Commission Implementing Regulation (EU) 2025/2333 of 19 November 2025 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of hardwood plywood originating in the People’s Republic of China
(162) The Commission recalled that the objective of not establishing the residual duty based on the dumping margin of the only cooperating party of the initially sampled parties was not to penalise the cooperating non-sampled companies, but rather to establish a duty based on the best available data, given the lack of cooperation from the initially sampled companies. The Commission disagreed that the duty rate for the non-sampled cooperating producers should have been established based on duty rate for Jiangshan Wood. Establishing the dumping margin for all the imports solely on data of one company may not have resulted in a representative dumping margin, since in this specific case, Jiangshan Wood’s exports to the Union only amounted to some 5 % of all the exports to the Union. This is different from a situation where dumping margin for cooperating non-sampled companies is based on a sample which is sufficiently representative. In this case the sampling was abandoned, and hence no sampled average duty for cooperating non-sampled companies could be calculated.
(163) The Commission further recalled that, as regards the export price, the residual duty was already based on the data of all exporting producers as export prices were based on Eurostat statistics. As regards the normal value, data of Jiangshan was used. Therefore, the Commission considered this as a reasonable and accurate method to calculate the residual duty rate and thus rejected the claim.
(164) With regard the request to disclose the list of non-sampled cooperating companies, the Commission recalled that sampling replies of the companies could be consulted in the open file. The list of the companies would only be part of a Regulation in case these companies obtain an individual TARIC code and duty rate, which was not the case. Furthermore, the fact that the companies were not listed in a separate annex did not affect the right of the companies to challenge the Commission’s findings in the Union Courts. The Commission thus disagreed that it should do a specific disclosure of a list of non-sampled cooperating producers.
(165) With regard to the calculations, the Commission considered these could not be disclosed, since the calculations were based on the normal value of Jiangshan Wood. Disclosure would therefore reveal confidential data of the company. The Commission however stressed that the method as to how the duty level for all other imports was established was sufficiently detailed in Section 3.5 of the provisional Regulation, which allowed the parties to make comments. The Commission thus rejected the claim that a detailed calculation of duty for all other imports should have been disclosed.
(166) Following the final disclosure, Saintland Wood submitted that it was not reasonable to establish two levels of the anti-dumping duty, one for Jiangshan Wood, and a second one for all other companies, and that the Commission should rather consider that the non-cooperating companies behaved as Jiangshan Wood. It mentioned that despite some companies were not unwilling to cooperate, they became subject to punitive measures.
(167) The Commission first recalled that the residual duty was not set to have an unfair effect. In case of non-cooperation, the Commission had no other choice than to base its findings on ‘facts available’ and that in this particular case, the duty reflected the export price of all non-cooperating producers, and therefore, the method more accurately reflected the behaviour on the non-cooperating producers than if the duty was based solely on data of Jiangshan Wood. The Commission recalled that this was explained in detail above in Section 1.6.2. The claim was thus rejected.
(168) The complainant claimed that both the dumping margin of Jiangshan Wood, as well as for the other producers in China, was very low, considering the market distortions found in China in the plywood industry, and the very low pricing levels widely available for the Chinese imports in the Union. It argued that the dumping margins were also much lower compared to the injury elimination levels found by the Commission. Therefore, the levels of the provisional duties were not sufficient to level the playing field and allow the Union producers to recover from the material injury. The complainant also argued that, in view of the very low level of cooperation by the Chinese exporting producers, the Commission should apply the wide margin of discretion it enjoys in trade defence cases and apply the highest possible anti-dumping duty for all other non-cooperating Chinese producers.
(169) The complainant also argued that, based on the information in the open file (such as sampling form or notes on factors of production), Jiangshan Wood exports predominantly poplar, which was the cheapest hardwood plywood by far compared to other types of plywood. It pointed out to the fact that the export price was mainly determined based on all imports to the Union including cheaper poplar plywood but also more expensive, eucalyptus and birch plywood. The complainant submitted the price differences based on Eurostat data demonstrating the price difference. It therefore requested the Commission to change the approach by adjusting the export price and by using solely the export price for poplar plywood, since it considered that this method would better reflect the dumping behaviour of the non-cooperating exporters.
(170) Contrary to the complainant’s allegations, Jiangshan Wood exported to the Union not only poplar but also other more expensive types of plywood such as eucalyptus and birch. It was thus not justified to base the export price solely on the exports of poplar plywood, since other more expensive types of plywood represented a sufficient share within the exports of Jiangshan Wood. These shares of poplar wood and other more expensive types exported by Jiangshan Wood were comparable to shares in the overall imports of hardwood plywood into the Union from the PRC, which confirmed that the use of Eurostat statistics to establish the export price in this case was reasonable and accurate. The Commission thus maintained that the method it used to establish the dumping margin for all other imports did not lead to any asymmetry and was accurate and reasonable. The Commission thus rejected the claim.
(172) Following the provisional disclosure, the PTIA pointed out that the Commission relied on data from a macro questionnaire by the European Panel Federation (‘EPF’) in recital (247) of the provisional Regulation without mentioning the sources of the data.
(173) The Commission referred the PTIA to the public version of the macro questionnaire reply (88) which itself refers to confidential information from EPF. The questionnaire reply of the EPF was verified and the report was available in the public file (89).
(174) Following the provisional disclosure, the PTIA requested the Commission to clearly indicate which companies were included under the term ‘Complainant’.
(175) The Commission defined the term ‘Complainant’ in recital (2) of the provisional Regulation.
(176) Following the provisional disclosure, the PTIA claimed that the injury analysis was flawed because it did not contain an analysis per hardwood species.
(177) The claim was rejected on the grounds that in view of the definition of the product concerned, see recitals (45) and (46) of the provisional Regulation, a separate injury analysis for each different species was not warranted. Furthermore, the main species, i.e. poplar, birch and eucalyptus, were examined, both in the injury and the dumping analysis.
(178) After the final disclosure, the PTIA reiterated that it had been prevented from a thorough and meaningful analysis of the complaint due to excessive and unjustified confidential treatment. The aggregation of injury indicators for the nine complainants was unjustified, allowing the PTIA to see the trends but preventing verification of data in individual years or checking injury indicators for consistency. The PTIA submitted that the objective legal standard for confidential treatment of injury indicators was not met.
