Commission Implementing Regulation (EU) 2026/114 of 15 January 2026 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of fused alumina originating in the People’s Republic of China

Image omitted; see official source	Official Journal of the European Union	EN L series
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	2026/114	16.1.2026

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 [^ntr1-L_202600114EN.000101-E0001] (‘the basic Regulation’), and in particular Article 9(4) thereof,

Whereas:

1. PROCEDURE

1.1.   Initiation

• (1) On 21 November 2024, the European Commission (‘the Commission’) initiated an anti-dumping investigation with regard to imports of fused alumina originating in the People’s Republic of China (‘the country concerned’ or ‘PRC’) on the basis of Article 5 of the basic Regulation. It published a Notice of Initiation in the Official Journal of the European Union [^ntr2-L_202600114EN.000101-E0002] (‘the Notice of Initiation’).

• (2) The Commission initiated the investigation following a complaint lodged on 9 October 2024 by Imerys S.A. (‘Imerys’ or ‘the complainant’). The complaint was made on behalf of the Union industry of fused alumina in the sense of Article 5(4) of the basic Regulation. The complaint contained evidence of dumping and of resulting material injury that was sufficient to justify the initiation of the investigation.

1.2.   Registration

• (3) The Commission made imports of the product concerned subject to registration by Commission Implementing Regulation (EU) 2025/260 [^ntr3-L_202600114EN.000101-E0003] (‘the registration Regulation’).

1.3.   Provisional measures

• (4) In accordance with Article 19a of the basic Regulation, on 26 June 2025, the Commission provided parties with a summary of the proposed duties and details about the calculation of the dumping margins and the margins adequate to remove the injury to the Union industry. Interested parties were invited to comment on the accuracy of the calculations within three working days.

• (5) Sampled exporting producers, Chongqing Saite Corundum Co., Ltd. (‘Saite’) and Luoyang Runbao Abrasives Co., Ltd. (‘Runbao’), noted the absence of calculation details concerning the non-injurious price, which were referred to in the documentation but not made available. Runbao further highlighted that the Commission had applied the same benchmark price to two distinct inputs – aluminium hydroxide of different purities – which they argued was factually and economically inaccurate. They requested that the benchmark for the lower-purity input be adjusted proportionally.

• (6) The request for disclosure of calculation details concerning the non-injurious price could not be accommodated, as this information is confidential, highly sensitive and its disclosure could be detrimental to the parties concerned. The Commission also explained that aggregate figures cannot be provided without risking disclosure of confidential data from a very limited number of Union producers. With regard to the alleged clerical error concerning aluminium hydroxide benchmarks, the Commission noted that such comments did not relate to the accuracy of the calculations and could not be addressed at that stage of the investigation. This comment is addressed in Section 3.2.3.1.

• (7) Union users and importers, such as Reckel GmbH (‘Reckel’) and Tyrolit – Schleifmittelwerke Swarovski AG & Co. KG (‘Tyrolit’), expressed serious methodological concerns. They argued that the Commission’s analysis focused only on brown fused alumina, while ignoring the wide variety of fused-alumina grades with differing applications and cost structures, leading to distorted price and cost comparisons. They also criticised the reliance on broad, heterogeneous tariff-line trade statistics for key inputs such as calcined bauxite and aluminium oxide, noting that these covered products of very different qualities and prices. In some cases, the same raw material (calcined bauxite) appeared to have been counted twice under separate headings.

• (8) These comments did not relate to the mathematical accuracy of the calculations as disclosed. Hence, these comments were addressed in Section 3.2.3.1 of this Regulation.

• (9) Further concerns were raised by Tyrolit and Reckel regarding the selection of the sources for reasonable amounts for SG & A costs and for profit. The relevant companies from which both rates were sourced were said to operate in unrelated sectors and thus provided unrepresentative data. Tyrolit stressed that this, combined with reliance on benchmark prices from Brazil for certain FOPs, including alumina and bauxite, resulted in inflated cost benchmarks. Both Tyrolit and Reckel warned that provisional anti-dumping duties of up to 136 % on the product under investigation, while leaving downstream finished abrasive products duty-free, would risk closures of Union production plants of downstream users, loss of skilled jobs, and greater dependency on imported finished products.

• (10) Similarly, the points raised regarding the selection of companies for sourcing financial data on SG & A costs and profit, the alleged distortion of input benchmarks, and the wider economic consequences of the measures do not pertain to the accuracy of the mathematical calculations presented in the pre-disclosure. These matters fall under the Commission’s broader methodological assessment and Union interest analysis and were dealt with in detail in Section 3.2.3.2.

• (11) On 17 July 2025, the Commission imposed provisional anti-dumping duties on imports of fused alumina originating in the People’s Republic of China by Commission Implementing Regulation (EU) 2025/1456 [^ntr4-L_202600114EN.000101-E0004] (‘the provisional Regulation’).

1.4.   Subsequent procedure

• (12) Following the disclosure of the essential facts and considerations on the basis of which a provisional anti-dumping duty was imposed (‘provisional disclosure’), the following parties filed written submissions making their views known on the provisional findings within the deadline provided by Article 2(1) of the provisional Regulation:

• — the Union producers Imerys and Alteo Fused Alumina (‘AFA’),

• — the sampled exporting producers Saite and Runbao,

• — the importers TRAXYS Europe SA and Reckel,

• — the users Calderys Deutschland GMBH, Calderys France S.A.S., Calderys Magyarorszag K.F.T., Calderys Italia SRL, Calderys Nordic AB, Calderys The Netherlands B.V. (‘Calderys’), Tyrolit, ABRANOVA s.r.o. (‘Abranova’), ANDRE ABRASIVE ARTICLES SP. Z O.O. SP.K, Vesuvius Poland Sp. z o.o. (‘Vesuvius’), August Rüggeberg GmbH & Co. KG, PFERD-Rüggeberg S.A., Smirdex, ABRASIENNE, ArcelorMittal Refractories Sp. z o. o. (‘ArcelorMittal’), MOLITAL ABRASIVI SRL, Federchimica–Aispec–Gruppo abrasive, G.W.S. GRINDING WHEELS SYSTEM SRL, GRANDINETTI SRL, Industria Mole Abrasive S.r.l., Mabtools France, RHI Magnesita GmbH, , SAINT-GOBAIN ABRASIFS (‘Saint-Gobain’), Syndicat National des Abrasifs et Superabrasifs, Granit Grinding Wheel Ltd., Techniflex Sp. z o.o. and ZAI AD, and

