and costs in China, due to the existence of significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation, the Commission did so on the basis of the evidence available on the file, including the evidence contained in the request, as well as in the updated Report. The Commission further supplemented these evidentiary elements with its own research on the various criteria relevant to confirm the existence of significant distortions in China, as established also in its previous investigations in this respect.

• (45) In the sector of the product under review, a substantial degree of ownership, control, policy supervision or guidance by the GOC persists in the sense of Article 2(6a)(b), first indent of the basic Regulation. In China, enterprises operating under the ownership, control and/or policy supervision or guidance by the state represent an essential part of the economy. The GOC and the Chinese Communist Party (‘CCP’) maintain structures that ensure their continued influence over enterprises, and in particular SOEs ²⁰. However, CCP interventions into operational decision making have become the norm not only in SOEs, but also in private companies ²¹, with CCP claiming leadership over virtually every aspect of the country’s economy.

• (46) Since there was no cooperation from Chinese exporters of the product under review, the exact ratio of the private and state-owned producers could not be determined. However, the investigation established that the sector of the product under review is served both by SOEs and private companies ²². For instance, several producers are private, including the Unbeatable Group (‘Unbeatable’) ²³, Zhejiang Navas Industry and Trade, formerly known as Yongkang Sanghe Radiator ²⁴ (‘Zhejiang Navas’), China Botai ²⁵ and China Flyhigh ²⁶, while China’s largest aluminium producer, China Aluminum Corporation (‘Chinalco’) ²⁷, is a SOE, with more than 35 % of public ownership ²⁸.

• (47) Furthermore, the GOC exerts guidance on enterprises also by setting specific objectives and policies for the sector, which all industry participants, regardless of their private or public nature, are obliged to comply with.

• (48) To give an example, the Standard Conditions Applicable to the Aluminium Industry (‘Standard Conditions) ²⁹, issued by the Ministry of Industry and Information Technology (‘MIIT’) in 2020, set the overall framework for the operation of the aluminium industry at the central level. Nominally, the Standard Conditions pursue the objective to: ‘[p]romote the supply-side structural reform of the aluminium industry, promote the technological development of the industry, and promote the high-quality development of the industry’ and provide that: ‘[b]auxite mining, alumina, electrolytic aluminium and secondary aluminium production must comply with national and local industrial policies, mineral resource plans, environmental protection and energy conservation laws, regulations and policies, mining laws, regulations and policies, safety production laws, regulations and policies, industry development plans and other requirements’ ³⁰.

• (49) The Shandong Province 14th Five Year Plan (‘FYP’) on Aluminium Industry Development (‘Shandong Plan’) ³¹ lists the following targets: ‘[b]y 2025, the value of aluminium industry output will reach RMB 800 billion, the end-products’ market size shall continue to expand, with high value-added products accounting for over 60 %, and the ratio of aluminium material production volume/electrolytic aluminium production volume will exceed the national average […]. The province will evolve into a major aluminium industrial cluster with significant domestic and overseas influence’ ³².

• (50) In September 2022, the Standing Committee of the People’s Congress of Guangxi Zhuang Autonomous Region issued the Decision on Promoting the High-quality Development of the Aluminium Industry (‘Guangxi Decision’) ³³ and specified the goals regarding cultivating leading enterprises and steering the development path of SOEs in the province: ‘Cultivate and introduce a group of leading enterprises with core competitiveness. Establish an ‘industrial chain leader’ system in the aluminium industry, for enterprises leading the alumina and electrolytic aluminium industrial chains, to implement a comprehensive energy efficiency evaluation and incentive mechanism covering the whole industry […] Strengthen efforts to foster small and medium-sized enterprises in the aluminium industry, focus on building up a group of specialized, professional, special and new ‘little giant’ enterprises in the field of aluminium deep processing, as well as champion enterprises in the field of aluminium manufacturing industry; and further promote the brand of Guangxi Aluminium. Improve the development quality and efficiency of aluminium-related state-owned enterprises, support Guangxi Investment Group and other state-owned enterprises to optimize and integrate their internal aluminium business; take and use capital to deploy the aluminium industry chain across provinces and countries via mergers and acquisitions, participating or controlling equity interest or other methods, so as to implement coordinated development of the whole industrial chain and build up leading enterprises in the aluminium industry with national influence and international competitiveness’ ³⁴.

• (51) Not only, government control and policy supervision can be also observed at the level of the relevant industry associations. Indeed, Chinese industry associations are to guarantee that industry implements the policies of the GOC. This responsibility is confirmed by the fact that in their activity, they liaise closely with State authorities, which is reflected in their statutes.

