Commission Implementing Regulation (EU) 2025/2287 of 12 November 2025 imposing a provisional anti-dumping duty on imports of adipic acid originating in the People’s Republic of China

(224) As noted in recital 157 the Union free market contracted during the period considered by 27 %. Regardless of this contraction, in the same period, the volume of Chinese imports increased by 33 %, which translated into a growth in their market share from 19,4 % in 2021 to 35,6 % in the investigation period. This happened to the detriment of the Union industry, which during the same period, lost 45 % of its free market sales volumes so that its market share declined from 77,2 % to 58,3 %. When looking at the absolute figures, a decline in the Union industry sales volumes on the free market proportionate to the consumption decline in the same market would have been around 110 000 tonnes (Table 1), whereas instead, due to the effect of the Chinese imports, it amounted to 140 000 tonnes.

(225) Furthermore, although consumption decreased already significantly in 2022, the Union industry was still profitable. The further slight decrease observed in the period between 2022 and the IP cannot, itself, explain the significant deterioration of the situation of the Union industry.

(226) Therefore, the contraction in demand in the market did not attenuate the causal link between the dumped Chinese imports and the injury suffered by the Union industry.

(227) As can be seen in Table 6 and concluded in recital 183, the captive market contracted in the same manner as the free market, given that it was driven by the same market forces of the downstream products. Therefore, it is important to note that even though captive use declined in volume, which affected negatively production volumes and unit cost of production, this rate of decline was not sharper than the decline on the free market.

(228) Moreover, as it can be seen in Table 8 and is explained in recital 193, the sales prices of captive use were based on transfer pricing and thus were following the developments in the cost of production and were consistently kept above the level of free market prices.

(229) Therefore, even if the decline in the volume of captive use could have had a negative impact on the Union industry’s economic situation, the Commission provisionally concluded that the developments in the captive use did not attenuate the causal link between the dumped imports and the injury.

(230) Based on the above, the Commission rejected the claim that injury was solely due to the decline in consumption be it captive or on the free market.

(231) A strong causal link was established between the dumped imports from the country concerned on one hand and the injury suffered by the Union industry on the other hand. There was a coincidence in time between the increase in volume and market share of the dumped imports and the deterioration of the Union industry’s performance, visible in particular as from 2023 onwards. In a contracting market, the increased volumes of dumped imports entering on prices undercutting the Union industry’s prices created a heavily price supressed environment and eroded the ability of the Union industry to set prices that would cover its cost of production. From this moment on, the Union industry lost its profitability and continued to be loss making until the end of the period considered.

(232) The Commission distinguished and separated the effects of all known factors which were capable of affecting the situation of the Union industry from the injurious effects of the dumped imports: such as imports from other countries; export performance of the Union industry; cost increases; contraction in demand and captive use. The effect of these factors on the Union industry’s negative developments in terms of production, free market sales volume, sales prices and profitability were only limited, if any.

(233) On the basis of the above, the Commission concluded at this stage that the dumped imports from the country concerned caused material injury to the Union industry and that the other factors, considered individually or collectively, did not attenuate the causal link between the dumped imports and the material injury. The injury consists of reduced market share, production, production capacity utilisation, productivity, profitability, cash flow, investments and return on investments. Furthermore, as explained in recitals 205 and 206, the Union industry suffered price suppression caused by imports from the country concerned.

(234) In the present case, the complainants claimed the existence of raw material distortions within the meaning of Article 7(2a) of the basic Regulation.

(235) Thus, in order to conduct the assessment on the appropriate level of measures, the Commission first established the amount of duty necessary to eliminate the injury suffered by the Union industry in the absence of distortions under Article 7(2a) of the basic Regulation.

(236) Then it examined whether the dumping margin of the sampled exporting producers would be higher than their injury margin.

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

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

(239) As a first step, the Commission established a basic profit covering full costs under normal conditions of competition. During the period considered the Union industry was heavily loss making with the exception of 2021 and 2022 when it managed to realise a very modest profit margin or stay at breakeven respectively. Furthermore, for the years prior to the period considered, precise or appropriate levels of profitability could not be identified. In the complaint, the Union industry proposed as target profit the average profit rate obtained by one of the Union producers based on a sales contract with one of its customers. Given that this result was based on only one of the Union producers and limited to the contractual arrangements with one customer, the Commission considered that it cannot be representative of the profit the Union industry could achieve in the absence of dumped imports. The Commission therefore established the target profit to determine the non-injurious price at 6 %, in accordance with Article 7(2c) of the basic Regulation.

