Commission Implementing Regulation (EU) 2025/2386 of 27 November 2025 imposing a definitive anti-dumping duty on imports of ironing boards 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

Image omitted; see official source	Official Journal of the European Union	EN L series
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	2025/2386	28.11.2025

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2016/1036 of the European Parliament and of the Council of 8 June 2016 on protection against dumped imports from countries not members of the European Union (‘basic Regulation’) [^ntr1-L_202502386EN.000101-E0001], and in particular Article 11(2) thereof,

Whereas:

1. PROCEDURE

1.1.   Previous investigations and measures in force

• (1) By Regulation of the Council (EC) No 452/2007 [^ntr2-L_202502386EN.000101-E0002], the Council imposed anti-dumping duties on imports of ironing boards, originating in the People’s Republic of China and Ukraine (‘the original measures’).

• (2) By Implementing Regulation (EU) No 1243/2010 [^ntr3-L_202502386EN.000101-E0003], the Council imposed a definitive anti-dumping duty on imports of ironing boards of Since Hardware (Guangzhou) Co, a Chinese exporting producer of ironing boards. The investigations that led to the imposition of the original measures will hereinafter be referred to as ‘the original investigations’.

• (3) By Implementing Regulation (EU) No 77/2010 [^ntr4-L_202502386EN.000101-E0004], the Council amended the definitive anti-dumping measures on imports of ironing boards originating in People’s Republic of China following a new exporter review pursuant to Article 11(4) of the basic Regulation.

• (4) By Implementing Regulation (EU) No 270/2010 [^ntr5-L_202502386EN.000101-E0005], the Council amended the measures following an interim review pursuant to Article 11(3) of the basic Regulation.

• (5) By Implementing Regulation (EU) No 805/2010 [^ntr6-L_202502386EN.000101-E0006], the Council re-imposed definitive anti-dumping duties on imports of ironing boards of Foshan Shunde Yongjian Housewares and Hardware Co. Ltd, Foshan, a Chinese exporting producer of ironing boards, to comply with the judgment of the Court of Justice in Case C-141/08 P [^ntr7-L_202502386EN.000101-E0007].

• (6) By Implementing Regulation (EU) No 987/2012 [^ntr8-L_202502386EN.000101-E0008], the Council re-imposed definitive anti-dumping duties on imports of ironing boards originating in the People’s Republic of China, manufactured by Zhejiang Harmonic Hardware Products Co. Ltd, to comply with the judgment of the Court of Justice in Case T-274/07 [^ntr9-L_202502386EN.000101-E0009].

• (7) By Implementing Regulation (EU) No 695/2013 [^ntr10-L_202502386EN.000101-E0010], the Council extended the measures for a further five years with regard to imports of ironing boards originating in the People’s Republic of China and repealed the measures on imports of ironing boards originating in Ukraine, following an expiry review in accordance with Article 11(2) of the basic Regulation and an interim review in accordance with Article 11(3) of the basic Regulation.

• (8) By Implementing Regulation (EU) 2019/1662 [^ntr11-L_202502386EN.000101-E0011], the Commission re-imposed the definitive anti-dumping measures on imports of ironing boards originating in the People’s Republic of China following an expiry review in accordance with Article 11(2) of the basic Regulation (the ‘previous expiry review’).

• (9) The anti-dumping duties currently in force are at rates ranging between 18,1 % and 39,6 % on imports from the sampled exporting producers and a duty rate of 42,3 % for all other companies in the People’s Republic of China.

1.2.   Request for an expiry review

• (10) Following the publication of a notice of impending expiry [^ntr12-L_202502386EN.000101-E0012], the European Commission (‘the Commission’) received a request for a review pursuant to Article 11(2) of the basic Regulation.

• (11) The request for review was lodged on 29 June 2024 by 5 Union producers (Afer FUTE – Fábrica de Utilidades de Tubo S.A., Brabantia Latvia SIA, Colombo New Scal SpA, Rörets Polska Sp. z o.o. and Sonecol Indústria Metalurgica de Utilidades Domésticas S.A.) (‘the applicants’) on behalf of the Union industry of ironing boards in the sense of Article 5(4) of the basic Regulation (‘the request’). The request was based on the grounds that the expiry of the measures would be likely to result in continuation of dumping and recurrence of injury to the Union industry.

1.3.   Initiation of an expiry review

• (12) Having determined, after consulting the Committee established by Article 15(1) of the basic Regulation, that sufficient evidence existed for the initiation of an expiry review, on 1 October 2024 the Commission initiated an expiry review with regard to imports into the Union of ironing boards originating in the People’s Republic of China (‘the country concerned’ or ‘China’ or ‘PRC’) on the basis of Article 11(2) of the basic Regulation. It published a Notice of Initiation in the Official Journal of the European Union [^ntr13-L_202502386EN.000101-E0013] (‘the Notice of Initiation’).

1.4.   Review investigation period and period considered

• (13) The investigation of continuation or recurrence of dumping covered the period from 1 July 2023 to 30 June 2024 (‘review investigation period’). The examination of trends relevant for the assessment of the likelihood of a continuation or recurrence of injury covered the period from 1 January 2020 to the end of the review investigation period (‘the period considered’).

1.5.   Interested parties

• (14) In the Notice of Initiation, interested parties were invited to contact the Commission in order to participate in the investigation. In addition, the Commission specifically informed the applicants, other Union producers, all known producers in the People’s Republic of China, importers, users, traders, as well as associations known to be concerned about the initiation of the expiry and invited them to participate.

• (15) Interested parties had an opportunity to comment on the initiation of the expiry review and to request a hearing with the Commission and/or the Hearing Officer in trade proceedings.

1.6.   Sampling

• (16) In the Notice of Initiation, the Commission stated that it might sample the interested parties in accordance with Article 17 of the basic Regulation.

Sampling of Union producers

• (17) In the Notice of Initiation, the Commission stated that it had provisionally selected a sample of Union producers. The Commission selected the sample on the basis of the representativity in terms of volume of production and sales of the like product. This sample consisted of three Union producers, accounting for more than 55 % of the estimated total volume of Union production and sales and ensured a good geographical spread. In accordance with Article 17(2) of the basic Regulation, the Commission invited interested parties to comment on the provisional sample. None of the interested parties had comments and the Commission confirmed therefore that the provisionally sampled Union producers have been finally selected to form part of the definitive sample. The sample is representative of the Union industry.

Sampling of importers

• (18) To decide whether sampling was necessary and, if so, to select a sample, the Commission asked unrelated importers to provide the information specified in the Notice of Initiation.

• (19) No unrelated importers provided the requested information and agreed to be included in the sample. In view of the absence of cooperation, the Commission decided that sampling was not necessary.