• (52) For instance, China Non-Ferrous Metals Fabrication Industry Association (‘CNFA’) ³⁵ notably states in Article 3 of its Articles of association that the organisation ‘[a]dheres to the overall leadership of the Communist Party of China, establishes an organization of the Communist Party of China, carries out Party activities, and provides the necessary conditions for the activities of the Party organization’ and ‘accepts the professional guidance, supervision and management by the entities in charge of registration and management, by entities in charge of Party building, as well as by the relevant administrative departments in charge of industry management’ ³⁶. According to Article 6, the scope of the Association’s business is, inter alia, the following: ‘[i]n accordance with the general policy and general task of establishing a socialist market economic system put forward by the Party and the state, and in view of the actual situation of the industry, actively put forward suggestions and opinions on industry development, industry policies, laws and regulation’ ³⁷. Moreover, the conditions to be eligible as a representative of the Association include the adhesion to the leadership of the Communist Party of China, support socialism with Chinese characteristics, resolutely implement the Party’s line, principles and policies, and possess good political qualities ³⁸.

• (53) As to the GOC being in a position to interfere with prices and costs through State presence in firms in the sense of Article 2(6a)(b), second indent of the basic Regulation, CCP cells in enterprises, state-owned and private alike, represent an important channel through which the state can interfere with business decisions. During the investigation, the Commission established the existence of personal connections between producers of the product under review and the CCP, such as CCP members among the senior management or members of the board of directors in a number of companies manufacturing the product under review.

• (54) For instance, Chinalco’s chairman and Chinalco’s director and general manager, are respectively the party secretary and the party deputy-secretary of Chinalco’s party organization. Not only, in 2024, all units of Chinalco Group launched the Party Discipline Study and Education: ‘[t]he deployment meeting of the Party Discipline Study and Education of Chinalco Group emphasized that party organizations at all levels should strengthen the combination of learning and application, combine the Party Discipline Study and Education with the implementation of the annual implementation system of the strategic planning of Chinalco Group’s “4 + 4+N+ annual key projects”, and strive to achieve annual goals and tasks, and effectively transform the learning results into an inexhaustible driving force for accelerating the construction of a world-class excellent aluminium company with strong comprehensive competitive advantages, and provide strong political guarantees for striving to write a new chapter of Chinalco’s modernization’ ³⁹ .

• (55) Also privately owned enterprises in the aluminium radiators industry are subject to party interference. For example, the Chairman and Secretary of the Party Branch of Jiangsu Unbeatable Group Co., Ltd., was appointed in 2021 among the best 100 CCP members in Nantong Municipality ⁴⁰. Moreover, Qidong Municipality (situated within the territory of Nantong, in the Jiangsu province) organised CCP learning sessions with Unbeatable Group: ‘In her speech, […] said that the construction of the On-site Teaching Point of the Unbeatable Group in the High-tech Zone is closely linked to the actual situation of the district and town, in line with the characteristics of the enterprise, and fully reflects the theme of high-level party building leading high-quality development.’ ⁴¹.

• (56) Further, policies discriminating in favour of domestic producers or otherwise influencing the market in the sense of Article 2(6a)(b), third indent of the basic Regulation are in place in the sector of the product under review.

• (57) The aluminium industry keeps being regarded as a key industry by the GOC ⁴². This is confirmed in the numerous plans, directives and other documents focused on aluminium, issued at national, provincial, and municipal level, which have been documented in detail by the Commission in previous investigations of the sector ⁴³, as well as in the Updated Report ⁴⁴.

• (58) At national level, for instance, the 14th FYP on Developing the Raw Materials Industry ⁴⁵ includes provisions ensuring availability of aluminium as raw material: ‘Implement actions to overcome shortages in key materials; […] Implement actions to consolidate and improve bulk basic materials and, on the basis of optimised production processes, guide enterprises to use the new generation information technologies such as industry internet so as to improve the overall competitiveness of […], high-strength aluminium alloy, […]’. The plan further calls for capacity control in the aluminium sector: ‘Strictly control newly increased production capacity. Improve and strictly implement production capacity replacement policies for […] the electrolytic aluminium sector, prevent the disorderly development of […] and aluminium oxide’. The plan also entails geographical distribution of different industries in China, under the chapter ‘Ensure guidance towards a reasonable layout’. The chapter reads as follows: ‘The layout of new production capacity will be improved. […] Implement national and regional key strategies, regional coordination development strategies, and key functional areas strategies, and encourage the raw materials industry to optimize and adjust its spatial layout. […] Ensure the orderly layout of coastal areas with projects using overseas resources such as aluminium oxide’. The plan further talks about the creation of industrial clusters: ‘Foster standardized industry clusters. […], foster the shift in the layout of the electrolytic aluminium sector from “coal – electricity – aluminium” to “clean energy, such hydropower, wind power – aluminium”’. The plan lastly provides for a promotion of advanced technologies in the aluminium sector, promotion of the sector transformation. As can be seen from the above list, the aluminium sector is closely monitored and steered by the central government and the sector is to a large extent shaped by governmental intervention rather than by free market forces.

