Commission Implementing Regulation (EU) 2025/1505 of 25 July 2025 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of epoxy resins originating in the People’s Republic of China, Taiwan, and Thailand and terminating the investigation on imports of epoxy resins originating in the Republic of Korea

• (140) First, as set out in recital 43 of the provisional Regulation, the Commission, in accordance with its standard practice selected a period of three full years as well as the investigation period for examination of the macro- and microeconomic trends and indicators. Second, the injury assessment involves a dynamic assessment of the economic factors over the period considered and not merely the conditions at the start and the end of the period considered. Third, regardless of the first year of the period considered, the Commission analysis clearly showed material injury to the Union industry during the investigation period. Therefore, a change of the period considered would not invalidate or otherwise alter the injury findings set out in this Regulation.

4.4.2.   Macroeconomic indicators

• (141) In the absence of comments on macroeconomic indicators, the conclusions set out in recitals 282 to 296 of the provisional Regulation were confirmed.

4.4.3.   Microeconomic indicators

• (142) In response to the provisional disclosure, Nan Ya claimed that the Commission cannot disregard the fact that the Union industry was loss-making even in 2020, when the volume of imports from concerned countries was very low. Nan Ya further argued that the profitability trends of the Union industry, in particular from 2022 onwards were linked to the increased cost of production incurred by the Union producers, and their ability (or lack thereof) to pass on those costs to consumers due to the very nature of the market.

• (143) First, as set out in recital 306 of the provisional Regulation, the lossmaking situation at the Union producers in 2020 was driven by the initial market response to the COVID-19 pandemic and it was only post-2022 when the injurious effects of the increased volumes of dumped imports were felt. As further outlined in recital 321 of the provisional Regulation, the pressure from increasing import volumes at dumped prices significantly below the production cost of the Union producers in 2023 and in the investigation period became unsustainable for the Union industry. It was due to this unfair competition from dumped imports that the Union industry became unable to increase its sales prices to pass on to customers the increasing cost of raw materials. To mitigate losses in production volumes and market share, the Union producers were subsequently forced to reduce prices at the expense of their profitability. Nan Ya’s claim is therefore rejected.

• (144) In the absence of further comments on microeconomic indicators, the conclusions set out in recitals 297 to 310 of the provisional Regulation were confirmed.

4.5.   Conclusion on injury

• (145) In view of the above, the Commission confirms its findings in recitals 311 to 317 of the provisional Regulation.

5. CAUSATION

5.1.   Effects of the dumped imports

• (146) Following the final disclosure ERC submitted that the Commission failed to establish a coherent timeline linking dumped imports to the alleged injury. According to ERC, the steepest import surge occurred in 2020-2022, when Union profitability peaked, whereas the downturn in 2022-IP coincided with exceptional energy and raw-material cost inflation.

• (147) As noted in the provisional Regulation (in particular recitals 321, 326 and 348), the cumulated imports from the countries concerned were steadily and at a significant rate increasing (see Table 3 of the provisional Regulation) every single year of the period considered (hence not only between 2020-2022), while the market share of the Union producers was dropping and total imports from other countries were stable. Although in 2021-2022 the Union producers managed to achieve healthy profits despite the unfair competition thanks to a surge in demand for epoxy-containing products, the injurious effects of dumped imports became apparent in 2023 and in the investigation period when the imports from the countries concerned kept increasing their market share in a shrinking Union market. The claim was therefore rejected.

• (148) In the absence of any further comments on the effects of the dumped imports, recitals 319 to 328 of the provisional Regulation are confirmed.

5.2.   Imports from third countries

• (149) Following the provisional disclosure as well as in its response to the final disclosure, ERC submitted that, inconsistent with Article 3(7) of the basic Regulation, the effects of imports from Korea on the Union industry were not isolated and properly assessed. According to ERC the Commission has not provided a convincing explanation as to why these imports should not be considered a significant contributing factor to the injury.

• (150) First, the effects of imports from other third countries and notably from Korea have been duly and separately assessed in recital 332 of the provisional Regulation. Furthermore, and contrary to the ERC’s claim, the Commission did conclude that imports from Korea contributed to the material injury of the Union industry. However, such contribution was not such as to attenuate the causal link between the injury suffered by the Union industry and the dumped imports from the countries concerned for the reasons already indicated in recitals 334 and 356 of the provisional Regulation.