Sampling of producers in the PRC

• (20) To decide whether sampling was necessary and, if so, to select a sample, the Commission asked all known producers in the PRC to provide the information specified in the Notice of Initiation. In addition, the Commission asked the authorities of the exporting country and associations of producers to identify and/or contact other producers, if any, that could be interested in participating in the investigation.

• (21) No exporting producers in the country concerned provided the requested information and agreed to be included in the sample. In view of the absence of cooperation, the Commission decided that sampling was not necessary.

• (22) Interested parties had an opportunity to comment on the initiation of the expiry review and to request a hearing with the Commission and/or the Hearing Officer in trade proceedings.

1.7.   Questionnaires and verification visits

• (23) The Commission sent a questionnaire concerning the existence of significant distortions in the PRC within the meaning of Article 2(6a)(b) of the basic Regulation to the Government of the People’s Republic of China (‘GOC’).

• (24) The Commission sent questionnaires to the sampled Union producers, unrelated importers and users. The same questionnaires had also been made available online [^ntr14-L_202502386EN.000101-E0014] on the day of initiation.

• (25) Questionnaire replies were received only from the three sampled Union producers.

• (26) The Commission sought and verified all the information it deemed necessary for the determination of likelihood of continuation or recurrence of dumping and injury and of the Union interest. Verification visits pursuant to Article 16 of the basic Regulation were carried out at the premises of the following companies:

Union producers:

• — Afer FUTE, Portugal,

• — Colombo New Scal SpA, Italy,

• — Rörets Polska Spółka z o.o., and AB Rörets Industrier, Sweden, both verified in Poland.

1.8.   Subsequent procedure

• (27) On 19 September 2025, the Commission disclosed the essential facts and considerations on the basis of which it intended to maintain the anti-dumping duties in force. All parties were granted a period within which they could make comments on the disclosure.

• (28) No comments contesting the Commission’s findings were received.

2. PRODUCT UNDER REVIEW, PRODUCT CONCERNED AND LIKE PRODUCT

2.1.   Product under review

• (29) The product subject to this expiry review is the same as in in the original investigations and previous expiry review, namely ironing boards, whether or not free-standing, with or without a steam soaking and/or heating top and/or blowing top, including sleeve boards, and essential parts thereof, i.e. the legs, the top and the iron rest (‘the product under review’).

2.2.   Product concerned

• (30) The product concerned by this investigation is the product under review originating in the PRC currently falling under CN codes ex 3924 90 00 , ex 4421 99 99 , ex 7323 93 00 , ex 7323 99 00 , ex 8516 79 70 and ex 8516 90 00 (TARIC codes 3924 90 00 10, 4421 99 99 10, 7323 93 00 10, 7323 99 00 10, 8516 79 70 10 and 8516 90 00 51).

2.3.   Like product

• (31) As established in the original investigations as well as in the previous expiry review, this expiry review investigation confirmed that the following products have the same basic physical and technical characteristics as well as the same basic uses:

• — the product concerned when exported to the Union,

• — the product under review produced and sold on the domestic market of the People’s Republic of China,

• — the product under review produced and sold by the exporting producers to the rest of the world, and

• — the product under review produced and sold in the Union by the Union industry.

• (32) These products are therefore considered to be like products within the meaning of Article 1(4) of the basic Regulation.

3. DUMPING

3.1.   Preliminary remarks

• (33) During the review investigation period, imports of ironing boards from China continued. According to data reported to the Commission by the Member States in accordance with Article 14(6) of the basic Regulation (‘Article 14(6) database’), imports of ironing boards from the PRC accounted for about 6 % of the Union market in the review investigation period, as compared to 11 % during the previous expiry review [^ntr15-L_202502386EN.000101-E0015]. In absolute terms the volume of imports was significant in the review investigation period, and it had an increasing trend over the period considered.

• (34) As mentioned in recital (21), none of the exporters/producers in China cooperated in the investigation. Therefore, on 16 December 2024, the Commission notified the authorities of the PRC that due to the absence of cooperation, the Commission might apply Article 18 of the basic Regulation and base its findings on continuation or recurrence of dumping and injury in respect of the exporters/producers in the PRC on the facts available. The Commission did not receive any comments or claims regarding the application of Article 18 of the basic Regulation from the GOC.

• (35) Consequently, in accordance with Article 18 of the basic Regulation, the findings in relation to the likelihood of continuation or recurrence of dumping and injury were based on facts available, in particular on the information provided in the request and the statistics based on the Article 14(6) database. In addition, the Commission used other sources of publicly available information such as the World Bank, the Global Trade Atlas (‘GTA’) and the Orbis Bureau van Dijk (‘Orbis’) databases and International Labour Organisation (‘ILO’) statistics. The Commission also relied on the findings of the previous expiry review as well as the findings of the anti-dumping investigations concerning the same product initiated by the competent authorities of the US and the UK.

3.2.   Dumping

3.2.1.   Procedure for the determination of the normal value under Article 2(6a) of the basic Regulation

• (36) Given the sufficient evidence available at the initiation of the investigation pointing to the existence of significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation, the Commission initiated the investigation on the basis of Article 2(6a) of the basic Regulation.

• (37) In order to obtain the information it deemed necessary for its investigation with regard to the alleged significant distortions, the Commission sent a questionnaire to the GOC. In addition, in point 5.3.2 of the Notice of Initiation, the Commission invited all interested parties to make their views known, submit information and provide supporting evidence regarding the application of Article 2(6a) of the basic Regulation within 37 days of the date of publication of the Notice of Initiation in the Official Journal of the European Union. No questionnaire reply was received from the GOC and no submission on the application of Article 2(6a) of the basic Regulation was received within the deadline. Subsequently, on 19 December 2024, the Commission notified the GOC that it would use facts available within the meaning of Article 18 of the basic Regulation for the determination of the existence of the significant distortions in the PRC. No comments or claims regarding the application of Article 18 of the basic Regulation were received.

• (38) In point 5.3.2. of the Notice of Initiation, the Commission also specified that, in view of the evidence available, it had provisionally selected Türkiye as an appropriate representative country pursuant to Article 2(6a)(a) of the basic Regulation for the purpose of determining the normal value based on undistorted prices or benchmarks. The Commission further stated that it would examine other possibly appropriate countries in accordance with the criteria set out in first indent of Article 2(6a) of the basic regulation.

• (39) On 19 May 2025, the Commission informed interested parties by a note on the relevant sources it intended to use for the determination of the normal value. In that note, the Commission provided a list of all factors of production such as raw materials, labour and energy used in the production of ironing boards (the ‘FOP Note’). In addition, based on the criteria guiding the choice of undistorted prices or benchmarks and the request, the Commission identified Türkiye as an appropriate representative country. The Commission received no comments on the FOP Note.

3.2.1.1.   Normal value

• (40) According to Article 2(1) of the basic Regulation, ‘the normal value shall normally be based on the prices paid or payable, in the ordinary course of trade, by independent customers in the exporting country’.