• — the exporting producers Binzhou Qinai New Material Co., Ltd, Chongqing Saite Corundum Co., Ltd., Henan Ant Advanced Materials Co., Ltd., Henan Hengxin Industrial & Mineral Products Co., Ltd., Henan Tuorui Abrasive Material Co., Ltd., Jiygo Refractory & Abrasive Ltd., Luoyang Runbao Abrasives Co., Ltd., Qingdao Sisa Abrasives Co., Ltd., Shandong Bosheng New Materials Co., Ltd., Shanxi Lvliangshan Minerals Co., Ltd., Yichuan Abrasives Industry Union, Zhengzhou Sinabuddy Mineral Co., Ltd. and Zhengzhou Goohe Co., Ltd. represented by the China Chamber of Commerce of Metals Minerals & Chemicals Importers & Exporters (‘the exporting producers represented by the CCCMC’),

• — the users’ associations Deutsche Feuerfest-Industrie e.V. (‘DFFI’), Verband Deutscher Schleifmittelwerke e.V. (‘VDS’), Federation of European Producers of Abrasives (‘FEPA’) and European Refractories Producers Federation (‘PRE’).

• (13) The parties who so requested were granted an opportunity to be heard. Following the publication of the provisional Regulation, the Commission invited the parties to provide additional input in particular for the purpose of assessing the Union interest, in light of the differing interests of the parties concerned. Hearings took place with AFA, Imerys, PRE, VDS, Tyrolit, Saint-Gobain, ArcelorMittal, the exporting producers represented by the CCCMC, Saite and Runbao.

• (14) The Commission continued to seek and verify all the information it deemed necessary for its final findings. When reaching its definitive findings, the Commission considered the comments submitted by interested parties and revised its provisional conclusions when appropriate.

• (15) The Commission informed all interested parties of the essential facts and considerations on the basis of which it intended to impose a definitive anti-dumping duty on imports of fused alumina originating in the People’s Republic of China (‘final disclosure’). Comments submitted by parties after the disclosure were addressed in the relevant sections below.

• (16) Following the disclosure referred to in recital (15), the Commission subsequently made an additional final disclosure to all interested parties. This additional disclosure contained updated findings and considerations. Parties were given the opportunity to comment on this additional disclosure, and the comments received were addressed in the relevant sections below.

1.5.   Claims on procedure

• (17) Following provisional disclosure, Reckel, Tyrolit and VDS argued that Article 19a(1) of the basic Regulation required provisional disclosure to take place three weeks before the imposition of provisional measures. The parties argued that the Commission, by providing information on the planned imposition of provisional duties to the parties on 26 June 2025, violated Articles 19a(1), 7(1) and 5(10) of the basic Regulation, as well as the terms of its Notice of Initiation.

• (18) The Commission noted that Article 7(1) of the basic Regulation provides that provisional duties shall not be imposed within three weeks of the information being sent to interested parties in accordance with Article 19a. Therefore, this provision defines the minimum interval between the communication of such information and the adoption of provisional measures. In the present case, the Commission sent the information on 26 June 2025 and imposed provisional measures on 18 July 2025. The interval was three weeks. The requirements of Article 7(1) were thus respected.

• (19) The Commission further recalled that Article 19a, as amended by Commission Delegated Regulation (EU) 2020/1173 [^ntr5-L_202600114EN.000101-E0005], governs the content and purpose of provisional disclosure, whereas Article 7(1) sets the procedural framework for the timing of provisional measures. The amendment of Article 19a did not modify the temporal rule laid down in Article 7(1). Consequently, the Commission considered that the argument concerning an alleged violation of the requirements of the provisional disclosure period was unfounded and therefore rejected this claim.

1.6.   Claims on initiation

• (20) Following provisional disclosure, no interested party submitted any further claims or comments on initiation than those referred to in Section 1.4 of the provisional Regulation. The Commission therefore confirmed its findings and conclusions as set out in recitals (6) to (11) of the provisional Regulation.

1.7.   Sampling

• (21) In the absence of comments regarding the sampling of Union producers, importers and exporting producers, the Commission confirmed recitals (12) to (28) of the provisional Regulation.

1.8.   Questionnaire replies and verification visits

• (22) Following provisional disclosure, no interested party submitted any claims or comments on questionnaire replies and verification visits. The Commission therefore confirmed its findings and conclusions as set out in recitals (29) to (32) of the provisional Regulation.

1.9.   Investigation period and period considered

• (23) As stated in recital (33) of the provisional Regulation, the investigation of dumping and injury covered the period from 1 October 2023 to 30 September 2024 (‘the investigation period’). The examination of trends relevant for the assessment of injury covered the period from 1 January 2021 to the end of the investigation period (‘the period considered’).

2. PRODUCT CONCERNED AND LIKE PRODUCT

2.1.   Product under investigation

• (24) The Commission recalled that, as set out in recital (34) of the provisional Regulation, the product under investigation is artificial corundum, whether or not chemically defined, also known as fused alumina (‘the product under investigation’).

• (25) Due to its hardness and thermal resistance, fused alumina is primarily used in two industrial sectors, abrasives and refractories. In the abrasives industry, it is used in a wide range of applications, including grinding, polishing, cutting and blasting. In the refractories industry, it functions as a refractory material in high-temperature settings, such as furnace linings, crucibles, and refractory bricks. Beyond these principal uses, fused alumina is also used in the manufacture of technical ceramics and as a wear-resistant additive in surface coatings within the laminated products industry.

2.2.   Product under investigation

• (26) The Commission recalled that, as set out in recital (38) of the provisional Regulation, the product concerned is the product under investigation originating in the PRC, currently falling under CN code 2818 10 11 , 2818 10 19 , ex 2818 10 91 , and 2818 10 99 (TARIC codes 2818 10 91 20, 2818 10 91 40, 2818 10 91 91, 2818 10 91 99) (‘the product concerned’).

