Commission Implementing Regulation (EU) 2025/2314 of 17 November 2025 imposing a provisional anti-dumping duty on imports of phosphorous acid originating in the People’s Republic of China

(259) Finally, the Commission examined whether yellow phosphorus affected by the export tax described in recital 256 accounted for at least 17 % of the cost of production of the product concerned. Considering the lack of cooperation by the exporting producers in the PRC, the Commission relied on the complainant’s cost of production. For the purpose of this calculation, an undistorted price of the raw material as established in the international markets mentioned in recital 258 was used. The Commission established that yellow phosphorus accounted for more than 50 % of the actual cost of production of the complainant.

(260) Consequently, the Commission concluded that yellow phosphorus was subject to a distortion within the meaning of Article 7(2a) of the basic Regulation.

(261) In accordance with Article 7(2b) of the basic Regulation, the Commission examined whether it could clearly conclude that it was in the Union interest to determine the amount of provisional duties in accordance with Article 7(2a) of the basic Regulation. The determination of the Union interest was based on an appreciation of all pertinent information to this investigation, including the spare capacities in the exporting country, competition for raw materials and the effect on supply chains for Union companies.

(262) The Commission established that Chinese producers of phosphorous acid possess exceptionally large spare production capacities, which create a serious risk of continued exports to the Union market even after the possible imposition of measures. According to the evidence in the complaint, the total installed capacity in the PRC was found to be more than forty times the size of Union consumption. Approximately 23 % of this capacity remained unused during the investigation period and could therefore be readily redirected towards exports to the Union.

(263) The Commission analysed the market conditions for the main raw material used in the production of phosphorous acid. Yellow phosphorus, the key input material in the production of phosphorous acid, is subject in China to a 20 % export tax. This measure restricts international supply and keeps Chinese domestic prices artificially low, giving Chinese producers a cost advantage. Yellow phosphorus represents [55-60 %] of the cost of production of phosphorous acid. This significant cost gap distorts competition and puts Union producers at a structural disadvantage.

(264) The Commission analysed the potential impact of the imposition of measures on the Union supply chains, including effects on the downstream market and the availability of the product concerned within the Union. This assessment was based on the information provided by cooperating interested parties. Only one user submitted a complete questionnaire reply, and the Commission therefore relied primarily on the data provided by that user. The analysis showed that the imposition of measures would not have a material adverse impact on the profitability of that user, which would remain at a sustainable level, allowing it to continue its operations without significant disruption. Furthermore, the Commission established that the Union industry retains sufficient unused capacity to increase production and thereby meet a greater share of Union demand.

(265) Having assessed all pertinent information to this investigation, the Commission concluded that it is in the Union interest to determine the amount of provisional duties in accordance with Article 7(2a) of the basic Regulation.

(267) Having decided to apply Article 7(2a) of the basic Regulation, the Commission also 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.

(268) The Union producer that lodged the complaint, accounting for the entire Union production available on the free market, cooperated fully in the investigation and expressed its interest to the imposition of measures. The other Union producer, Italmatch, also cooperated fully by providing dedicated questionnaire responses.

(269) The imposition of duties is expected to restore fair trade conditions on the Union market and enable the Union industry to recover from the material injury suffered during the investigation period. In particular, the measures would allow the Union producer to regain lost sales volumes and market share, improve profitability, and ensure the sustainable operation of production facilities. The imposition of measures is therefore likely to have a positive impact on the viability and long-term competitiveness of the Union industry.

(270) In the absence of measures, Chinese exporting producers would continue to export the product concerned to the Union at dumped prices, thereby further depressing prices on the Union market and eroding the Union industry’s profitability. This would undermine its capacity to invest, innovate, and maintain production, ultimately threatening its viability.

(271) It was therefore concluded that imposing measures on imports originating in the PRC would be in the interest of the Union industry.

(272) The Commission did not receive questionnaire responses from Union importers or traders. One importer (S. Goldmann GmbH & Co. KG, Germany) provided a written submission, expressing its opposition to measures.

(273) Goldmann claimed that the measures would give the complainant a monopolistic position which would likely increase their own costs and would also endanger the supply chain in the Union, as ICL cannot cover the entire demand. Regarding the supply chain security, the Commission concluded that the only sources of phosphorous acid are the complainant and the Chinese producers. The loss of the Union industry would make the PRC the sole source of phosphorous acid. Regarding the monopolistic position of the Union industry, the Commission concluded measures would reinstate fair trade conditions for all parties; the downstream industry could still source material from the PRC, but at fair non-dumped prices.