• (59) At local level, the extent of China’s interference into the aluminium industry is more evident. One such example is the Shandong Plan, which, alongside the goals described in recital (49) above sets out support measures for the local aluminium enterprises in the following terms: ‘Increase policy and regulatory support. Actively implement various national and provincial-level support policies, provide support to eligible industrial clusters, key products and key technologies. Support enterprises undertaking major national and provincial projects. Make good use of the package of policies supporting key energy transition projects, foster pioneering enterprises by providing support from aspects including fiscal incentives, land supply, green energy allocation, tax cuts, and technological innovations, and implement tax incentives for aluminium recycling. Encourage provincial-level equity investment funds to invest in the R & D and industrialisation of new key products, and attract investment from social capital’ ⁴⁶ .

• (60) In Yunnan, the Yunnan Province Action Plan on Reshaping the Whole Chain of Nonferrous Metals and New Material Industries with New Advantages 2021-2023 (‘Yunnan Plan’) ⁴⁷ contains, inter alia, measures to lower the operating costs of the aluminium industry by means of preferential tax policies: ‘Implement preferential tax policies for the development of the western region, and duly conduct investigation and registration of relevant enterprises for the green silicon industry, green aluminium industry and non-ferrous metal deep processing industry listed in the catalogue of encouraged industries in the western region; provide unsolicited advice and services to help enterprises reduce their tax burden’ ⁴⁸.

• (61) The Guangxi Decision, as already demonstrated in recital (50) sets out several objectives for the aluminium industry development in the province. Furthermore, it mandates that: ‘[b]y 2030, the ratio of aluminium production to electrolytic aluminium production will exceed 2:1, and the proportion of refined and deep processed aluminium products in aluminium products will exceed 60 %. Government bodies shall organize and implement projects to extend and strengthen the industry chain and create a profitable aluminium deep processing industry which has both quantity and quality, and focus on developing and creating advantages in the following sectors: aluminium for lightweight automobiles, aluminium for new energy sources such as photovoltaics and batteries, aluminium used for power, aluminium used for food and medicine packaging, aluminium for electronic appliances, and aluminium for construction and home furnishing. Continued support shall be provided for the development of high-end products such as aluminium for aerospace, ships, and railways […]’ ⁴⁹.

• (62) In addition to the above, the aluminium radiators producers have also benefitted from financial support measures, which clearly reveal the interest of the state in this sector. For instance, Zhejiang Navas benefitted from the public Guarantee of Yongkang Municipality State Owned Capital Investment holding, for a loan of RMB 10 million that was still outstanding in 2022 ⁵⁰.

• (63) In sum, the GOC has measures in place to induce operators to comply with the public policy objectives of supporting encouraged industries, including the production of the main inputs used in the manufacturing of the product under review. Such measures impede market forces from operating freely.

• (64) The present investigation has not revealed any evidence that the discriminatory application or inadequate enforcement of bankruptcy and property laws according to Article 2(6a)(b), fourth indent of the basic Regulation in the aluminium would not affect the manufacturers of the product under review.

• (65) The product under review is also affected by the distortions of wage costs in the sense of Article 2(6a)(b), fifth indent of the basic Regulation, as also referred to above in recital (35). Those distortions affect the sector both directly (when producing the product under review or the main inputs), as well as indirectly (when having access to inputs from companies subject to the same labour system in China).

• (66) Moreover, no evidence was submitted in the present investigation demonstrating that the sector of the product under review is not affected by the government intervention in the financial system in the sense of Article 2(6a)(b), sixth indent of the basic Regulation, as also referred above in recital (35). Even at policy level, the government deeply regulates financial measures. For instance, the Guangxi Decision mandates to: ‘[e]stablish a special fund for the high-quality development of the aluminium industry and increase support for the transformation and upgrading of the aluminium industry. Give full play to the guiding role of Guangxi Industrial Highquality Development Fund as well as of government industry investment funds at all levels; encourage leading enterprises in alumina and electrolytic aluminium industry and social capital to participate in the establishment of aluminium industrial investment funds to focus on supporting aluminium deep processing and high value-added aluminium industry projects. Encourage financial institutions to innovate and develop aluminium supply chain finance, technology finance, and green finance for the aluminium industry, and to implement differentiated credit support policies for alumina and electrolytic aluminium enterprises’ projects such as energy conservation and emission reduction, technological transformation, industrial chain extension and repair, and comprehensive utilization of resources. Support qualified aluminium companies to be listed on domestic and foreign stock exchanges, and to be listed on the New Third Board and regional equity trading markets. Guide aluminium enterprises to receive direct financing through the bond market. Support the securitization of the debt assets of aluminium enterprises via financial leasing. Adjust and optimize the fiscal and taxation support policies for the aluminium industry; adjust the focus of support to key areas of the industry chain such as aluminium deep processing, technology research and development, supply chain security, energy conservation and emission reduction, as well as the development of recycled aluminium’ ⁵¹.