2.3.   Like product

• (27) In the absence of any related claim or comment, the conclusions in recitals (40) and (41) of the provisional Regulation are hereby confirmed.

2.4.   Claims regarding product scope

• (28) Certain Union users from the refractory industry claimed that substitution between abrasive-grade and refractory-grade fused alumina is not possible, based on their different physical and chemical characteristics, particle size distribution, properties, applications and consumer perception. In particular, ArcelorMittal also argued that there is insufficient production and production capacity of refractory-grade fused alumina. ArcelorMittal based its claim on an estimation of the total Union consumption of fused alumina at 400 000 tonnes, including 170 000 tonnes of refractory-grade fused alumina. The parties argued that refractory-grade fused alumina should thus be excluded from the product scope of the investigation.

• (29) The Commission recalled that these arguments had already been examined and addressed in recitals (42) to (45) and (307) to (308) of the provisional Regulation. The Commission reiterated that both grades share the same basic physical, chemical and technical characteristics, including comparable alumina content, hardness, density and melting point. Variations in particle size distribution were found to stem from post-fusion processing rather than any inherent product difference. The Commission also observed a substantial overlap in particle sizes enabling interchangeability for certain applications.

• (30) Furthermore, the Commission noted that the claim concerning limited Union production and production capacity of refractory-grade fused alumina does not relate to the essential nature of the product. As set out in recitals (307) and (308) of the provisional Regulation, the Commission found that the Union industry is capable of supplying the Union market in the required quantities, including specific types of the product concerned. Although the Union industry’s production volumes substantially decreased over the period considered due to dumped imports from China, the Commission noted that the Union industry significantly underutilised its production capacity during this period. The Commission further confirmed that the available additional capacity includes production of refractory-grade fused alumina, which is available immediately or can become operational within a very short period of time. The claim regarding insufficient Union production capacity is further addressed in Section 7.4.

• (31) Additionally, regarding the Union consumption, the Commission recalled that, as set out in recitals (188) to (190) of the provisional Regulation, Union consumption amounted to 305 360 tonnes during the investigation period (‘IP’). ArcelorMittal’s claim regarding the estimated consumption of refractory-grade and overall fused alumina not only contradicts the verified data but also diverges from the assessment provided by the European Refractories Producers Federation, the users association representing several Union operators in the sector, which estimated the consumption of refractory-grade fused alumina at 80 000 tonnes.

• (32) Accordingly, the Commission maintained its conclusion in recitals (42) to (45) of the provisional Regulation that both grades constitute a single product, as the variations described by the parties did not demonstrate any material differences that would justify the exclusion of refractory-grade fused alumina from the product scope.

• (33) Reckel claimed that sol-gel corundum differs from other types of fused alumina in its basic physical, chemical and technical characteristics, including hardness, fracture toughness, and thermal properties, and argued that it cannot be substituted in high-end precision applications without significant operational difficulties. Reckel thus argued that sol-gel corundum should be excluded from the product scope of the investigation.

• (34) The Commission recalled that these arguments had already been examined and addressed in recitals (46) to (48) of the provisional Regulation. The Commission reiterated that sol-gel corundum has similar physical, chemical, and technical characteristics as other fused alumina, including comparable hardness, thermal resistance, and chemical stability. Although produced by a different process and from different raw materials, these differences do not materially affect the functional properties of the product. Additionally, cost differences alone are insufficient to treat sol-gel as a separate product. The ability of other types of fused alumina to replace sol-gel, even with reduced performance in demanding applications, demonstrates sufficient functional similarity and interchangeability for most abrasive uses.

• (35) Accordingly, the Commission maintained its conclusion in recitals (46) to (48) of the provisional Regulation that sol-gel corundum falls within the scope of the product under investigation.

• (36) A number of interested parties claimed that brown fused alumina should be excluded from the scope of the measures, noting that it differs from white fused alumina in its chemical composition, including lower Al2O3 content and higher impurity levels. They further claimed that brown fused alumina is either not produced in the Union or is available only in insufficient quantities to meet Union demand. In addition, the interested parties argued that switching production between brown fused alumina and white fused alumina is technically challenging, and market evidence indicates that the two products are not readily substitutable in terms of technical characteristics or price.

• (37) The Commission considered that, while brown fused alumina has slightly lower Al2O3 content and higher impurity levels than white fused alumina, these differences do not constitute a material distinction in physical, chemical, or technical characteristics sufficient to define a separate product. Furthermore, the Commission noted that the claim concerning limited Union production and production capacity of brown fused alumina does not relate to the essential nature of the product. However, the Commission noted that brown fused alumina is currently produced by the Union industry. Regarding the quantities, as set out in recitals (307) and (308) of the provisional Regulation, the Commission found that the Union industry is capable of supplying the Union market in the required quantities, also for brown fused alumina. The Commission further confirmed that a substantial proportion of the available additional capacity, which is either immediately available or can be made operational within a very short period of time, relates to the production of brown fused alumina. The claim regarding insufficient Union production capacity is further addressed in Section 7.4.

• (38) For these reasons, the Commission considered that brown fused alumina falls within the product scope of the investigation and rejected the claim for its exclusion.

• (39) Accordingly, the Commission concluded that all comments received regarding the product scope did not provide sufficient justification for the product exclusions. Consequently, all claims were rejected.

3. DUMPING

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

• (40) In the absence of any related claim or comment, the conclusions in recitals (49) to (55) of the provisional Regulation were hereby confirmed.

3.2.   Normal value

3.2.1.   Existence of significant distortions

• (41) Following provisional disclosure, Abranova, Tyrolit and VDS submitted comments related to the presence of significant distortions.

• (42) Abranova rejected the Commission’s reliance on the concept of significant distortions in China. They argued that cost advantages of Chinese producers derive mainly from natural factors: access to raw materials, lower energy costs, and long-standing investments in pollution control technology. They insisted that Union producers’ difficulties are instead due to high electricity prices and dependence on imported raw materials. Abranova strongly contested the view that China’s political system or CPC congress targets amount to proof of systemic distortions in production costs. They stressed that even state-owned and private firms in China must operate profitably and cannot survive on subsidies alone. Therefore, the Commission’s reliance on state influence as evidence of distortions was, in their view, unsubstantiated.

