Commission Implementing Regulation (EU) 2025/1901 of 22 September 2025 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of glyoxylic acid originating in the People’s Republic of China

• (128) Concerning Jaer’s and Brűggemann claims regarding specific grades for their respective production processes, initially neither Jaer or Brűggemann disclosed information on those specific grades needed, and therefore the Union industry was not in a position to respond on whether or not they could provide such grades. The Commission concluded that indeed both Jaer and Brűggemann source specific grades of glyoxylic acid from China, however the Commission could not verify whether the same grades could be supplied by the Union industry as information on the specific grades was not disclosed. The claims were therefore dismissed. Following definitive disclosure, Brűggemann disclosed additional information. The claim is addressed in recitals 158 to 163.

7.1.4.   Financial situation of the users

• (129) As explained in recital (18) of the provisional Regulation, glyoxylic acid is an intermediate product to produce antibiotics, vanillin, chelated fertilisers and allantoin. Three fertiliser producers, Trade Corporation, Nouryon, and Jaer, one antibiotics producer, Deretil, and one specialty chemicals producer, Brüggemann, representing 75 % of imports and 72 % of EU consumption of glyoxylic acid, made submissions following the imposition of provisional measures.

• (130) The users claimed that the imposition of measures would significantly increase their costs, decrease their profits with Deretil and Brüggemann claiming that they would incur losses and impact their competitiveness at a time when they are facing increasing pressure in their respective markets from Chinese and Indian exporters that would not be impacted by the measures. The users further claimed that due to the competition from exporting producers in their respective markets, they would not be able to pass-on the increased costs. On these grounds, Jaer and Nouryon requested the Commission to reconsider the level of measures. In particular, Jaer requested the application of measures in accordance with Article 7(2) of the basic Regulation.

• (131) The Commission had established the existence of raw material distortions within the meaning of Article 7(2a) of the basic Regulation (recital 281 of the provisional Regulation). In order to assess whether it was in the Union’s interest to impose measures in accordance with Article 7(2) or 7(2a) of the basic Regulation, the Commission first made simulations on the users’ profitability on the basis of the definitive dumping and injury margins, assuming that volumes of glyoxylic acid, as well as turnover achieved on downstream products, remained equal to those in the investigation period.

• (132) Second, the Commission assessed the impact of the duties on profitability by reducing the profit in proportion to glyoxylic acid’s contribution to turnover, multiplied by the effective price increase resulting from the imposition of the duties. The effective price increase took into consideration the provenance of the imports, the duties imposed on the exporting producers, as well as the price increases reported for the Union industry.

• (133) The impact of the measures varied in line with differences regarding the users’ initial profitability, the contribution of glyoxylic acid to the downstream products’ turnover and the source of supply of the glyoxylic acid. Specifically, the contribution of glyoxylic acid to the downstream products’ turnover ranges between 5 % to 18 %. Profit margins for chelate and dedicated chemicals producers were well above 10 %, whereas the antibiotics producer reported profits in the range of 5 % to 7 %. Lastly, there were higher effective increases in prices when companies were sourcing from non-cooperating producers.

• (134) The results of the simulations showed that if duties were imposed on exports from China pursuant to Article 7(2a) of the basic Regulation, except for Deretil, users would remain profitable, even if they do not increase prices, due to their high profit margins. The simulations showed the same result for users sourcing from non-cooperating producers. The duties would certainly have an impact in the profitability of users, but redirection of purchases to increase the share of Union industry or exporters with lower duties like Hubei, would further mitigate the impact.

• (135) In the case of Deretil, due to its moderate profit margin, if duties were imposed in accordance with Article 7(2a) of the basic Regulation, the measures would seriously affect its profitability, and the company would become loss-making. The Commission acknowledged, as pointed out by Deretil, that amoxicillin is included in the list of critical medicines for which continuity of supply is a priority ¹⁴. Therefore, since Deretil is the only producer of the amoxicillin precursor and one of the two producers of amoxicillin in the Union, it is important that its healthy profitability and security of supply would not be jeopardised.