• (151) Further to the final disclosure, ERC also claimed that Korea should have been included in the Commission’s cumulative analysis and that the selective cumulation, excluding Korean imports, distorts the macroeconomic picture. The Commission noted with reference to Article 3(4) of the basic Regulation as well as the Section 4.3.1 of the provisional Regulation that the effects of Korean imports could not have been cumulatively assessed as no dumping margin was found for Korea. Hence, ERC’s claim was dismissed. Ina any event, the potential injurious effect of imports from Korea was analysed in section 5.2.1 and in particular in recital 332 of the provisional Regulation.

• (152) In a similar vein, Nan Ya argued in response to the provisional disclosure that the Commission’s conclusion that Union imports from Korea did not attenuate the causal link between the dumped imports from Taiwan and the injury is inadequate, and Nan Ya requested the Commission to revisit its determination. Nan Ya claimed that Korea accounted for a large proportion of all imports during the period considered, while Union imports from Taiwan remained of a very limited importance throughout (and decreased during most of) the period considered, and Taiwan maintained an insignificant market share compared to the Union industry and Korea.

• (153) As set out in Section 4.3.1 of the provisional Regulation, Taiwanese imports are assessed cumulatively with imports from China and Thailand for the purposes of this case. The countries concerned increased their share on total Union imports from less than 11 % to over 35 %, while Korean imports as a proportion of total imports decreased over the period considered by 2 percentage points. Even when considering the evolution of Taiwanese imports individually, they increased by 73 % over the period considered. Therefore, as outlined in recital 332 of the provisional Regulation, given the volumes and prices of the dumped imports from the countries concerned and their development throughout the period considered, it could not be concluded that imports from Korea were capable of attenuating the causal link between the dumped imports from countries concerned and the material injury they caused to the Union industry. Hence, Nan Ya’s claim has to be dismissed.

• (154) In the absence of any further comments, recitals 329 to 334 of the provisional Regulation are confirmed.

5.3.   Export performance of the Union industry

• (155) ERC submitted following the provisional disclosure that the Union industry’s inability to maintain export volumes and prices was a key factor contributing to its overall deteriorating financial situation. This decline in export performance cannot be ignored or downplayed in the causality assessment, according to ERC.

• (156) The export performance was duly evaluated by the Commission. As outlined in section 5.2.2 and recital 357 of the provisional Regulation, the Commission did not ignore or downplay the export performance in its assessment. Indeed, it concluded that the export performance contributed to the adverse situation at the Union producers, but not in such a magnitude to attenuate the causal link between the imports from countries concerned and the injury suffered by the Union industry. ERC’s claim is therefore dismissed.

• (157) In the absence of any further comments, recitals 335 to 340 of the provisional Regulation are confirmed.

5.4.   Effects of other factors

• (158) Following the provisional disclosure, ERC restated that the deterioration in performance began in 2022, coinciding with rising energy prices and raw material costs, rather than increased imports. ERC also noted that the Union producers’ decision to reduce production volumes and capacity utilisation was inconsistent with normal competitive responses expected in a commodity market. According to ERC, the Commission should have verified whether this sharp reduction in production was not a result of deliberate strategic decisions taken in anticipation of this anti-dumping proceeding.

• (159) In its comments on following the definitive disclosure, ERC claimed that the Commission did not demonstrate with positive evidence that the dumped imports were the main cause of the Union industry’s injury and not the sharp increase in the cost of energy and certain raw materials.

• (160) In fact, the Commission analysed the effect of the increased cost of production and the spike in energy costs in recitals 341, 342 and 358 of the provisional Regulation and concluded that in absence of the price pressure from the dumped imports, the Union industry would have been able to pass on the cost increases and adequately respond to the changing market conditions.

• (161) Nan Ya also argued following the provisional disclosure that the cost of production remained exceptionally high during the period considered, which explained why the Union industry could not pass the additional costs to its customers in a shrinking Union market.