• (43) As set out in recitals (74) to (110) of the provisional regulation, the Commission carried out a detailed assessment under Article 2(6a) of the basic Regulation and established the existence of significant distortions in the PRC affecting the formation of production costs and prices. The evidence showed pervasive state influence in the economy, including in energy, raw materials, labour, and access to finance, which affects cost structures across the sector. The arguments presented by Abranova did not alter these findings. The claim was therefore rejected.

• (44) Tyrolit submitted that the Commission’s reliance on generalised evidence to establish the existence of raw material distortions in alumina and bauxite was not supported by substantive positive evidence. They argued that alumina and bauxite are traded in an integrated global market and that Chinese domestic prices for these commodities closely tracked international benchmarks. In their view, the Commission’s reliance on generalised policy evidence, while disregarding specific pricing data from sources such as S & P Global Commodity Insights, was unsubstantiated. Tyrolit maintained that although distortions may exist for some factors of production (e.g. energy, labour), such considerations did not apply uniformly, and, in particular, not to alumina and bauxite. VDS supported this position, pointing to evidence that Chinese alumina and bauxite prices largely mirrored global levels, which undermined the Commission’s finding of distortions.

• (45) As detailed in recitals (59)-(110) of the provisional regulation, the evidence on the file, including the Commission’s Report on significant distortions in China, the complaint, and the Commission’s own research, demonstrated substantial state intervention in the Chinese economy, including in the alumina and bauxite sectors. The Government of China was sent questionnaires regarding the existence of significant distortions and raw material distortions, but it did not reply. Similarly, no Chinese exporting producer submitted substantiated evidence showing that their input costs, including for alumina and bauxite, were free from distortions. On the contrary, the investigation established that both SOEs and private operators in these sectors operate under the ownership, control, or policy supervision of the Chinese authorities, with extensive planning documents and industrial policies specifically targeting alumina and bauxite. In this context, the Commission concluded that prices and costs of alumina and bauxite in the PRC cannot be considered the result of free market forces.

• (46) The Commission therefore maintained its position and the conclusions in recitals (56) to (115) of the provisional Regulation were hereby confirmed.

3.2.2.   Representative country

• (47) Following provisional disclosure, Andre Abrasives Articles and VDS criticised the selection of Brazil as the representative country.

• (48) Andre Abrasives Articles requested a reassessment, arguing that Brazil is inappropriate due to its very different energy-cost structure and smaller market size, which undermined its comparability to China.

• (49) The request for a reassessment of the normal value methodology and for the rejection of Brazil as representative country due to the cost structure or market size were not substantiated. The Commission recalled that Brazil was selected in accordance with Article 2(6a)(a) of the basic Regulation, based on the availability of reliable and representative data as noted in recital (141) of the provisional Regulation. The claim was therefore rejected.

• (50) VDS additionally stressed that the Commission had initially rejected Mexico due to an alleged lack of production but then shifted to Brazil without clear justification.

• (51) The Commission recalled that the choice of Brazil as representative country was made after it was established that, contrary to Brazil, there was no genuine production of the product under investigation in Mexico. Such determination was also made following comments on the absence of production in Mexico by interested parties including VDS. The claim was therefore rejected.

• (52) The Commission therefore maintained its position and the conclusions in recitals (116) to (143) of the provisional Regulation are hereby confirmed.

3.2.3.   Sources used to establish undistorted costs

• (53) Following provisional disclosure, several interested parties submitted comments related to the benchmarks used for certain factors of production and to the selling general and administrative (‘SG & A’) costs used to construct the normal value.

3.2.3.1.   Factors of production

• (54) Saite, Runbao, DFFI, PRE and Vesuvius raised concerns about the Commission’s reliance on Brazilian import prices for bauxite as a source for undistorted prices. They argued that Brazil is a major exporter of bauxite, so imports only represent niche, high-priced products, that are unrepresentative of fused alumina production costs. Moreover, a significant share of Brazil’s imports originated from China, which raised the risk of distortions. By contrast, Mexico’s import structure was considered more diverse and economically relevant, providing a more reliable basis for calculating normal value.

• (55) The Commission noted that the use of Brazilian import prices, as a reflection domestic prices, was consistent with Article 2(6a)(a) of the basic Regulation. The fact that Brazil is a significant exporter of bauxite did not undermine the reliability of its import statistics, which covered a sufficient volume and a variety of origins. As explained in the first Note on factors of production, imports originating in the PRC were excluded from the calculation of the benchmark for bauxite. Also, in spite of their relative share, imports from the PRC did not have a significant impact on import prices from the rest of the world, which were made at significantly higher prices. The claim was therefore rejected.

• (56) Tyrolit also challenged the benchmarks for alumina and bauxite, emphasising that these inputs are globally traded commodities with Chinese prices tracking international market levels, and therefore benchmark pricing was unnecessary. Tyrolit and Saite also criticised the use of Brazilian import data that included high-quality Spanish exports of calcined bauxite not comparable to standard industrial feedstock, and highlighted inconsistencies such as changes in HS codes that did not affect dumping margins. They argued that normal values should have reflected undistorted domestic Brazilian prices, or export prices where appropriate, but ultimately maintained that there was no evidence of raw material distortions in China justifying surrogate benchmarks.

• (57) The Commission recalled that benchmarks had to be established because domestic Chinese prices and costs could not be used due to the existence of significant distortions in the PRC, as set out in recitals (74)–(110) of the provisional Regulation. Brazilian import data were used as the most appropriate source of undistorted benchmark prices, in accordance with Article 2(6a)(a). The presence in the import statistics of data related to specialised types of products does not invalidate the import dataset as a whole, which covered sufficient volumes from a variety of origins. In addition, these parties did not provide supporting evidence that the benchmarks did not reflect undistorted domestic Brazilian prices. The claim was therefore rejected.