• (67) Therefore, the substantial government intervention in the financial system leads to the market conditions being severely affected at all levels.

• (68) Finally, the Commission recalls that in order to produce the product under review, a number of inputs is needed. When the producers of the product under review purchase/contract these inputs, the prices they pay (and which are recorded as their costs) are clearly exposed to the same systemic distortions mentioned before. For instance, suppliers of inputs employ labour that is subject to the distortions. They may borrow money that is subject to the distortions on the financial sector/capital allocation. In addition, they are subject to the planning system that applies across all levels of government and sectors.

• (69) As a consequence, not only the domestic sales prices of the product under review are not appropriate for use within the meaning of Article 2(6a)(a) of the basic Regulation, but all the input costs (including raw materials, energy, land, financing, labour, etc.) are also affected because their price formation is affected by substantial government intervention, as described in Parts I and II of the updated Report. Indeed, the government interventions described in relation to the allocation of capital, land, labour, energy and raw materials are present throughout China. This means, for instance, that an input that in itself was produced in China by combining a range of factors of production is exposed to significant distortions. The same applies for the input to the input and so forth.

• (70) In sum, the evidence available showed that prices or costs of the product under review, including the costs of raw materials, energy and labour, are not the result of free market forces because they are affected by substantial government intervention within the meaning of Article 2(6a)(b) of the basic Regulation, as shown by the actual or potential impact of one or more of the relevant elements listed therein. On that basis, and in the absence of any cooperation from the GOC, the Commission concluded that it is not appropriate to use domestic prices and costs to establish normal value in this case. Consequently, the Commission proceeded to construct the normal value exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks, that is, in this case, on the basis of corresponding costs of production and sale in an appropriate representative country, in accordance with Article 2(6a)(a) of the basic Regulation, as described in the following section.

• (71) No evidence or argument to the contrary has been adduced by the GOC in the present investigation.

3.3.1.   Representative country

3.3.1.1.   General remarks

• (72) The choice of the representative country was based on the following criteria pursuant to Article 2(6a) of the basic Regulation:

• — A level of economic development similar to China. For this purpose, the Commission used countries with a gross national income per capita similar to China on the basis of the database of the World Bank ⁵²;

• — Production of the product under review in that country ⁵³;

• — Availability of relevant public data in the representative country;

• — Where there is more than one possible representative country, preference should be given, where appropriate, to the country with an adequate level of social and environmental protection.

• (73) The Commission issued a Note on the sources for the determination of the normal value. This Note described the facts and evidence underlying the relevant criteria, and addressed the comments received by the parties on these elements and on the relevant sources. In the Note, the Commission informed interested parties of its intention to use Türkiye as an appropriate representative country in the present case.

3.3.1.2.   A level of economic development similar to China

• (74) In the Note, the Commission identified Türkiye as a country with a similar level of economic development as China according to the World Bank, i.e. they are all classified by the World Bank as ‘upper-middle income’ countries on a gross national income basis where production of the product under review was known to take place.

• (75) Before the publication of the Note, the Commission received comments on the representative country from the applicant which had also suggested that Türkiye would be a suitable representative country.

3.3.1.3.   Availability of relevant public data in the representative country

• (76) In the Note the Commission indicated that for Türkiye, data with regard to the financial data from producers of the aluminium radiators as well as imports for relevant raw material, energy and labour are publicly available.

• (77) Thus, the Commission searched on Orbis for the availability of financial data of the producing companies in Türkiye ⁵⁴. Readily available data was found for two producers of aluminium radiators in Türkiye: Sanica Isi Sanayi Anonim Sirketi and Peksa Profil Sanayi Ve Ticaret Anonim Sirketi. The most recent financial statements of these companies cover the financial year ending in 2022. In addition, Türkiye has available import data on needed factors of production, electricity and labour costs.

• (78) The Commission informed the interested parties with the Note that it intends to use Türkiye as an appropriate representative country and the data of the two companies recalled above, in accordance with Article 2(6a)(a), first ident of the basic Regulation in order to source undistorted prices or benchmarks for the calculation of normal value.

• (79) Interested parties were invited to comment on the appropriateness of Türkiye as a representative country and of those two companies as producers in the representative country.

• (80) The Commission did not receive any comments after the publication of the Note.

3.3.1.4.   Level of social and environmental protection

• (81) Having established that Türkiye was the only available appropriate representative country, based on all of the above elements, there was no need to carry out an assessment of the level of social and environmental protection in accordance with the last sentence of Article 2(6a)(a) first indent of the basic Regulation.