(240) The Union Industry provided evidence that its level of investments, research and development and innovation during the period considered would have been higher under normal conditions of competition. The Commission verified this information during the on-spot verification by checking the company’s internal records related to investment plans and management decisions. The claims of the EU Industry were found to be warranted. To reflect this in the target profit, the Commission calculated the difference between investments, R & D and innovation (‘IRI’) expenses under normal conditions of competition as provided by the EU Industry and verified by the Commission with actual IRI expenses over the period considered. Such difference, expressed as a percentage of turnover, was less than 1 % for one of the sampled Union producers and between 1 %–2 % for the other one.

(241) This percentage was added to the basic profit of 6 % mentioned in recital 239, leading to a target profit of 6 %–8 %.

(242) On this basis, the non-injurious price is between [1 750 – 1 950 EUR/tonne], resulting from applying the above-mentioned profit margin of 6 %-8 % to the cost of production of the sampled Union producers during the investigation period.

(243) As no substantiated claims were made pursuant to Article 7(2d) concerning current or future costs which result from multilateral environmental agreements and protocols thereunder or from the listed ILO Conventions, no further costs were added to the non-injurious price thus established.

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

(246) As explained in the Notice of Initiation, the complainants provided the Commission sufficient evidence that there are raw material distortions in the country concerned regarding the product under investigation. Therefore, in accordance with Article 7(2a) of the basic Regulation, this investigation examined the alleged distortions to assess whether, if relevant, a duty lower than the margin of dumping would be sufficient to remove injury.

(247) However, as the margins adequate to remove injury were higher than the dumping margins, the Commission considered that, at this stage, it was not necessary to address this aspect. Following the above assessment the Commission concluded that it is appropriate to determine the amount of provisional duties in accordance with Article 7(2) of the basic Regulation.

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

(250) During the period considered, there were four known producers of adipic acid across the Union (with one of them having two separate production plants). The complainants, composed of two producers covered over 60 % of the free market sales on the Union market. All Union producers cooperated with the investigation. The two Union producers, who were not the complainants, did not oppose the investigation.

(251) The investigation showed that the Union industry suffered material injury caused by the dumped imports from the country concerned. During the period considered, the Union industry lost sales volumes and market share to the dumped Chinese imports. These imports significantly undercut the Union industry’s prices and exerted a strong price suppression, which in turn eroded the profitability of the Union industry as from 2023 and during the investigation period as elaborated in Section 5.

(252) The imposition of measures would likely lead to the normalisation of price levels on the Union market. This would enable the Union industry to regain sales and market share and thus recover its production volumes and obtain healthy capacity utilisation rates, thereby decreasing its unit costs. The Union industry would also be able to sell at prices covering its costs and therefore recover from the injurious dumping.

(253) In the absence of measures however, given the very aggressive pricing behaviour of the Chinese exporting producers and the huge spare capacities available in China, dumped imports would, in all likelihood, surge further on the Union market. Given the magnitude of injury already suffered, this would not only hamper the recovery of the Union industry but would render its situation outright untenable. As a result, without the measures, the survival of the Union industry could not be guaranteed and in all likelihood, it would be forced to cease operation in the foreseeable future.

(254) It is therefore concluded that imposing measures on imports of adipic acid originating in China would be in the interest of the Union industry.

(255) One unrelated importer, LCM, agreed to cooperate and submitted a questionnaire reply. No comments or submissions were received from any other importer or trader.

(256) LCM is a well-established trader of industrial chemical products with a stable customer basis predominantly located in Italy. During the investigation period sales of adipic acid corresponded to between 30 % and 40 % of its total turnover. In the same period, the volume of adipic acid imported by LCM from China represented between 7 % and 9 % of the total imports from China. Therefore, also considering the level of cooperation by users, the level of cooperation from the importers is considered medium.

(257) LCM opposed the imposition of measures mainly for fear that it will hurt its customers, the users of adipic acid mostly producing coating resins and polyester polyols. LCM expressed concern that the price increase of adipic acid resulting from the duties will place its customers in an unfavourable position compared to integrated Chinese manufacturers providing the same products but obtaining adipic acid at lower prices from Chinese producers. LCM also contested that Chinese exporters were selling at dumped prices. In this respect, LCM considered that based on its knowledge, the prices paid by users for adipic acid originating in China and in the EU were the same if one considers customs duties (6,5 %) and customs clearance costs, transportation costs, handling and repackaging costs or additional costs due to ‘massaging’ or ‘crushing’ required for caked adipic acid that had spent months in transportation as well as the trader’s margin. After all these adjustments, LCM considered that the prices of the product concerned and the like product did not differ significantly. A similar claim was also made by one of the users, Allnex.