• (162) The Commission noted with reference to its causation analysis in sections 5.2.3 and 5.2.5 of the provisional Regulation that factors such as business decisions of the Union producers, energy prices and raw material price increases have been duly examined and assessed. As set out in recitals 306 and 314 of the provisional Regulation, it was the low-priced dumped imports from the countries concerned which caused significant price depression to the Union industry following 2022. As a result of these dumped imports (and of no other factors such as business decisions of the Union producers or energy crisis or rising raw material prices), the Union industry was unable to sell at prices covering their cost of production and became loss-making in 2023 and in the investigation period. Had it not been for the price pressure from the dumped imports, the Union industry would have been able to absorb the increasing cost of production and adequately respond to the changing market conditions. In terms of cost and sales price evolution, as it transpires from Table 8 (‘Sales prices in the Union’) of the provisional Regulation, while the Union cost of production decreased by 20 percentage points in the period 2022-IP, the Union sales prices dropped by 90 percentage points over the same period. ERC’s and Nan Ya’s claims are therefore rejected.

• (163) Furthermore, Aditya Birla argued in its response to the provisional disclosure that the Commission failed to properly account for the distorting effects of the COVID-19 pandemic on the injury assessment. According to the exporter, basing injury calculations on data between 2020 and 2021 without sufficient adjustments, conflates economic distortions with actual injury leading to a manifest error in the causal link and non-attribution analysis. First, the injury calculations (including underselling and undercutting) are based on the investigation period and not the period of the COVID-19 pandemics preceding that period by several years. Furthermore, and in more general terms, the Commission injury assessment takes into account the data for the period considered, conducting a dynamic assessment of the macro- and microeconomic indicators of the Union industry over that period, including the years 2020-2021. As it follows from recitals 257, 258, 288, 306, 321, 345 and 364 of the provisional Regulation and contrary to Aditya Birla’s claim, the Commission duly took account of the COVID-19 pandemic’s impact on the situation of the Union industry in its injury assessment. Finally, Aditya Birla failed to substantiate how the effects of the COVID-19 pandemics would attenuate the causal link or otherwise invalidate the Commission’s causality assessment. The claim of Aditya Birla is therefore dismissed.

• (164) In view of the above and in the absence of further comments, the Commission confirms its findings in recitals 341 to 353 of the provisional Regulation.

5.5.   Conclusion on causation

• (165) The conclusions on causation reached in recitals 354 to 360 of the provisional Regulation were confirmed.

6. LEVEL OF MEASURES

6.1.   Injury margin

• (166) The complainant submitted, following the provisional disclosure, that the Commission underestimated the target profit of the Union epoxy resin industry by taking the minimum profit margin of 6 % as a basis. The complainant suggested that a reasonable profit margin should be at least [10-20] %, which is the average profit margin between 2020 and 2022. According to the complainant, adjusting the target profit above the 6 % threshold would also be in line with the Commission’s recent practice, where profitability in excess of 6 % was achieved by the Union industry prior to the period considered and accepted by the Commission.

• (167) First, reference is made to recital 364 of the provisional Regulation which provided exhaustive explanation regarding the establishment of the target profit in accordance with Article 7(2c) of the basic Regulation. Second, although the complainant argued in favour of using the average profit margin between 2020 and 2022, the complainant alone downplayed such choice by acknowledging that ‘while 2021 profit levels were substantially above the expected target profit, the 6 % profit margins reported in 2020 and 2022 also fail to serve as a representative benchmark’. Furthermore, and as outlined in the Commission’s provisional findings, profitability of the sampled Union producers for the period prior to the period considered could not be meaningfully considered given the lack of reliable data or heavy volatility in profits in the said period. The complainant’s claim has to be therefore rejected.

• (168) Furthermore, the complainant claimed in response to the provisional disclosure that in establishing the target price, the Commission should apply a default compliance cost per industry (referring to a Commission report on cost assessment in the Union chemical industry, published in 2016) in the absence of specific quantitative data from questionnaire responses of the sampled Union producers.

• (169) First, and as acknowledged by the complainant in its submission, the Commission requires quantifiable and verifiable data for its calculations of future compliance costs, which the sampled Union producers failed to produce in this case as set out in recitals 364 to 365 of the provisional Regulation. Furthermore, the calculation of the non-injurious price (including the R & D, innovation and future compliance costs) is an exercise involving individualised figures of the sampled Union producers. Hence it would not be possible to replace the company-specific figures with sector-specific figures as part of the exercise. For the reasons above, the complainant’s claim has to be dismissed.

• (170) Finally, the complainant submitted that Chinese producers seem to have adopted a synchronized pricing strategy, as the injury margins calculated for Chinese sampled exporters exhibit an almost identical alignment, raising concerns about potential anti-competitive practices. Since the complainant did not provide any substantiated evidence to support its claim (which in any event does not fall under scope of the basic Regulation) the Commission could not examine it and hence it has to be rejected. The claim was reiterated by the complainant following the final disclosure, however still with no supporting evidence.