• (58) FEPA and Smirdex s.a. argued that Brazilian fused alumina producers source bauxite domestically, making import statistics irrelevant for cost benchmarking. Both parties recommended using, what they referred to as, transparent and internationally recognised indices, such as those from S & P Global Commodity Insights or CBIX, which according to the interested parties, better capture market realities. Smirdex further pointed to evidence that Brazilian market prices for bauxite and alumina were only around 10–15 % higher than Chinese levels, which does not support the very high dumping margins established in the provisional regulation.

• (59) The Commission applied Article 2(6a)(a) of the basic Regulation by using data from a representative country where the relevant data was readily available. The benchmark for bauxite sourced in the representative country i.e. Brazil was considered as appropriate. Besides, the alleged price differentials between Brazil and China were not supported by evidence, they were only the result of unverified allegations. Consequently, interested parties did not demonstrate that the benchmark selected for bauxite was inappropriate and that the Commission should resort to an alternative methodology to establish an undistorted benchmark for this factor of production. The Commission further noted that the benchmark price for bauxite was in the same range as the Chinese export price for bauxite, refractory grade, 85 %/2,0/3,15–3,2 (0–6 mm), FOB Xingang, as reported in Metal Bulletin’s independent industry benchmarks for the global metal and mining industry (Fastmarkets’ prices). The claim was therefore rejected.

• (60) Vesuvius argued that the Commission failed to disclose clearly which HS codes were used to construct benchmarks for bauxite and calcined bauxite. They noted that while the pre-disclosure documents referred to HS 2508 30 , the provisional regulation mentioned customs code 2606 00 12 and 2606 00 90 . In their view, this inconsistency creates uncertainty about the data actually relied upon and undermines the transparency of the methodology. Vesuvius therefore requested that the Commission provide proper disclosure of the exact HS codes used for the determination of normal value.

• (61) The Commission noted that calcined bauxite was initially listed under HS code 2508 30 in the first Note on factors of production , corresponding to aluminium ores and concentrates in general. Following further examination and verification at the premises of the sampled exporting producers, it confirmed that calcined bauxite is properly classified under CN codes 2606 00 12 and 2606 00 90 , which were used to construct the benchmarks in the provisional regulation. This change ensured the correct customs classification of the factor of production actually used by the exporting producers and did not alter the underlying methodology. The reference to HS 2508 30 in earlier documents reflected preliminary information supplied by the exporting producers. In Table 1 of the provisional regulation, only calcined bauxite was retained as an input since exporting producers used calcined, not raw, bauxite. The Commission therefore concluded that the methodology was applied consistently and transparently, and the claim was rejected.

• (62) Vesuvius argued that the Commission’s method for determining the net-of-tax energy costs for Chinese exporters, based on Brazilian electricity and gas prices, inaccurately used a 17,5 % ICMS tax deduction. They asserted that the ICMS rates in Brazil ranged from 17 % to 20 %, with many sources indicating that intra-state transactions, such as energy supply, typically fell within this range. Therefore, Vesuvius suggested that an average rate of 18,5 % should have been used instead of 17,5 %.

• (63) The Commission established that for the investigation period most Brazilian states applied ICMS rates of 17–18 % to industrial electricity consumption. While a few states did set higher rates, these were applied primarily to residential consumption above certain thresholds and not to industrial users. The Commission therefore considered that the 17,5 % deduction applied in the provisional calculations accurately reflected the average conditions faced by industrial users and provided a reasonable and representative basis for establishing the net-of-tax energy costs. The claim was therefore rejected.

• (64) The Commission therefore maintained its position and the conclusions in recitals (144) to (160) of the provisional Regulation were hereby confirmed.

• (65) Upon final disclosure, Vesuvius commented that the Commission relied on ILO data for weekly hours actually worked in the general manufacturing sector in Brazil (40,4 hours), which, in Vesuvius’ view, does not reflect the economic activity relevant to the product under investigation. Vesuvius argued that sector-specific ILO data for economic sector 23 (‘Manufacture of other non-metallic mineral products’), showing 41,3 weekly hours actually worked, were available and should have been used instead.

• (66) The Commission examined this claim and confirmed that the ILO dataset provides disaggregated information for economic sector 23. Since the production of the product concerned falls within this sector, the Commission accepted the comment. Accordingly, the Commission recalculated the benchmark for labour costs by replacing the previously used weekly hours actually worked (40,4 hours) with the sector-specific figure of 41,3 hours. All other methodological steps remained unchanged. This adjustment resulted in a reduction of the hourly labour cost from 58,36 CNY/hour to 57,09 CNY/hour.

3.2.3.2.   SG & A costs and profits

• (67) DFFI and PRE submitted comments that the selected Brazilian companies – Tecnosulfur, Bozel Brasil S.A., and Trevo Industrial – were not reliable proxies for the fused alumina industry, as they operated in unrelated fields with distinct production processes and markets. According to DFFI and PRE, these companies did not reflect the economic or technical characteristics of fused alumina production.

• (68) Tyrolit similarly argued that the comparability of the selected Brazilian companies with fused alumina industry was limited. While Bozel, as a ferroalloy producer operating arc furnaces, had some resemblance to fused alumina producers, Trevo and Tecnosulfur were deemed unsuitable. Trevo operated in plasterboard manufacturing [^ntr6-L_202600114EN.000101-E0006], a completely different sector, and Tecnosulfur’s business model required significantly higher SG & A spending linked to marketing, R & D, and sales support. Tyrolit urged the Commission to replace these companies with data from more appropriate Brazilian producers in the ferroalloy sector, which use arc furnaces for processing ores, making them highly energy-intensive, such as Ferbasa, RIMA, Nova Era Silicon, or Ferro Ligas, whose published financial statements would provide a closer benchmark.

• (69) Vesuvius added that two of the three companies selected – Trevo and Tecnosulfur – had no connection to fused alumina production. Trevo’s activity is confined to drywall manufacturing, which does not involve electrofusion, while Tecnosulfur supplies desulfurising products for liquid metals [^ntr7-L_202600114EN.000101-E0007]. Although Bozel operates electrofusion furnaces, Vesuvius emphasised that, overall, the Commission’s chosen companies lack sufficient comparability to fused alumina producers, making them unsuitable for establishing a reliable undistorted and reasonable amount for administrative, selling and general costs and for profits.