• (41) However, according to Article 2(6a)(a) of the basic Regulation, ‘in case it is determined […] that it is not appropriate to use domestic prices and costs in the exporting country due to the existence in that country of significant distortions within the meaning of point (b), the normal value shall be constructed exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks’, and ‘shall include an undistorted and reasonable amount of administrative, selling and general costs and for profits’ (‘administrative, selling and general costs’ is referred to hereinafter as ‘SG&A’).

• (42) As further explained below, the Commission concluded in the present investigation that, based on the evidence available, and in view of the lack of cooperation of the GOC and the exporting producers, the application of Article 2(6a) of the basic Regulation was appropriate.

3.2.1.1.1.   Existence of significant distortions

• (43) The Commission examined the evidence on the file to decide whether significant distortions within the meaning of Article 2(6a)(b) of the basic Regulation exist in the PRC, rendering the use of domestic prices and costs in that country inappropriate. That analysis covered the following evidentiary elements on the various criteria relevant to establish the existence of significant distortions.

• (44) First, the evidence contained in the request included the following elements pointing to the existence of significant distortions.

• (45) The applicants pointed out that the market in question is served to a significant extent by enterprises operating under the ownership, control or policy supervision of the Chinese authorities. The applicants noted that such influence involves not only the market of the product under review but also the market of key raw materials (namely steel). According to the applicants, this is achieved by the GOC through two main channels, one involves the reshaping of the corporate structure of the sector, and the other the exercise of control over management and personnel of individual SOEs [^ntr16-L_202502386EN.000101-E0016].

• (46) The applicants took note of the Commission’s findings in the previous expiry review, stating that suppliers of main components of the product concerned are owned by the Chinese state. In the request, the applicants not only noted that ironing board producers, such as Hardware (Guangzhou) Co. Ltd, maintain tight links with the CCP [^ntr17-L_202502386EN.000101-E0017], but also referred to, as established in the previous expiry review, the influence of the CCP on providers of key components of the product under review [^ntr18-L_202502386EN.000101-E0018].

• (47) The applicants also emphasised that the state presence in firms allows it to interfere with respect to prices and costs. It referred to the findings of the Commission in the previous expiry review, stating that this is achieved through the presence of CCP cells within both public and private enterprises [^ntr19-L_202502386EN.000101-E0019]. Prices and costs are influenced through various instruments such as the artificial increase or decrease of the level of raw material supply or through a price setting mechanism [^ntr20-L_202502386EN.000101-E0020].

• (48) Moreover, the applicants indicated that public policies or measures discriminate in favour of domestic suppliers or otherwise influence free market forces. The applicants noted in that respect that ‘Chinese policies are demonstrably interventionist’. In particular, the applicants mentioned policy measures such as the Made in China 2025, ‘which sets the goal of promoting manufacturing industry, […] and it identifies loan interest subsidies as a type of financial support to be provided to enterprises’, stating further that ‘banks and other lenders are supposed to support these policies by giving loans to companies active in such sectors’ [^ntr21-L_202502386EN.000101-E0021].

• (49) The applicants noted that the sector of the product under review is highly influenced by policy measures on steel, which is the main raw material for manufacturing of ironing boards. Regarding this, the applicants noted the ‘overarching control of the government which prevents free market forces from prevailing in the steel sector’ [^ntr22-L_202502386EN.000101-E0022].

• (50) Moreover, the applicants claimed the lack, discriminatory application or inadequate enforcement of bankruptcy, corporate or property laws. The applicants referred to the Commission findings in the previous expiry review, stating that ‘the sector of the product concerned is subject to the top-down distortions arising from the discriminatory application or inadequate enforcement of bankruptcy and property laws’ [^ntr23-L_202502386EN.000101-E0023].

• (51) The applicants further pointed out the distortions of wage costs in the sector of the product under review and its raw materials in China, making reference to the previous expiry review which had established that ‘wage costs were distorted in the ironing boards manufacturing sector and in the sectors of its key components’ [^ntr24-L_202502386EN.000101-E0024].

• (52) Lastly, the applicants noted that access to finance is distorted in favour of producers of the product under review. In particular, according to the applicants, ‘the functioning of the financial system is characterised by state presence, on both borrowing and lending side as well as by the absence of normal market mechanisms such as effective and transparent bankruptcy and market exit procedures’ [^ntr25-L_202502386EN.000101-E0025].

• (53) Second, in recent investigations concerning the sector of the product under review or the steel sector – steel being the principal raw material used for the manufacturing of ironing boards – in the PRC [^ntr26-L_202502386EN.000101-E0026], the Commission found that significant distortions in the sense of Article 2(6a)(b) of the basic Regulation were present. In those investigations, the Commission found that there is substantial government intervention in the PRC resulting in a distortion of the effective allocation of resources in line with market principles [^ntr27-L_202502386EN.000101-E0027]. In particular, the Commission concluded that in the steel sector, not only does a substantial degree of ownership by the GOC persists in the sense of Article 2(6a)(b), first indent of the basic Regulation [^ntr28-L_202502386EN.000101-E0028] but the GOC is also in a position to interfere with prices and costs through State presence in firms in the sense of Article 2(6a)(b), second indent of the basic Regulation [^ntr29-L_202502386EN.000101-E0029]. The Commission found further that the State’s presence and intervention in the financial markets, as well as in the provision of raw materials and inputs further have an additional distorting effect on the market. Indeed, overall, the system of planning in the PRC results in resources being driven to sectors designated as strategic or otherwise politically important by the GOC, rather than being allocated in line with market forces [^ntr30-L_202502386EN.000101-E0030]. Moreover, the Commission concluded that the Chinese bankruptcy and property laws do not work properly in the sense of Article 2(6a)(b), fourth indent of the basic Regulation, thus generating distortions in particular when maintaining insolvent firms afloat and when allocating land use rights in the PRC [^ntr31-L_202502386EN.000101-E0031]. In the same vein, the Commission found distortions of wage costs in the steel sector in the sense of Article 2(6a)(b), fifth indent of the basic Regulation [^ntr32-L_202502386EN.000101-E0032], as well as distortions in the financial markets in the sense of Article 2(6a)(b), sixth indent of the basic Regulation, in particular concerning access to capital for corporate actors in the PRC [^ntr33-L_202502386EN.000101-E0033].

• (54) Third, in the most recent expiry review concerning the product under review [^ntr34-L_202502386EN.000101-E0034] the Commission concluded that significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation were present. No major structural changes in the PRC in general and/or in the relevant sector in particular, capable of affecting that conclusion, are known to the Commission.

• (55) Fourth, additional evidence available in the Report, prepared by the Commission pursuant to Article 2(6a)(c) of the basic Regulation, pointed to the existence of significant distortions also during the review investigation period.

• (56) Fifth, no evidence or arguments to the contrary have been adduced by the GOC or the exporting producers in the present investigation.