(179) The Commission confirmed its findings in recital (13). The complaint included sufficient evidence on injury factors, as was reasonably available. The disclosure of this data in the open file in an aggregated format struck an adequate balance between the right of the complainant for confidential treatment of information and the right of defence of interested parties. The data allowed for an analysis of the trends in injury indicators providing sufficient evidence for a prima facie determination of injury at initiation. The Commission noted that its positive prima facie determination of the existence of injury at initiation was confirmed at both provisional and definitive stage of the investigation.
(180) After the final disclosure, the PTIA submitted that in case the Commission continued to consider that the product definition was correct and consistent with the birch plywood from Russia case, a segmented injury analysis should be conducted.
(181) The Commission rejected the argument because the PTIA did not define the precise segments that were meant to be analysed separately, nor did it supply evidence of their existence and the clear dividing lines between them. In this respect, a reference to the ruling of the Court in the birch plywood from Russia case that distinguished poplar, birch and beech as wood species used for the face veneer was not considered sufficient or precise enough. In addition, the Commission found in recital (53), (64), (74) and (242) that birch and eucalyptus plywood, as well as eucalyptus and beech plywood were interchangeable and, therefore, there was competition between these adjoining products. These specific findings were not challenged by interested parties. In view of the above, the claim was rejected.
(182) In the absence of any comments regarding the definition of the Union industry, recitals (246) to (247) of the provisional Regulation were confirmed.
(183) In the absence of any comments regarding Union consumption recitals (248) to (250) of the provisional Regulation were confirmed.
(184) Following the provisional disclosure, CEP, an ad hoc association of Chinese producers, argued that the decline in Chinese import prices in 2023 and the IP should have resulted in significantly increased imports. Instead, the volume of imports from China declined in 2023 compared to 2022, the previous year, and only increased marginally in the IP.
(185) The argument was rejected, because the volume of imports was affected by several other factors than only prices. In 2022, such factors were the removal of Russian and Belarusian plywood from the Union market by sanctions and the expectation of economic recovery following the COVID-19 pandemic whereby orders increased significantly. These factors pushed up the quantity of imports from China in 2022. The effect of those factors, however, was less pronounced in the following years, so that imports first decreased in 2023 before increasing again in the IP.
(186) In the absence of any comments regarding prices of imports from the country concerned, recitals (258) to (260) of the provisional Regulation were confirmed.
(187) Following the provisional disclosure, the PTIA challenged the representativity of the undercutting and underselling calculation arguing that imported film-faced eucalyptus plywood could not be compared with Union industry production and should be rejected from the product scope as explained and addressed in Section 2.1.2. Should the product scope rejection be denied, PTIA requested the Commission to ensure fair comparison by taking price difference between structural vs non-structural characteristics in the calculations.
(188) The Commission found that the overwhelming majority of imported PRC film faced hardwood plywood was poplar and eucalyptus, while the sampled complaining Union producers produced film faced hardwood plywood using mostly birch. There was a price difference in the resulting product due to the variance in the price of the raw material used. The Commission, therefore, performed a quality adjustment, based on the price difference between the average purchase price paid during the IP of poplar and birch logs in the EU, in order to meaningfully compare matching types of film faced hardwood plywood produced by the Union industry and imported from the PRC. The result of the adjustment was a decrease of the undercutting margin from 46,3 % to 32,3 % and of the underselling margin from 144,37 % to 93,16 % for Jiangshan Wood and a corresponding decrease from 192,7 % to 185,9 % for all other PRC imports.
(189) In the absence of any comments regarding general remarks, recitals (264) to (268) of the provisional Regulation were confirmed.
(190) Following the provisional disclosure, CEP argued that production capacity remained stable and that a production decline of 11 % during the period considered was normal.
(191) The argument was rejected, as a decline of 11 % in production volume of the Union industry from 2021 to the IP, especially in view of the market gap created by the sanctions against Russia and Belarus, was detrimental to the Union industry.
(192) Following the provisional disclosure, the PTIA claimed that capacity utilisation of the Union industry has been stable.
(193) The Commission rejected the claim because capacity utilisation declined by 9 % from 2021 to the IP.
(194) Following provisional disclosure, the PTIA claimed that it was erroneous for the Commission to consider in recital (270) of the provisional Regulation that the Union industry could have increased its production capacity to fill in some of the gap in the market created by the banning of Russian and Belarusian hardwood plywood in 2022.
(195) After the imposition of the ban on Russian and Belarusian hardwood plywood, the Union plywood industry having a large spare production capacity had a justified expectation that the demand for hardwood plywood could shift to its own products. Instead, at least partly, that demand was supplied by dumped and injurious Chinese imports. The availability of raw material for such an increase, disputed by the PTIA, does not take into account the harvesting of reserve plantations and the trade in logs and veneer.
(196) Following the provisional disclosure, the PTIA noted that a capacity utilisation of 66 % was realistic for the Union industry. Furthermore, CEP claimed that the capacity utilisation was already low at the beginning of the period considered, in 2021. Therefore, its subsequent decline could not be attributed to imports from China but to a general lack of business know-how of the Union industry.
(197) The Commission rejected these arguments, these were not backed by any evidence.
(198) In the absence of any comments regarding sales quantity, recitals (273) to (275) of the provisional Regulation were confirmed.
(199) Following the provisional disclosure, the PTIA noted that the market share of the Union industry had increased. They argued that the explanation provided in recital (276) of the provisional Regulation whereby the exclusion of Russian and Belarusian hardwood plywood products from the Union market led to a decrease in consumption was illogical as illegal Russian plywood continued to enter the Union market as evidenced by the conclusions of the anti-circumvention investigation of birch hardwood plywood from Kazakhstan and Türkiye (90) (‘the anti-circumvention investigation’). PTIA added that the decrease in consumption was rather linked to a normalisation of the demand following the post-Covid economic rebound.
(200) The claim was rejected because in the anti-circumvention investigation, evidence was found that 130 900 m3 of Russian hardwood plywood were imported through Kazakhstan and Türkiye in July 2022–June 2023, which was less than 10 % of the amount imported from Russia and Belarus in 2021, i.e. the last year before the introduction of the sanctions. Hence, if there was a displacement of the imports from Russia and Belarus to consignments from Kazakhstan and Türkiye, it was only limited.
