Commission Implementing Regulation (EU) 2025/1189 of 13 June 2025 imposing provisional anti dumping duties on imports of screws without heads originating in the People’s Republic of China

Type Implementing Regulation
Publication 2025-06-13
Last updated 2026-04-15
State In force
Department European Commission, TRADE
Source EUR-Lex
articles 4
Reform history JSON API

(238) The unit cost of production in the Union has increased significantly since 2021. It rose by 32 % from 2021 to 2022, it further rose in 2023 and slightly declined during the IP. The overall increase was by 46 % in relation to 2021. This followed the sharp increase in labour (81) and raw material pricing (82) and was due to the outbreak of the Russian war against Ukraine, which caused a large increase in inflation in the Union, supply chain disruptions, significantly increased raw material costs in the Union.

(239) The average unit sales price showed a similar trend. By 2022-2023, the rise in sales price had reached 41 %. However, during the IP the unit price dropped in comparison with the year 2023 even though it overall remained 34 % higher than 2021.

(240) The fact that the average unit sales price had an overall increase by 34 % while the unit cost of production increased by 46 % during the same period indicates that the Union industry was not able to fully absorb the rising production costs. In other words, the increasing volumes of dumped Chinese imports into the Union market prevented the Union producers to raise their prices to sustainable levels to cover the increased cost of production. This situation severely impacted the Union industry’s financial performance.

(242) Average labour cost per employee increased by + 9 % over the period considered.

(244) The level of closing stocks increased by 16 % in 2022 in relation to the year before, following the decrease in sales. By 2023 and throughout the investigation period, Union producers visibly undertook efforts to adjust stock levels in response to declining sales and production. In 2023, stock levels reverted to baseline figures, and further reductions were observed during the investigation period. Overall closing stock was reduced by 25 % during the period concerned.

(246) The Commission established the profitability of the sampled Union producers by expressing the pre-tax net profit of the sales of the like product to unrelated customers in the Union as a percentage of the turnover of those sales. The profitability was positive at the start of the priod considered in 2021 (83) and 2022. Over the period considered, the Union industry’s profitability decreased significantly, from around 1 % in 2021-2022 to – 5 % in 2023 and further to – 10 % in the IP. The fact that the Union industry had to perform with – 10 % losses in the IP can be explained by the increased competition of Chinese exports at dumped prices, which forced the Union industry to decrease its prices to lossmaking levels in a period of increasing cost of production, as explained in Section 4.5.3.1

(247) The net cash flow is the ability of the Union producers to self-finance their activities. The unsustainable profit levels of the Union industry, as explained above, were also reflected in a negative cash flow for nearly the entire period, which deteriorated further in the IP, surpassing – 2 million EUR, equivalent to approximately 15 % of the sales value during the IP.

(248) While investments in maintenance and replacement increased in the period 2021-2023, they fell dramatically during the IP, similar to other main injury indicators. Overall investments declined by one-third from the beginning to the end of the period considered.

(249) The return on investments is the profit in percentage of the net book value of investments. The Union industry's return on investment fell from 6 % in 2021 to – 27 % in the IP.

(250) Given the dramatic drop in profitability, net cash flow and return on investment, the sampled Union producers’ ability to raise capital was severely affected.

(251) All main injury indicators showed a negative trend during the period considered. The production volume of the Union industry decreased by 27 % and its sales volume decreased by 28 %. The Union industry also lost market share, which fell from 31 % in 2021 to 25 % in the IP. On the contrary, the market share of Chinese imports to the Union during the same period increased by 10 percentage points; it was 51 % in 2021 and in the IP it rose to 61 %. This was achieved despite the drop in Union consumption by 13 % during the period considered.

(252) The profitability of the Union industry declined over the period considered, decreasing from around 1 % in 2021-2022 to – 5 % in 2023 and further to – 10 % in the IP, which is clearly not sustainable. A similar decreasing trend was observed for the productivity of the Union industry (decreased by 23 %), its employment (decreased by 6 %), investments (decreased by 31 %), return on investment and cash flow, which all decreased over the period considered.

(253) The Union industry was unable to compensate for the lost sales volumes in the Union market through increased exports, as exports accounted for only approximately 8 % of the industry’s total production and were gradually declining, as set out in Section 5.4 below.

(254) On the basis of the above, the Commission concluded at this stage that the Union industry suffered material injury within the meaning of Article 3(5) of the basic Regulation.

(255) In accordance with Article 3(6) of the basic Regulation, the Commission examined whether the dumped imports from the country concerned caused material injury to the Union industry. In accordance with Article 3(7) of the basic Regulation, the Commission also examined whether other known factors could at the same time have injured the Union industry. The Commission ensured that any possible injury caused by factors other than the dumped imports from the country concerned was not attributed to the dumped imports. These factors are: the imports from countries other than China, the export performance of the Union industry, consumption decline and increase in cost.

