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

• (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.

8.3.   Interest of users

• (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.

8.4.   Conclusion on Union interest

• (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.

9. DEFINITIVE ANTI-DUMPING MEASURES

9.1.   Definitive measures

• (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.

• (265) On the basis of the above, the definitive anti-dumping duty rates, expressed on the CIF Union border price, customs duty unpaid, should be as follows:

Company	Dumping margin (%)	Injury margin (%)	Definitive anti-dumping duty (%)
Pizhou Jiangshan Wood Co., Ltd	43,3	93,1	43,3
All other imports originating in the People’s Republic of China	86,8	185,9	86,8

• (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).

9.2.   Definitive collection of the provisional duties

• (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.

9.3.   Retroactivity

• (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.

• (276) There was no further substantial rise in imports in addition to the level of imports which caused injury during the investigation period. 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 (i.e. November 2024) up to and including the month in which provisional measures were imposed (i.e. June 2025), a 39 % drop in the level of imports into the Union could be observed.

	Imports from the PRC in tons
Monthly average IP	37 798
Monthly average 11/2024 - 06/2025	22 892

• (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.

10. MONITORING OF IMPORTS

• (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.

11. FINAL PROVISION

• (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

Country of origin	Company	Definitive anti-dumping duty (%)	TARIC additional code
The People’s Republic of China	Pizhou Jiangshan Wood Co., Ltd	43,3	89MK
The People’s Republic of China	All other companies	86,8	8999

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.

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

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.

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.

ELI: http://data.europa.eu/eli/reg_impl/2025/2333/oj

ISSN 1977-0677 (electronic edition)