• (136) The Commission then made a simulation on the profitability of Deretil if duties were imposed on exports from China in accordance with Article 7(2) of the basic Regulation. Deretil’s profitability would be also impacted under the Article 7(2) measures, however in that scenario, Deretil would remain profitable even in the event that it would have to source from non-cooperating exporters. Moreover, the Commission analysed the source of supply and the quality grades of glyoxylic acid Deretil uses and concluded that the company could source a greater share of the glyoxylic acid from the Union industry and cooperating exporting producers, thus significantly mitigating the impact of the measures on their profitability.

7.1.5.   Conclusion on Union interest under Article 7(2b) of the basic Regulation

• (137) In recitals 296 and 297 of the provisional Regulation, the Commission concluded that it was in the interest of the Union to determine the amount of duties in accordance with Article 7(2a) of the basic Regulation, and set the level of provisional duties on the basis of the level of dumping.

• (138) The analysis of the submissions of the users following the imposition of provisional measures showed that, while for all other users the imposition of measures in accordance with Article 7(2a) of the basic Regulation is not likely to lead to significant negative consequences, such level of duties would severely impact specifically the profitability of Deretil, which would become loss-making. The analysis also showed that when applying the duties in accordance with Article 7(2) of the basic Regulation, Deretil would remain profitable.

• (139) On that basis, the Commission did carefully weigh all the elements and could not conclude that it is in the Union’s interest to determine the amount of duties in accordance with Article 7(2a), namely it was not in the interest of the Union to set the level of the measures at the level of dumping in view of the disproportionally negative effect this is likely to have on supply chains for Union companies.

• (140) The Commission therefore confirmed that the measures should be set in accordance with Article 7(2) of the basic Regulation.

7.2.   Union interest under Article 21 of the basic Regulation

• (141) Having assessed the Union interest pursuant to Article 7(2b) of the basic Regulation, the Commission then 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, and users.

7.2.1.   Interest of the Union industry

• (142) As explained in recital 299 of the provisional Regulation, the sole producer of glyoxylic acid in the Union lodged the complaint, cooperated fully in the investigation and expressed its interest to the imposition of measures.

• (143) In the absence of comments, recitals 299 to 302 of the provisional Regulation are confirmed.

7.2.2.   Interest of unrelated importers and traders

• (144) In the absence of comments from Union importers and traders, recitals (303) and (304) of the provisional Regulation are confirmed.

7.2.3.   Interest of users

• (145) As set out in section 7.1.3 of this Regulation, the users Trade Corporation, Deretil and Jaer repeated their concerns regarding the limited production capacity of the complainant and the availability of sufficient quantities of glyoxylic acid in the Union.

• (146) Trade Corporation and Deretil opposed the adoption of the measures. Furthermore, Nouryon, Trade Corporation, Deretil, Jaer and Brüggemann made also comments regarding the effect on their profitability and competitiveness (see also section 7.1.4).

• (147) Concerning claims on capacity and profitability, the Commission addressed those claims in recital 80 of this Regulation. Furthermore, as set out in section 7.1.4 of this Regulation, with the application of definitive anti-dumping duties in accordance with Article 7(2) of the basic Regulation, all users would remain profitable, even if they need to source from non-cooperating producers. Consequently, in cases where production is disrupted either in the Union industry or in Hubei — the exporting producer with lower duties — users would still have access to other sources of supply, ensuring the availability of alternatives to the Union industry. Therefore, claims on profitability, competitiveness, capacity and availability are dismissed.

• (148) Following the imposition of provisional measures, Jaer requested a product scope exclusion of the type of grade of glyoxylic acid they use to produce fertilisers. It claimed being unable to source enough quantities of this grade from the Union industry.

• (149) To assess any product exclusion request, the Commission has to examine (i) the basic physical, chemical and technical characteristics of those product types, (ii) their end-use and interchangeability, (iii) end-customer perception, (iv) impact of duties on the user, (v) alternative sources of supply, and (vi) impact of exemption on duties. As Jaer made its request after the deadline to submit product scope claims, the Commission could not consider the request as it could not carry out the analysis to grant or reject this product scope exclusion.

