Commission Implementing Regulation (EU) 2025/2153 of 22 October 2025 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of screws without heads originating in the People’s Republic of China, and levying the definitive anti-dumping duty on the registered imports of screws without heads originating in the People’s Republic of China

• (165) Furthermore, pursuant to Article 10(4)(d) of the basic Regulation, there needs to be ‘a further substantial rise in imports in addition to the level of imports which caused injury during the investigation period’ that in light of its timing and volume and other circumstances are likely to serious undermine the remedial effect of the definitive duties.

• (166) The Commission’s analysis showed a 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.

• (167) For this analysis, the Commission compared the monthly average import volumes of the product concerned during the investigation period with the average monthly import volumes and prices after initiation (during the period from November 2024 to June 2025), distinguishing between (i) the first full months following the initiation of the investigation up to the last full month when the registration took place (November 2024 to January 2025) and (ii) the first full months following the initiation of the investigation up to the last full month when provisional measures were adopted (November 2024 to June 2025).

Table 1

Imports of headless screws from China

• (168) The average monthly import volume from China during the investigation period was 9 360 tonnes. The average monthly import volume from China in the period starting in the first full month after publication of the Notice of initiation of the investigation in the Official Journal of the European Union and ending in the last full month up to the last full month when the registration took place (November 2024 to January 2025) was 13 458 tonnes, 44 % higher than in the investigation period. When comparing the imports after the investigation period with the same months during the investigation period (i.e. November 2023 to January 2024, with a monthly average import volume of 8 768 tonnes), to avoid any differences in seasonality, the change in monthly average is even higher at an increase of 53 %.

• (169) The same trend can be seen when comparing the imports during the investigation period with the period following the initiation of the case up to the last full month when provisional measures were adopted.

• (170) The average monthly import volume from China in the period starting in the first full month after publication of the Notice of initiation of the investigation in the Official Journal of the European Union and ending in the last full month preceding the imposition of provisional measures (November 2024 to June 2025) was 13 427 tonnes, 43 % higher than in the investigation period. When comparing the imports after the investigation period with the same months during the investigation period (i.e. November 2023 to June 2024, with a monthly average import volume of 8 978 tonnes), the increase in monthly average is 50 %.

• (171) Therefore, the Commission concluded that there was a substantial increase in imports volumes after initiation.

• (172) EFDA argued that the observed increase in import volumes during the early months of 2025, particularly in January and February, aligns with normal seasonal patterns in the industry, as companies typically reduce stock levels in November and December for year-end inventory management and subsequently replenish supplies in the first months of the year. This fluctuation is unrelated to the anti-dumping investigation and instead reflects routine market behaviour. The Commission however rejected the argument, since it also compared identical periods during and post-IP, in particular the early months of each year and therefore the seasonal effects were reflected in the comparison.

• (173) EFDA argued that the IP saw unusually low import volumes due to post-pandemic excess stock in the Union warehouses, driven by supply chain disruptions and delayed shipments that led to stockpiling. The subsequent increase in imports after the IP reflects a market correction as inventories return to typical levels, rather than an abnormal trend. The Commission dismissed the argument, since, as noted in recital 212 of the provisional regulation, the import volumes increased during the IP in relation to 2023 despite demand in the Union remaining low during the IP.

• (174) Moreover, the Commission noted that the average price of imports decreased following the initiation of the investigation. When comparing (i) the first full months following the initiation of the investigation up to the last full month when the registration took place with the average price in the IP, a decrease of 8,6 % in price is shown from 1 213 EUR/tonne to 1 109 EUR/tonne, and when comparing (ii) the first full months following the initiation of the investigation up to the last full month when provisional measures were adopted with the average price in the IP, a decrease of 9 % in price is found (from 1 213 EUR/tonne to 1 104 EUR/tonne).

• (175) In view of the foregoing the Commission could conclude that the rise of imports was likely to seriously undermine the remedial effect of the definitive anti-dumping duty to be applied, within the meaning of Article 10(4)(d) of the basic Regulation.