(256) The Commission examined whether there was a casual link between the dumped imports and the injury suffered by the Union industry. During the period considered the imports of the dumped like product from China increased by 5 % despite the declining Union consumption.

(257) The reduced prices of the Chinese imports by 7 % in the period considered in combination with the significantly increased cost of production by the Union industry by 46 % in the same period, helped Chinese imports to the Union increase their market share by 21 %. This was at the expense of the Union industry, which had significant losses in sales volume by 28 % and a decrease in its market share by 18 %. At the same time the profitability of the Union industry was significantly reduced to non-sustainable levels (it operated with – 10 % losses in the IP).

(258) The fact that there was such a significant gap between the average price of the dumped imported product from China and the average price of the Union industry like product (1 213 EUR/tonne v 1 833 EUR/tonne) prevented the Union industry to increase its prices to reflect the increased cost of production and, thus, sustain its profitability.

(259) The Commission examined whether other factors of injury other than the dumped imports from China had an impact on the state of the Union industry, but did not find any other factors that could have had a substantial impact on the injurious situation of the Union industry.

(261) Imports from other third countries originated mainly from the United Kingdom, Taiwan and Turkey. Total imports volume from all third countries except China decreased by 38 %, between 2021 and the IP, going from 39 374 tonnes to around 24 410 tonnes.

(262) The market share of all third countries apart from China was reduced from 19 % in 2021 to 13 % in the IP.

(263) Overall, the average import prices of other third countries increased by 59 % during the period considered and were on average considerably higher than the prices of imports from China, which decreased by 7 % during the period considered. In the IP, the average import price of other third countries excluding China was 4 368 EUR/tonne, while the average import price from China was 1 213 EUR/tonne.

(264) On the basis of the above, the Commission concluded that imports from other third countries were not the source of the material injury suffered by the Union industry.

(266) During the period considered, the Union industry’s exports decreased by overall 20 %. This trend is similar to the negative trend of the Union producers’ sales within the Union, which dropped even more than their exports, i.e. by 28 %, during the period considered. It is also similar to the negative trend of the reduced market share of the Union producers within the Union, which dropped by 18 % during the period considered.

(267) The average export price of the Union producers also dropped by 6 % during the period considered. It should be noted that the export sales represent 9 % of the Union industry’s overall sales. Therefore the effect of reduced sales to the injury of the Union industry is found to be limited and, while it might have contributed to the injury suffered by the Union industry to a small extend considering the volumes involved, it was not capable of attenuating the causal link between the dumped imports from China and the injury suffered by the Union industry.

(268) The Union market contracted by 13 % during the period considered. The decrease was due to several interconnected factors: the European economy experienced a slower growth in 2023 in comparison to the year before (the Union GDP grew by 0,4 % in 2023 v 3,5 % in 2022), with apparent steel consumption shrinking by 6,3 % (84). This downturn affected various sectors, including construction and manufacturing, which are major consumers of industrial products like screws. High energy prices and uncertainty in the energy market also contributed to reduced industrial output and weakened demand across sectors (85). Under normal conditions of competition, in such a shrinking market, sales volumes of all the market participants would have gone down more or less equally. However, in the present case, China gained an additional 10 percentage point market share of the Union market during the period considered to the detriment of the Union industry and the other importing countries (which equally lost 5,4 percentage points of market share). Therefore, the economic contraction of the Union market was not found to cause material injury to the Union industry in this case.

(269) As outlined in recital (238) above, the unit cost of production within the Union increased substantially (by 46 %) over the period considered. Nevertheless, in 2022, Union producers were able to raise their sales prices in response to the rising production costs, enabling them to partially offset these increases and achieve a degree of profitability. However, during the investigation period, despite a slight decrease in the cost of production, the profitability of Union producers declined sharply, reaching significantly negative levels. This deterioration clearly demonstrates the material injury sustained by the Union industry. The presence of dumped imports should not prevent the Union producers from adjusting their prices to reflect increased production costs. In circumstances where Union producers' prices were severely suppressed by the growing volume of dumped imports, while production costs remained elevated, the resulting collapse in profitability cannot be attributed to internal inefficiencies or market mismanagement. Rather, it is a direct consequence of the injurious effects of dumped imports.