(201) In any case, the sales of the Union industry decreased by 12 % or more than 165 000 m3 between 2021 and the investigation period, whereas imports from the PRC increased by 16 % and over 100 000 m3 in the same period. The market share of the Union industry increased by 25 % between 2021 and the investigation period but that of the Chinese imports increased by 67 % in the same period. On this basis, this claim was rejected.
(202) In the absence of any comments regarding growth, recital (278) of the provisional Regulation was confirmed.
(203) Following the provisional disclosure, CEP argued that the level of employment of the Union industry was stable and that its productivity showed a positive development.
(204) The arguments were rejected, because the 2 % decline in employment, 11 % fall in production volume and 9 % decrease in productivity showed a deterioration of the situation of the Union industry rather than signalling stability or improvement as argued by CEP. The Commission also recalled that its injury analysis was not simply static, only comparing end-points, but also dynamic, analyzing the trend in between end-points, too. In the case at hand, the dynamic analysis of the employment, production volume and productivity data confirmed the existence of material injury.
(205) In the absence of any comments regarding the magnitude of the dumping margin and recovery from past dumping, recitals (283) to (284) of the provisional Regulation were confirmed.
(206) Following the provisional disclosure, the PTIA highlighted that the significant increase in Union sales prices between 2021 and 2023 demonstrated that there was no injury to the Union industry.
(207) The Commission rejected the argument because the increase in the sales price was offset by the significant increase of production costs. The price depression by imports lead to the loss of profitability by the Union industry, indicating material injury. Furthermore, the Commission also considered that conclusions on the overall situation of the Union industry should not be based on certain injury indicators taken in isolation, but rather on an assessment of the evolution of the whole set of injury indicators during the period considered.
(208) In the absence of any comments regarding labour costs, recitals (289) and (290) of the provisional Regulation were confirmed.
(209) Following the provisional disclosure, PTIA submitted that the stock level increase should be considered immaterial as, when expressed as a percentage of production, it increased only from 1,74 % in 2021 to 2,43 % in the IP.
(210) The Commission noted that PTIA did not dispute that there was an increase in stocks both in relative and absolute terms, as assessed by the Commission. The 2,43 % of unsold hardwood plywood stocks in the IP, labelled ‘immaterial’ by PTIA, in real terms accounted for 44 504 m3 of the product under investigation, i.e. more than the amount of birch plywood from Russia that was found to be circumvented through Türkiye in the anti-circumvention investigation. Moreover, any increase in stocks represents a cost for its holder that needs to be financed. The Commission rejected the argument.
(211) Following the provisional disclosure, the PTIA expressed concerns regarding the representativeness of the profitability of the sampled companies. It identified certain birch plywood producers that reported good results in the period considered. PTIA argued that it was not able to comment on which wood species will be affected more by the measures because the Commission had not performed an analysis per segment.
(212) The Commission rejected the argument because the profitability of the Union industry was assessed by examining a duly selected representative sample of Union producers of the product under investigation. Its representativity was not disputed by interested parties at sampling stage. Furthermore, Union producers, including those referenced by the PTIA, did not manufacture the product under investigation only, whereby the scope of the investigation was narrower than their published financial results. The Commission determined in recital (55) of the provisional Regulation that the basic physical, technical and chemical characteristics of plywood made from all hardwood species were the same and they formed a single product category, thereby making an analysis per segment unnecessary. The determination regarding basic physical, technical and chemical characteristics of hardwood plywood from different species has been challenged by the PTIA based on the findings and the Court ruling in the Russia birch plywood case but was rejected in recitals (55) and (56) of the provisional Regulation and recital (52), above. On this basis, the claim was rejected.
(213) Following the provisional disclosure, the PTIA claimed that Union prices were not depressed and that the profitability issues resulted from cost of production increases. The PTIA claimed that Union industry’s sales prices increased in the IP according to market reality leading to a loss of profitability, and that the Union sales volume followed the general decline in consumption. PTIA argued that the Commission erred by attributing the decline in consumption to the Russian and Belarusian plywood ban because the anti-circumvention investigation demonstrated that Russian birch plywood continued entering the Union market.
(214) In the absence of any new evidence, the Commission sustained its findings in recitals (285)–(288) of the provisional Regulation. The argument relating to the decline in consumption was addressed in recital (200).
(215) Following the provisional disclosure, the PTIA claimed that there is no investment benchmark demonstrating the health of an industry, the hardwood plywood industry is not capital intensive and noted that investments between 2023 and the IP increased by 8 %.
(216) The Commission sustained its finding in recital (296) of the provisional Regulation that investment by the Union industry decreased by 31 % during the period considered. The existence of a benchmark and the capital intensity of the hardwood plywood industry were irrelevant because these injury indicators were not analysed separately but as a part of a larger analysis of material injury indicators, meaning that even without a benchmark or an assessment of the capital intensity of the industry, the trend of the decrease in investment supported rather than negated the existence of material injury.
(217) Following the provisional disclosure, the PTIA claimed that for reasons discussed above, injury indicators did not support the provisional conclusion of the Commission that the Union industry suffered injury.
(218) The Commission addressed the claims by the PTA with regard to a number of injury indicators above, see recitals (172) to (177), (187) to (188), (192) to (196), (199) and (200), (206) to (207), and (209) to (210). With exception of the comment on undercutting, the claims of the PTIA were rejected. The recalculated undercutting margins remained, however, high, see recital (188).
(219) The Commission, therefore, maintained the conclusion that the Union industry suffered material injury within the meaning of Article 3(5) of the basic Regulation.
(220) Following the provisional disclosure, the PTIA claimed that the Commission did not properly assess the impact of the increase of the volume of imports and that there was no significant increase of import volume of Chinese origin in relation to consumption or production quantity in 2023 and the IP. Imports peaked in 2022 with an increase of 32 % but, in 2023 and the IP, imports were only 11 % and 16 % higher than in 2021, respectively. The PTIA took issue with the statement in recital (324) of the provisional Regulation that Chinese manufacturers were ‘continuously increasing their import volumes at significantly lower prices’.