• (70) In light of these new observations it was found that the companies initially selected were not sufficiently connected to the fused alumina industrial sector due to their activities or that the level of SG & A costs found for Bozel 2-3 % were considered not reasonable within the meaning of Article 2(6a)(a) of the basic Regulation since they were too low in comparison with the level SG & A costs normally observed for companies operating in this sector [^ntr8-L_202600114EN.000101-E0008] during the period considered which exceeded 10 %. Hence, they were not considered representative of the fused alumina sector. Consequently, the Commission reassessed its selection to identify companies with activities more technically and economically comparable to fused alumina production, even if classified under a different but related NACE code 24.1 (Manufacture of basic iron and steel and ferroalloys). The newly identified companies are FERBASA, RIMA Industrial, Aço Verde do Brasil, MINASLIGAS and Viena Siderúrgica.

• (71) The Commission considered that these companies were more appropriate proxies for fused alumina producers, as their operations in ferroalloy sector involve production processes and costs structures closely aligned with those of fused alumina production. Specifically they share key technical and economic characteristics: (i) production in electric arc or electric furnaces; (ii) high-temperature reduction/smelting processes; (iii) energy- and capital-intensive cost structures; (iv) mineral-based raw material supply chains; (v) by-product recovery and environmental controls; and (vi) strong links to steelmaking industries, in which fused alumina also plays a crucial role as a refractory input.

• (72) The Commission therefore accepted that companies originally selected at provisional stage were not sufficiently representative. The calculations were performed again based on the financial data of companies in the ferroalloys and steel sector, who are considered to be more connected to the production of the product under investigation. This modification ensured that the SG & A costs and profit benchmarks used for the construction of normal value more accurately reflect the realities of producers operating in comparable energy-intensive industries. On this basis, the SG & A costs and profit percentages amounted to 11,41 % and 5,63 % of the cost of goods sold.

• (73) Upon final disclosure, Imerys commented that the SG & A costs and profit benchmark should be revised, arguing that it did not reflect ‘undistorted and reasonable’ levels within the meaning of Article 2(6a)(a) of the basic Regulation. In their view, two of the selected companies – Aço Verde do Brasil and Viena Siderúrgica – are not technically comparable to fused alumina producers, as they do not operate in the ferroalloy sector and use blast-furnace rather than electric-arc-furnace. Imerys further claimed that the SG & A costs and profit levels of these companies were not representative, citing Viena’s size and profitability and Aço Verde do Brasil’s lower SG & A costs ratio based on Imerys’ SG & A costs calculations. In this regard, Imerys claimed that net financial expenses should not be subtracted from the numerator when determining the SG & A costs calculation. Imerys also referred to publicly reported labour-rights investigations involving certain suppliers linked to Viena as evidence of conditions allegedly not reflecting normal market behaviour. On this basis, Imerys requested that these two companies be excluded and that the benchmark be recalculated using only producers they consider genuinely comparable.

• (74) The Commission considered that the arguments raised did not demonstrate that the SG & A costs and profit levels of the companies concerned were distorted or unrepresentative. While the type of furnace used may differ, the underlying production processes and cost structures remain comparable for the purposes of establishing a reasonable proxy under Article 2(6a)(a).

• (75) The Commission further noted that the assertions concerning differing supply-demand dynamics or cost structures were not substantiated. The size of the companies is likewise nor a relevant factor for determining representativeness. With respect to SG & A costs, the Commission confirmed that the SG & A costs ratios were calculated in line with standard practice, whereby relevant financial income and expenses were taken into account for the determination of the SG & A costs rate. Based on the Commission’s own verified calculations, the SG & A ratios of both companies fall within the range normally observed for comparable operators.

• (76) Finally, the Commission notes that the labour-related allegations raised by Imerys concern ongoing proceedings involving certain upstream suppliers rather than the companies themselves and therefore did not affect the suitability of their financial data for establishing the benchmark.

• (77) On this basis, the Commission maintained that the selected companies were appropriate and that no revision of the benchmark was warranted.

• (78) Following the additional final disclosure, Imerys reiterated the same comments it had already submitted after the final disclosure, without providing any new factual evidence or information. The additional final disclosure concerned solely the elements that had been modified in light of the comments received on the final disclosure, and interested parties were invited to comment only on those specific changes. As Imerys’ reiterations did not relate to the elements that had been amended, these comments were not taken into account.

3.3.   Export price

• (79) In the absence of any related claim or comment, the conclusions in recitals (170) to (172) of the provisional Regulation were hereby confirmed.

3.4.   Comparison

• (80) Following provisional disclosure, Tyrolit and VDS submitted comments related to the comparison.

• (81) VDS and Tyrolit argued that the Commission failed to disclose which specific qualities of fused alumina were used in the normal value calculations, stressing that meaningful comparisons can only be made on a like-for-like basis given the wide price variation between grades. They claimed that Brazilian prices of product under investigation are generally only 10–15 % higher than Chinese levels and pointed to discrepancies between Runbao and Elfusa, a known producers of the product under investigation in Brazil, prices ranging from – 18 % to +16 %. They further argued that the excessive dumping margins reported in the provisional regulation are the result of methodological errors, such as overly broad product coverage, reliance on unrepresentative data, and the use of flawed Brazilian pricing, while also noting that Elfusa itself indicated that a fair price for certain alumina qualities would be 30–35 % above Chinese prices.

• (82) The Commission recalls that all relevant parameters forming the basis of the dumping calculations were disclosed in accordance with Article 19 of the basic Regulation, allowing parties to comment on the essential facts. Claims that Brazilian prices of product under investigation are only 10–15 % higher than Chinese levels, that discrepancies between Runbao and Elfusa prices show methodological flaws, or that ‘fair’ prices should be 30–35 % above Chinese levels were not substantiated with evidence. The Commission’s findings were based on verified data from sampled exporting producers and benchmarks as described in Section 3.2.3.1 of the provisional Regulation. The Commission therefore considered that its methodology follows the relevant legal provisions of the basic anti-dumping regulation and was consistent with established practice and that the provisional dumping margins were correctly determined.