• (150) Following imposition of provisional measures, Deretil requested an end-use exemption under Article 254 of the Union Customs Code ¹⁵ for the use of glyoxylic acid for the production of an antibiotic precursor D(-) Alpha Parahydroxy PhenylGlycine Methyl Ester ‘Methyl Ester’ and of the antibiotic amoxicillin.

• (151) After analysing the evidence and the comments presented by Deretil, the Commission determined that there are no grounds to grant the end-use exemption, since Deretil does not require a special grade of glyoxylic acid and could source from the Union industry and all exporting producers in China. Moreover, as explained in recitals 136 and 147 , the imposition of the measures is in accordance with Article 7(2), therefore Deretil would remain profitable even if it would source from non-cooperating producers in China.

• (152) Brüggemann reiterated its request for an end-use exemption under Article 254 of the Union Customs Code, already made at provisional stage as mentioned in recital 24 of the provisional Regulation. Brüggemann provided more information concerning the type of glyoxylic acid it sources from China and claimed that contrary to the Commission’s findings in the provisional Regulation, the glyoxylic acid sourced from China and the glyoxylic acid sourced from the Union were not interchangeable.

• (153) In recitals 25 to 28 of the provisional Regulation, the Commission explained the reasons why it could not grant end-use exemption to Brüggemann. The Commission analysed the new information provided by the company after the imposition of provisional measures. As explained in recital 128, Brüggemann did not disclose specific information regarding the type of grade of glyoxylic acid it sources from China and therefore the Union industry was initially not in a position to comment on whether or not they could source that grade. The Commission therefore rejected the end-use exemption request.

• (154) The Commission had therefore concluded that the requests made by Deretil and Brüggemann if granted, would account for a significant amount of total Union consumption of glyoxylic acid (13 % to 18 %) in the case of Deretil and 3 % to 5 % in the case of Brüggemann. Therefore, granting them it would put into question the effectiveness of the measures in protecting the Union industry.

• (155) However, as explained in recitals 158 to 163, the request of Brüggeman could now be accepted.

7.2.4.   Interest of consumers

• (156) After the imposition of provisional measures, Trade Corporation alleged that the imposition of antidumping duties on glyoxylic acid would impact the price of fertilisers and could lead to increased costs in agricultural production, and thus to higher food prices for consumers. Deretil similarly argued that the increase in price of glyoxylic acid, would increase significantly the price of antibiotic precursors produced in the Union and, therefore, increase the price of antibiotics and impact EU consumers, especially those with lower income. In the absence of corroborating evidence, the claims are dismissed.

7.2.5.   Strategic interest of the Union industry

• (157) As shown by the users’ submissions glyoxylic acid is a crucial intermediate for Union industries in general and for antibiotic production in particular. In recent legislative proposals ^{16 , 17} the Commission has noted that shortages of medicinal products can result from supply chain disruptions and vulnerabilities affecting the supply of key ingredients and components and has sought to address them and increase the resilience of the pharmaceutical sector. The loss of the only glyoxylic acid producer in the Union as a result of the dumped imports would increase the vulnerability of the pharmaceutical sector since they will become solely dependent on long supply chains that have been disrupted on several occasions in the last few years, e.g. due to accidents in the Suez Canal or conflict in the Red Sea. Furthermore, the disappearance of glyoxylic production in the Union would lead to the dependency of the Union on Chinese imports, as there is no alternative source, and would compromise the Union’s strategic autonomy in a crucial sector ¹⁸. Conversely, imposing measures at the proposed levels will protect the production of glyoxylic acid and avoid extensive harm to downstream industry and thus mitigate dependence on foreign supply chains.

• (158) Following final disclosure, Brüggemann reiterated that the rejection of its end-use exemption request by the Commission was unjustified. It claimed that such an exemption was warranted and justified in the present case since the end-use exemption for producing FFSRAs would not reduce effectiveness of duties. Brüggeman claimed that its imports from China and its total demand for glyoxylic acid are a negligible percentage of EU consumption. In addition, Brüggeman demonstrated that glyoxylic acid accounts for a significant share of production cost of FFSRAs and that it cannot change suppliers.