(221) The Commission when assessing the volume of imports and their impact on prices found that a significant increase in the volume of imports in 2022, was followed by a more moderate increase in 2023 and the IP as compared to 2021, at sharply declining prices. These trends, however, continued to point to the existence of a causal link between imports from China and the injury suffered by the Union industry. Import of hardwood plywood from China in relation to Union consumption rose from 18 % in 2021, to 26 % in 2022, and 29 % in 2023, increasing again to 31 % in the IP. In relation to Union production, the percentage of Chinese imports was 37 % in 2021 that grew to 49 %, 44 % and 48 % in 2022, 2023 and the IP, respectively. The argument was, therefore, rejected.
(222) Following the provisional disclosure, the PTIA submitted that the more significant increase of the production costs of the Union industry in relation to its sales price was the result of extraordinary events like the increase in the cost of raw materials, the war in Ukraine and the resulting energy crisis.
(223) The Commission found that the Union industry was able to increase prices above its production costs in 2022. However, following this increase, sales prices declined and remained below the level of production costs. The latter were constant in 2023 and the IP. The element impacting Union industry prices showing change was the increasing volume and decreasing price of Chinese imports. On this basis, the Commission maintained its conclusion that Chinese imports were causing injury to the Union industry.
(224) Following the provisional disclosure, CEP argued that the sales prices of the Union industry were not affected by the decline in import prices because when import prices dropped significantly in 2023, while the Union industry was able to increase prices.
(225) As already set out in recitals (306) and (307) of the provisional Regulation, the drop in the prices of Chinese imports prevented the Union industry from raising its prices above its production costs. The Commission found that the claim of CEP rather than showing a lack of causality demonstrated that in a situation of increasing production costs and decreasing import prices, the Union industry attempted but did not succeed raising its prices to sustainable levels, precisely because of the low-priced imports.
(226) Following the provisional disclosure, to demonstrate the alleged lack of causal link, the PTIA referred to production cost data from the birch plywood from Russia case (91), where Paged, one of the sampled Union producers in this case was also part of the sample.
(227) The reference was deemed irrelevant because it concerned a case with a different investigation period and product scope.
(228) After the final disclosure, the PTIA submitted that the increase of production costs of the Union industry was so sharp that it could not be passed on to customers in full in the form of price increases. It was the pace of the increase of costs rather than the presence of low-priced Chinese imports that prevented the Union industry from raising prices to a profitable level.
(229) The Commission rejected the argument because the radical increase in production costs of the Union industry in 2022 compared to the year 2021, was matched by a corresponding price increase, showing that the former could be passed on to consumers. The further, a much smaller increase in production costs in 2023 and the investigation period could not be passed on leading to a situation where the profitability of the Union industry turned negative, as stated in recital (288) of the provisional Regulation.
(230) Following the provisional disclosure, the PTIA and CEP attributed the injury suffered by the Union industry to the decline of its export performance.
(231) The Commission found that more than 80 % of the sales of the Union industry were made in the Union and that exports were profitable throughout the period considered. Given the share of the export sales, their decline was not considered to attenuate the causal link between the injury suffered by the Union industry and the dumped Chinese imports.
(232) The Commission assessed the impact of all known factors, taking into account the comments of interested parties, and concluded that those factors did not attenuate the causal link. The Commission, therefore, confirmed the conclusions in recitals (332) to (334) of the provisional Regulation that there was a causal link between the injury suffered by the Union industry and the dumped imports from China.
(233) In the present case, the complainant claimed the existence of raw material distortions within the meaning of Article 7(2a) of the basic Regulation. 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. Then it examined whether the dumping margin of the sampled exporting producers would be higher than their injury margin.
(234) Based on data from the Surveillance 2 database, import volumes from China during the four weeks period before pre-disclosure were 82 % lower than the average import volumes in the investigation period on a four-week basis. On that basis, the Commission concluded that there had not been a substantial rise in imports subject to the investigation during the period of pre-disclosure.
(235) The Commission, therefore, did not adjust the injury elimination level in this regard.
(237) In recital (347) of the provisional Regulation, it was established that the margins adequate to remove injury were higher than the dumping margins.
(238) After the revision of the injury elimination levels at definitive stage, the margins adequate to remove injury remained higher than the dumping margins. The Commission thus maintained that it was appropriate to determine the amount of definitive duties in accordance with Article 7(2) of the basic Regulation.
(240) Following the provisional disclosure, the PTIA argued that it is not in the interest of the Union industry to impose measures on Chinese film-faced plywood for formwork, because, in view of the limitations of formwork plywood production in the EU, it is not economically viable for the Union industry to produce it.
(241) The Commission noted that Chinese film-faced plywood can have different grades of durability, some can be used up to ten times for formwork. The Union industry produced high and lower durability film-faced plywood using different hardwood species. Restoring fair pricing in this part of the film-faced plywood market is clearly in the interest of the Union industry.
(242) As far as low-reusability film faced plywood, mainly used by construction firms for formwork was concerned, during the verification of the questionnaire reply of one of the sampled Union producers, the claim was made that in case of fair pricing the company is capable and willing to produce it The Commission has no reason to doubt this specific statement especially in the light of the fact that beech plywood produced in the Union may be a viable alternative for low-reusability film-faced Chinese imports, as explained in recital (73). The argument was, therefore, rejected.
(243) Following the provisional disclosure, ISB, a sampled unrelated Union importer, argued in its questionnaire reply that the measures would cause a shortage in product supply and an increase in their price for the end consumer. Altripan, another sampled unrelated Union importer, argued in its questionnaire reply that importers and traders relying on Chinese-origin products would face increased costs, leading to reduced margins or higher prices for downstream buyers. Altripan supported the imposition of anti-dumping duties on birch plywood, but as a member of the PTIA, argued for the exclusion of poplar and eucalyptus plywood, addressed in Section 2.1.1 and Section 2.5 of the provisional Regulation. The PTIA submitted support letters from importers and users opposing the imposition of the measures (92). These letters were based on common templates and were unsupported by additional evidence.