• (171) As set out in recitals 113 and 114 above, the export price for the Thai company was corrected and subsequently the Commission revised the injury margin for Thailand. Therefore, the final injury elimination level for the cooperating exporting producers and all other companies is as follows:

Country	Company	Definitive dumping margin (%)	Definitive injury margin (%)
China	Jiangsu Sanmu Group Co., Ltd.	17,3	116
China	Sinochem Group: — Jiangsu Ruiheng New Material Technology Co., Ltd. — Nantong Xingchen Synthetic Material Co., Ltd. — Jiangsu Kumho Yangnong Chemical Co., Ltd.	33,0	118,9
China	Other cooperating Chinese companies	23,0	117,1
China	All other imports originating in China	33,0	118,9
Taiwan	Chang Chun Plastics Co	10,8	105,8
Taiwan	Nan Ya Plastics Corporation	11,0	96,5
Taiwan	All other imports originating in Taiwan	11,0	105,8
Thailand	Aditya Birla Chemicals (Thailand) Limited	29,9	71
Thailand	All other imports originating in Thailand	29,9	71

6.2.   Conclusion on the level of measures

• (172) Following the above assessment, definitive anti-dumping duties should be set as below in accordance with Article 7(2) of the basic Regulation:

Country	Company	Definitive anti-dumping duty (%)
China	Jiangsu Sanmu Group Co., Ltd.	17,3
	Sinochem group, consisting of: — Jiangsu Ruiheng New Material Technology Co., Ltd. — Nantong Xingchen Synthetic Material Co., Ltd. — Jiangsu Kumho Yangnong Chemical Co., Ltd	33,0
	Other cooperating companies	23,0
	All other imports originating in China	33,0
Taiwan	Chang Chun Plastics Co	10,8
Taiwan	Nan Ya Plastics Corporation	11,0
Taiwan	All other imports originating in Taiwan	11,0
Thailand	Aditya Birla Chemicals (Thailand) Limited	29,9
Thailand	All other imports originating in Thailand	29,9

7. UNION INTEREST

7.1.   Comments on the Union interest following the provisional disclosure

• (173) ERC argued that the high level of duties will impede access of imports from China to the Union and reiterated that the reduced availability of competitively priced epoxy resins could lead to higher costs for downstream industries relying on these inputs. ERC’s claim is rejected with reference to section 7.4 of the provisional Regulation, in particular to recitals 391 and 392. Following the final disclosure, ERC restated its arguments, considering the Union-interest analysis unbalanced and calling for a specific downstream impact assessment, without submitting any evidence or new arguments.

• (174) Furthermore, Aditya Birla claimed that the imposition of anti-dumping duties would have a negative impact on the Union’s clean energy goals and energy security, as it would lead to higher costs, reduced supply security, and undermine key EU climate and energy policies, ultimately contradicting the Union’s objectives of scaling up renewable energy and electrification. The exporter equally submitted that the imposition of measures would also lead to the closure of production facilities of CTP, which is a Union affiliate of Aditya Birla.

• (175) Contrary to Aditya Birla’s claim and in line with recital 388 of the provisional Regulation, the absence of measures (rather than their imposition) would put the existence of the Union epoxy resin industry and the stability of supply for the user industries in jeopardy. Reliance on dumped imports would in fact undermine the Union efforts to develop its own reliable industrial base to meet the renewable energy and carbon neutrality goals. Further to the operations of Aditya Birla’s Union affiliate, it is recalled that in addition to the sufficient capacity available at the Union producers there are other large exporting countries such as India, Korea, or Switzerland and their producers (including Aditya Birla and CTP’s related Indian producer) represent alternative sources of supply and pose a healthy competition to the Union industry. Second, Chinese, Thai and Taiwanese imports will not be prevented from entering the Union, they will simply enter at fair prices by paying the duties. In view of the aforementioned, Aditya Birla’s claim is rejected.

• (176) In response to the final disclosure, Nan Ya claimed (also with reference to the declared force majeure at Westlake’s plant for one of the product types) that the measures would likely not protect Union production but would allow the complainant companies to substitute their Union epoxy resin production with their own imports from the United States, where the cost of production was significantly lower. Nan Ya further submitted that the measures increased the risk of anti-competitive behaviour by the largest Union producers, referring to Westlake’s previous involvement in cartel activity in the Union and the United Kingdom.