• (159) At the provisional stage, Brüggemann had not disclosed specific information regarding the type of grade of glyoxylic acid it sources from China and therefore the Union industry was not in a position to comment on whether or not it could provide that grade. However, following final disclosure Brüggemann made public the range (an iron (Fe) content of ≥ 10 and ≤ 20 PPM) in which the specific iron content of the type of glyoxylic acid it sources from China falls and repeated the claim that contrary to the Commission’s findings in the provisional Regulation, first, the glyoxylic acid sourced from China and the glyoxylic acid sourced from the Union were not interchangeable and, second, it could only source this product from a specific Chinese supplier.

• (160) Following this submission by Brüggemann, Weylchem claimed that it could produce the glyoxylic acid type for which the end-use exemption was requested. However, the Commission noted that the supporting evidence did not confirm that that was indeed the case. In any event, it recalled that even if other suppliers could produce that very specific glyoxylic acid type, the Commission would still be within its discretion to conclude that an end-use exemption was still appropriate if the circumstances of the case would support granting an end-use exemption.

• (161) Weylchem also claimed that Brüggemann’s request should be rejected as it had been made outside the deadline set in the notice of initiation for submitting comments on the product scope. The Commission clarified that such deadline applies to comments on the actual product scope (including the product concerned and the like product), which need to be addressed at an early stage of the procedure because of potential implications to the scope of the investigation itself. On the other hand, the request by Brüggemann concerned an end-use exemption made in view of the potential application of measures. Such request was made in due course in the proceeding before the provisional stage. Further to the provisional rejection of its request, Brüggemann submitted additional comments and evidence at this later stage of the procedure to support its original request made in due course. Therefore, the Commission rejected that claim.

• (162) Finally, Weylchem indicated to fear that other Union users and importers might explore the risks of importing under the same regime, thus circumventing the measures through misdeclaration. The Commission notes that an end-use exemption is not company specific but provided for a specific end-use. Therefore, the exemption can be used by any company as long as the imported product is used for the production of FFSRA’s and has an iron (Fe) content of ≥ 10 and ≤ 20 PPM. The end-use exemption is implemented and supervised by Member States customs authorities, which strictly ensure that imports for other uses will not benefit from the exemption and pay anti-dumping duties accordingly. The Commission thus rejected the claim.

• (163) On that basis, and in the light of the comments made by Brüggemann following disclosure as explained in recital 159, the Commission concluded that Brüggemann’s request for an end-use exemption of glyoxylic acid used in the production of FFSRAs and with an iron (Fe) content of ≥ 10 and ≤ 20 PPM should be accepted. As the circumstances justifying the granting of the end-use exemption were already prevalent well before the imposition of the provisional anti-dumping measures, the Commission further concluded that it should be applied retroactively up to the imposition of the provisional anti-dumping measures.

• (164) Deretil disagreed with the Commission’s finding that Deretil would remain profitable after the imposition of the anti-dumping duties. Deretil also disagreed with the Commission’s finding that ‘there are no grounds to grant the end-use exemption’. It claimed that the reasons for this refusal, (i) Deretil does not require a special grade of glyoxylic acid, (ii) it could source from the Union industry and all exporting producers in China and (iii) because Deretil would remain profitable ‘even if they source from non-cooperating producers in China’ were unfounded and insufficient. On the first reason, Deretil claimed it had based its claim on reasoned economic and end-use arguments and that therefore, the Commission’s reference to ‘a special grade’ was of no use. On the second and third reasons, it mentioned that Deretil would be left in an extremely vulnerable situation if no end-use exemption for the production of methyl ester would be granted.

• (165) However, thosee arguments were not able to change the Commission’s findings for the following reasons. Firstly, Deretil’s request refers to the end-use exemption for a standard grade of glyoxylic acid which is produced by the Union industry in sufficient quantities. Secondly, the Commission simulated the impact of measures on Deretil and it would remain profitable even if it sources from non-cooperating producers in China. In simulating the impact of the measures, the Commission took into consideration the increase of prices by the Union industry, contrary to Deretil’s claim that this parameter had not been included. Thirdly, Deretil is large user and the biggest importer of glyoxylic acid in the Union, and the production of antibiotics is one of the major uses of glyoxylic acid. Thus, granting the end-use exemption for the production of antibiotics would impact at least [13 to 18 %] of the market and significantly undermine the efficacy of the measure.