(258) As regards the question of dumping, as explained in Section 3.6, the investigation found that all imports from China were sold at dumped prices. Concerning the price comparison as explained in recital 166 it was carried out based on the landed Chinese import price i.e. including all necessary adjustments and post importation costs. The undercutting margins thus found were significant, meaning that the Chinese imports were priced significantly lower than the like product offered by the Union industry. Furthermore, the Commission also provisionally concluded on the existence of price suppression as explained in recital 199.

(259) Concerning the effect of the duties on the prices and the potential loss of customers for the importer, the aim of the measures is not to close up the market from Chinese imports altogether instead, their aim is to restore normal market conditions and a level playing field for all parties concerned. In this respect, given the significant spare capacities, it is expected that imports from China would continue and the importer should be able to pass on the cost increases to most of its customers. Moreover, alternative sources both within and outside the Union remain a possibility too.

(260) Finally, as regards the impact of duties on the downstream market, this concern has also been echoed by a number of users in their questionnaire replies and/or submissions. This point is addressed in detail in Section 7.3 below.

(261) Based on above, the Commission provisionally concluded that the impact on importers would be limited and, in any event, any negative consequence for importers in the Union stemming from measures cannot outweigh the positive consequences of the latter on the Union industry.

(262) Numerous users of the product under investigation came forward during the investigation. Twelve of them provided a questionnaire reply. The combined import volume of the twelve users represented approximately 28 % of volume of imports from the country concerned during the investigation period and roughly 32 % of the Union free consumption. Some of the questionnaire replies however were very deficient with essential information missing and/or lacking an open version available for inspection by interested parties and therefore could not be taken into account for the detailed assessment on the impact of the measures.

(263) Altogether seven questionnaire responses were detailed and complete enough to carry out a detailed assessment on the impact of the measures (Allnex, BorsodChem, COIM, Elachem, Envalior, Kurita and Purinova), representing approximately 91 % of the import volume of the product concerned from the cooperating users and producing a wide range of intermediate chemicals. The Commission therefore considered this group to be representative of the situation of cooperating users. Three of these users, Allnex, COIM and Purinova provided a written submission.

(264) The main concern expressed by the users against the imposition of measures was the likely impact that the price increase of adipic acid would have on their precarious situation on the market of the downstream products. Users of adipic acid mainly produce various intermediary chemicals in particular polyester polyols or other final chemicals such as polyurethane resins and foams, Nylon 6.6, various adhesives, sealants, plasticisers and lubricants that are then further used by a great variety of sectors including textile, furniture, construction, automotive and footwear.

(265) Numerous users either in their questionnaire responses (Elachem, Reagens, Stepan and Valtris) or in specific submissions (Allnex, COIM and Purinova) claimed that duties on adipic acid would undermine their competitiveness as producers of downstream products against their third country competitors, particularly those located in China and Türkiye who will be able to obtain the product under investigation without similar price increase. Moreover, some of the users stated that they are in fact competitors of the Union industry on the downstream markets, which therefore could gain unfair advantage by the imposition of duties. In this respect, Purinova also added that following a recent anti-dumping investigation (101), the price of another raw material, namely alkyl phosphate esters, used by polyester polyol producers and produced by the same Union industry, has already increased. Allnex also mentioned a previous investigation on epoxy resins (102) and claimed that following the imposition of duties prices of epoxy resins rose sharply despite the decrease in the cost of a raw material, putting users in a difficult situation. Finally, Elachem and Purinova argued that in case measures are nevertheless imposed it is necessary to extend the scope of the proceeding to cover also imports of downstream products that contain more than 15 % of the product concerned in order to adequately safeguard the interests of the Union and in particular the producers of downstream products.

(266) These claims were rejected as it is not possible to extend the scope of the investigation and that of the ensuing duties in the course of the investigation. The product under investigation was clearly specified in the Notice of Initiation and all interested parties i.e. the Union industry, exporting producers, unrelated importers and users were defined accordingly. Consequently, all determinations regarding dumping, injury and causation refer solely to the product under investigation. Similarly, trends regarding other products (such as epoxy resins or alkyl phosphate esters and their raw materials) that were subject to other anti-dumping investigations cannot be analysed in the course of this proceeding.