• (177) Nan Ya’s claims were not accompanied by evidence and therefore were considered purely speculative. The exporter failed to substantiate how a temporary force majeure declaration on a particular product type or a past anticompetitive behaviour of Union producers could call into question or override the overall interest in imposing trade defence measures aimed at restoring the level playing field in the epoxy resins sector. Therefore, Nan Ya’s claims were rejected.

• (178) In response to the provisional disclosure, the unrelated importer De Monchy, distributing Nan Ya’s resins, restated its opposition against anti-dumping duties introduced for Taiwanese imports. According to the importer, a restricted supply from Nan Ya due to the measures could negatively affect the end users, increase the price level for the end products, and could also result in a loss of business and personnel for the importer.

• (179) Furthermore, another unrelated importer of resins from Taiwanese Nan Ya and at the same time also a user (QR Polymers) came forward following the provisional disclosure, calling for reconsideration of the provisional findings. QR Polymers submitted that unlike provisionally concluded by the Commission in recital 389 of the provisional Regulation, the company did not have the level of profit presented by the Commission, the proportion of the epoxy costs on total costs of the company is not limited, and the alternative sources of supply are absent or are not prepared to supply the quantities of epoxy resins QR Polymers will need. QR restated its claim following the final disclosure, adding that the company had provided the Commission with detailed quantitative data on its financial performance, on its purchases, on the share of imports of its purchases and its sales. According to QR Polymers the Commission possessed all the data necessary for the assessment of QR Polymer’s situation. QR further emphasised that the damage inflicted upon QR Polymers would propagate along the chain, providing the Commission with support letters from QR Polymers’ customer, a supplier, a toll manufacturer and one of its distributors.

• (180) First, as neither De Monchy nor QR Polymers completed a dedicated Commission questionnaire with verifiable data, which would quantify the effect that the duties would have on these respective companies, the claims raised are purely speculative and cannot be assessed on their merits. QR Polymers did not show that it would be unprofitable and did not substantiate the claims that it could not pivot to suppliers other than Nan Ya or how the 11 % duty imposed on Nan Ya would affect its business performance. QR Polymers equally represents only a fraction of the Union epoxy resin industry, and its situation would not be liable to alter the Union interest analysis and overall conclusions drawn by the Commission in the provisional findings or in this Regulation. Moreover, the letters provided in support of its arguments express only general concerns over the implications of anti-dumping measures against Nan Ya and were only provided in confidential form. In any event, such general statements could not invalidate the Commission Union interest analysis in this case. It is further recalled that QR Polymers did not supply any substantiated evidence as to why it should receive a special individualised treatment (see recitals 189 and 190 below). Second, as set out in recital 393 of the provisional Regulation, the measures will likely have only an insignificant impact (if any) on importers as they can continue importing epoxy resin at fair prices from the countries concerned (and their exporters, such as Nan Ya) or from other third countries. While the anti-dumping measures might lead to an increase in the epoxy resins price and might have an adverse effect on importers and users, as outlined in recital 391 of the provisional Regulation, only a modest price increase is projected as a result of the duties. Moreover, any price correction would merely be a manifestation of the fair-trade restoration in a situation where Union industry prices were depressed by a downward pressure coming from the dumped imports. The claims of the parties are therefore dismissed.