• (166) Following final disclosure, Jaer claimed that neither their product scope exclusion request nor their end-use exemption request were assessed by the Commission meaningfully.

• (167) The Commission maintained its position that the scope exclusion was requested after the deadline. Moreover, with respect to the request submitted by Jaer to grant end-use exemption for a high-quality grade of glyoxylic acid that is used for the production of chelate fertilisers, the Commission noted the following. Firstly, high quality glyoxylic acid is available from the Union industry and Jaer has been purchasing from them. Jaer had not replied to the users questionnaire and it had not disclosed the exact grade of glyoxylic acid it requires. Thus, the Union industry could not respond, and the Commission could not corroborate the finding that Jaer would be facing problems procuring sufficient quantities from the Union industry. Secondly, the Commission has examined the profitability of the company following imposition of the measures and concluded that it would remain profitable. Thirdly, the production of chelate fertilisers accounts for approximately 30 % of imports and for one third of the Union’s consumption of glyoxylic acid, with Jaer’s consumption accounting for the largest part of this. Therefore, even if only used for fertilisers by Jaer, this exemption would impact [20 to 25 %] of the market and significantly undermine the efficacy of the measures. Therefore, Jaer’s request was rejected.

• (168) Following final disclosure, AEFA claimed that the proposed anti-dumping duty levels would entail a significant increase in the production cost of iron chelates, which would have to be passed on through the manufacturer–industry–distributor–farmer chain.This would then result in chelate prices reaching a level unaffordable for the various commercial agents and loss of competitiveness, not only for chelate manufacturers, but also for numerous Spanish and European users. The latter would then in turn enable and facilitate the entry of non-European competition into a market where the ‘Spain and Europe’ label is widely recognised and valued for its technology. AEFA also claimed there were already supply limitations for a raw material for a precursor for various products, such as amoxicillin or vanillin, currently unavailable in sufficient volumes in the Union market. AEFA therefore requested end-use exemptions for agricultural use and restrictions on finished iron chelates from China, to mitigate the competitive disadvantage faced.

• (169) The end use exemption request for agricultural use was not substantiated by verifiable facts supporting such exemption. Moreover, imposing restrictions on finished iron chelates from China is outside the scope of this proceeding. Therefore the claims were rejected.

• (170) After the additional final disclosure, in addition to its comments on Brüggemann’s end-use exemption request, Weylchem claimed that since the opening of this investigation, Chinese glyoxylic acid has been pouring into the Union market at prices that further undercut the levels established in the investigation period for the Union industry. It claimed that the Commission had decided not to impose retroactive duties on Chinese imports for policy reasons rather than economic ones, since there was no question that Chinese imports surged following the registration of imports, especially relative to Union consumption.

• (171) The Commission recalled that the analysis provided in recitals 191 to 195 below, which was disclosed to Weylchem in the final disclosure, was based on the legal requirements of Article 10(4) of the basic Regulation for the retroactive collection of duties, which in this particular proceeding were not met. This claim was therefore rejected.

• (172) Following the additional final disclosure, Jaer claimed that its requests for product-scope exclusion and end-use exemption were not properly considered and repeated both claims.

• (173) The Commission explained in recitals 166 and 167 above that the product exclusion request was made very late in the procedure and also why Jaer’s end-use exemption request was rejected.

• (174) Trade Corporation repeated its claim that the Commission had not demonstrated a causal link between the allegedly dumped Chinese imports and the Union producer's losses highlighting that the concentration of the Union industry in a single producer might not be representative of a broader industry context and that external factors such as the energy crisis were not adequately considered. Trade Corporation also argued that imposing definitive duties would create a de-facto monopoly for the sole Union producer, jeopardising supply security and resilience.

• (175) The Commission disagreed, as explained in recital 93. In the absence of additional arguments or evidence, this claim was rejected.

• (176) Hubei claimed that it could produce the glyoxylic acid type for which the end-use exemption was requested and considered that other producers of glyoxylic acid, including the complainant, could also produce it. Therefore they objected to the granting of the end-use exemption.