(244) The Commission considered that when birch hardwood plywood from Russia and Belarus was banned by sanctions in 2022 supply was substituted by eucalyptus hardwood plywood, mainly from the PRC. In case the measures imposed on hardwood plywood from the PRC in this investigation would cause temporary disturbances in the Union market, importers will be able to rely on sources of supply in Southeast Asia, Africa or Latin America to supply hardwood plywood to substitute current imports from the PRC, should importers and/or users wish to rely on an alternative source of supply.
(245) Following the provisional disclosure, ISB argued that the limited supply of logs in certain production centres, especially the Union, and the lack of their worldwide trade would make it impossible to find alternative sources to the volume of hardwood plywood currently supplied by China. PTIA highlighted that this is especially true for eucalyptus plywood where the Union industry does not have the capacity to supply the Union market with eucalyptus hardwood plywood panels due to the lack of eucalyptus logs.
(246) The Commission found evidence of imports to the Union of eucalyptus hardwood plywood produced in China from logs originating in Uruguay demonstrating that trade in logs existed and that the allegedly limited amount of logs available in the Union could be supplemented by imports. PTIA itself submitted that the EU relies on imports for its production of eucalyptus plywood.
(247) Following the provisional disclosure, the PTIA submitted that there was no verification of the replies of unrelated Union importers.
(248) Sampled unrelated importers providing a complete questionnaire reply were verified before final disclosure.
(249) In view of the above the Commission maintained that the overall benefits of the measures outweighed the potential negative impact for importers and confirmed the conclusions in recitals (360) to (361) of the provisional Regulation.
(250) After the final disclosure, Andrex submitted that it was not in the interest of the Union to impose anti-dumping duties on container flooring plywood boards made entirely of rubberwood. This product was fundamentally different from the birch, poplar, or eucalyptus plywood manufactured in the Union. There was no EU manufacturer of 28 mm container flooring plywood made of rubberwood. Andrex further claimed that the measures would disrupt the EU container-repair industry, force operators to import finished containers instead of repairing existing ones and undermine the EU circular economy objectives under the Green Deal.
(251) The Commission found that container flooring plywood boards made entirely of rubberwood were a lower quality alternative to container flooring plywood made of keuring and apitong, two tropical species widely used for the best quality container flooring. Container flooring plywood boards made entirely of rubberwood were in competition with bamboo plywood and steel flooring for containers, providing alternatives for container part importers in the Union. The Commission identified the UPM-Kymene Corporation of Finland as a significant actor in the container and truck flooring industry (93) in the Union, the Overseas Hardwood Company in the United States (94) and several companies in India (95) providing alternative sources of supply for Union importers of both high- and low-quality container flooring hardwood boards. Also, in the absence of cooperation at an earlier stage by Andrex or other companies operating in the container sector, and the consequent absence of verifiable information, the Commission was not in a position to confirm the claims of Andrex. The Commission, therefore, found that the overall benefits of the measures outweighed the potential negative impact for importers of container flooring hardwood plywood.
(252) Following the provisional disclosure, the PTIA, supported by the ETTF and GD Holz, complained that essential evidence in the form of support letters from users was not considered at provisional stage. In addition, the PTIA submitted further support letters from users.
(253) The Commission examined the support letters from users at definitive stage. The Commission found that the majority of the entities filing them did not register as interested parties, some of the letters filled in by hand were illegible, others were duplicates based on a common template. None of the letters was complemented by actual evidence in support of the statements contained therein. Nevertheless, the opposition of users to the measures, mainly representing the construction industry and its suppliers and other industries represented in the cover letters, was duly considered in respect of industrial users, e.g. the transport industry, and non-industrial users, as explained in recital (20) and recital (364) of the provisional Regulation
(254) Following the provisional disclosure, the ETTF and PTIA argued that the construction industry was struggling in the Union, and that their plight would be worsened by the increase in the cost of film faced plywood. The Union must ensure that a genuine universal right to housing is guaranteed, imposing anti-dumping duties on film faced plywood from China would lead to rising construction costs that are one of the main causes of the EU housing crisis. The PTIA listed a number of steps by the European Commission, the Economic and Social Committee and the European Parliament to support its position,
(255) The Commission examined the submission and found that its provisional determination, as reported in recital (364) of the provisional Regulation, that expenses related to film-faced plywood for formwork in construction projects amount to a small portion of the overall costs held true. Any increase in the price of film-faced plywood imported from China for end users, therefore, will only have a minor impact on the overall cost and affordability of housing and the demand for construction works. In addition, the international hardwood plywood market was diverse and flexible, with actors ranging from Indonesia to Uruguay, that can supply different parts of the Union market at competitive and fair prices. Furthermore, the level of the duties imposed in this investigation was not considered prohibitive so that importers can continue sourcing from Chinese exporting producers at fair prices.
(256) After the final disclosure, the PTIA argued that the Commission did not disclose the calculations supporting the findings that expenses related to film-faced plywood for formwork in construction projects amounted to a small portion of the overall costs.
(257) At provisional stage, the Commission found that for most industrial users generally the cost of hardwood plywood panels used for formwork for construction is not very significant in relation to its total costs, as mentioned in recital (364) of the provisional Regulation. The Commission noted that the PTIA did not supply evidence to the contrary. In addition, the Commission’s preliminary determination that costs related to film-faced plywood for formwork were low, was not challenged at preliminary stage by any interested party. Most importantly, such finding was not contested by interested parties including when the issue of the impact of measures on construction projects was raised by the Commission during the verification visit of the questionnaire reply of sampled importers, including a member of the PTIA. In addition, no construction company registered as an interested party supplying evidence of the exact proportion of film-faced plywood for formwork costs in its projects. In view of the above, the argument was rejected.
(258) In view of the above, the Commission maintained that the overall benefits of the measures outweighed the potential negative impact for users and, therefore, the conclusions in recitals (362) to (364) of the provisional Regulation were confirmed.
(259) On the basis of the above, the Commission concluded that there were no compelling reasons to rule that it was clearly not in the Union interest to impose measures on imports of hardwood plywood originating in China.
(260) After the final disclosure, the PTIA submitted that at provisional stage, the views of users, mainly in the construction sector, supporting the PTIA were not considered at all and that there was no injury analysis by product segment, these alleged shortcomings rendered inadequate the assessment of Union interest by the Commission.
(261) The argument about the views of users in the construction sector was rebutted in recitals (29) and (253). The argument about the necessity of segmented injury analysis was rebutted in recital (181) and (212). The Commission, therefore, rejected the claim that the analysis of Union interest is inadequate.