• (181) Furthermore, De Monchy maintained in its response to the provisional disclosure that many older production sites in the Union require significant maintenance, which leads to potential supply delays or shortages for end users. As outlined in recital 387 of the provisional Regulation, there are other large countries exporting epoxy resins to the Union, such as India, Korea, or Switzerland, in addition to the sufficient capacity at the Union producers and the countries concerned (whose imports can enter the Union at fair prices). Moreover, De Monchy did not provide any substantiated evidence that the Union producers would not be able to satisfy the demand coming from the Union users. De Monchy’s claim is therefore rejected. Further to the final disclosure, QR Polymers argued that a force majeure declared by Westlake on bisphenol F production and ceasing of ECH manufacturing by Westlake was illustrative of the fact that the imposition of measures would deteriorate, and not improve the situation of epoxy resin manufacturing in Europe. QR Polymers claim was dismissed on the grounds that a temporary force majeure on one of the product types or production stoppage of an upstream raw material by one of the Union producers cannot materially affect the supply situation in the Union, in particular in presence of supplies from other Union producers (e.g. Olin) or from countries concerned (e.g. Taiwan or Thailand) at fair prices or other third countries. Both, QR Polymers and De Monchy further argued with reference to the Westlake announcement to close down the liquid epoxy production plant in the Netherlands in 2025 that the epoxy market situation in Europe has changed radically, resulting in an immediate shortage of availability of epoxy resins produced in Europe in order to serve the Union market. According to these importers, losing Westlake’s capacity in Europe has to be compensated by import from Taiwan and the Commission should re-examine its determination for Taiwanese imports in order to minimize damage to the European epoxy market. It is underscored that the measures aim at protecting legitimate interests of the entire Union industry (comprising six groups of producers as set out in recital 249 of the provisional Regulation), not just those of a particular company such as Westlake. Closure of one of the plants cannot invalidate the Commission’s conclusion that the supply situation for users and importers in the Union is not in jeopardy, given the remaining substantial capacity in the Union and existence of supply sources in third countries, including countries concerned, at fair prices. Furthermore, if anything, the announcement on closure is just a manifestation of devastating effects that the dumped imports from countries concerned (including Taiwan) had on one of the Union epoxy resin producers and make the need to impose measures even more compelling in order to protect employment and production in the Union. QR Polymers’ and De Monchy’s additional arguments therefore have to be dismissed.

• (182) In response to the final disclosure, Akzo Nobel appealed to the Commission to reduce or remove the level of duty intended to be imposed on Chang Chun Plastics Co (CCP). According to this user, this level of duty would jeopardize supply stability, reduce production efficiency, and weaken the competitiveness of the Union’s coatings industry.

• (183) First, CCP’s anti-dumping margin is not prohibitive and will not preclude Akzo Nobel from continuing sourcing epoxy resins from CCP at fair price levels. Furthermore, Akzo Nobel has at its disposal other available sources of supply from within or outside the Union. Second, reference is made to recital 380 of the provisional Regulation, finding that the users in coating industry (including also Akzo Nobel) (i) enjoyed large profit margins; (ii) the proportion of epoxy resins cost on their cost of production was limited; and (iii) their revenues derived from epoxy-containing products are limited, hence further reducing the impact measures will have in general on the coatings industry. Akzo Nobel’s claim was therefore dismissed as unjustified.

• (184) Further to the final disclosure, ERC claimed that the Commission interpreted selectively the capacity utilisation rates of the Union industry. According to ERC, the Commission makes two mutually incompatible propositions that cannot simultaneously be true – on one hand the production capacity of the Union producers, whose low utilisation is evidence of material injury, and on the other hand the same capacity is presented as a guarantee of reliable supply once duties are in place.

• (185) There is no contradiction in the Commission’s own findings, nor incompatibility. In fact, capacity utilisation is one of the indicators examined as part of the injury analysis. A low capacity utilization rate resulting from the pressure from dumped imports does not contradict the finding that sufficient production capacity is available in the Union and a potential increase of supply to downstream industries is possible following the imposition of measures. ERC’s argument was therefore rejected.

7.2.   Conclusion on Union interest

• (186) In view of the above and in the absence of any further comments, the Commission confirmed its conclusion set out in recital 394 of the provisional Regulation that there were no compelling reasons that it was not in the Union interest to impose measures on imports of epoxy resins originating in China, Taiwan and Thailand.

8. TERMINATION AND DEFINITIVE ANTI-DUMPING MEASURES

• (187) Given the fact that no dumping has been established regarding imports from Korea, the proceeding with regard to imports originating in Korea shall be terminated.

8.1.   Definitive measures

• (188) In view of the conclusions reached with regard to dumping, injury, causation, level of measures and Union interest, and in accordance with Article 9(4) of the basic Regulation, definitive anti-dumping measures should be imposed in order to prevent further injury being caused to the Union industry by the dumped imports of the product concerned.

• (189) Following the provisional disclosure, QR Polymers requested the Commission to grant an end-use exemption on the epoxy resins imported by QR Polymers from Nan Ya from the application of the anti-dumping measures. QR reiterated its claim following the final disclosure, without however bringing forward any new evidence.

• (190) QR Polymers failed to substantiate in its request on what basis and for which end-use the epoxy resin types imported from Nan Ya should be subject to an end-use exemption. Therefore, QR Polymers’ claim has to be dismissed.