• (177) As explained above in recital 162, an end-use exemption is not company specific and apply when products are imported to be used in the production of a particular downstream product. The fact that several exporting producers are able to produce a certain product type is irrelevant for the Commission's decision. Therefore, this claim was rejected.

7.3.   Conclusion on Union interest

• (178) On the basis of the above, the Commission confirms its conclusion set out in recital 314 of the provisional Regulation, that there are no compelling reasons that it is not in the Union interest to impose measures on imports of glyoxylic acid originating in the PRC.

8. DEFINITIVE ANTI-DUMPING MEASURES

8.1.   Definitive measures

• (179) 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.

• (180) 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:

• (181) Following final disclosure, Guangdong Joy Chemical, Inner Mongolia Tianyuda Biological Technology, Jinyimeng Group, Deretil and Jaer claimed that the non-sampled cooperating exporting producers had fully cooperated with the Commission throughout this investigation and that the non-selection for sampling by the Commission should not result have resulted in the imposition of a duty that exceeded the rate applied to the sampled producer/exporter with the highest anti-dumping duty among the cooperating companies. The interested parties claimed that the Commission applied inconsistently Article 9(6) of the basic Regulation.

• (182) The Commission clarified that it followed the provision of Article 9(6) of the basic Regulation, which stipulate that the anti-dumping duty applied to imports from exporters not included in the investigation should not exceed the weighted average margin of dumping established with respect to the parties in the sample. The definitive anti-dumping duty was not calculated as a weighted average of the individual rates of anti-dumping duty, but the average dumping and injury margins were calculated, followed by application of the lesser duty rule. In the present case, the anti-dumping duty applied to imports from cooperating non-sampled exporters was based on the weighted average dumping margin of the sampled exporting producers and was fully compliant with Article 9(6) of the basic Regulation. The claim was rejected.

• (183) 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 PRC’.

• (184) 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 ¹⁹. 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.

• (185) 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 People’s Republic of China’.

• (186) 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.

• (187) 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.

• (188) To ensure a proper enforcement of the anti-dumping duties, the anti-dumping duty for all other imports originating in the PRC 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.

• (189) Exporting producers 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 investigation period; (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

• (190) 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.   Retroactive collection

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

• (192) 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.

• (193) The Commission’s analysis showed no 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 the monthly average import volumes of the product concerned during the investigation period, which was 1 309 tonnes, with the monthly average import volumes during the period from the month following the initiation of this investigation until the last full month preceding the imposition of provisional measures (August 2024 – February 2025) which was 1 306 tonnes.

• (194) Also, when comparing the monthly average import volumes of the product concerned during the investigation period with the monthly average import volumes during the period from the month following the initiation of this investigation up to and including the month in which provisional measures were imposed (August 2024 – March 2025), no further substantial increase could be observed.

• (195) On that basis, the Commission concluded that the conditions as set out in Article 10(4) of the basic Regulation for the retroactive application of the definitive anti-dumping duty were not met.

9. FINAL PROVISION

• (196) In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council ²⁰, 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.

• (197) 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

Article 2

The product described in Article 1(1) shall be exempted from definitive anti-dumping duty if it is imported for use in the production of formaldehyde-free sulfur-based reducing agents (“FFSRAs”) and with an iron (Fe) content of ≥ 10 and ≤ 20 PPM (parts per million).

This exemption shall be subject to the conditions laid down in the customs provisions of the Union on the end-use procedure, in particular Article 254 of Regulation (EU) No 952/2013.

Article 3

Article 4

Article 1 (2) may be amended to add new exporting producers from the PRC 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 (01/07 2023 to 30/06/2024);

• (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 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, 22 September 2025.

For the Commission

The President

Ursula VON DER LEYEN

-TDI-NAME-CHANGE-REQUESTS@ec.europa.eu; European Commission, Directorate-General for Trade, Directorate G, Wetstraat 170 Rue de la Loi, 1040 Brussels, Belgium.

ANNEX

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

ELI: http://data.europa.eu/eli/reg_impl/2025/1901/oj

ISSN 1977-0677 (electronic edition)