(274) The Commission therefore concluded that no sufficient evidence was submitted demonstrating that the imposition of anti-dumping duties on imports of phosphorous acid originating in the PRC would have a lasting adverse effect on the profitability of importers or traders.

(275) One user, Giovanni Bozzetto Spa, came forward during the investigation and provided a questionnaire reply and a written submission, expressing its opposition to measures. Phosphorous acid is one of the raw materials for Bozzetto in the production of detergent and water treatment formulations.

(276) The Commission established, based on the data reported in the company’s questionnaire reply and the total imports from the PRC shown in Table 3, that Bozzetto accounted for 15 % to 25 % of all imports of the product concerned from the PRC into the Union.

(277) Bozzetto claimed that the measures would give the complainant a monopolistic position which would likely increase their own costs and would also endanger the supply chain in the Union, as the complainant cannot cover the entire demand.

(278) Regarding the effects on supply chain security, the Commission noted that anti-dumping measures are not meant to block imports, but rather to reinstate fair trade conditions for all parties; the downstream industry could still source material from China, thus the Union industry would not enjoy a monopolistic position. Conversely, the loss of the Union industry would make China the sole source of phosphorous acid.

(279) Bozzetto expressed its concerns over the ability of vertically integrated Chinese producers to avoid the measures, by further processing phosphorous acid into phosphonates and exporting the downstream product into Union distorting competition in the Union phosphonates market. Third-country chemical producers for downstream products would gain a competitive advantage over Union producers as they would continue to purchase Chinese phosphorous acid without AD duties and thus sell the final product at a lower price in the Union. Also, third-country phosphorous acid importers could perform targeted assembly activities for the product originating in China and circumvent the measures by exporting the product into the Union market.

(280) Regarding the potential circumvention and surge of imports in the downstream product markets, the Commission has tools to address these issues should they arise.

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

(282) 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.

(283) Provisional anti-dumping measures should be imposed on imports of phosphorous acid originating in the PRC, in accordance Article 7(2a) of the basic Regulation. The Commission concluded in recital 266 that the appropriate level to remove injury should be the dumping margin.

(284) On the basis of the above, the provisional anti-dumping duty rate, expressed on the CIF Union border price, customs duty unpaid, should be set at the level of 122,8 %.

(285) This duty rate is exclusively applicable to imports of the product concerned originating in the country concerned.

(286) 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.

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

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

(289) 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 the website of DG Trade and Economic Security. Interested parties were given three working days to provide comments on the accuracy of the calculations specifically disclosed to them.

(290) Three cooperating Chinese companies submitted comments within the deadline. They however did not concern the accuracy of the calculations. Those comments will be therefore duly addressed at the definitive stage of the investigation.

(291) 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.

(292) 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 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, 17 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) OJ C, C/2025/1687, 19.3.2025, ELI: http://data.europa.eu/eli/C/2025/1687/oj.

(3) Commission Implementing Regulation (EU) 2025/1334 of 10 July 2025 making imports of phosphorous acid originating in the People’s Republic of China subject to registration (OJ L, 2025/1334, 11.7.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/1334/oj).

(4) https://tron.trade.ec.europa.eu/investigations/case-view?caseId=2781.

(5) t25.009318, t25.009323.

(6) Note for the file of 12 June 2025, t25.006313, on the clarification of the production of phosphorous acid.

(7) 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/oj).

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

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

(10) 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 the PRC’s company law, a CCP organisation is to be established in every company (with at least three CCP members as specified in the CCP Constitution) and the company shall provide the necessary conditions for the activities of the party organisation. In the past, this requirement appears not to have always been followed or strictly enforced. However, since at least 2016 the CCP has reinforced its claims to control business decisions in SOEs as a matter of political principle. The CCP is also reported to exercise pressure on private companies to put ‘patriotism’ first and to follow party discipline. In 2017, it was reported that party cells existed in 70 % of some 1,86 million privately owned companies, with growing pressure for the CCP organisations to have a final say over the business decisions within their respective companies. These rules are of general application throughout the Chinese economy, across all sectors, including to the producers of the product under review and the suppliers of their inputs.

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

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

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

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

(15) 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.