• (191) On the basis of the above, the definitive anti-dumping duty rates, expressed on the CIF Union border price, customs duty unpaid, should be as follows:

Country	Company	Dumping margin (%)	Injury margin (%)	Definitive anti-dumping duty (%)
China	Jiangsu Sanmu Group Co., Ltd.	17,3	116	17,3
China	Sinochem Group: — Jiangsu Ruiheng New Material Technology Co., Ltd. — Nantong Xingchen Synthetic Material Co., Ltd. — Jiangsu Kumho Yangnong Chemical Co., Ltd.	33,0	118,9	33,0
China	Other cooperating Chinese companies	23,0	117,1	23,0
China	All other imports originating in China	33,0	118,9	33,0
Taiwan	Chang Chun Plastics Co	10,8	105,8	10,8
Taiwan	Nan Ya Plastics Corporation	11,0	96,5	11,0
Taiwan	All other imports originating in Taiwan	11,0	105,8	11,0
Thailand	Aditya Birla Chemicals (Thailand) Limited	29,9	71	29,9
Thailand	All other imports originating in Thailand	29,9	71	29,9

• (192) 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 in respect to these companies. These duty rates are thus exclusively applicable to imports of the product under investigation originating in the country concerned and produced by the named legal entities. Imports of the product concerned manufactured by any other company not specifically mentioned in the operative part of this Regulation, including entities related to those specifically mentioned, cannot benefit from these rates and should be subject to the duty rate applicable to ‘all other imports’ originating in the respective country concerned.

• (193) A company may request the application of these individual anti-dumping duty rates if it changes subsequently the name of its entity. The request must be addressed to the Commission ²⁷. The request must contain all the relevant information enabling to demonstrate that the change does not affect the right of the company to benefit from the duty rate which applies to it. If the change of name of the company does not affect its right to benefit from the duty rate which applies to it, a regulation about the change of name will be published in the Official Journal of the European Union.

• (194) To minimise the risks of circumvention due to the difference in duty rates, special measures are needed to ensure the proper 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 the respective country concerned.

• (195) 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 should 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 rate of duty is justified, in compliance with customs law.

• (196) Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume, in particular 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, an anti-circumvention investigation may be initiated, provided that the conditions for doing so are met. 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.

• (197) To ensure a proper enforcement of the anti-dumping duties, the anti-dumping duty for all other imports originating in the respective country concerned should apply not only to the non-cooperating exporting producers in this investigation, but also to the producers which did not have exports to the Union during the investigation period.

• (198) Exporting producers in the People’s Republic of China that did not export the product concerned to the Union during the investigation period should be able to request the Commission to be made subject to the anti-dumping duty rate for cooperating companies not included in the sample. The Commission should grant such request provided that three conditions are met. The new exporting producer would have to demonstrate that: (i) it did not export the product concerned to the Union during the IP; (ii) it is not related to an exporting producer that did so; and (iii) has exported the product concerned thereafter or has entered into an irrevocable contractual obligation to do so in substantial quantities.

8.2.   Definitive collection of the provisional duties

• (199) In view of the dumping margins found and given the level of the injury caused to the Union industry, the amounts secured by way of provisional anti-dumping duties imposed by the provisional Regulation, should be definitively collected up to the levels established under the present Regulation.

8.3.   Retroactivity

• (200) As mentioned in section 1.2, the Commission made imports of the product under investigation subject to registration.

• (201) During the definitive stage of the investigation, the data collected in the context of the registration was assessed. The Commission analysed whether the criteria under Article 10(4) of the basic Regulation were met for the retroactive collection of definitive duties.

• (202) The Commission analysed, on the basis of Surveillance data, whether there was any further substantial rise in imports in addition to the level of imports which caused injury during the investigation period, as prescribed by Article 10(4)(d) of the basic Regulation. For this analysis, the Commission compared:

• (a) The average monthly imports from the first full month after initiation to the full month when registration took place (July 2024–October 2024) with the average monthly imports in the same months in the investigation period;

• (b) The average monthly imports from the first full month after initiation to the full month when provisional duties were adopted (July 2024–February 2025) with the average monthly imports in the same months in the investigation period;

• (c) The average monthly imports from the first full month after initiation to the full month when registration took place (July 2024–October 2024) with the average monthly imports in the whole investigation period; and

• (d) The average monthly imports from the first full month after initiation to the full month when provisional duties were adopted (July 2024–February 2025) with the average monthly imports in the whole investigation period.