• (57) In view of the above, the evidence available showed that prices or costs of the product under review, including the costs of raw materials, energy and labour, are not the result of free market forces because they are affected by substantial government intervention within the meaning of Article 2(6a)(b) of the basic Regulation as shown by the actual or potential impact of one or more of the relevant elements listed therein. On that basis, the Commission concluded that it is not appropriate to use domestic prices and costs to establish normal value in this case. Consequently, the Commission proceeded to construct the normal value exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks, that is, in this case, on the basis of corresponding costs of production and sale in an appropriate representative country, in accordance with Article 2(6a)(a) of the basic Regulation.

3.2.1.1.2.   Representative country

General remarks

• (58) The choice of the representative country was based on the following criteria pursuant to Article 2(6a) of the basic Regulation:

• — A level of economic development similar to China. For this purpose, the Commission used countries with a gross national income per capita similar to China on the basis of the database of the World Bank [^ntr35-L_202502386EN.000101-E0035],

• — Production of the product under review in that country [^ntr36-L_202502386EN.000101-E0036],

• — Availability of relevant public data in the representative country,

• — Where there is more than one possible representative country, preference should be given, where appropriate, to the country with an adequate level of social and environmental protection.

• (59) As explained in recital (39), the Commission issued a note for the file on the sources for the determination of the normal value: the note on production factors of 19 May 2025, i.e. the FOP Note. This note described the facts and evidence underlying the relevant criteria. In the FOP Note, the Commission informed interested parties of its intention to consider Türkiye as an appropriate representative country in the present case if the existence of significant distortions pursuant to Article 2(6a) of the basic Regulation would be confirmed.

A level of economic development similar to the PRC

• (60) In the FOP Note, the Commission identified Türkiye as the country with a similar level of economic development as the PRC according to the World Bank, i.e. it is classified by the World Bank as ‘upper-middle income’ country on a gross national income basis where production of the product under review was known to take place.

• (61) No comments were received concerning the country identified in that note.

Availability of relevant public data in the representative country

• (62) The Commission carefully analysed all relevant data available in the file for the factors of production in the potential representative country and noted the following:

• — The Commission analysed the import statistics of all raw materials listed in the FOP Note. The Commission established that Türkiye imported all the relevant raw materials in the review investigation period.

• — Electricity and gas prices for non-household consumers were negligible considering the insignificant quantity needed for the production process of ironing boards.

• — The ILO statistics provided information on monthly wages in the manufacturing sector and weekly hours worked in Türkiye. Similar information for Türkiye was also publicly available on the website of the Turkish Statistical Institute (‘TURKSTAT’ [^ntr37-L_202502386EN.000101-E0037]).

• — In the FOP Note, the Commission indicated that the request did not identify any ironing board producers in Türkiye, nor did the Commission find any. Instead, the request relied on sectoral statistics published by the Central Bank of Türkiye, using data on for Turkish companies operating in sector NACE C-259: Manufacture of Other Fabricated Metal Products. In the FOP Note, the Commission considered that the Central Bank of Türkiye's financial data for businesses under NACE C-259 is official and reliable and intended to use the most recent available data (2023) to calculate SG&A and profits.

• (63) In light of the above considerations, the Commission informed the interested parties with the FOP Note that it intends to use Türkiye as an appropriate representative country, in accordance with Article 2(6a)(a), first indent of the basic Regulation in order to source undistorted prices or benchmarks for the calculation of the normal value.

• (64) Interested parties were invited to comment on the appropriateness of Türkiye as a representative country in the representative country.

• (65) No comments were received.

Level of social and environmental protection

• (66) Having established that Türkiye was the only available appropriate representative country, based on all of the above elements, there was no need to carry out an assessment of the level of social and environmental protection in accordance with the last sentence of Article 2(6a)(a) first indent of the basic Regulation.

Conclusion

• (67) In view of the above analysis, Türkiye met the criteria laid down in Article 2(6a)(a), first indent of the basic Regulation in order to be considered as an appropriate representative country.

• (68) No comments from interested parties were received in this respect.

Sources used to establish undistorted costs

• (69) In the FOP Note, the Commission listed the factors of production such as materials, energy and labour used in the production of the product under review by the exporting producers and invited the interested parties to comment and propose publicly available information on undistorted values for each of the factors of production mentioned in that note. No comments were received.

• (70) The Commission also stated that, in order to construct the normal value in accordance with Article 2(6a)(a) of the basic Regulation, it would use GTA to establish the undistorted cost of most of the factors of production, notably the raw materials. In addition, the Commission stated that it would use TURKSTAT for establishing undistorted costs of labour [^ntr38-L_202502386EN.000101-E0038]. As for energy, the previous investigation showed that electricity and natural gas consumed during the production process of ironing boards are insignificant. Therefore, for the purpose of this investigation, the energy cost will again be considered as negligible [^ntr39-L_202502386EN.000101-E0039].

Factors of production

• (71) Considering the information contained in the request, the following factors of production and their sources have been identified in order to determine the normal value in accordance with Article 2(6a)(a) of the basic Regulation:

Table 1

Factors of production of ironing boards

Factor of Production	HS Code	Undistorted value	Unit of measurement	Source of information
Raw materials	Raw materials	Raw materials	Raw materials
Steel tubes: (19 × 0,7 mm) (EN 1035-3) / 22 × 0,7 mm) (EN 10305-3)	730 630	14,76	kg	Global Trade Atlas[^ntr40-L_202502386EN.000101-E0040] (GTA)
Steel tubes: (20 × 0,6 × 1 080  mm)	730 669	15,14	kg	GTA
Wire 5,5 mm	721 710	12,16	kg	GTA
Wire 7,75 mm	721 720	12,12	kg	GTA
Wire 5-7 mm (C9D)	721 790	21,14	kg	GTA
Metal (DC01) and metal sheet 0,7 mm, 1 mm and 3 mm	721 123	6,55	kg	GTA
Metal mesh 320 × 1 100  mm	731 450	17,62	kg	GTA
Washers, rivets and screws	731 823	87,38	kg	GTA
Springs	731 829	142,68	kg	GTA
Foam Polyurethane 25 kg/m3	392 113	60,00	kg	GTA
Foam (Polyurethane 25 kg/m3)	392 490	39,04	kg	GTA
Silicone and plastic parts	392 630	103,90	kg	GTA
Cotton	520 852	18,55	M2	GTA
String	550 922	19,48	kg	GTA
Thread	550 810	31,88	kg	GTA
Paint Epoxy/polyester blend	320 649	31,66	kg	GTA
Carton+label	481 910	16,12	kg	GTA
Shrink foil	392 020	17,64	kg	GTA
Colour label	480 258	10,25	kg	GTA
Shrink wrap	392 010	23,22	kg	GTA
Labour	Labour	Labour	Labour
Labour cost	N/A	44,88	Hour	ILO/national statistics

3.2.1.1.3.   Raw materials

• (72) An ironing board is generally a piece of hard narrow flat material protected by a heat-safe cover and often having folding legs, on which clothing or linens may be ironed. According to the definition of the product under review covered by this investigation it can also include a steam soaking, heating top, blowing top, sleeve boards, and other parts. The primary raw material used in ironing boards is metal, mainly steel (metal sheet, tubes, wire). Other raw materials used in the production of ironing boards include paint/coating, plastic parts, foam and fabric.