(262) After the final disclosure, Saintland Wood submitted that it is not in the interest of the Union to replace Chinese plywood products with Southeast Asian and South American imports, where, compared to China, the level of the protection of the environment was lower, and forests were not managed in a sustainable way.
(263) The Commission rejected the argument because the purpose of the measures is not to replace Chinese plywood with other sources but to restore a level playing field. The Commission noted, during the verification of unrelated importers, that at the individual company level, Forest Stewardship Council (‘FSC’) qualification (96) of imports was widespread because consumers in the Union market demanded it. Should Chinese imports be replaced with Southeast Asian and South American, the Commission considered that the new entrants would face pressure to comply with the same requirements.
(264) 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.
(266) The individual company anti-dumping duty rate specified in this Regulation was established on the basis of the findings of this investigation. Therefore, it reflects the situation found during this investigation in respect to this company. This duty rate is thus exclusively applicable to imports of the product under investigation originating in the country concerned and produced by the named legal entity. 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 People’s Republic of China’.
(267) 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 (97). 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.
(268) 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’.
(269) 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.
(270) Should the exports by the company benefiting from lower individual duty rate 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.
(271) To ensure a proper enforcement of the anti-dumping duties, the anti-dumping duty for all other imports originating in the People’s Republic of China 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.
(272) Statistics of hardwood plywood are frequently expressed in m3. There is a supplementary unit for CN codes 4412 31 10 , 4412 31 90 , 4412 33 10 , 4412 33 10 , 4412 33 20 , 4412 33 30 , 4412 33 90 , and 4412 34 00 for the hardwood plywood specified in the Combined Nomenclature laid down in Annex I to Council Regulation (EEC) No 2658/87 (98). Accordingly, the supplementary unit m3 is applicable for TARIC codes 4412 31 10 80, 4412 31 90 00, 4412 33 10 12, 4412 33 10 22, 4412 33 10 82, 4412 33 20 10, 4412 33 30 10, 4412 33 90 10 and 4412 34 00 10 and must be entered in the declaration for release for free circulation. The weight in kg or tonnes should be indicated independently from the supplementary unit (i.e. the number in m3).
(273) 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.
(274) As mentioned in Section 1.2, the Commission made imports of the product under investigation subject to registration.
(275) 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.
(277) After the final disclosure, the complainant submitted that the Commission’s assessment of the conditions for retroactivity, especially the fourth condition in Article 10(4) of the basic Regulation, failed to take into account imports arriving into the Union under CN codes ex 4412 10 00 and ex 4412 39 00 (TARIC codes 4412 10 00 10 and 4412 39 00 20) for which monitoring was introduced following the imposition of provisional measures and Article 1(5), thereof.
(278) The Commission rejected the argument because the requirement of further substantial rise in imports in Article 10(4) of the basic Regulation referred to the product under investigation. The monitored products, made of bamboo or softwood, were outside the product scope of the investigation and their customs codes, being created by the provisional Regulation, did not exist during the investigation period. Their alleged change in import pattern, therefore, could not be taken into account 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.
(279) In recital (382) of the provisional Regulation, the Commission decided to monitor imports under newly created TARIC codes within CN codes 4412 10 00 and 4412 39 00 , in view of alleged circumvention consisting of placing very thin outer layers of softwood veneer on top of the hardwood plywood face veneer.
(280) After the provisional disclosure, the PTIA and the unrelated importer and wholesaler Ljungberg Fritzoe, respectively, submitted that imports of plywood with both outer plies made of coniferous wood and with a core containing plies of non-coniferous wood did not represent a new practice since it imported this type of plywood in the past. Ljungberg Fritzoe submitted that this type of plywood (‘K-plywood Twin’) served a specific purpose on the market, since due to its light weight and material composition, it was well suited for a wide range of interior and non-structural applications. Its main use, however, was in wall constructions, as a wall panel behind gypsum board. It, therefore, considered that absence of a change of a pattern of trade, the practice did not constitute an anti-circumvention. It also urged the Commission to apply a consistent and cautious approach to product scope, since in view of the concurrent investigation covering softwood plywood from Brazil, an unwarranted extension of the current case risked undermining the legal certainty for importers and weakening the clarity of the Union trade remedy framework. The PTIA listed several products by the Union industry combining softwood and hardwood as alleged proof that placing very thin outer layers of softwood veneer on top of the hardwood plywood face veneer is common practice.
(281) The Commission considered that these submissions constituted no reason to cease the monitoring of the imports of this product type. These elements will nevertheless be considered in any follow-up action the Commission may resort to in the future linked to possible circumvention activities.
(282) The measures provided for in this regulation are in accordance with the opinion of the Committee established by Article 15(1) Regulation (EU) 2016/1036,
HAS ADOPTED THIS REGULATION:
Article 1
A definitive anti-dumping duty is imposed on imports of plywood consisting solely of sheets of wood other than bamboo and okoumé, each ply not exceeding 6 mm thickness, with at least one outer ply of tropical wood or non-coniferous wood, of species specified under subheadings 4412 31 , 4412 33 and 4412 34 , whether or not coated or surface-covered, currently falling under CN and TARIC codes 4412 31 10 80, 4412 31 90 00, 4412 33 10 12, 4412 33 10 22, 4412 33 10 82, 4412 33 20 10, 4412 33 30 10, 4412 33 90 10 and 4412 34 00 10, and originating in the People’s Republic of China.
The rate of the definitive anti-dumping duty applicable to the net, free-at-Union-frontier price, before duty, of the products described in paragraph 1 and produced by the companies listed below, shall be as follows:
The application of the individual duty rate specified for the company mentioned in paragraph 2 shall be conditional upon presentation to the Member States’ customs authorities of a valid commercial invoice, on which shall appear a declaration dated and signed by an official of the entity issuing such invoice, identified by name and function, drafted as follows: ‘I, the undersigned, certify that the (volume) of (product concerned) sold for export to the European Union covered by this invoice was manufactured by (company name and address) (TARIC additional code) in [country concerned]. I declare that the information provided in this invoice is complete and correct.’ Until such invoice is presented, the duty applicable to all other imports originating in the People’s Republic of China shall apply.