(270) The injury analysis showed that the Chinese imports suppressed the Union market price during the period considered. The significant increase of the dumped imports from China and the price suppression, as explained in recital (219), they exerted during the second half of the IP affected the Union industry’s ability to pass on the higher cost of production to the users. This coincided in time with the deterioration of the Union industry’s financial performance indicators, like a decrease in profitability, resulting in losses in 2023-IP. The gain of 10 percentage points in market share of the Chinese imports was at the expense of the Union industry, which lost sales volume and market share (by 6 percentage points), especially notable in the second half of the period considered. Therefore, we concluded that the material injury was caused by the dumped imports from China.

(271) The Commission distinguished and separated the effects of all known factors on the situation of the Union industry from the injurious effects of the dumped imports. While the export performarce of the Union industry might have contributed to the material injury suffered by the Union industry to a small extend, it did not attenuate the causal link between the dumped imports and the material injury found.

(272) Regarding the effects of imports from other third countries, the Commission concluded that those imports did not cause injury to the Union industry. Similar to the Union industry the imports from third countries other than China also lost market share during the period considered and their cumulative import volumes significantly decreased (by 38 %). Moreover, the average import prices from other third countries increased by 59 % during the period considered. Hence, imports from other third countries did not attenuate the causal link between the imports from China and the injury suffered by the Union industry.

(273) Regarding the effects of export performance of the Union industry, even though the trend was negative with reduced sales, it should be noted that the export sales represent a small part of the Union overall sales. This means that the effect to the injury of the Union industry was found to be limited.

(274) With respect to the consumption decline and the increase in cost of production, it is undisputable that the Union industry was faced with challenges over the period considered. In the absence of price pressure from dumped imports, the industry would have been able to adjust prices to reflect higher costs and better respond to shifting market conditions. As previously noted, dumped imports should not hinder Union producers from passing on cost increases. Therefore, despite the impact of the increase in cost and reduced demand, consumption decline and increase in cost of production were found not to have caused material injury to the Union industry.

(275) On the basis of the above, the Commission concluded at this stage that the dumped imports from the country concerned caused material injury to the Union industry and that the other factor (the export performance of the Union industry) did not attenuate the causal link between the dumped imports and the material injury. The injury consists of reduced market share, production, production capacity utilisation, productivity, profitability, closing stocks, cash flow and return on investments. Furthermore, as explained above in recital (219), the Union industry suffered price supression caused by imports from China.

(276) To determine the level of the measures, the Commission examined whether a duty lower than the margin of dumping would be sufficient to remove the injury caused by dumped imports to the Union industry.

(277) The injury would be removed if the Union Industry were able to obtain a target profit by selling at a target price in the sense of Articles 7(2c) and 7(2d) of the basic regulation.

(278) In accordance with Article 7(2c) of the basic Regulation, for establishing the target profit, the Commission took into account the following factors: the level of profitability before the increase of imports from the country under investigation, the level of profitability needed to cover full costs and investments, research and development (R&D) and innovation, and the level of profitability to be expected under normal conditions of competition. Such profit margin should not be lower than 6 %.

(279) The Commission could not established a basic profit covering full costs under normal conditions of competition before increase of imports from China, since Chinese imports accounted for over 50 % of market share during the whole period considered, while market shares before the start of the period considered could not be calculated due to insufficient data. The Commission, thus, established the target profit to determine the non-injurious price at 6 %, in accordance with Article 7(2c) of the basic Regulation

(280) No claims were made that the Union industry’s level of investments, R&D and innovation during the period considered would have been higher under normal conditions of competition.

(281) Likewise, no claims were made concerning the future costs resulting from Multilateral Environmental Agreements, and protocols thereunder, to which the Union is a party and that the Union industry will incur during the period of the application of the measure pursuant to Article 11(2), in accordance with Article 7(2d) of the basic Regulation.

(282) On this basis, the Commission calculated a non-injurious price for the like product of the Union industry by applying the above-mentioned 6 % target profit margin to the cost of production of the sampled Union producers during the investigation period and then adding the adjustments under Article 7(2d) on a type-by-type basis.

(283) The Commission then determined the injury margin level on the basis of a comparison of the weighted average import price of the sampled cooperating exporting producers in country concerned, as established for the price undercutting calculations, with the weighted average non-injurious price of the like product sold by the sampled Union producers on the Union market during the investigation period. Any difference resulting from this comparison was expressed as a percentage of the weighted average import CIF value.

(286) Having decided to apply Article 7(2) of the basic Regulation, the Commission examined whether it could clearly conclude that it was not in the Union interest to adopt measures in this case, despite the determination of injurious dumping, in accordance with Article 21 of the basic Regulation. The determination of the Union interest was based on an appreciation of all the various interests involved, including those of the Union industry, importers, wholesalers, retailers, users, consumers.

(287) According to information available to the Commission, there were fourty-two known producers of screws without heads in the Union during the period considered. The complaint was submitted by the European Industrial Fasteners Institute (‘EIFI’), on behalf of eight Union producers, all of which were SMEs, and supported by another seven Union producers.