• (73) The cost structure varies depending on the type of board being produced, e.g. high-end boards contain different types of material compared to basic level boards. The Commission relied on the request for review in order to specify the factors of production used to produce ironing boards. As mentioned above, none of the interested parties provided any comments in this respect.

• (74) In order to establish the undistorted price of raw materials as delivered at the gate of a representative country producer, the Commission used as a basis the weighted average import price to the representative country as reported in the GTA to which import duties were added. An import price in the representative country was determined as a weighted average of unit prices of imports from all third countries excluding the PRC and countries which are not members of the WTO, listed in Annex 1 of Regulation (EU) 2015/755 of the European Parliament and the Council [^ntr41-L_202502386EN.000101-E0041]. The Commission decided to exclude imports from the PRC into the representative country as it concluded in recitals (43) to (57) that it is not appropriate to use domestic prices and costs in the PRC due to the existence of significant distortions in accordance with Article 2(6a)(b) of the basic Regulation. Given that there is no evidence showing that the same distortions do not equally affect products intended for export, the Commission considered that the same distortions affected export prices. After excluding imports from the PRC into the representative country, the volume of imports from other third countries remained representative.

• (75) Normally, domestic transport prices should also be added to these import prices. However, considering the findings of dumping in recitals (87) to (89) as well as the nature of this expiry review investigation, which is focused on finding whether dumping continued during the review investigation period or could reoccur, rather than finding its exact magnitude, the Commission decided that adjustments for domestic transport were unnecessary. Such adjustments would only result in an increase of the normal value and consequently a higher dumping margin.

3.2.1.1.4.   Labour

• (76) The Turkish Statistical Institute publishes detailed information on wages in different economic sectors in Türkiye. The Commission used the latest available statistics 2022 for average labour cost in the steel sector of the Statistical Classification of Economic Activities, commonly referred to as NACE, which includes costs for labour in the steel manufacturing sector, i.e. NACE code C-259 Manufacture of other fabricated metal products [^ntr42-L_202502386EN.000101-E0042].

3.2.1.1.5.   Energy

• (77) According to the request for review, the energy (electricity and natural gas) that is consumed during the production process of ironing boards is insignificant. This was confirmed by the findings of the previous expiry review, which were not contested in the current investigation Since the investigation did not bring into light any information contradicting these findings, they were accepted and for the purpose of this investigation energy costs were therefore considered as negligible.

3.2.1.1.6.   Manufacturing overhead costs, SG&A, profits and depreciation

• (78) According to Article 2(6a)(a) of the basic Regulation, ‘the constructed normal value shall include an undistorted and reasonable amount for administrative, selling and general costs and for profits’. In addition, a value for manufacturing overhead costs needs to be established to cover costs not included in the factors of production referred to above.

• (79) In order to establish an undistorted value of the manufacturing overheads and given the absence of cooperation from the exporting producers, the Commission used facts available in accordance with Article 18 of the basic Regulation. Therefore, based on the data provided by the applicants, the Commission established the ratio of manufacturing overheads to the total manufacturing and labour costs. This percentage was then applied to the undistorted value of the cost of manufacturing to obtain the undistorted value of manufacturing overheads, depending on the model produced. Absent any publicly available information for Turkish ironing boards producers, SG&A costs and profit were determined based on the information found in the sectoral statistics published by the Central Bank of Turkey, namely on the latest available statistics (2023) for C-259 Manufacture of other fabricated metal products.

3.2.1.1.7.   Calculation of the normal value

• (80) On the basis of the above, the Commission constructed the normal value per product type on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation. Due to the absence of cooperation from the Chinese producers/exporting producers, it could not be established which models of ironing boards were produced in China. The Commission relied on the information provided by the applicants in the request for review in accordance with Article 18 of the basic Regulation. To this end, the applicants identified six models of ironing boards including low- and high-end level ironing boards. Normal value was established for these models following the methodology explained in recitals (81) to (83) below.

• (81) First, the Commission established the undistorted manufacturing costs. In the absence of cooperation by the exporting producers, the Commission relied on the information provided by the applicants in the review request on the usage of each factor (materials and labour) for the production of ironing boards.

• (82) Once the undistorted manufacturing cost was established, the Commission added the manufacturing overheads, SG&A and profit as noted in recital (78). The Commission added the following items to the undistorted costs of manufacturing:

• — Manufacturing overheads, which accounted in total for 20 % of the direct costs of manufacturing,

• — SG&A and other costs, which accounted for 10 % of the Costs of Goods Sold (‘COGS’), and

• — Profits, which amounted to 16 % of the COGS, were applied to the total undistorted costs of manufacturing and manufacturing overheads.

• (83) On that basis, the Commission constructed the normal value per product type on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation.

• (84) Due to the fact that no Chinese exporting producer cooperated and consequently the Commission had no information on the product mix for either the domestic side or the exports to the Union, the Commission also established a country-wide normal value by averaging the normal values per product type.

3.2.1.2.   Export price

• (85) In the absence of cooperation by exporting producers from the PRC, the determination of the export price for all imports was based on facts available. The export price was based on information from the Article 14(6) database and adjusted to free on board (‘FOB’) level by deducting handling and ocean freight based on the evidence provided in the request for review [^ntr43-L_202502386EN.000101-E0043]. As in the 14(6) database import volumes are reported in kg, the Commission converted the figures into pieces (units) by using the conversion key that was established in the previous expiry review [^ntr44-L_202502386EN.000101-E0044] mentioned in recital (8).

• (86) The Commission has no detailed information on the product mix due to the absence of cooperation by exporting producers from the PRC, and the figures from the 14(6) database include all ironing boards without distinguishing types. Consequently, the Commission also used the export prices, by product type, from the offers and quotes provided in the request [^ntr45-L_202502386EN.000101-E0045], adjusted to FOB level on the same basis as the data from the 14(6) database. The request did not have any evidence of internal transport costs in China, so it used the FOB price as a proxy for the ex-works price. Considering the finding of dumping in recitals (87) to (89) as well as the nature of this expiry review investigation, which is focused on finding whether dumping continued during the review investigation period or could reoccur, rather than finding its exact magnitude, the Commission decided that deducting domestic transport was unnecessary as it would only result in a decrease of the export price and consequently a higher dumping margin.