Where a declaration for release for free circulation is presented in respect of the product referred to in paragraph 1, irrespective of its origin, the size in cubic metres of the products imported shall be entered in the relevant field of that declaration.
Member States shall, on a monthly basis, inform the Commission of the number of cubic metres imported under CN and TARIC codes 4412 31 10 80, 4412 31 90 00, 4412 33 10 12, 4412 33 10 22, 4412 33 10 82, 4412 33 20 10, 4412 33 30 10, 4412 33 90 10 and 4412 34 00 10.
Imports of plywood with both outer plies made of coniferous wood or bamboo and with a core containing plies of species specified under subheadings 4412 31 , 4412 33 and 4412 34 , whether coated or surface covered or not, currently falling under CN codes ex 4412 10 00 and ex 4412 39 00 (TARIC codes 4412 10 00 10 and 4412 39 00 20) shall be monitored by the Commission.
Unless otherwise specified, the provisions in force concerning customs duties shall apply.
Article 2
The amounts secured by way of the provisional anti-dumping duty under Commission Implementing Regulation (EU) 2025/1139 shall be definitively collected. The amounts secured in excess of the definitive rates of the anti-dumping duty shall be released.
Article 3
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, 19 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 hardwood plywood originating in the People’s Republic of China (OJ C, C/2024/6048, 11.10.2024, ELI: http://data.europa.eu/eli/C/2024/6048/oj).
(3) Commission Implementing Regulation (EU) 2024/3140 of 17 December 2024 making imports of hardwood plywood originating in the People’s Republic of China subject to registration (OJ L, 2024/3140, 18.12.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/3140/oj).
(4) Commission Implementing Regulation (EU) 2025/1139 of 6 June 2025 imposing a provisional anti-dumping duty on imports of hardwood plywood from the People’s Republic of China (OJ L, 2025/1139, 10.6.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/1139/oj).
(5) The Spanish Timber Trade Federation (‘AEIM’) submitted a letter supporting the PTIA position, but they did not register as an interested party. Baukrane, a user, provided comments but did not register as an interested party.
(6) t25.009783, Section: Procedure.
(7) t24.008384.
(8) See for example t24.008226 for Panguaneta.
(9) t25.000896.
(10) t25.000277.
(11) t24.009472, t24.010197 and t24.040502.
(12) Appellate Body Report, US – Hot-Rolled Steel, paragraph 77; Appellate Body Report, US – Hot-Rolled Steel, paragraphs 74 and 77; see also Case T-633/11, Guangdong Kito Ceramics and Others v Council (paragraphs 70-91).
(13) t24.010502.
(14) t25.000176.
(15) See footnote 13.
(16) See footnote 14.
(17) Commission Implementing Regulation (EU) 2021/1930 of 8 November 2021 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of birch plywood originating in Russia, (OJ L 394, 9.11.2021, p. 7, ELI: http://data.europa.eu/eli/reg_impl/2021/1930/oj).
(18) See footnote 13.
(19) See footnote 14.
(20) t24.009472.
(21) t24.010197.
(22) See footnote 14.
(23) See footnote 20.
(24) See footnote 21.
(25) See footnote 13.
(26) See footnote 14.
(27) See footnote 20.
(28) See footnote 21.
(29) See footnote 13.
(30) See footnote 14.
(31) See footnote 20.
(32) See footnote 21.
(33) See footnote 13.
(34) See footnote 14.
(35) See footnote 14.
(36) Section 7 Notice of Initiation, see footnote 2.
(37) Section 8 Notice of Initiation, see footnote 2.
(38) See footnote 9.
(39) ‘Any information for the stage of provisional findings should be submitted within 70 days from the date of publication of this Notice, unless otherwise specified.
Unless otherwise specified, interested parties should not submit new factual information after the deadline to comment on the disclosure of the provisional findings or the information document at the stage of provisional findings. After this deadline, interested parties may only submit new factual information if they can demonstrate that such new factual information is necessary to rebut factual allegations made by other interested parties and provided that such new factual information can be verified within the time available to complete the investigation in a timely manner’. Notice of Initiation Section 7, Alinea 1 and 2, see footnote 2.
(40) Recitals 29-45, see footnote 9.
(41) Section 2 of the Notice of Initiation, see footnote 2.
(42) See footnote 10.
(43) See footnote 20.
(44) See footnote 21.
(45) See footnote 13.
(46) ‘The measures will lead multiple companies, from importers/traders to end-users, to shut down operations since it is impossible to pass on to their customers a duty that could range between 89 % and 335 %. It is noted that we’ve received more than 100 support letters from importers’ customers. These are retail shops, DIY stores, wood stores, construction companies, packaging materials and furniture companies in Belgium, France, Netherlands, Germany, Ireland and Luxembourg who oppose the imposition of duties since duties will limit their product offering and suppress their margins. We will submit the support letters separately to the Commission’, recital 149, see footnote 13.
(47) See Hitit Seramik Sanayi ve Ticaret AŞ v European Commission, Case T-230/23, ECLI:EU:T:2025:579, Judgment of the General Court (Third Chamber) (11 June 2025).
(48) See footnote 17.
(49) Idem, recital 26.
(50) https://www.sinbpla.fr/produits/panneaux-dagencement, https://fokuspremium.eu/kategorie/sklejki-dla-branzy-meblowej/, https://www.frischeis.at/shop/platte/sperrholz-platte~c14208283.
(51) EN 635-2 Plywood – Classification by surface appearance – Part 2: Hardwood, EN 635-3 Plywood – Classification by surface appearance – Part 3: Softwood.
(52) Commission Implementing Regulation (EU) 2023/2364 of 26 September 2023 amending Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff (OJ L, 2023/2364, 31.10.2023, ELI: http://data.europa.eu/eli/reg_impl/2023/2364/oj).
(53) E.g., judgments of 2 October 2024, China Chamber of Commerce for Import and Export of Machinery and Electronic Products (CCCME) and Others v European Commission, Case T-263/22, ECLI:EU:T:2024:663, paragraph 294; of 13 September 2010, Whirlpool Europe v Council, T-314/06, EU:T:2010:390, paragraph 138; of 17 December 2010, EWRIA and Others v Commission, T-369/08, EU:T:2010:549, paragraph 82.