(288) The imposition of measures will improve the market conditions for Union producers, thereby allowing them to enhance their competitive position in the market, regain lost sales volume and market share, increase capacity utilisation, and raise their prices to sustainable levels. This, in turn, would assist them in improving their profitability to the levels that are anticipated under normal competition conditions.

(289) The absence of measures would have significant negative effects for the Union industry, as the latter would continue to endure economic injury due to sustained price pressure from dumped Chinese imports. Market share losses would accelerate, leading to further declines in sales and production. As a result, capacity utilisation, already at an unsustainable 15 % during the investigation period, will continue to drop, making operations increasingly unviable. The already loss-making situation would be further exacerbated, with severe consequences for investments and employment in the Union. The Commission therefore concluded that the imposition of provisional measures is in the interest of the Union industry.

(290) Twenty-six importers came forward following the initiation of the investigation. Three were selected for sampling, and of those two submitted questionnaire responses. The cooperating importers that responded to the sampling exercise imported over 90 % of their total imports of screws without heads from China. Among the sampled cooperating importers, Chinese imports accounted for more than 80 % of their total imports of the product concerned. The sampled importers were found to be profitable, and the turnover generated from the product concerned represented only 0,5 % to 2,5 % of their total business turnover.

(291) Given the limited share of the product in their overall business activities, the imposition of anti-dumping measures is unlikely to have a material impact on the financial stability of importers. Furthermore, importers can mitigate potential cost increases by diversifying their sourcing strategies, including exploring alternative suppliers within the Union or other third countries. The data suggested that any potential impact on importers would be minimal.

(292) In the absence of cooperation of users the Commission was not able to assess the actual impact of the anti-dumping duties for users. However, taking into account the existence of alternative suppliers in other third countries, together with the large production capacities of the Union industry, the Commission considered that the users could continue to source screws from multiple sources of adequate quality and quantity. The Commission thus considered that in case the anti-dumping measures are imposed, the impact on the users was limited.

(293) On the basis of the above, the Commission concluded that there were no compelling reasons that it was not in the Union interest to impose measures on imports of screws originating in China at this stage of the investigation.

(294) On the basis of the conclusions reached by the Commission on dumping, injury, causation, level of measures and Union interest, provisional measures should be imposed to prevent further injury being caused to the Union industry by the dumped imports.

(295) Provisional anti-dumping measures should be imposed on imports of product originating in countryies concerned, in accordance with the lesser duty rule in Article 7(2) of the basic Regulation. The Commission compared the injury margins and the dumping margins in recital (284) above. The amount of the duties was set at the level of dumping margins for all the exporting producers, which was found to be the lower of the dumping and the injury margins.

(297) The individual company anti-dumping duty rates specified in this Regulation were established on the basis of the findings of this investigation. Therefore, they reflect the situation found during this investigation with respect to these companies. These duty rates are exclusively applicable to imports of the product concerned originating in China and produced by the named legal entities. Imports of the product concerned produced by any other company not specifically mentioned in the operative part of this Regulation, including entities related to that those specifically mentioned, should be subject to the duty rate applicable to ‘all other imports originating in country concerned’. They should not be subject to any of the individual anti-dumping duty rates.

(298) To minimise the risks of circumvention due to the difference in duty rates, special measures are needed to ensure the application of the individual anti-dumping duties. The application of individual anti-dumping duties is only applicable upon presentation of a valid commercial invoice to the customs authorities of the Member States. The invoice must conform to the requirements set out in Article 1(3) of this Regulation. Until such invoice is presented, imports should be subject to the anti-dumping duty applicable to ‘all other imports originating in country concerned’.

(299) While presentation of this invoice is necessary for the customs authorities of the Member States to apply the individual rates of anti-dumping duty to imports, it is not the only element to be taken into account by the customs authorities. Indeed, even if presented with an invoice meeting all the requirements set out in Article 1(3) of this Regulation, the customs authorities of Member States must carry out their usual checks and may, like in all other cases, require additional documents (shipping documents, etc.) for the purpose of verifying the accuracy of the particulars contained in the declaration and ensure that the subsequent application of the lower rate of duty is justified, in compliance with customs law.

(300) Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume after the imposition of the measures concerned, such an increase in volume could be considered as constituting in itself a change in the pattern of trade due to the imposition of measures within the meaning of Article 13(1) of the basic Regulation. In such circumstances and provided the conditions are met an anti-circumvention investigation may be initiated. This investigation may, inter alia, examine the need for the removal of individual duty rate(s) and the consequent imposition of a country-wide duty.