3.3.1.5.   Conclusion

• (82) In view of the above analysis, Türkiye met the criteria laid down in Article 2(6a)(a), first indent of the basic Regulation in order to be considered as an appropriate representative country.

3.3.2.   Undistorted costs and benchmarks

• (83) In the Note, the Commission listed the factors of production such as materials, energy and labour used in the production of the product under review according to the methodology explained by the applicant and reflecting the manufacturing process used in the Union. The Commission also stated that, in order to construct the normal value in accordance with Article 2(6a)(a) of the basic Regulation, it would use the GTA ⁵⁵ to establish the undistorted cost of most of the factors of production, notably the raw materials. In addition, the Commission stated that it would use the Turkish Statistical Institute for establishing undistorted cost of labour ⁵⁶, and the Energy Market Regulatory Authority of Turkiye for establishing the undistorted cost of energy ⁵⁷.

• (84) The Commission invited the interested parties to comment and propose publicly available information on undistorted values for each of the factors of production mentioned in that note. The Commission did not receive any comment concerning the list of factors of production after the publication of the Note.

3.3.2.1.   Factors of production

• (85) Considering all the information based on the request and subsequent information analysed by the Commission, the following factors of production and their sources have been identified in order to determine the normal value in accordance with Article 2(6a)(a) of the basic Regulation:

Table 1

Factors of production of aluminium radiators

Factor of Production	Commodity Code in China	Undistorted value	Unit of measurement	Source of information
RAW MATERIALS	RAW MATERIALS	RAW MATERIALS	RAW MATERIALS
Aluminium alloy (slabs and billets)	76012020	13,91 RMB/Kg	Kg	GTA
Aluminium alloy (excluding slabs and billets)	76012080	14,00 RMB/Kg	Kg	GTA
Nipple	73079910, 730799800011, 730799800012, 730799800019	98,51 RMB/Kg	Kg	GTA
LABOUR	LABOUR	LABOUR	LABOUR
Labour cost	N/A	35,02 RMB per hour	hour	Turkish Statistical Institute58
ENERGY	ENERGY	ENERGY	ENERGY
Electricity	N/A	1,12 RMB per KWh	KwH	Energy Market Regulatory Authority of Turkiye59

3.3.2.2.   Raw materials

• (86) An aluminium radiator can be made using various methods, the most common being die-casting and extrusion. An aluminium radiator is commonly recognized to be one in which the metal used is aluminium or an aluminium alloy, or more in general when the metal used is mostly aluminium.

• (87) In order to establish the undistorted price of raw materials as delivered at the gate of a representative country producer, the Commission used as a basis the weighted average import price to the representative country as reported in the GTA database in which import duties were included and transport costs were added. An import price in the representative country was determined as a weighted average of unit prices of imports from all third countries excluding China and countries which are not members of the WTO, listed in Annex I of Regulation (EU) 2015/755 of the European Parliament and the Council ⁶⁰. The Commission decided to exclude imports from China into the representative country as it concluded in recital (70) and Section 3.3 that it is not appropriate to use domestic prices and costs in China due to the existence of significant distortions in accordance with Article 2(6a)(b) of the basic Regulation. Given that there is no evidence showing that the same distortions do not equally affect products intended for export, the Commission considered that the same distortions affected export prices of raw materials. After excluding imports from China into the representative country, the volume of imports from other third countries remained representative.

3.3.2.3.   Labour

• (88) The Turkish Statistical Institute publishes detailed information on wages in different economic sectors in Türkiye ⁶¹. The Commission established the benchmark for the investigating period based on the hourly average labour cost for the manufacturing sector ⁶² in 2020, indexed to 2023. The average hourly labour cost per FTE ⁶³ amounts to 35,02 CNY per hour.

3.3.2.4.   Electricity

• (89) The price of electricity for companies (industrial users) in Türkiye is published by the Turkish Energy Market Regulatory Authority ⁶⁴. The Commission used the data on the industrial electricity prices as published on 15 July 2024. These statistics indicate an average industrial tariff for 2023 of 1,12 CNY per kWh.

3.3.2.5.   Manufacturing overhead costs, SG&A, profits and depreciation

• (90) According to Article 2(6a)(a) of the basic Regulation, ‘the constructed normal value shall include an undistorted and reasonable amount for administrative, selling and general costs and for profits’. In addition, a value for manufacturing overhead costs needs to be established to cover costs not included in the factors of production referred to above.

• (91) To establish undistorted values for manufacturing overheads, SG & A and profit and due to the absence of cooperation from Chinese exporting producers, the Commission used facts available in accordance with Article 18 of the basic Regulation.

• (92) Using data from two Turkish producers of aluminum radiators (Sanica Isi Sanayi Anonim Sirketi and Peksa Profil Sanayi Ve Ticaret Anonim Sirketi ⁶⁵), the Commission calculated the SG & A (10,33 %) and profit (9,12 %) as a percentage of the cost of goods sold.