• (176) Consequently, the Commission concluded that all the conditions for retroactive collection are met. A definitive anti-dumping duty should therefore be levied on the product concerned, which was made subject to registration by Implementing Regulation (EU) 2025/141.

• (177) The level of the duty to be collected retroactively should be set at the level of the definitive duty included in Article 1(2) below.

• (178) Following the definitive disclosure, EFDA, supported by Junyue and Chinafar Groups, challenged the retroactive application of duties under Article 10(4)(c) of the basic Regulation, arguing that the conditions for retroactive imposition were not satisfied as there was no evidence of sustained dumping over an extended period for the product under investigation. Therefore, importers were neither aware of the alleged dumping nor the extent of the injury claimed, particularly given the product’s explicit exclusion from the prior anti-dumping investigation on certain iron or steel fasteners ²⁰.

• (179) EFDA emphasized that most importers are small and medium-sized enterprises (‘SMEs’) with limited capacity to independently assess dumping risks. These entities typically operate under the assumption that imported products are fairly priced, and it would be unreasonable to expect SMEs to proactively take precautionary measures against dumping for products not previously subject to anti-dumping scrutiny, as well as to penalize them. The surge in imports following the investigation’s initiation was primarily due to supply chain lead times, lasting up to eight months between the order’s issuance and customs clearance, rather than intentional circumvention. Therefore, they claimed that imports to the Union in January to March 2025 were ordered as early as May to July 2024. They noted that the lead times should be taken into account when analysing the necessity of the retroactive application of duties in other investigations ²¹.

• (180) EFDA also highlighted that import volumes of the product under investigation began to decline from February 2025, signalling a return to normalized trade flows. Alongside, import prices have steadily increased, indicating that market conditions are naturally readjusting. These developments, they contended, further undermined the justification for retroactive duties.

• (181) EIFI disputed the claim of six-month lead times between order placement and customs clearance, providing information for shorter lead times in 2024. It argued that the 153-day gap between the investigation’s initiation (17 October 2024) and the beginning of the retroactive anti-dumping duty application (19 March 2025) meant that orders for imports subject to duties were placed after the initiation of the investigation, when importers were aware of the alleged dumping and injury. EIFI emphasized that the trend in imports showed a sharp rise in Chinese imports of screws without heads starting in July 2024 (12 694-22 584 tonnes/month), compared to pre-July 2023 levels (6 510-11 449 tonnes/month). This trend indicated market awareness of the impending anti-dumping complaint, with importers front-loading shipments to avoid duties. EIFI further asserted that importers knowingly assumed the risk of retroactive duties despite this awareness and now seek to evade liability by citing speculative lead times.

• (182) EIFI also disputed claims that the surge in Chinese imports in 2024-2025 reflected post-pandemic stock adjustments or seasonal patterns, arguing it stemmed from market anticipation of the anti-dumping complaint. The 109 % year-on-year increase in the first quarter 2025 and a sustained price decline (1 302 €/tonne in 2023 to 1 093 €/tonne by mid-2025) contested assertions of temporary or cyclical behaviour. EIFI emphasized that the surge and pricing trends correlated with the upcoming investigation, invalidating alternative explanations and underscoring the need for retroactive duties to address predatory imports.

• (183) The Commission recalled that Article 10(4)(d) of the basic Regulation refers to ‘imports’ and not ‘orders’ that are likely to seriously undermine the remedial effect of the definitive anti-dumping duty to be applied. These imports must be assessed for their timing, volume, and potential to undermine the remedial effect of anti-dumping duties. Article 10(4)(c) hinges on importer awareness of dumping, but stresses that retroactive duties are not punitive. Instead, their purpose is to preserve the effectiveness of anti-dumping measures by addressing imports that, as a whole, risk undermining their remedial impact. The assessment under Article 10(4)(d) prioritizes the objective effect of import volumes and market dynamics over individual importers’ subjective intentions or lead times ²².