3.5.   Dumping margins

• (83) As described in recital (72), following substantiated and accepted claims from interested parties, the Commission revised the dumping margins.

• (84) Following provisional disclosure, August Riiggeberg GmbH & Co. KG, PFERD-Riiggeberg S.A. and VDS submitted comments on dumping margins.

• (85) August Riiggeberg GmbH & Co. KG and PFERD-Riiggeberg S.A. submitted that the residual dumping margin of 136,36 % was disproportionate and did not reflect actual market conditions. They argued that the residual duty was derived from a small subset of sales by the producer with the highest margin, making it unrepresentative. The parties further stated that they were unable to verify the calculation due to insufficient transparency, but considered it likely to be erroneous, possibly as a result of incompatible product comparisons. In their view, the actual price differences between Chinese and Brazilian artificial corundum are significantly smaller than those indicated by the Commission, even during recent market fluctuations linked to the Ukraine war and the energy crisis.

• (86) The residual dumping margin was established on the basis of verified findings from a subset of sales by Saite, the sampled exporter with the highest dumping margin. This subset, accounting for 7 % of its exports of the product concerned to the Union (and [4,8] % of the exports of the product concerned by the sampled exporting producers) during the investigation period, was deemed an appropriate and representative basis for determining the residual duty applicable to non-cooperating exporters, in line with Article 18 of the basic Regulation. The Commission disclosed the essential facts and considerations forming the basis of the calculation, while ensuring an appropriate balance between transparency and the protection of confidential information. Unsubstantiated allegations of possible error or disproportionality could not have been accepted. The product comparisons and the determination of normal value were carried out on the basis of the relevant legal provisions and consistent Commission’s practice. Therefore, these claims were rejected.

• (87) The definitive dumping margins expressed as a percentage of the cost, insurance and freight (CIF) Union frontier price, duty unpaid, are as follows:

Company	Definitive dumping margin (%)
Chongqing Saite Corundum Co., Ltd.	99,8
Luoyang Runbao Abrasives Co., Ltd.	88,7
Other cooperating companies	94,5
All other imports originating in the PRC	110,6

4. INJURY

4.1.   General remarks

• (88) Certain interested parties claimed that the provisional analysis of injury and causation was flawed because it did not analyse certain parts of the market separately. They argued that a segmented injury analysis for different product types was warranted because of differences in the physical, chemical and technical characteristics of the product types. More specifically, ArcelorMittal, Saite and the exporting producers represented by the CCCMC claimed that separate analyses were required for refractory-grade fused alumina. The exporting producers represented by the CCCMC also argued for a segmented injury analysis for sol-gel. Reckel and Tyrolit claimed that the injury calculations for Runbao are based on a mismatch in the product mixes because Runbao predominantly produced brown fused alumina, whereas Union industry’s production primarily focuses on white fused alumina. Similarly, Tyrolit claimed that the injury calculations for Saite are even less representative because Saite produces only brown fused alumina.

• (89) The investigation established that the sampled Union companies do produce brown fused alumina. The sampled Chinese exporting producers were found to compete directly with the products manufactured by the Union industry, including brown fused alumina. Therefore, the injury analysis is representative and reflects actual market competition.

• (90) Furthermore, for the reasons mentioned in recitals (42) to (48) of the provisional Regulation and reiterated in recitals (28) to (39), the Commission confirmed that the product under investigation should be treated as one single product. The Commission noted that the absence of full interchangeability of the product types and the fact that products belong to different grades is not sufficient to necessitate an assessment by segment. The submissions received after provisional disclosure do not change these findings. Additionally, all product types are distributed through the same channels and sold to the same customer groups. These facts demonstrate that the products are part of the same competitive market. The Commission confirmed that the various types of fused alumina share core functional characteristics to a sufficient degree and that the price differences among different product types is already considered under the PCN method used to analyse price undercutting.

4.2.   Definition of the Union industry and Union production

• (91) In the absence of any comments with respect to the definition of the Union industry and Union production, the conclusions set out in recitals (186) to (187) of the provisional Regulation were confirmed

4.3.   Union consumption

• (92) In the absence of any comments with respect to the Union consumption, the conclusions set out in recitals (188) to (190) of the provisional Regulation were confirmed.

4.4.   Imports from the country concerned

4.4.1.   Prices of the imports from the country concerned and price undercutting

• (93) Saite and Runbao argued that the adjustment in the PCN regarding brown fused alumina, as explained in recitals (11) and (199) of the provisional Regulation, was inaccurate in view of the technical distinction between the two grades. Consequently, Saite and Runbao claimed that, in the absence of Union production of second grade brown fused alumina, second grade brown fused alumina produced by the exporting producers should be either removed from the price comparison or adjusted appropriately.

• (94) Furthermore, the exporting producers represented by the CCCMC argued that the analysis of price undercutting is undermined by the fact that it lacks analytical context and relies on an average price comparison that does not account for distinctions between the different product types. The exporting producers represented by the CCCMC claimed that the wide range of import prices of fused alumina, observed not only in imports from China but also from third countries, reflects divergences in the nature of the products manufactured, leading to a flawed comparison.

• (95) Additionally, the exporting producers represented by the CCCMC argued that no substantiated assessment of price suppression was conducted.

• (96) Concerning the claim on the PCN adjustment, the Commission noted, as explained in recital (11) of the provisional Regulation, that the investigation established that the distinction between first and second grade brown fused alumina in the PCN was artificial, does not reflect industry-recognised standards and is subject to interpretation. Thus, an adjustment in the PCN was necessary regarding brown fused alumina. The Commission considered that when comparing products, the critical elements are the contents of Al2O3 and Fe2O3, which are reflected in values A1/A2 and F1/F2 within the PCN. The claim was therefore rejected.

• (97) Concerning the undercutting analysis claim the Commission noted that the PCN methodology used in the investigation already accounts for price differences among product types. This ensures that comparisons are made between products with similar physical and chemical characteristics, thereby preserving the integrity of the price undercutting analysis. The claim was therefore rejected.