(301) As mentioned in recital (3), the Commission made imports of the product concerned subject to registration. Registration took place with a view to possibly collecting duties retroactively under Article 10(4) of the basic Regulation.

(302) In view of the findings at provisional stage, the registration of imports should be discontinued.

(303) No decision on a possible retroactive application of anti-dumping measures has been taken at this stage of the proceeding.

(304) In accordance with Article 19a of the basic Regulation, the Commission informed interested parties about the planned imposition of provisional duties. This information was also made available to the general public via DG TRADE’s website. Interested parties were given three working days to provide comments on the accuracy of the calculations specifically disclosed to them.

(305) No comments on the accuracy of the calculations were received.

(306) In the interests of sound administration, the Commission will invite the interested parties to submit written comments and/or to request a hearing with the Commission and/or the Hearing Officer in trade proceedings within a fixed deadline.

(307) The findings concerning the imposition of provisional duties are provisional and may be amended at the definitive stage of the investigation,

HAS ADOPTED THIS REGULATION:

Article 1

1.

A provisional anti-dumping duty is imposed on imports of screws and bolts, whether or not with their nuts and washers, without heads, of iron or steel other than stainless steel, regardless of tensile strength, excluding coach screws and other wood screws, screw hooks and screw rings, self-tapping screws, and screws and bolts for fixing railway track construction material, currently falling under CN codes 7318 15 42 and 7318 15 48 and originating in the People’s Republic of China.

2.

The rates of the provisional anti-dumping duty applicable to the net, free-at-Union-frontier price, before duty, of the product described in paragraph 1 and produced by the companies listed below shall be as follows:

3.

The application of the individual duty rates specified for the companies mentioned in paragraph 2 shall be conditional upon presentation to the Member States’ customs authorities of a valid commercial invoice, on which shall appear a declaration dated and signed by an official of the entity issuing such invoice, identified by his/her name and function, drafted as follows: ‘I, the undersigned, certify that the (volume in unit we are using) of (product concerned) sold for export to the European Union covered by this invoice was manufactured by (company name and address) (TARIC additional code) in country concerned. I declare that the information provided in this invoice is complete and correct.’ Until such invoice is presented, the duty applicable to all other imports originating in country concerned shall apply.

4.

The release for free circulation in the Union of the product referred to in paragraph 1 shall be subject to the provision of a security deposit equivalent to the amount of the provisional duty.

5.

Unless otherwise specified, the provisions in force concerning customs duties shall apply.

Article 2

1.

Interested parties shall submit their written comments on this regulation to the Commission within 15 calendar days of the date of entry into force of this Regulation.

2.

Interested parties wishing to request a hearing with the Commission shall do so within 5 calendar days of the date of entry into force of this Regulation.

3.

Interested parties wishing to request a hearing with the Hearing Officer in trade proceedings are invited to do so within 5 calendar days of the date of entry into force of this Regulation. The Hearing Officer may examine requests submitted outside this time limit and may decide whether to accept to such requests if appropriate.

Article 3

1.

Customs authorities are hereby directed to discontinue the registration of imports established in accordance with Article 1(1) of Implementing Regulation (EU) 2025/141.

2.

Data collected regarding products which entered the EU for consumption not more than 90 days prior to the date of the entry into force of this Regulation shall be kept until the entry into force of possible definitive measures, or the termination of this proceeding.

Article 4

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 13 June 2025.

For the Commission The President Ursula VON DER LEYEN

(1) OJ L 176, 30.6.2016, p. 21, ELI: http://data.europa.eu/eli/reg/2016/1036/oj.

(2) OJ C, C/2024/6209, 17.10.2024, ELI: http://data.europa.eu/eli/C/2024/6209/oj.

(3) OJ L, 2025/141, 30.1.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/141/oj.

(4) https://tron.trade.ec.europa.eu/investigations/case-view?caseId=2754.

(5) E.g. O.M.CI. Citterio srl is specialising in double threaded screws, which are commonly known as hanger bolts (https://www.omcicitterio.it/eng/home.php).