• (184) In the current investigation, the Commission acknowledged that several months may have elapsed between the order and the import date. It reviewed the evidence submitted by the parties regarding supply chain lead times for the product under investigation but largely rejected it as unsubstantiated or incomplete. Key deficiencies included missing orders and/or corresponding invoices followed by customs documentation in certain cases. Additionally, some importers providing information failed to cooperate with this investigation, leaving their total import volumes to the Union unknown. Consequently, the information submitted by the cooperating importers represented less than 5 % of total imports of the product under investigation to the Union during the investigation period. Therefore, in addition to being essentially irrelevant in view of the principles recalled in recital 183, the Commission did not consider the data sufficiently representative to assume that all other importers were in the similar situation.

• (185) In view of the Commission’s analysis of substantial rise in imports after the investigation period, it considered that, while some of the deliveries from November 2024 to February 2025 could partially be due to pre-investigation orders placed before October 2024, this explanation was insufficient to account for the sustained surge in imports, which amounted to a 47 % increase from February to June 2025 compared to the same period in 2024. Additionally, the Commission observed an 11 % decrease in the average import price of the product during February-June 2025 compared to February-June 2024, a trend inconsistent with EFDA’s assertion of market normalization. This price decline, combined with the surge in import volumes, directly undermined the parties’ argument that trade flows had naturally readjusted after February 2025.

• (186) Furthermore, EFDA’s claim that imports to the Union in January-March 2025 were ordered as early as May-July 2024 was found incorrect upon analysis of the average import price. If the claim was accurate, the average import price in January-March 2025 (1 057 EUR/tonne) should have aligned with the price range of May-July 2024 (1 218 EUR/tonne) or earlier, but instead was 13 % lower.

• (187) The Commission rejected the parties’ argument regarding the exclusion of the product under investigation from the prior anti-dumping investigation on certain iron or steel fasteners, as irrelevant to the current proceeding. Under established practice and Article 10(4)(c) of the Basic Regulation, each investigation is confined to the product scope defined in the complaint. The absence of screws or bolts in the prior complaint did not negate the current investigation’s validity, as the scope of any proceeding is determined solely by the specific allegations and evidence presented in the complaint at issue. Furthermore, the Commission emphasized that the industries producing screws without heads and those producing other iron or steel fasteners are distinct in terms of production processes, market functions, and injury. The parties’ reliance on the prior exclusion is therefore misplaced, as it conflated unrelated investigations with different product scopes. This argument was accordingly dismissed as factually and legally unsubstantiated.

• (188) Considering the above, the Commission concluded that the retroactive application of duties is justified, as the evidence demonstrated that the surge in imports and the timing of deliveries could not be reconciled with lead times and the conditions for retroactive imposition under Article 10(4)(c) of the Basic Regulation have been satisfied.

• (189) Pursuant to Article 10(4) of the basic Regulation, the retroactive application of the duty is levied from 19 March 2025.

9. FINAL PROVISION

• (190) In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council ²³, 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.

• (191) 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 amounts secured by way of the provisional anti-dumping duty under Commission Implementing Regulation (EU) 2025/1189 of 13 June 2025 imposing a provisional anti-dumping duty on imports of screws without heads originating in the People’s Republic of China shall be definitively collected. The amounts secured in excess of the definitive rates of the anti-dumping duty shall be released.

Article 3

A definitive 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, which were registered under Implementing Regulation (EU) 2025/141 at the rates set out in Article 1(2). The duty is applicable as from 19 March 2025.

Article 4

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 (1 July 2023 to 30 June 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 October 2025.

For the Commission

The President

Ursula VON DER LEYEN

‘Structures (excluding prefabricated buildings of heading 9406 and parts of structures (for example, bridges and bridge-sections, lock-gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns), of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel’.

https://www.xn--72ca6basbt6cwa6f4b1a8owe.com/ (last consulted 16.9.2025).

https://www.thaimongkol.com (last consulted 16.9.2025).

https://th.nc-net.com/company/101653/ (last consulted 16.9.2025).

ANNEX

Chinese cooperating exporting producers not sampled

ELI: http://data.europa.eu/eli/reg_impl/2025/2153/oj

ISSN 1977-0677 (electronic edition)