(267) Regarding the situation on the downstream market, the analysis of the users’ questionnaires concluded that users on average are profitable and would remain so even with the highest level of duties. Therefore, the Commission concluded that most users should be able to absorb the price increases.

(268) Finally, as regards the allegation that the duties would grant undue competitive advantage to the Union industry versus the users on the downstream products, firstly it is recalled that the duties will only restore the unfair and unsustainable conditions created by dumping by the Chinese exporting producers. Moreover, as concluded in recital 178, one of the biggest concerns of the Union industry is the low capacity utilisation rate under which it was forced to operate as from 2023 due to the loss of sales and market share to dumped Chinese imports. Following the normalisation of the price level on the Union market, it is expected that the Union industry will be able to regain some of the lost sales and production quantities and thus achieve lower unit cost of production. Together with the alternative sources of supply, including those of Chinese origin, users will have stable supply on economically viable prices for all. The alternative scenario without the duties and the disappearance of the Union industry is much more harmful for the users than the expected price increase of the product under investigation.

(269) In conclusion, the Commission found that the measures are necessary for the Union industry to recover sales and return to profitability. The importing users would face an increase of costs when sourcing adipic acid from China and it would cause a certain decline in their profitability varying according to their product portfolio, however, broadly they would remain profitable. The restoration of healthy competition and a level playing field would ensure that users will have multiple sources available both within and outside of the Union. On the other hand, the non-imposition of measures would result in full dependence on Chinese imports, which would place all users and various downstream industries into a vulnerable position.

(270) On the basis of above, the Commission provisionally concluded that there were no compelling reasons demonstrating that it was not in the Union interest to impose measures on imports of adipic acid originating in China.

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

(272) Provisional anti-dumping measures should be imposed on imports of adipic acid originating in China, in accordance Article 7(2a) of the basic Regulation. The Commission concluded in recital 248 that the appropriate level to remove injury should be the dumping margin.

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

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

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

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

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

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

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

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

(282) Comments were received from Zhonghao and Huafon, who both noted a clerical error with regard to the calculation of the normal value. In addition, the Commission noted a calculation error in the calculation of the benchmark for steam. The Commission recalculated the dumping margins accordingly.

(283) One other comment from Zhonghao concerned the methodology used for the calculation of the benchmark for water and will therefore be addressed, where appropriate, at the definitive stage of the investigation.

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

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

HAS ADOPTED THIS REGULATION:

Article 1

Article 2

Article 3

Article 4

This Regulation shall enter into force on the first 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, 12 November 2025.

For the Commission The President Ursula VON DER LEYEN

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

(2) Notice of initiation of an anti-dumping proceeding concerning imports of adipic acid originating in the People’s Republic of China (OJ C, C/2025/1608, 14.3.2025, ELI: http://data.europa.eu/eli/C/2025/1608/oj).

(3) Commission Implementing Regulation (EU) 2025/1041 of 27 May 2025 making imports of adipic acid originating in the People’s Republic of China subject to registration (OJ L, 2025/1041, 28.5.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/1041/oj).

(4) https://tron.trade.ec.europa.eu/investigations/case-view?caseId=2782.

(5) Commission Implementing Regulation (EU) 2024/1959 of 17 July 2024 imposing a provisional anti-dumping duty on imports of erythritol originating in the People’s Republic of China (OJ L, 2024/1959, 19.7.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/1959/oj); Commission Implementing Regulation (EU) 2023/2180 of 16 October 2023 amending Implementing Regulation (EU) 2021/607 imposing a definitive anti-dumping duty on imports of citric acid originating in the People’s Republic of China as extended to imports of citric acid consigned from Malaysia, whether declared as originating in Malaysia or not, following a new exporter review pursuant to Article 11(4) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L, 2023/2180, 17.10.2023, ELI: http://data.europa.eu/eli/reg_impl/2023/2180/oj); Commission Implementing Regulation (EU) 2023/752 of 12 April 2023 imposing a definitive anti-dumping duty on imports of sodium gluconate originating in the People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 100, 13.4.2023, p. 16, ELI: http://data.europa.eu/eli/reg_impl/2023/752/oj); Commission Implementing Regulation (EU) 2021/441 of 11 March 2021 imposing a definitive anti-dumping duty on imports of sulphanilic acid originating in the People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 85, 12.3.2021, p. 154, ELI: https://eur-lex.europa.eu/eli/reg_impl/2021/441).