(6) Commission Implementing Regulation (EU) 2024/1666 of 6 June 2024 imposing a definitive anti-dumping duty on imports of steel ropes and cables originating in the People’s Republic of China as extended to imports of steel ropes and cables consigned from Morocco and the Republic of Korea, whether declared as originating in these countries or not, following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L, 2024/1666, 7.6.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/1666/oj); Commission Implementing Regulation (EU) 2023/1444 of 11 July 2023 imposing a provisional anti-dumping duty on imports of steel bulb flats originating in the People’s Republic of China and Türkiye (OJ L 177, 12.7.2023, p. 63, ELI: http://data.europa.eu/eli/reg_impl/2023/1444/oj); Commission Implementing Regulation (EU) 2023/100 of 11 January 2023 imposing a provisional anti-dumping duty on imports of stainless steel refillable kegs originating in the People’s Republic of China (OJ L 10, 12.1.2023, p. 36, ELI: http://data.europa.eu/eli/reg_impl/2023/100/oj); Commission Implementing Regulation (EU) 2022/2068 of 26 October 2022 imposing a definitive anti-dumping duty on imports of certain cold-rolled flat steel products originating in the People’s Republic of China and the Russian Federation following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 277, 27.10.2022, p. 149, ELI: http://data.europa.eu/eli/reg_impl/2022/2068/oj); Commission Implementing Regulation (EU) 2022/191 of 16 February 2022 imposing a definitive anti-dumping duty on imports of certain iron or steel fasteners originating in the People’s Republic of China (OJ L 36, 17.2.2022, p. 1, ELI: http://data.europa.eu/eli/reg_impl/2022/191/oj).

(7) See Implementing Regulation (EU) 2024/1666, recital 76; Implementing Regulation (EU) 2023/1444, recital 66; Implementing Regulation (EU) 2023/100, recital 58; Implementing Regulation (EU) 2022/2068, recital 80; Implementing Regulation (EU) 2022/191, recital 208.

(8) See Implementing Regulation (EU) 2024/1666, recital 60; Implementing Regulation (EU) 2023/1444 recital 45; Implementing Regulation (EU) 2023/100, recital 38; Implementing Regulation (EU) 2022/2068, recital 64; Implementing Regulation (EU) 2022/191, recital 192.

(9) See Implementing Regulation (EU) 2024/1666, recitals 66-68; Implementing Regulation (EU) 2023/1444 recital 58; Implementing Regulation (EU) 2023/100, recital 40; Implementing Regulation (EU) 2022/2068, recital 66; Implementing Regulation (EU) 2022/191, recitals 193-194. While the right to appoint and to remove key management personnel in SOEs by the relevant State authorities, as provided for in the Chinese legislation, can be considered to reflect the corresponding ownership rights, CCP cells in enterprises, state owned and private alike, represent another important channel through which the State can interfere with business decisions. According to the PRC’s company law, a CCP organisation is to be established in every company (with at least three CCP members as specified in the CCP Constitution) and the company shall provide the necessary conditions for the activities of the party organisation. In the past, this requirement appears not to have always been followed or strictly enforced. However, since at least 2016 the CCP has reinforced its claims to control business decisions in SOEs as a matter of political principle. The CCP is also reported to exercise pressure on private companies to put ‘patriotism’ first and to follow party discipline. In 2017, it was reported that party cells existed in 70 % of some 1,86 million privately owned companies, with growing pressure for the CCP organisations to have a final say over the business decisions within their respective companies. These rules are of general application throughout the Chinese economy, across all sectors, including to the producers of the product under review and the suppliers of their inputs.

(10) See Implementing Regulation (EU) 2024/1666 recitals 61-65; Implementing Regulation (EU) 2023/1444, recital 59; Implementing Regulation (EU) 2023/100, recital 43; Implementing Regulation (EU) 2022/2068, recital 68; Implementing Regulation (EU) 2022/191, recitals 195-201.

(11) See Implementing Regulation (EU) 2023/1444 recital 62; Implementing Regulation (EU) 2023/100 recital 52; Implementing Regulation (EU) 2022/2068 recital 74; Implementing Regulation (EU) 2022/191, recital 202.

(12) See Implementing Regulation (EU) 2024/1666, recital 72; Implementing Regulation (EU) 2023/1444, recital 45; Implementing Regulation (EU) 2023/100, recital 33; Implementing Regulation (EU) 2022/2068, recital 75; Implementing Regulation (EU) 2022/191, recital 203.

(13) See Implementing Regulation (EU) 2024/1666, recital 73; Implementing Regulation (EU) 2023/1444 recital 64; Implementing Regulation (EU) 2023/100, recital 54; Implementing Regulation (EU) 2022/2068, recital 76; Implementing Regulation (EU) 2022/191, recital 204.

(14) Commission staff working document SWD (2024) 91, 10 April 2024, available at: https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2024)91&lang=en.

(15) Implementing Regulation (EU) 2022/191.

(16) Implementing Regulation (EU) 2022/191, recital 194.

(17) See: https://cn.linkedin.com/company/zhejiang-minmetals-huijin-imp.-&-exp.-co.-ltd (accessed 20 March 2025) as well as Zhejiang International Trade Group’s audit report and financial statements 2021-2023, page 1 of the notes to the financial statements https://www.shclearing.cn/xxpl/cwbg/nb/202410/t20241031_1501107.html (accessed 20 March 2025).

(18) Implementing Regulation (EU) 2022/191, recital 192.