(16) Complaint (open version), p. 11–12.

(17) Complaint (open version), p. 13–14.

(18) Complaint (open version), p. 15–17.

(19) Complaint (open version), p. 17–19.

(20) Complaint (open version), p. 20–21.

(21) Complaint (open version), p. 22–23.

(22) Complaint (open version), p. 23–24.

(23) Complaint (open version), p. 24–27.

(24) Available at http://www.tzycchem.com/p./about.html (last viewed 16 September 2025).

(25) Available at https://yth.cn/ywycp/jxhgjxcl.html (last viewed 16 September 2025).

(26) Yunnan Yuntianhua Co. Ltd. Annual report 2024, p. 115. Available at https://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-3/2025-03-25/10802990.PDF (last viewed 16 September 2025).

(27) Available at https://www.xingfagroup.com/index.php/product/category?id=5 (last viewed 16 September 2025).

(28) Hubei Xingfa Chemicals Group Ltd. Annual report 2024, p. 76. Available at https://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-4/2025-04-01/10835918.PDF (last viewed 16 September 2025).

(29) Ibid.

(30) Available at https://en.hbyihua.cn/product_detail/261.html (last viewed 16 September 2025).

(31) Hubei Yihua Chemical Industry Co. Ltd. Annual report 2024, p. 113. Available at: http://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESZ_STOCK/2025/2025-4/2025-04-03/10844871.PDF. (last viewed 16 September 2025).

(32) Available at https://www.sdlomon.com/about/aboutjj/ (last viewed 16 September 2025).

(33) Ibid.

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

(35) CPCIF Articles of Association, Article 3. Available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (last viewed 19 September 2025).

(36) Ibid.

(37) CPCIF Articles of Association, Article 36. Available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (last viewed 19 September 2025).

(38) Available at http://www.cpcif.org.cn/detail/4aa3eebc-85ca-4893-aacf-85c552107b4e (last viewed 16 September 2025).

(39) Available at http://www.cpcif.org.cn/detail/78f4fdd0-52c0-429d-b47b-a34ee66ff54f (last viewed 16 September 2025).

(40) Available at http://www.cpcif.org.cn/detail/9d10963a-e7ba-4444-8903-6ae4248adb58 (last viewed 16 September 2025).

(41) Available at http://www.cpfia.org/web/meeting.php?column=3 (last viewed 17 September 2025).

(42) CPFIA Articles of Association, Article 3. Available at: http://www.cpfia.org/web/content.php?column=65&id=10483 (last viewed 17 September 2025).

(43) Ibid.

(44) CPFIA Articles of Association, Article 36. Available at: http://www.cpfia.org/web/content.php?column=65&id=10483 (last viewed 17 September 2025).

(45) See at: http://www.cpfia.org/web/content.php?column=41&id=18892 (last viewed 17 September 2025).

(46) 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 (last viewed 17 September 2025).

(47) Available at https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (last viewed 17 September 2025).

(48) Ibid., Section I.3.

(49) Ibid., Section III.4.

(50) Section IV.1 of the 14th FYP on Developing the Raw Materials Industry, available at: https://www.gov.cn/zhengce/zhengceku/2021-12/29/5665166/files/90c1c79a00b44c67b59c29392476c862.pdf (last viewed 17 September 2025).

(51) See Section III.2 of the 14th FYP on Developing the Green Industry. Available at https://www.gov.cn/zhengce/zhengceku/2021-12/03/5655701/files/4c8e11241e1046ee9159ab7dcad9ed44.pdf (last viewed 17 September 2025).

(52) Available at https://www.ndrc.gov.cn/xxgk/zcfb/fzggwl/202312/P020231229700886191069.pdf (last viewed 17 September 2025).

(53) Available at https://www.gov.cn/zhengce/zhengceku/202401/content_6923991.htm (last viewed 18 September 2025).

(54) Available at https://huanbao.bjx.com.cn/news/20211201/1191133.shtml (last viewed 19 September 2025).

(55) Ibid., Section II.2.4.

(56) Hubei 14th FYP on Economic and Social Development and 2035 Perspectives, box 3, p. 25. Available at https://www.ndrc.gov.cn/fggz/fzzlgh/dffzgh/202104/P020210427315108290779.pdf (last viewed 18 September 2025).