• (93) The Commission used the information provided by the applicant in the review request to calculate manufacturing overhead costs. These costs were determined as a percentage, dividing manufacturing overheads by the direct and indirect costs. This percentage (15,6 %) was then applied to the undistorted value of the cost of manufacturing to obtain the undistorted value of manufacturing overheads.

3.3.3.   Calculation of the normal value

• (94) On the basis of the above, the Commission constructed the normal value on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation.

• (95) First, the Commission established the undistorted manufacturing costs. In the absence of cooperation by the exporting producers, the Commission relied on the information provided by the applicant in the review request on the usage of each factor (materials and labour) for the production of aluminium radiators. The Commission multiplied the consumption ratios by the undistorted costs per unit observed in the representative country Türkiye, as described in Section 3.3.2.

• (96) Once the undistorted manufacturing costs were established, the Commission added the manufacturing overheads, SG & A and profit as noted in Section 3.3.2.5:

• — Manufacturing overheads, which accounted in total for 15,6 % of the direct costs of manufacturing,

• — SG & A and other costs, which accounted for 10,3 % of the Costs of Goods Sold (‘COGS’) of Sanica Isi Sanayi Anonim Sirketi and Peksa Profil Sanayi Ve Ticaret Anonim Sirketi, and

• — Profits, which amounted to 9,12 % of the COGS as achieved by Sanica Isi Sanayi Anonim Sirketi and Peksa Profil Sanayi Ve Ticaret Anonim Sirketi, were applied to the total undistorted costs of manufacturing.

• (97) On that basis, the Commission constructed the normal value on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation.

3.3.4.   Continuation of dumping

• (98) During the period considered and, in particular, during the review investigation period imports of aluminium radiators from China were negligible. According to Eurostat, the volume of imports of aluminium radiators from China amounted to 159 913 elements ⁶⁶ in the RIP, which equaled to a EU market share in the range of 0,5–1 %. In comparison, the market share of Chinese imports amounted to 24 % in the original investigation period and to 3 % in the previous review investigation period.

• (99) This negligible volume could not form the basis for analysing the continuation of dumping. The Commission therefore analysed the likelihood of recurrence of dumping in the next section.

3.3.5.   Likelihood of recurrence of dumping

• (100) The Commission investigated, in accordance with Article 11(2) of the basic Regulation, the likelihood of recurrence of dumping should the measures be allowed to lapse. The following elements were analysed: the export prices to third countries, the production capacity and spare capacity in China, the attractiveness of the Union market and the possible absorption capacity of third country markets in view of the anti-dumping measures in place in these countries.

3.3.5.1.   Comparison between export prices to third countries and the normal value

• (101) The Commission analysed the price pattern of Chinese exports to third countries during the review investigation period.

• (102) The Commission first analysed export data from China to third countries at eight-digit level customs code level in the Global Trade Atlas during the review investigation period. However, these export prices were not considered to accurately represent aluminium radiator prices as the classifications at that level included a wide range of products in addition to the product concerned, by far exceeding (by at least 100 times) the volume of imports of aluminium radiators. Therefore, Chinese export statistics do not provide conclusive evidence concerning Chinese export prices on other markets.

• (103) In turn, as a consequence of non-cooperation of exporting producers from China, the estimation of export prices from China to third countries was based on the information available to the Commission, that is, information supplied in the request for review, namely Chinese price quotations to importers in third countries. In particular, the applicant provided several price offers to countries in the proximity of the Union, such as Moldova, Russia and Azerbaijan, as well as quotations from online sales platforms.

• (104) The Commission adjusted the estimated export price to third countries as described in recital (103) for differences affecting prices and price comparability, in accordance with Article 2(10) of the basic Regulation. In this regard, Article 2(10) of the basic Regulation requires the Commission to make a fair comparison between the normal value and the export price at the same level of trade and to make allowances for differences in factors which affect prices and price comparability. In the case at hand, the Commission adjusted the export price to ex-works level by removing domestic transport cost ⁶⁷.

• (105) The average export price to third countries estimated as described in recital (103) was 3,68 EUR/element expressed in FOB, or 3,52 EUR/element when adjusted to ex-works level.

• (106) The resulting average export price to third countries found during the review investigation period was 34,4 % below the normal value established on the basis of the criteria indicated in sections 3.2 and 3.3 above. Therefore, it was considered likely that, if the current measures were to be repealed, the Chinese exporting producers would start selling to the Union at levels below that normal value.

• (107) After disclosure, the applicant signaled that there was a discrepancy in the ex-works export price and the resulting dumping margin between the Disclosure Document and the dumping calculation file. As the discrepancy was due to a clerical error in the dumping calculation file, the Commission corrected it.