(6) Implementing Regulation (EU) 2024/1959, recitals 161-162; Implementing Regulation (EU) 2023/2180, recitals 89-90; Implementing Regulation (EU) 2023/752, recital 70.

(7) Implementing Regulation (EU) 2024/1959, recitals 103-113; Implementing Regulation (EU) 2023/2180, recitals 46-50; Implementing Regulation (EU) 2023/752, recital 49.

(8) Implementing Regulation (EU) 2024/1959, recitals 114-122; Implementing Regulation (EU) 2023/2180, recitals 51-55; Implementing Regulation (EU) 2023/752, recitals 50-54. While the right to appoint and to remove key management personnel in SOEs by the relevant State authorities, as provided for in the Chinese legislation, can be considered to reflect the corresponding ownership rights, CCP cells in enterprises, state-owned and private alike, represent another important channel through which the State can interfere with business decisions. According to China’s company law, a CCP organisation is to be established in every company (with at least three CCP members as specified in the CCP Constitution) and the company shall provide the necessary conditions for the activities of the party organisation. In the past, this requirement appears not to have always been followed or strictly enforced. However, since at least 2016 the CCP has reinforced its claims to control business decisions in SOEs as a matter of political principle. The CCP is also reported to exercise pressure on private companies to put ‘patriotism’ first and to follow party discipline. In 2017, it was reported that party cells existed in 70 % of some 1,86 million privately owned companies, with growing pressure for the CCP organisations to have a final say over the business decisions within their respective companies. These rules are of general application throughout the Chinese economy, across all sectors, including to the producers of the product under review and the suppliers of their inputs.

(9) Implementing Regulation (EU) 2024/1959, recitals 123-133; Implementing Regulation (EU) 2023/2180, recitals 65-65; Implementing Regulation (EU) 2023/752, recitals 55-63.

(10) Implementing Regulation (EU) 2024/1959, recitals 134-138; Implementing Regulation (EU) 2023/2180, recitals 66-69; Implementing Regulation (EU) 2023/752, recital 64.

(11) Implementing Regulation (EU) 2024/1959, recitals 139-142; Implementing Regulation (EU) 2023/2180, recitals 71-72; Implementing Regulation (EU) 2023/752, recital 65.

(12) Implementing Regulation (EU) 2024/1959, recitals 143-152; Implementing Regulation (EU) 2023/2180, recitals 72-81; Implementing Regulation (EU) 2023/752, recital 66.

(13) Commission Staff Working Document on Significant Distortions in the Economy of the People’s Republic of China for the purposes of Trade Defence Investigations, 10 April 2024, SWD(2024) 91 final, available at: https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2024)91&lang=en, including the previous version of the document: Commission Staff Working Document on Significant Distortions in the Economy of the People’s Republic of China for the purposes of Trade Defence Investigations, 20 December 2017, SWD(2017) 483 final/2, available at: https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2017)483&lang=en.

(14) See: https://www.huafeng.com/syly/hgsy/zqhfhg61/index.shtml (accessed on 12 August 2025).

(15) Complaint (open version), pages 12-13.

(16) Complaint (open version), pages 14-16.

(17) Complaint (open version), pages 16-18.

(18) Complaint (open version), pages 19-21.

(19) Complaint (open version), pages 21-24.

(20) Complaint (open version), pages 24-25.

(21) Complaint (open version), pages 25-27.

(22) Complaint (open version), pages 27-30.

(23) See at: https://www.huafeng.com/syly/hgsy/zqhfhg61/index.shtml (accessed on 12 August 2025).

(24) See at: https://www.hailichemical.com/ (accessed on 13 August 2025).

(25) See at: https://global.hengli.com/article/835 (accessed on 13 August 2025).

(26) See at: www.kailuan.com.cn (accessed on 13 August 2025).

(27) See at: https://www.hl-hengsheng.com/HOME/index.html (accessed on 13 August 2025).

(28) See at: https://stock.finance.sina.com.cn/stock/go.php/vReport_Show/kind/search/rptid/803032274731/index.phtml (accessed on 13 August 2025).

(29) See Shandong Hualu Hengsheng Co. Ltd. 2024 Annual report, page 60, available at: http://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-3/2025-03-29/10821388.PDF (accessed on 13 August 2025).