(54) E.g. Duroform, high quality hardwood plywood, Meraform Indo high quality hardwood plywood, https://www.altripan.com/en/products.
(55) Department of Commerce International Trade Administration [A–570–051] Certain Hardwood Plywood Products From the People’s Republic of China: Initiation of Less-Than-Fair-Value Investigation, Federal Register / Vol. 81, No 242 / Friday, 16 December 2016 / Notices 91125.
(56) https://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/donp2020/donp2020-in-eng.html#toc3-1.
(57) Notice of initiation of an anti-dumping proceeding concerning imports of Softwood plywood originating in Brazil (OJ C, C/2025/1490, 6.3.2025, ELI: http://data.europa.eu/eli/C/2025/1490/oj).
(58) See footnote 17.
(59) General Court (Sixth Chamber), 11 September 2024, Case T-32/22, ECLI:EU:T:2024:617, paragraph 50.
(60) AEIM also submitted an exclusion claim regarding eucalyptus plywood but it did not register as an interested party.
(61) ‘The customers have experienced a price increase since the Russian/Belarusian plywood was banned. The Chinese Eucalyptus plywood actually helped the packaging industry to survive. Not by offering a cheaper solution, but simply as an alternative to the illegal imports of Russian birch (but that’s another story)’.t25.006761.
(62) t24.010595.
(63) t24.010593.
(64) Eucapypto Twin for Panguaneta, and Eucalyptus Globulus for Garncia.
(65) DYAS film – Film faced plywood | Dyas.eu.
(66) ‘Following the sanctions imposed in 2022 on the Russian Federation and Belarus and in the context of proposed trade restrictions on Chinese imports, the European market already has faced a serious supply gap. This is particularly critical for construction sectors reliant on disposable, low-cost formwork plywood … In this context, the import of film-faced plywood from countries with 6 controlled, high-yield plantations, such as China, plays a stabilizing role, helping to preserve Europe’s forests while ensuring the continuity of essential construction activities’, t25.006824, p. 20.
(67) Footnote 48.
(68) Idem.
(69) For example Duroform or Paged Wiremesh, https://www.altripan.com/en/products.
(70) See footnote 55.
(71) ‘ UFP argues that … PFF should be excluded from the scope of the current investigations … petitioners state they do not oppose the modified scope exclusion language proposed by UFP … ’, Certain Hardwood Plywood Products from the People’s Republic of China: Scope Comments Decision Memorandum for the Preliminary Determinations, A-570-051, C-570-052, 17 April 2017.
(72) https://www.garnica.one/en-uk/plywood-panels/range/reinforced/reinforced-globulus-poplar-sg.html.
(73) https://www.garnica.one/en-uk/plywood-panels/range/efficiency/efficiency-poplar.html, https://pagedplywood.com/en/produkty/paged-stringply-3.
(74) http://www.gtis.com/gta/secure/default.cfm.
(75) The report can be obtained for a fee at https://www.informa.es/en.
(76) Case T-763/20, Inner Mongolia Shuangxin Environment-Friendly Material v Commission, paragraph 100; see also, Case T-442/12, Changmao Biochemical Engineering v Council, paragraph 139 and the case-law cited.
(77) https://www.informa.es/en/business-information/international.
(78) Commission Implementing Regulation (EU) 2020/1336 of 25 September 2020 imposing definitive anti-dumping duties on imports of certain polyvinyl alcohols originating in the People’s Republic of China (OJ L 315, 29.9.2020, p. 1, ELI: http://data.europa.eu/eli/reg_impl/2020/1336/oj), recital 228.
(79) Case T-763/20, Inner Mongolia Shuangxin Environment-Friendly Material v Commission, EU:T:2024:114, para 88 and 104.
(80) https://www.informa.es/en/business-information/international.
(81) The general webpage of Dun&Bradstreet relating to its worldwide services leads to local providers. In case of Belgium, for instance, the webpage links directly to the local provider Altares (https://www.altares.be/en/), where the report is directly available through https://order.altares.be/, against a fee of EUR 415,03 (last accessed on 17 October 2025).
(82) Case T-263/22, CCCME v Commission, EU:T:2024:663, para. 188.
(83) https://turanlargroup.com/sirket-detay.php?slug=pelit-arslan-kontraplak-fab-as&id=5.
(84) https://www.peliparke.com/, https://pelicompact.com/.
(85) Commission Implementing Regulation (EU) 2025/78 of 15 January 2025 imposing a provisional anti-dumping duty on imports of multilayered wood flooring originating in the People’s Republic of China (OJ L, 2025/78, 15.1.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/78/oj), recital 164.
(86) https://www.peliparke.com/en.
(87) https://turanlargroup.com/sirket-detay.php?slug=vezrkopru-orman-urunler-ve-kagit-san-as&id=6.
(88) The macro questionnaire reply is available at t24.011339 in the public file.
(89) t25.00938.
(90) Commission Implementing Regulation (EU) 2024/1287 of 13 May 2024 extending the definitive anti-dumping duty imposed by Implementing Regulation (EU) 2021/1930 on imports of birch plywood originating in Russia to imports of birch plywood consigned from Türkiye and Kazakhstan, whether declared as originating in Türkiye and Kazakhstan or not (OJ L, 2024/1287, 14.5.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/1287/oj).
(91) See footnote 48.
(92) PTIA submission nr. t25.006824.
(93) https://pmarketresearch.com/hc/container-flooring-plywood-market/.
(94) https://www.ohc.net/product/container-flooring/#.
(95) For example, the Yamunagar Company, https://plyxpert.com/our-factory/.
(96) https://fsc.org/en/businesses/wood.
(97) Email: TRADE-TDI-NAME-CHANGE-REQUESTS@ec.europa.eu; European Commission, Directorate-General for Trade, Directorate G, Wetstraat 170 Rue de la Loi, 1040 Bruxelles/Brussel, BELGIQUE/BELGIË.
(98) Council Regulation (EEC) No 2658/87 of 23 July 1987 on the tariff and statistical nomenclature and on the Common Customs Tariff (OJ L 256, 7.9.1987, p. 1, ELI: http://data.europa.eu/eli/reg/1987/2658/oj).
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