(19) See: http://wap.sasac.gov.cn/n2588045/n27271785/n27271792/c14159097/content.html (accessed on 17 March 2025).

(20) See: http://wap.sasac.gov.cn/n2588045/n27271785/n27271792/c14159097/content.html (accessed on 17 March 2025).

(21) See: https://www.baoganggf.com/gsjj (accessed on 17 March 2025).

(22) See: https://www.shougang.com.cn/en/ehtml/CompanyProfile.html (accessed on 17 March 2025).

(23) See: https://www.shougang.com.cn/sgweb/html/index.html (accessed on 17 March 2025).

(24) See: https://www.gov.cn/zhengce/zhengceku/2022-02/08/content_5672513.htm (accessed on 17 March 2025).

(25) Ibid.

(26) See Section IV, Subsection 3 of the 14th FYP on Developing the Raw Materials Industry.

(27) See: https://www.miit.gov.cn/zwgk/zcwj/wjfb/tz/art/2023/art_2a4233d696984ab59610e7498e333920.html (accessed on 17 March 2025).

(28) See the Hebei Province’s Three Year Action Plan on Cluster Development in the Steel Industry Chain, Chapter II, Section 3.8; available at: https://huanbao.bjx.com.cn/news/20200717/1089773.shtml (accessed on 17 March 2025).

(29) Ibid, Chapter I, Section 2.

(30) Ibid, Chapter I, Section 3.2.

(31) See the Henan Implementation Plan for the Transformation and Upgrade of the Steel Industry during the 14th FYP, Chapter II, Section 3; available at: https://huanbao.bjx.com.cn/news/20211210/1192881.shtml (accessed on 17 March 2025).

(32) Jiangsu Province’s Work Plan Steel Sector Transformation and Upgrade and Layout Optimisation 2019-2025; available at: http://www.jiangsu.gov.cn/art/2019/5/5/art_46144_8322422.html (accessed on 17 March 2025).

(33) Shandong Province’s 14th FYP on the Steel Industry Development; available at: https://m.mysteel.com/21/1119/11/DFD9D26D73D90F7D_abc.html (accessed on 17 March 2025).

(34) Shanxi Province’s 2020 Steel Industry Transformation and Upgrade Action Plan; available at: https://m.mysteel.com/20/0715/11/7BF7729C99CEB3EA_abc.html (accessed on 17 March 2025).

(35) Zhejiang Province’s Action Plan to Foster a High Quality Development of the Steel Industry: ‘Foster enterprise mergers and reorganisation, accelerate the concentration process, reduce the number of steel smelting enterprises to approximately 10 enterprises’; available at: https://www.jiaxing.gov.cn/art/2022/4/20/art_1228922756_59529426.html (accessed on 17 March 2025).

(36) See: http://www.ansteel.cn/dangdejianshe/dangjiandongtai/2023-03-17/12429.html (accessed on 17 March 2025).

(37) See: https://www.zibchina.com/news/newsinfo.html?id=695278 (accessed on 20 March 2025).

(38) http://www.fastener-cn.net/reception/association/constitution.js (accessed on 17 March 2025).

(39) See Baoshan Iron and Steel Ltd.’s 2023 Annual Report, page 41 https://static.sse.com.cn/disclosure/listedinfo/announcement/c/new/2024-04-27/600019_20240427_B5D4.pdf (accessed on 7 February 2025).

(40) See: https://www.wuganggroup.cn/people/3143 (accessed on 17 March 2025).

(41) See: https://mp.weixin.qq.com/s?__biz=MjM5Njg2NjIwMQ==&mid=2654952836&idx=1&sn=505b807e2826f1e3e6f08ba15b727722&chksm=bd294c728a5ec5641240246649545fda2b2065c015f861fa599249b2165962ca848a25a1faa2&token=1369557425&lang=zh_CN#rd (accessed on 17 March 2025).

(42) See: https://www.baoganggf.com/ggry (accessed on 17 March 2025).

(43) See: https://www.shougang.com.cn/sgweb/html/gsld.html (accessed on 17 March 2025).

(44) See: https://www.afastener.com/association/detail-18.html (accessed on 13 May 2025).

(45) See: https://www.afastener.com/association/detail-17.html (accessed on 13 May 2025).

(46) See: http://www.cncma.org/article/472 (accessed on 17 March 2025).

(47) See https//www.miit.gov.cn/cms_files/filemanager/oldfile/miit/n5084605/c7592204/part/752209.pdf, page 55 listing strength fasteners.

(48) See http://www.gov.cn/xinwen/2019-11/06/5449193/files/26c9d25f713f4ed5b8dc51ae40ef37af.pdf, page 29.