(30) See at: https://www.shenma.com/ (accessed on 13 August 2025).

(31) See Shenma Industrial Co. Ltd. annual report 2024, p. 132, available at: http://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-3/2025-03-26/10806904.PDF (accessed on 13 August 2025).

(32) See at: https://stock.finance.sina.com.cn/stock/go.php/vReport_Show/kind/search/rptid/803032274731/index.phtml (accessed on 13 August 2025).

(33) See at: https://www.tszhcc.com/index.php (accessed on 13 August 2025).

(34) See Kailuan Energy Chemical Co. Ltd. annual report 2023, p. 63-66, available at: http://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2024/2024-3/2024-03-30/9920751.PDF (accessed on 13 August 2025).

(35) See Article 33 of the CCP Constitution, Article 19 of the Chinese Company Law. See also the Report, Chapter 3, p. 47-50.

(36) See CPCIF Articles of Association, Article 3, available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (accessed on 13 August 2025).

(37) Ibid.

(38) See CPCIF Articles of Association, Article 36, available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (accessed on 13 August 2025).

(39) See at: http://www.cpcif.org.cn/detail/40288043661fd28501661fd4ed380000?e=1 (accessed on 13 August 2025).

(40) Ibid.

(41) See CCFA Articles of Association, Article 3, available at: https://www.ccfa.com.cn/3/202109/2260.html (accessed on 13 August 2025).

(42) Ibid.

(43) See CCFA Articles of Association, Article 36, available at: https://www.ccfa.com.cn/3/202109/2260.html (accessed on 13 August 2025).

(44) See at: https://www.ccfa.com.cn/11/202404/4264.html (accessed on 13 August 2025).

(45) See Section III.8.3 of the 14th FYP on economic and social development and 2035 perspectives, available at: https://www.gov.cn/xinwen/2021-03/13/content_5592681.htm (accessed on 14 August 2025).

(46) See at: https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (accessed 14 August 2025).

(47) Ibid., Section I.3.

(48) Ibid., Section II.3.

(49) Ibid., Section III.4.

(50) See at: https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=93802 (accessed on 14 August 2025).

(51) Ibid., Table 2.4.

(52) See at: https://huanbao.bjx.com.cn/news/20211201/1191133.shtml (accessed on 14 August 2025).

(53) Ibid., Section II.2.4.

(54) Ibid, Section III.1.2.

(55) See at: https://fgw.henan.gov.cn/2023/04-12/2723836.html (accessed on 15 August 2025).

(56) Ibid., Section II.3.

(57) See at: https://www.cq.gov.cn/zwgk/zfxxgkml/szfwj/qtgw/202108/t20210803_9538603.html (accessed on 14 August 2025).

(58) See at: https://www.huafeng.com/gyhf/hfdj/djry/ (accessed on 14 August 2025).

(59) See Huafeng Chemicals annual report 2024, p. 43, available at: http://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESZ_STOCK/2025/2025-3/2025-03-29/10826837.PDF (accessed on 14 August 2025).

(60) See at: https://www.hl-hengsheng.com/ESJSZQH/2025-03-26/4597.html (accessed on 14 August 2025).

(61) See at: https://www.hl-hengsheng.com/ESJSZQH/2025-04-17/5578.html (accessed on 14 August 2025).

(62) See Shenma Industrial Co. Ltd annual report 2024, p. 58, available at: http://static.cninfo.com.cn/finalpage/2025-03-21/1222865317.pdf (accessed on 14 August 2025).

(63) The Report, Part III, Chapter 16.

(64) Ibid., Section 16.3.

(65) See Section IV.1.3, available at: https://www.gov.cn/zhengce/zhengceku/2021-12/29/content_5665166.htm (accessed on 14 August 2025).

(66) See at: https://cq.gov.cn/ywdt/zwhd/qxdt/202209/t20220920_11125978.html (accessed on 14 August 2025).

(67) Ibid.

(68) See Shandong 14th FYP on the Development of the Chemical Industry, available at: https://huanbao.bjx.com.cn/news/20211201/1191133.shtml, Section I.1.3 (accessed on 14 August 2025).

(69) See at: http://vip.stock.finance.sina.com.cn/corp/view/vCB_AllBulletinDetail.php?stockid=600426&id=10821393 (accessed on 14 August 2025).

(70) See at: https://www.tszhcc.com/index.php (accessed on 14 August 2025).