3.3.5.2.   Production capacity and spare capacity in China

• (108) Concerning the production capacity and spare capacity in China, due to the non-cooperation of the Chinese producers, findings were based on the information provided in the expiry review request. The applicant provided evidence that the Chinese aluminium market has been expanding and will continue to expand even after 2026. Based on this information, in the full year 2022 China’s aluminium output hit a record high ⁶⁸. Moreover, in September 2023 it was reported that ‘China powers global aluminium output to record high’ ⁶⁹. Finally, an independent study requested by the applicant, ‘China Household Aluminum Radiators Industry Market Research Report’ ⁷⁰, updated in October 2023 provides significant and recent data on Chinese overcapacity.

• (109) In particular, the study estimates the capacity of Chinese aluminum radiators production at approximately 240 million elements per year in 2023, an increase of 35 million elements compared to 2021. This capacity growth exceeds the increase in production, which rose from 188 million to 217 million elements during the same period, an increase of 29 million elements.

• (110) Both the increase in production and production capacity between 2021 and 2023 were significantly higher than the increase in domestic consumption in China, which only rose from 19 million to 23 million elements, an increase of just 4 million elements.

• (111) As a consequence, spare capacity grew from 17 million to 23 million elements between 2021 and 2023, nearly matching the total Union consumption of 23-25 million elements during the RIP.

• (112) Moreover, neither the study nor the investigation brought to light any elements that could indicate any significant increase of Chinese exports to other third countries as there is no information available that would indicate any significant increase of demand for aluminium radiators worldwide.

• (113) Therefore, in the absence of any other information, the Commission considered that neither Chinese domestic demand nor worldwide demand will be able to absorb the significant spare capacity available in China.

• (114) This confirms the Commission’s conclusions from the previous expiry review ⁷¹ that Chinese producers have sufficient spare capacity to supply the Union market if the measures are allowed to lapse.

3.3.5.3.   Attractiveness of the Union market and export prices to third countries

• (115) The Union market for aluminium radiators, being 23-25 million elements in the RIP, is one of the largest markets in the world. Although the Union consumption of aluminium radiators decreased by 22 % over the period considered due to a contraction of the construction industry explained in recital (132), it still remains a strong market driven by stringent energy efficiency regulations and the renovation of old buildings in order to meet new standards and to reduce carbon emissions.

• (116) To have an indication of the likely prices to the Union in the absence of measures, the Commission analysed the export prices of aluminium radiators originating in China to other export markets outside the Union. As explained in recitals (102) and (103), since export statistics at eight digits custom code do not provide accurate values and due to non cooperation, the Commission established export prices using actual invoices and quotations by the Chinese exporting producers to third markets, as provided by the applicant (see also recital (103) above).

• (117) In the RIP, the Union industry average selling price was 8,56 EUR/element. This is 82 % higher than the average selling price of Chinese aluminium radiators (ie 4,70 EUR/element), calculated using the quotations made by Chinese exporting producers to customers in Moldova, Russia and Azerbaijan, as well as quotations from online sales platforms, that were provided in the request for review.

• (118) These export prices were considerable lower compared to the Union industry prices and therefore, the Union market, in terms of prices, remains attractive for Chinese producers.

• (119) Before the imposition of the measures in 2012, Chinese imports into the Union amounted to 10,6 million elements annually. In addition to the measures imposed on Chinese imports that are subject to this review, anti-dumping measures were imposed on imports of aluminium radiators from China by many other third countries ⁷², which makes it more difficult for the Chinese exporting producers to export to these markets and further increases the attractiveness of the Union market, where such exports may be redirected.

3.3.5.4.   Possible absorption capacity of third country markets and trade defence measures in other export markets

• (120) According to information of the WTO database ⁷³, the Commission found that anti-dumping duties and countervailing duties were applicable in 2023 on imports of Chinese aluminium radiators into Argentina and the UK ⁷⁴. These restrictions constitute an export limitation factor for Chinese producers of aluminium radiators. However, based on the request for review ⁷⁵ and the conclusions in recitals (108) and (109), Chinese producers are significantly export-oriented, as China internal consumption of aluminium radiators is estimated to be only one tenth of its total production volume.

• (121) Given the Chinese exporters’ difficulties to sell to these markets due to the measures imposed by those other third countries on imports of aluminium radiators from China, if the current measures were allowed to expire, the Union market would become even more attractive to Chinese exporters seeking to export their excess production and use spare capacity.

• (122) In their comments on the General Disclosure Document, the applicant recalled that Ukraine initiated in 2024 an anti-dumping investigation on imports of aluminium radiators from China.

3.3.5.5.   Conclusion

• (123) Based on the above, in particular given the significant spare capacity available in China and the attractiveness of Union market, the Commission expects that a repeal of measures would likely result in a recurrence of dumping, and that dumped exports will enter the Union market in significant quantities. It is therefore considered that there is a likelihood of recurrence of dumping should the current anti-dumping measures be allowed to lapse.