(57) Hubei 14th FYP on the High Quality Development of the Manufacturing Industry, Section III.1.3. Available at https://www.hubei.gov.cn/zfwj/ezf/202111/t20211119_3871028.shtml (last viewed 18 September 2025).

(58) Hubei 14th FYP on the High Quality Development of the New Materials Industry, Section IV.2.2. Available at https://jxt.hubei.gov.cn/fbjd/xxgkml/jhgh/202203/t20220325_4056642.shtml (last viewed 18 September 2025).

(59) Guizhou 14th FYP on the Development of Strategic and Emerging Industry Clusters, Section V. Available at https://fgw.guizhou.gov.cn/ztzl/sswgh_5643328/202109/P020220524636540764870.pdf (last viewed 18 September 2025).

(60) Available at https://yth.cn/xwzx/dqgz/202407/20240702_6616.html (last viewed 18 September 2025).

(61) Yunnan Yuntianhua Co. Ltd. 2024 Annual report, p. 51. Available at https://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-3/2025-03-25/10802990.PDF (last viewed 18 September 2025).

(62) Hubei Xingfa Group Ltd. 2024 Annual report, p. 34. Available at https://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESH_STOCK/2025/2025-4/2025-04-01/10835918.PDF (last viewed 18 September 2025).

(63) Hubei Yihua Chemical Industry Co. Ltd. 2024 Annual report, p. 52. Available at https://file.finance.sina.com.cn/211.154.219.97:9494/MRGG/CNSESZ_STOCK/2025/2025-4/2025-04-03/10844871.PDF (last viewed 18 September 2025).

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

(65) Ibid., Section 16.3.

(66) Section IV.1.3. Available at: https://www.gov.cn/zhengce/zhengceku/2021-12/29/content_5665166.htm (last viewed 18 September 2025).

(67) Section VI. Available at: https://www.gov.cn/zhengce/202401/content_6923987.htm (last viewed 18 September 2025).

(68) Ibid.

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

(70) Section VIII.16. Available at: https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (last viewed 18 September 2025).

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

(72) To ascertain that the import prices of the inputs were not affected by the market distortions, the Commission consulted the Global Trade Alert (available at https://globaltradealert.org/data-center; last viewed 14 August 2025) database and the Market Access Map (available at https://www.macmap.org/en/query/regulatory-requirement; last viewed 14 August 2025).

(73) Global Trade Alert. Indonesia: Relaxed import and export licensing requirements. Available at https://globaltradealert.org/intervention/85328-indonesia-relaxed-import-and-export-licensing-requirements (last viewed 2 September 2025).

(74) Global Trade Alert. Malaysia: Imposition of import licensing requirements on certain nicotine-based products, chemicals and smoking replacement aids. Available at https://globaltradealert.org/state-act/27000 (last viewed 2 September 2025).

(75) Eurostat – Methodologies and working papers. NACE Rev. 2 – Statistical classification of economic activities in the European Community. Available at https://ec.europa.eu/eurostat/documents/3859598/5902521/KS-RA-07-015-EN.PDF (last viewed 14 August 2025).

(76) Orbis database of Bureau Van Dijk Editions, a Moody’s Analytics company. Available at https://login.bvdinfo.com/R1/Orbis (last viewed 2 September 2025).

(77) Global Trade Atlas. Available at https:/connect.ihsmarkit.com/gta/home/ (last viewed 19 August 2025).

(78) 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.

(79) Market Access Map. Customs Tariff. Available at https://www.macmap.org/en/query/customs-duties (last viewed 28 August 2025).

(80) Brazil was not affected by the alleged data manipulation in Doing Business reports of 2018 and 2020. See Investigation of Data Irregularities in Doing Business 2018 and Doing Business 2020. Available at https://thedocs.worldbank.org/en/doc/84a922cc9273b7b120d49ad3b9e9d3f9-0090012021/original/DB-Investigation-Findings-and-Report-to-the-Board-of-Executive-Directors-September-15-2021.pdf (last viewed 20 August 2025).

(81) World Bank. Business ready 2024. Available at https://www.worldbank.org/en/businessready (last viewed 28 August 2025).

(82) Brazil was not affected by the alleged data manipulation in Doing Business reports of 2018 and 2020. See Investigation of Data Irregularities in Doing Business 2018 and Doing Business 2020. Available at https://thedocs.worldbank.org/en/doc/84a922cc9273b7b120d49ad3b9e9d3f9-0090012021/original/DB-Investigation-Findings-and-Report-to-the-Board-of-Executive-Directors-September-15-2021.pdf (last viewed 20 August 2025).