• (203) Neither of the four comparisons outlined above showed a further substantial rise in imports in addition to the level of imports which caused injury during the investigation period.

• (204) Consequently, the Commission concluded that the conditions for retroactive collection are not met.

9. FINAL PROVISION

• (205) In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council ²⁸, when an amount is to be reimbursed following a judgment of the Court of Justice of the European Union, the interest to be paid should be the rate applied by the European Central Bank to its principal refinancing operations, as published in the C series of the Official Journal of the European Union on the first calendar day of each month.

• (206) The measures provided for in this regulation are in accordance with the opinion of the Committee established by Article 15(1) of Regulation (EU) 2016/1036,

HAS ADOPTED THIS REGULATION:

Article 1

The following products are excluded from the product described in Article 1(1):

• — Certain paint and coating products, which are blends, mixtures, or other formulations of epoxy resin, curing agent, and pigment, in any form, packaged in one or more containers, wherein (1) the pigment represents a minimum of 10 percent of the total weight of the product; (2) the epoxy resin represents a maximum of 80 percent of the total weight of the product; and (3) the curing agent represents 5 to 40 percent of the total weight of the product.

• — Pre-impregnated fabrics or fibres, often referred to as ‘pre-pregs’, which are composite materials consisting of fabrics or fibres (typically carbon or glass) impregnated with epoxy resin.

• — Blends of epoxy resins with other materials, currently classified under CN codes other than 2910 90 00 , 3824 99 92 , 3824 99 93 , and 3907 30 00 .

Country of origin	Company	Definitive anti-dumping duty (%)	TARIC additional code
China	Jiangsu Sanmu Group Co., Ltd.	17,3	89LO
	Sinochem group: — Jiangsu Ruiheng New Material Technology Co., Ltd. — Nantong Xingchen Synthetic Material Co., Ltd. — Jiangsu Kumho Yangnong Chemical Co., Ltd	33,0	89LP
	Other cooperating companies listed in Annex	23,0
	All other imports originating in China	33,0	8999
Taiwan	Chang Chun Plastics Co	10,8	89LQ
Taiwan	Nan Ya Plastics Corporation	11,0	89LR
Taiwan	All other imports originating in Taiwan	11,0	8999
Thailand	Aditya Birla Chemicals (Thailand) Limited	29,9	89LS
Thailand	All other imports originating in Thailand	29,9	8999

Article 2

The amounts secured by way of the provisional anti-dumping duty under Implementing Regulation (EU) 2025/393 imposing a provisional anti-dumping duty on imports of epoxy resins originating in the People’s Republic of China, Taiwan and Thailand shall be definitively collected. The amounts secured in excess of the definitive rates of the anti-dumping duty shall be released.

Article 3

Article 1 (2) may be amended to add new exporting producers from the People’s Republic of China and make them subject to the appropriate weighted average anti-dumping duty rate for cooperating companies not included in the sample. A new exporting producer shall provide evidence that:

• (a) it did not export the goods described in Article 1(1) during the period of investigation;

• (b) it is not related to an exporter or producer subject to the measures imposed by this Regulation, and which could have cooperated in the original investigation; and

• (c) it has either actually exported the product concerned or has entered into an irrevocable contractual obligation to export a significant quantity to the Union after the end of the period of investigation.

Article 4

The anti-dumping proceeding concerning imports of the product mentioned in Article 1(1) originating in Korea is hereby terminated.

Article 5

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, 25 July 2025.

For the Commission

The President

Ursula VON DER LEYEN

ANNEX

Cooperating exporting producers not sampled in the People’s Republic of China

Company Name	TARIC additional code
Allnex Resins (China) Co., Ltd.	89LT
Chang Chun Chemical (JiangSu) Co., Ltd.	89LU
Chang Chun Chemical (Panjin) Co. Ltd.	89LV
Dalian Qihua New Material Co., Ltd.	89LW
Dongying Hebang Chemical Co., Ltd.	89LX
Fujian Huanyang New Material Co., Ltd.	89LY
Sinopec Hunan Petrochemical Co., Ltd.	89LZ
Techstorm Advanced Material Corporation Limited	89M0
Zhuhai Epoxy Base Electronic Material Co., Ltd.	89M1

ELI: http://data.europa.eu/eli/reg_impl/2025/1505/oj

ISSN 1977-0677 (electronic edition)