4. INJURY

4.1.   Definition of the Union industry and Union production

• (124) The like product was manufactured by 11 producers in the Union during the period considered. They constitute the ‘Union industry’ within the meaning of Article 4(1) of the basic Regulation.

• (125) The Commission established the Union production on the basis of all the available information concerning the Union industry, such as:

• — the reply to the macroeconomic questionnaire provided by the applicant AIRAL;

• — data supplied by the Union producer F.I.R. Fabbrica Italiana Radiatori S.r.l. (‘FIR’), which provided the data for completing the macroeconomic questionnaire directly to the Commission.

• (126) To protect the confidentiality of FIR’s data, the Commission could not disclose the exact figures obtained by combining FIR data with the data provided by Airal for other Union producers. The Commission therefore provided this information in ranges and indexes, providing sufficient information to all interested parties to understand the Commission’s analysis and conclusions and to provide comments in this regard.

• (127) The total Union production during the review investigation period was established at around [30-32] million elements. As indicated in recital (13), the sampled Union producers represented about 65 % of the total Union production of the like product.

4.2.   Union consumption

• (128) The Commission established the Union consumption on the basis of the total Union industry’s sales in the Union and the total imports from third countries to the Union.

• (129) Sales of the Union industry in the Union were obtained from the verified sales in the Union of the sampled Union producers, from data supplied by the applicant in the macroeconomic questionnaire and from data received separately by FIR.

• (130) For imports, the Commission relied on the Surveillance database ⁷⁶. As the Surveillance database provided only the weight and not the number of elements imported, it was necessary to convert the weight into elements by using a conversion factor based on the verified data of the three sampled Union producers indicated at recital (23) above.

• (131) Union consumption developed as follows:

Table 2

Union consumption

	2020	2021	2022	Review Investigation period
Total Union consumption (elements)	30 000 000 – 32 000 000	36 000 000 – 38 000 000	32 000 000 – 34 000 000	23 000 000 – 25 000 000
Index (2020 = 100)	100	118	105	78
Source: Surveillance database, AIRAL, FIR and verified questionnaire replies.	Source: Surveillance database, AIRAL, FIR and verified questionnaire replies.	Source: Surveillance database, AIRAL, FIR and verified questionnaire replies.	Source: Surveillance database, AIRAL, FIR and verified questionnaire replies.	Source: Surveillance database, AIRAL, FIR and verified questionnaire replies.

• (132) The Union consumption of aluminium radiators decreased by 22 % over the period considered. A year-to-year analysis shows an increase of 18 % from 2020 to 2021, followed by a gradual decline in consumption in the following two years.

• (133) The sharp increase in the demand of aluminium radiators from 2020 to 2021 was mainly driven by the growth experienced in residential and commercial construction activities after the launch of several economic stimulus packages to boost the economy after the COVID-19 outbreak. In Italy, for example, where the sampled Union producers are based, the so called ‘Relaunch decree’ ⁷⁷ provided incentives for the renovation of residential buildings and the improvement of the energy efficiency.

• (134) However, the demand for aluminium radiators started declining in 2022 with the onset of the energy crisis and the the rapid increase of raw material prices and interest rates. The negative trend continued in the RIP, with the consumption dropping from [36-38] million elements to [23-25] million elements, almost the same levels of 2014.

4.3.   Imports from China

4.3.1.   Volume and market share of the imports from China

• (135) The Commission established the volume of imports of aluminium radiators from China on the basis of Surveillance database, converted into elements by using as conversion factor based on the verified data of the three sampled Union producers, as stated in recital (130)). The market share of the imports was established by comparing these import volumes with the Union consumption as shown in Table 2.

• (136) Imports into the Union from China developed as follows:

Table 3

Import volume and market share

	2020	2021	2022	Review Investigation period
Volume of imports from China (elements)	407 356	297 909	276 081	159 913
Index (2020 = 100)	100	73	68	39
Market share (%)	1 –1,5	0,5 –1	0,5 –1	0,5 –1
Index (2020 = 100)	100	62	65	50
Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.

• (137) Over the period considered, imports of aluminium radiators from China were limited in quantities and steadily decreased by 61 %, reaching the lowest point in the RIP. The market share of the imports from China decreased by 38 % in 2021 and then remained stable from 2021 to the RIP due to the lower consumption.

4.3.2.   Prices of the imports from China

• (138) The Commission established the prices of imports on the basis of Surveillance database.

• (139) The average price of imports into the Union from China developed as follows:

Table 4

Average import prices

	2020	2021	2022	Review Investigation period
Import prices from China (EUR per element)	3,71	5,98	8,98	8,07
Index (2020 = 100)	100	161	242	217
Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.	Source: Surveillance database.