(83) Doing Business 2020. Economy profile – Brazil, p. 84 and 88. Available at https://archive.doingbusiness.org/content/dam/doingBusiness/country/b/brazil/BRA.pdf (last viewed 20 August 2025).

(84) World Bank. A Global Database of Inflation. Available at https://www.worldbank.org/en/research/brief/inflation-database (last viewed 20 August 2025).

(85) IBGE. PIA-Empresa – Annual Survey of Industry – Enterprise. Available at https://www.ibge.gov.br/en/statistics/economic/industry-and-construction/16906-pia-enterprise-pia1.html?lang=en-GB&t=downloads (last viewed 29 August 2025).

(86) Phosphorous acid is, inter alia, a vital precursor in the manufacturing of phosphate fertilisers. See, for example, https://www.blitchem.com/phosphorous-acid-h3po3-uses-applications-and-benefits-in-various-industries/ (last viewed 29 August 2025).

(87) ILOSTAT. Country profiles – Brazil. Available at https://ilostat.ilo.org/data/country-profiles/ (last viewed 29 August 2025).

(88) Ministério de Minas e Energia. Boletins Mensais de Energia. Available at https://www.gov.br/mme/pt-br/assuntos/secretarias/sntep/publicacoes/boletins-mensais-de-energia/boletins%20anos%20anteriores/2024/english (last viewed 28 August 2025).

(89) Ministério de Minas e Energia. Boletins Mensais de Energia. Available at https://www.gov.br/mme/pt-br/assuntos/secretarias/sntep/publicacoes/boletins-mensais-de-energia/boletins%20anos%20anteriores/2024/english (last viewed 28 August 2025).

(90) Compare the price of natural gas for consumption range of 20 000 m3/day in December 2024 published in Boletim Mensal de Acompanhamento da Indústria de Gás Natural – December 2024 (Histórico de Preços – Segmento Industrial, p. 13). Available at https://www.gov.br/mme/pt-br/assuntos/secretarias/petroleo-gas-natural-e-biocombustiveis/publicacoes-1/boletim-mensal-de-acompanhamento-da-industria-de-gas-natural/2024 (last viewed 29 August 2025). And the same price published in Boletim Mensal de Energia – December 2024 (p. 6). Available at https://www.gov.br/mme/pt-br/assuntos/secretarias/sntep/publicacoes/boletins-mensais-de-energia/boletins%20anos%20anteriores/2024/english (last viewed 29 August 2025).

(91) U.S. Department of Energy. Benchmark the Fuel Cost of Steam Generation. Available at https://www.energy.gov/sites/prod/files/2014/05/f16/steam15_benchmark.pdf (last viewed 28 August 2025).

(92) Central de Resultados – Resultados 2024. Available at https://ri.vittia.com.br/pt/informacoes-financeiras/central-de-resultados (last viewed 14 August 2025).

(93) Informações Financeiras Intermediárias Individuais e Consolidadas 31 de Dezembro de 2024. Available at https://solucoes.nortox.com.br/hc/pt-br/articles/39105568452244-Informa%C3%A7%C3%B5es-Financeiras-Intermedi%C3%A1rias-Individuais-e-Consolidadas-31-de-Dezembro-de-2024 (last viewed 14 August 2025).

(94) The Surveillance 3 database is managed by DG TAXUD and provides information on EU export and import transactions (if declared for entry for free circulation), at TARIC level and including the additional TARIC codes (for individual exporting producers subject to ADD, for example) on a daily basis. It is a useful tool to check latest data, as Comext data is only updated with a two-three months delay.

(95) t25.009782.

(96) State Council Customs Tariff Commission. Notice on Adjusting Export Tariffs on Certain Products. Tariff Commission [2009] No 6. Available at https://www.gov.cn/zwgk/2009-06/22/content_1347236.htm (last viewed 10 September 2025).

(97) Announcement of the State Council Tariff Commission on the Issuance of the ‘Customs Tariff of the People’s Republic of China for Import and Export (2024)’. Tariff Commission Announcement No 12 of 2023. Available at https://www.gov.cn/zhengce/zhengceku/202312/content_6923614.htm (last viewed 10 September 2025).