3.2.1.3.   Comparison and dumping margin

• (87) The Commission compared the country-wide average constructed normal value established in accordance with Article 2(6a)(a) of the basic Regulation and the export price on an ex-works basis as established above. On this basis, the weighted average dumping margin, expressed as a percentage of the CIF Union frontier price, duty unpaid, was above 10 %.

• (88) The Commission also compared the export prices based on the request for review to the normal values established for the corresponding product types as established during this investigation. On this basis, the dumping margins, expressed as a percentage of the CIF Union frontier price, duty unpaid, range from 37 % to 104 %, depending on the product type.

• (89) It was therefore concluded that dumping continued during the review investigation period.

4. LIKELIHOOD OF CONTINUATION OF DUMPING

• (90) Further to the findings of the existence of dumping during the review investigation period, the Commission investigated, in accordance with Article 11(2) of the basic Regulation, the likelihood of continuation of dumping, should the measures be repealed. The following additional elements were analysed: the production capacity and spare capacity in China and the attractiveness of the Union market.

4.1.   Production capacity and spare capacity in China

• (91) None of the Chinese exporters/producers provided any information as to the actual production capacity in China. There is also no publicly available information concerning ironing boards specifically, such as statistics or market studies and therefore findings had to be based on the information provided by the applicants in the request for review and the findings of the previous expiry review, as information available in accordance with Article 18 of the basic Regulation.

• (92) According to the information in the request, Chinese producers have an excess production capacity [^ntr46-L_202502386EN.000101-E0046]. The evidence provided by the applicants in the request was based on the previous expiry review and confirmed by the conclusions of the latest US ITC report from August 2021 (third review of the antidumping duty order). The latter shows that Chinese producers have the capacity to further increase exports of the product concerned, by shifting production between the existing production lines depending on demand. The export data used in the US ITC report already showed that between 2015 and 2020 the Chinese producers were the biggest global exporters of other metal furniture, which includes ironing boards and other products in the same overall product category. They represented between 46 % and 56 % of global exports of these products [^ntr47-L_202502386EN.000101-E0047]. Moreover, according to the applicants and based on the latest Report, this overcapacity derives from the distortive support by the GOC and the overcapacities for the main input, i.e. steel.

• (93) Based on findings in the previous expiry review, which were not contested in the current investigation, Chinese producers can easily install additional production capacity because the manufacturing process is mainly labour based. Moreover, Chinese producers of ironing boards also produce other metal products on production lines that could easily be used to produce ironing boards. This enables Chinese producers to increase production of ironing boards by shifting production between the existing production lines depending on demand. Such increase of capacity does not require any important investments or skills and the switch between different products is therefore easy. The current investigation did not bring into light any information that would put these findings into question.

• (94) Based on this, the previous expiry review concluded that there are high production capacities available in the PRC, covering at least almost 100 % of the consumption in the EU, that can be easily increased even further [^ntr48-L_202502386EN.000101-E0048]. The current investigation did not bring into light any information that would put these findings into question.

4.2.   Attractiveness of the Union market

• (95) The analysis of Chinese exports revealed that, despite the anti-dumping measures in force, the EU market remains one of the most important export markets for Chinese ironing boards producers.

• (96) This is confirmed by the fact that the Chinese market share during the review investigation period was still 6 % despite the anti-dumping measures in force. This clearly indicates that the EU remains an attractive market for Chinese producers of ironing boards and that imports from the PRC would likely increase should measures be allowed to lapse.

• (97) In August 2021, within the framework of the US third sunset review [^ntr49-L_202502386EN.000101-E0049], following a first [^ntr50-L_202502386EN.000101-E0050] and a second sunset review [^ntr51-L_202502386EN.000101-E0051] stemming from the original anti-dumping investigation initiated in 2003 and imposing anti-dumping duties on ironing boards from PRC ranging from 9,47 % to 157,68 %, the US Department of Commerce (‘DOC’) gave notice of the continuation of the antidumping duty order on ironing boards from the China for other five years.

• (98) In addition to those duties, as of 24 September 2018, ironing boards imported from China have been subject to a further 10 % ad valorem duty in the US, which was further increased to a 25 % ad valorem duty as of 10 May 2019 [^ntr52-L_202502386EN.000101-E0052].

• (99) Following a changed circumstances review of the anti-dumping duty order regarding imports of ironing boards from PRC originally initiated in 2022, on 19 April 2023 the US DOC determined not to revoke the order imposing such duties [^ntr53-L_202502386EN.000101-E0053].

• (100) Similarly in the UK, the UK Trade Remedy Authority (‘TRA’) determined that the EU anti-dumping duties on ironing boards originating in China were to be transitioned. Therefore, anti-dumping duties on Chinese imports of ironing boards into the EU, i.e. those currently applicable in the EU, were imposed by way of transition to Chinese imports of ironing boards into the UK as well [^ntr54-L_202502386EN.000101-E0054].

• (101) These measures in the US and the UK limit Chinese producers’ export markets, making it likely that they would increase their exports to the Union should the anti-dumping measures be allowed to lapse.

4.3.   Conclusion

• (102) In view of its findings on the continuation of dumping during the review investigation period as established in recitals (87) to (89) and on the likely development of exports should the measures lapse as explained in recitals (91) to (101), the Commission concluded that there is a strong likelihood that the expiry of the anti-dumping measures on imports from the PRC would result in the continuation of dumping.

5. INJURY

5.1.   Definition of the Union industry and Union production

• (103) The like product was manufactured by 11 producers in the Union during the period considered. They constitute the ‘Union industry’ within the meaning of Article 4(1) of the basic Regulation.

• (104) The total Union production during the review investigation period was established at around 3,7 million pieces. The Commission established this figure on the basis of the data provided by the applicant, which was cross-checked with the verified data of the sampled companies. As indicated in recital (17), Union producers were selected in the sample representing 55 % of the total Union production of the like product.

5.2.   Union consumption

• (105) The consumption in the EU was established on the basis of the import volume as recorded in the Article 14(6) database and the sales volumes of the Union industry in the EU as submitted by the applicant. These sales volumes were cross-checked and updated when necessary as regards verified information from the sampled Union producers. As in the Article 14(6) database , import volumes are reported in kg, the Commission converted the figures, if needed, into pieces (units) by using the conversion key that was established in the previous expiry review [^ntr55-L_202502386EN.000101-E0055] mentioned in recital (8).

• (106) During the period considered Union consumption developed as follows:

Table 2

Union consumption (pieces)

	2020	2021	2022	2023	Review Investigation period
Total Union consumption	6 322 017	5 995 470	5 501 707	5 273 174	5 535 074
Index	100	95	87	83	88
Source: Questionnaire replies and Article 14(6) database.	Source: Questionnaire replies and Article 14(6) database.	Source: Questionnaire replies and Article 14(6) database.	Source: Questionnaire replies and Article 14(6) database.	Source: Questionnaire replies and Article 14(6) database.	Source: Questionnaire replies and Article 14(6) database.