(71) Implementing Regulation (EU) 2024/1959, recitals 153-157; Implementing Regulation (EU) 2023/2180, recitals 82-84; Implementing Regulation (EU) 2023/752, recital 67.

(72) See Section VIII.16, available at: https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (accessed on 18 April 2025).

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

(74) For further information on the BOL dataset used by GTA, see: https://connect.spglobal.com/document/show/phoenix/4083269?connectPath=Search&searchSessionId=b9caf866-5975-45eb-a3f2-713a9562f140.

(75) https://datamercantil.com.br/wp-content/uploads/2025/08/05-08-2025-Data-Mercantil-certificado.pdf.

(76) See footnote 74.

(77) https://www.ibge.gov.br/estatisticas/economicas/industria/9042-pesquisa-industrial-anual.html?=&t=downloads.

(78) English – Ministério de Minas e Energia.

(79) English – Ministério de Minas e Energia.

(80) https://www.sabesp.com.br/servicos/para-voce.

(81) Benchmark the Fuel Cost of Steam Generation, Energy Tips: STEAM, Steam Tip Sheet #15 (Fact Sheet), Advanced Manufacturing Office (AMO), Energy Efficiency & Renewable Energy (EERE). The methodology refers to the cost of saturated steam for typical values of operating pressure and feedwater temperature. In the application of the methodology, an average of these typical values was used.

(82) https://reliefweb.int/report/brazil/acaps-thematic-report-brazil-impact-drought-brazilian-amazon-and-2025-outlook-28-january-2025.

(83) See for example tariff data for 2022 and 2023 in the annex to https://www.arsesp.sp.gov.br/LegislacaoArquivos/ldl15142024.pdf.

(84) Common Nomenclature of Mercosur.

(85) https://connect.ihsmarkit.com/gta/home/.

(86) Regulation (EU) 2015/755 of the European Parliament and of the Council of 29 April 2015 on common rules for imports from certain third countries (OJ L 123, 19.5.2015, p. 33, ELI: http://data.europa.eu/eli/reg/2015/755/oj). Article 2(7) of the basic Regulation considers that domestic prices in those countries cannot be used for the purpose of determining normal value.

(87) Market Access Map by the International Trade Centre. Available at https://www.macmap.org/en/query/customs-duties.

(88) https://www.ibge.gov.br/estatisticas/economicas/industria/9042-pesquisa-industrial-anual.html?=&t=downloads.

(89) IMF International Financial Statistics Database, https://legacydata.imf.org/regular.aspx?key=63087884.

(90) English – Ministério de Minas e Energia.

(91) English – Ministério de Minas e Energia.

(92) https://www.sabesp.com.br/servicos/para-voce.

(93) Benchmark the Fuel Cost of Steam Generation, Energy Tips: STEAM, Steam Tip Sheet #15 (Fact Sheet), Advanced Manufacturing Office (AMO), Energy Efficiency & Renewable Energy (EERE). The methodology refers to the cost of saturated steam for typical values of operating pressure and feedwater temperature. In the application of the methodology, an average of these typical values was used.

(94) English – Ministério de Minas e Energia.

(95) https://datamercantil.com.br/wp-content/uploads/2025/08/05-08-2025-Data-Mercantil-certificado.pdf.

(96) Case C-319/24 P, Commission v Sinopec Chongqing SVW Chemical and others, pending (Judgment in the General Court T-762/20, ECLI:EU:T:2024:113).

(97) Judgment of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663.

(98) Judgment of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, paras. 188 and 189.

(99) See also Judgment of 18 March 2009, Shanghai Excell M&E Enterprise Co. Ltd and Shanghai Adeptech Precision Co. Ltd v Council of the European Union, T-299/05, ECLI:EU:T:2009:72, para. 266.

(100) DESTATIS – Statistisches Bundesamt: https://www.destatis.de/EN/Press/2025/01/PE25_020_611.html?templateQueryString=average+annual+inflation+rate+2021+to+2024+in+germany+.

(101) Commission Implementing Regulation (EU) 2024/2415 of 12 September 2024 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of certain alkyl phosphate esters originating in the People’s Republic of China (OJ L, 2024/2415, 13.9.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/2415/oj).

(102) Commission Implementing Regulation (EU) 2025/393 of 26 February 2025 imposing a provisional anti-dumping duty on imports of epoxy resins originating in the People’s Republic of China, Taiwan, and Thailand (OJ L, 2025/393, 27.2.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/393/oj).