(49) http://www.haiyan.gov.cn/art/2019/12/6/art_1512856_40973400.html.

(50) Report, Part III, Chapter 14, p. 346 ff.

(51) See the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, Part III, Article VIII, available at: https://cset.georgetown.edu/publication/china-14th-five-year-plan/ (accessed on 17 March 2025).

(52) See in particular Sections I and II of the 14th FYP on Developing the Raw Materials Industry.

(53) See: https://www.miit.gov.cn/zwgk/zcwj/wjfb/tz/art/2023/art_2a4233d696984ab59610e7498e333920.html (accessed on 17 March 2025).

(54) See: at : http://gxt.shandong.gov.cn/module/download/downfile.jsp?classid=0&filename=1f79d908601e479f83707e67b133e347.pdf (accessed on 17 March 2025).

(55) http://www.haiyan.gov.cn/art/2019/12/6/art_1512856_40973400.html.

(56) See Implementing Regulation (EU) 2023/1444, recital 63; Implementing Regulation (EU) 2023/100, recital 33.

(57) DS473: European Union – Anti-Dumping measures on Biodiesel from Argentina.

(58) World Bank Open Data – Upper Middle Income (https://data.worldbank.org/income-level/upper-middle-income).

(59) Regulation (EU) 2015/755 of the European Parliament and of the Council of 29 April 2015 on common rules for imports from certain third countries (OJ L 123, 19.5.2015, p. 33, ELI: http://data.europa.eu/eli/reg/2015/755/oj), as amended by Delegated Regulation (EU) 2017/749 (OJ L 113, 29.4.2017, p. 11, ELI: http://data.europa.eu/eli/reg_del/2017/749/oj).

(60) Sanwa Iron (Thailand) Company Ltd., Thai Meira Co. Ltd., S.J. Screw Thai Company Ltd.

(61) https://tong.com.my/wp-content/uploads/2025/BURSA/TH-B-250225-1-2.pdf (last consulted 24 April 2025).

(62) https://www.chinwell.com.my/screws/ (last consulted 24 April 2025).

(63) Sanwa Iron (Thailand) Company Ltd., Thai Meira Co. Ltd.

(64) https://app.bot.or.th/BTWS_STAT/statistics/BOTWEBSTAT.aspx?reportID=636&language=ENG (last consulted 3 April 2025).

(65) BOI : The Board of Investment of Thailand (last consulted 3 April 2025).

(66) https://www.eppo.go.th/index.php/en/en-energystatistics/energy-economy-static (last consulted 3 April 2025).

(67) Company-specific and based on respective peak & off-peak consumption, demand and service charge as set out in recitals (161) and (162).

(68) Article 2(7) of the basic Regulation considers that domestic prices in those countries cannot be used for the purpose of determining normal value.

(69) https://app.bot.or.th/BTWS_STAT/statistics/BOTWEBSTAT.aspx?reportID=636&language=ENG (last consulted 3 April 2025).

(70) https://www.papayaglobal.com/countrypedia/country/thailand/ (last consulted 3 April 2025).

(71) ILO, Labor Force Statistics database, ‘Mean weekly hours actually worked per employed person by sex and economic activity – Annual’, Thailand. https://rshiny.ilo.org/dataexplorer35/?lang=en&segment=indicator&id=HOW_TEMP_SEX_ECO_NB_A&ref_area=THA (last consulted 3 April 2025).

(72) ○ BOI : The Board of Investment of Thailand (last consulted 3 April 2025).

(73) https://www.mea.or.th/en/our-services/tariff-calculation/latestft (last consulted 3 April 2025).

(74) Ministry of Energy – Energy policy and planning office (Table 7.2.4) https://www.eppo.go.th/index.php/en/en-energystatistics/energy-economy-static (last consulted 3 April 2025).

(75) Sinopec Chongqing SVW Chemical and Others v Commission.

(76) Case C-319/24 P, Commission v Sinopec Chongqing SVW Chemical and others, pending.

(77) Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 183.

(78) Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 185.

(79) Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para 188.

(80) Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 184.

(81) Labour representing on average 16 % of the cost of production over the period considered.

(82) Raw materials representing on average 48 % of the cost of production over the period considered.

(83) As long as the selling price per tonne was higher than the variable cost per tonne, while fixed cost covered, each additional sale brought in some profit (a positive contribution margin). Since Union producers sold a high volume that year, it helped them to gain some profit even though the average production cost per tonne was higher.

(84) https://www.eurofer.eu/press-releases/persisting-downside-factors-deepen-downturn-in-2023-and-curb-steel-demand-rebound-in-2024.

(85) https://orgalim.eu/wp-content/uploads/orgalim-economics-and-statistics-report-autumn-2024-2.pdf.

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