• (107) During the period considered, consumption in the EU decreased by 12 %. The main part of this decrease occurred between 2020 and 2022. The decrease from 2021 to 2023 occurred during a period of increasing prices in order to cover the sudden increase of input material costs, mainly steel, following the outbreak of the war in Ukraine [^ntr56-L_202502386EN.000101-E0056]. Consumption increased slightly again in the review investigation period compared with the full year of 2023.

5.2.1.   Imports into the EU from the PRC

• (108) During the period considered imports into the Union from the PRC and market share developed as follows:

Table 3

Import volume (pieces) and market share

	2020	2021	2022	2023	Review investigation period
Volumes of imports from the PRC	473 904	319 767	261 542	274 324	306 328
Index	100	67	55	58	58
Market share	7 %	5 %	5 %	5 %	6 %
Index	100	71	63	69	74
Source: Article 14(6) database and questionnaire replies.	Source: Article 14(6) database and questionnaire replies.	Source: Article 14(6) database and questionnaire replies.	Source: Article 14(6) database and questionnaire replies.	Source: Article 14(6) database and questionnaire replies.	Source: Article 14(6) database and questionnaire replies.

• (109) Imports decreased between 2020 and 2022 by 45 %, but subsequently increased again, including in the review investigation period. Overall, they decreased by 35 % during the period considered. However, the market share of Chinese imports remained relatively stable decreasing from 7 % in 2020 to 5 % in 2021 but increasing again to 6 % during the review investigation period. Although total quantities of imports decreased, reflecting also the pattern of Union consumption as described in recital (107), the market share of Chinese imports remained consequential during the whole period considered.

• (110) Due to the absence of cooperation from the exporting producers, there is a lack of information on the product types imported from the PRC. Therefore, the Commission took into account the different TARIC customs codes under which imports of the product under review from the PRC were registered, as set out in recital (30). Based on this, during the period considered between 80 % and 95 % of the ironing boards imported from the PRC were composed of steel (TARIC 7323 93 00 10 and 7323 99 00 10) [^ntr57-L_202502386EN.000101-E0057]. Among these, the import volume using the relevant TARIC code for stainless steel (7323 93 00 10) increased during the period considered from 19 % of total import volume in 2020 to 36 % in the review investigation period compared with a decline from 75 % to 59 % of total import volumes for the TARIC code covering other steel (7323 99 00 10).

5.2.2.   Prices of the imports from the PRC concerned and price undercutting

• (111) Due to the absence of cooperation of the Chinese exporting producers the average import price from the PRC had to be established on the basis of the facts available in accordance with Article 18 of the basic Regulation, i.e. on the basis of the information contained in the Article 14(6) database and using the same conversion key as set out in recital (105). Price undercutting of the imports compared with Union industry prices was established taking into account the information submitted by the applicants and the sampled Union producers.

• (112) The weighted average price of imports into the Union from the PRC developed as follows during the period considered:

Table 4

Import prices (EUR/pieces)

Imports from PRC	2020	2021	2022	2023	Review Investigation period
Average import price (EUR/piece)	11,36	17,00	20,69	18,35	17,73
Index	100	150	182	162	156
Source: Article 14(6) database.	Source: Article 14(6) database.	Source: Article 14(6) database.	Source: Article 14(6) database.	Source: Article 14(6) database.	Source: Article 14(6) database.

• (113) Import prices from the PRC increased by 56 % during the period considered. Import quantities increased in particular for product types using stainless steel covered by HS code 7323 93 00 (TARIC 7323 93 00 10) yielding higher prices than product types imported under 7323 99 00 (TARIC 7323 99 00 10). The import quantities of the latter decreased during the period considered, as illustrated in recital (110).

• (114) In order to determine price undercutting during the review investigation period, the weighted average sales price of the sampled Union producers charged to unrelated customers on the EU market, adjusted to an ex-works level (i.e. excluding freight costs in the EU and after deduction of discounts and rebates), was compared on a type-by-type basis to the corresponding weighted average price of the imports as established above in recital (111), on a CIF basis, and then including the customs and anti-dumping duty.

• (115) The comparison showed that, when expressed as a percentage of the sampled Union producers’ turnover during the review investigation period, imports from the PRC were undercutting the prices of the Union industry by 4 %. When deducting the anti-dumping duty in place, the undercutting margin amounted to 26 %.

5.3.   Imports from third countries other than PRC

• (116) The imports of ironing boards from third countries other than the PRC were mainly from Türkiye, Ukraine and India.

• (117) The (aggregated) volume of imports into the Union as well as the market share and price trends for imports of ironing boards from other third countries developed as follows during the period considered:

Table 5

Imports from third countries

Country		2020	2021	2022	2023	Review Investigation period
Türkiye	Volume (pieces)	1 120 887	1 120 413	929 773	945 325	1 028 524
	Index	100	100	83	84	92
	Market share	18 %	19 %	17 %	18 %	19 %
	Average price (EUR/pieces)	9,04	9,28	12,59	11,88	11,62
	Index	100	103	139	131	129
Ukraine	Volume (pieces)	1 076 875	960 185	564 541	491 488	655 160
	Index	100	89	52	46	61
	Market share	17 %	16 %	10 %	9 %	12 %
	Average price (EUR/pieces)	11,03	11,64	14,15	14,44	14,07
	Index	100	106	128	131	128
India	Volume (pieces)	193 309	132 660	240 236	173 572	181 278
	Index	100	69	124	90	94
	Market share	3 %	2 %	4 %	3 %	3 %
	Average price (EUR/pieces)	8,99	10,84	14,29	19,61	19,36
	Index	100	120	159	218	215
Others	Volume (pieces)	218 575	195 270	87 398	68 899	95 031
	Index	100	89	40	32	43
	Market share	3 %	3 %	2 %	1 %	2 %
	Average price (EUR/pieces)	11,9	12,5	18,9	20,4	20,1
	Index	100	105	159	172	169
Total of imports from third countries other than PRC	Volume (pieces)	2 549 008	2 516 117	1 755 299	1 687 004	1778 729
	Index	100	99	69	66	70
	Market share	41 %	40 %	33 %	32 %	35 %
Source: 14(6) database.	Source: 14(6) database.	Source: 14(6) database.	Source: 14(6) database.	Source: 14(6) database.	Source: 14(6) database.	Source: 14(6) database.

• (118) The volume of imports from all third countries not subject to measures taken as a whole was about 1,8 million pieces in the review investigation period, translating into a market share of 35 %. Most of these imports came from Türkiye and Ukraine. Over the whole period considered, the volume of imports from all third countries not subject to measures decreased from 41 % in 2020 to 32 % in 2023 before increasing slightly again up to 35 % in the review investigation period.

• (119) Imports from Türkiye remained overall stable during the period considered fluctuating between 0,9 and 1,1 million pieces per year. Total imports amounted to 1,1 million in 2020 and 1,0 million during the review investigation period.

• (120) In contrast to this, imports from Ukraine decreased from 1,0 million to 0,5 million pieces in 2023. The biggest drop occurred from 1,0 million 2021 to less than 0,6 million pieces in 2022 reflecting the outbreak of the war in Ukraine. In the review investigation period, imports from Ukraine started to increase again.

• (121) Imports from India remained relatively stable around 0,2 million pieces annually during the period considered. The volume of imports from other third countries was low, decreasing from 0,2 million pieces to 0,1 million pieces during the period considered.

• (122) In terms of market share, the trends described above translated into an increase by 1 percentage point, from 18 % in 2020 to 19 % in the review investigation period, for Türkiye and a decrease from 17 % market share in 2020 to 12 % in the review investigation period for Ukraine. The market share of India remained stable around 3 % during the period considered. The market share of the remaining third countries decreased from 3 % in 2020 to 2 % in the review investigation period.

• (123) The average price of imports from Türkiye increased from 9 EUR/piece in 2020 to 11,6 EUR/piece in the review investigation period. During the same period, the average price of imports from Ukraine increased slightly from 11 EUR/piece to 14 EUR/piece, while the average price of imports from India increased from 8,99 to 19,36 EUR/piece.

5.4.   Economic situation of the Union industry

5.4.1.   General remarks

• (124) The assessment of the economic situation of the Union industry included an evaluation of all economic indicators having a bearing on the state of the Union industry during the period considered.

• (125) As mentioned in recital (17), sampling was used for the assessment of the economic situation of the Union industry.

• (126) For the injury determination, the Commission distinguished between macroeconomic and microeconomic injury indicators. The Commission evaluated the macroeconomic indicators on the basis of data contained in the questionnaire submitted by the applicants as well as data contained in the Article 14(6) database. The Commission evaluated the microeconomic indicators on the basis of data contained in the questionnaire replies from the sampled Union producers.

• (127) The macroeconomic indicators are: production, production capacity, capacity utilisation, sales volume, market share, growth, employment, productivity.

• (128) The microeconomic indicators are: average unit prices, unit cost, labour costs, inventories, profitability, cash flow, investments and return on investments.

5.4.2.   Macroeconomic indicators

5.4.2.1.   Production, production capacity and capacity utilisation

• (129) The total Union production, production capacity and capacity utilisation developed over the period considered as follows:

Table 6

Production, production capacity and capacity utilisation

	2020	2021	2022	2023	Review Investigation period
Production volume (measuring unit)	3 809 828	3 817 450	4 036 480	3 813 199	3 722 588
Index	100	100	106	100	98
Production capacity (measuring unit)	6 038 000	6 038 000	6 038 000	6 038 000	6 038 000
Index	100	100	100	100	100
Capacity utilisation	63 %	63 %	67 %	63 %	62 %
Index	100	101	106	103	101
Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.

• (130) The total Union production remained stable over the period considered, only increasing in 2022 by 6 % amounting to 4,0 million pieces, but decreasing in 2023 and during the review investigation period where it reached similar levels as in 2020. The peak of production in the year 2022 followed the evolution of sales volume being presented in the following section. The production capacity remained the same during the whole period considered.

5.4.2.2.   Sales volume and market share

• (131) The Union industry’s sales volume and market share developed over the period considered as follows:

Table 7

Sales volume and market share (pieces)

	2020	2021	2022	2023	Review Investigation period
Total sales volume on the Union market	3 238 467	3 267 174	3 418 216	3 319 567	3 268 752
Index	100	101	106	103	101
Market share	51 %	54 %	62 %	63 %	59 %
Index	100	106	121	123	115
Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.

• (132) The sales volume of the Union industry on the EU market remained basically stable with slight fluctuations during the period considered. After an increase from 3,2 million in 2021 to 3,4 million pieces in 2022, sales volume decreased again to 3,3 million in 2023 and, in the review investigation period, was about the same level as in the year 2020 amounting to 3,2 million pieces. Market share of the Union industry followed the trend of sales, increasing in 2022 and 2023 and decreasing again during the review investigation period, overall, it increased by 15 % during the period considered.

• (133) While the sales volume remained about the same level during the period considered, the market share of the EU industry increased by 9 percentage points to 59 %. This is explained by the overall slightly declining Union consumption, as described in recital (107).

5.4.2.3.   Growth

• (134) The Union Industry’s production and sales volume remained stable while consumption was declining slightly, resulting in an increase of the Union’s industry’s market share. Employment of the Union industry remained stable throughout the period considered. On this basis, it can be concluded that the Union industry maintained but did not increase its position in terms of production and sales in a slightly decreasing market during the considered period.

5.4.2.4.   Employment and productivity

• (135) Employment and productivity developed over the period considered as follows:

Table 8

Employment and productivity

	2020	2021	2022	2023	Review Investigation period
Number of employees	484	472	492	482	482
Index	100	98	102	100	100
Productivity (unit/employee)	7 877	8 088	8 212	7 914	7 725
Index	100	98	102	100	100
Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.

• (136) Employment, while fluctuating slightly, remained overall stable during the period considered. More specifically, there was a decrease of employment from 2020 to 2021 followed by an increase in the year 2022 to peak level. Subsequently, the number of employees decreased again to the same level as in 2020, reflecting also the lower production and sales volumes in the year 2023 and the review investigation period when compared with the year 2022.

• (137) Productivity, measured as output (pieces) per person employed per year, remained rather stable with minor fluctuations. Starting in 2020, it increased slightly in 2022 and fell back to the level of 2020 in the review investigation period.

5.4.2.5.   Magnitude of the dumping margin and recovery from past dumping

• (138) Dumping continued during the review investigation period at a material level. Chinese exporting producers also continued to undercut the Union industry’s sales prices during the review investigation period.

• (139) At the same time, despite the anti-dumping measures in place, the level of imports from China remained material representing between 5 % and 7 % of the market share in the review investigation period. Therefore, the impact of the magnitude of the actual dumping margin from China on the Union industry persisted and cannot be considered to be negligible.

• (140) However, despite the fact there was still dumping for imports from the PRC, the analysis of the injury indicators shows that the measures in place had a shielding effect and an overall positive impact on the Union industry.

5.4.3.   Microeconomic indicators

5.4.3.1.   Prices and factors affecting prices

• (141) The average unit sales prices of the sampled Union producers to unrelated customers in the Union developed over the period considered as follows:

Table 9

Sales prices and cost of production in the Union (EUR/pieces)

	2020	2021	2022	2023	Review Investigation period
Average unit sales price in the Union on the total market	10,8	12,4	13,9	14,5	14,4
Index	100	114	128	133	133
Unit cost of production	11	13	15	14	15
Index	100	119	138	130	132
Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.	Source: Questionnaire replies.