• (98) Regarding the claim that no substantiated assessment of price suppression was conducted, the Commission noted that, as detailed in Section 4.3.2, and Section 5.1 of the provisional Regulation, the Commission conducted a thorough analysis of price trends, cost developments, and profitability of the Union industry. The investigation revealed that despite rising costs, the Union industry was unable to increase its sales prices, accordingly, leading to price suppression and a deterioration in profitability. As the Commission noted in recitals (196) and (278) of the provisional Regulation, the Union industry’s average non-injurious price during the IP was EUR 1 880 per tonne in contrast to an average import price of EUR 878 per tonne from China. This confirms the existence of material injury caused by dumped imports. The claim was therefore, rejected.

4.5.   Economic situation of the Union industry

4.5.1.   Macroeconomic indicators

4.5.1.1.   Production, production capacity and capacity utilisation

• (99) The exporting producers represented by the CCCMC argued that the decrease in the Union industry’s production by 37 % is not causally related to the increase of Chinese imports. Regarding capacity utilisation, the exporting producers represented by the CCCMC claimed that capacities were underutilised even prior to the increase in imports from China and before the start of the period considered, as evidenced by the fact the Union industry’s capacity utilisation was already at 69 % at the beginning of the period considered. The exporting producers represented by the CCCMC also argued that the decline of the Union industry’s exports was not a result of the pressure exerted by Chinese exporting producers.

• (100) The Commission considered the arguments to relate to causation rather than the macroeconomic indicators as such and addresses the arguments in Section 5 below. However, the Commission noted that, irrespective of the Union industry’s capacity utilisation at the start of the period considered, utilisation rates sharply decreased from 69 % in 2021 to 43 % during the IP, as found in recital (206) to (208) of the provisional Regulation, which demonstrates that the industry’s production capacity utilisation was significantly affected during the investigation period.

• (101) In the absence of any further comments with respect to the production, production capacity and capacity utilisation, the conclusions set out in recitals (206) to (208) of the provisional Regulation were confirmed.

4.5.1.2.   Sales volume and market share

• (102) The exporting producers represented by the CCCMC argued that that the increase in Chinese imports and Chinese prices in 2022 did not exert downward pressure on Union industry prices or market share, as the Union industry was able to raise prices while losing only limited sales. The exporting producers represented by the CCCMC further noted that Chinese imports captured only a small portion of the market previously held by third countries, and that the Union industry’s subsequent market share loss in 2023 occurred despite a decline in the volume Chinese imports, reflecting an overall decline of the Union market rather than the impact of Chinese imports.

• (103) The Commission noted that the entire period considered was examined for trends in import volumes, market share, and the injury indicators, and price suppression. Furthermore, the Commission noted that the argument does not take into account the variation in the size of the Union market between 2022 and 2023. As explained in recital (189) to (190) of the provisional Regulation, the Union consumption decreased from 367 672 tonnes in 2022 to 294 891 tonnes in 2023. Any assessment of market share developments and their relationship to import volumes should be made taking into account the overall contraction of the market. The Commission found that, despite a decrease in import volumes from China between 2022 and 2023, China’s market share increased from 48 % to 51 %, while the Union industry’s share declined from 38 % to 35 %. The Commission also noted that in 2022 the Union industry increased its prices in line with the price rises from China, but nevertheless experienced an 11 % reduction in sales and an 8 % decline in market share. The Commission therefore rejected the claim in its entirety.

• (104) In the absence of any further comments with respect to the sales volume and market share, the conclusions set out in recitals (209) to (210) of the provisional Regulation were confirmed.

4.5.1.3.   Growth

• (105) In the absence of any comments with respect to the growth, the conclusions set out in recital (211) of the provisional Regulation were confirmed.

4.5.1.4.   Employment and productivity

• (106) The exporting producers represented by the CCCMC argued that the impact on employment was negligible and that notable changes only took place in the IP and not during the period considered.

• (107) As set out in recitals (212) to (214) of the provisional Regulation, the number of employees producing the product concerned decreased by 8 % from 2021 to 2023 and 16 % over the period considered. The fact that the decrease peaks during the IP did not change the conclusions on the trend seen during the period considered. Absent any further comments with respect to employment and productivity, the conclusions set out in recitals (212) to (214) of the provisional Regulation were confirmed.

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

• (108) In the absence of any comments with respect to the magnitude of the dumping margin and recovery from past dumping, the conclusions set out in recitals (215) to (216) of the provisional Regulation were confirmed.

4.5.2.   Microeconomic indicators

4.5.2.1.   Prices and factors affecting prices

• (109) The exporting producers represented by the CCCMC argued that that the increase in Chinese imports and Chinese prices in 2022 did not exert downward pressure on Union industry prices or market share, as the Union industry was able to raise prices while losing only limited sales.

• (110) The Commission considered the argument in recital (103).

• (111) In the absence of any further comments with respect to the prices and factors affecting prices, the conclusions set out in recitals (217) to (219) of the provisional Regulation were confirmed.

4.5.2.2.   Labour costs

• (112) In the absence of any comments with respect to the labour costs, the conclusions set out in recitals (220) to (221) of the provisional Regulation were confirmed.

4.5.2.3.   Inventories

• (113) In the absence of any comments with respect to the inventories, the conclusions set out in recitals (222) to (225) of the provisional Regulation were confirmed.

4.5.2.4.   Profitability, cash flow, investments, return on investments and ability to raise capital

• (114) The exporting producers represented by the CCCMC argued that the Commission’s assessment of declining profitability was flawed because profitability and investments increased in 2022 despite a 25 % increase in Chinese imports. The exporting producers represented by the CCCMC claimed that subsequent decrease in profitability resulted from substantial increases in investments and rising production costs, including energy, raw materials and production processes, which continued to escalate even as electricity prices declined in 2023, thereby demonstrating that the alleged injury was not caused by Chinese imports.

• (115) The Commission considered the arguments to relate to causation rather than the microeconomic indicators as such and addresses the arguments in Section 5 below.

• (116) In the absence of any further comments with respect to the profitability, cash flow, investments, return on investments and ability to raise capital, the conclusions set out in recitals (226) to (231) of the provisional Regulation were confirmed.

4.6.   Conclusion on injury

• (117) In the absence of any other comments with respect to the injury, the Commission confirmed the conclusions set out in recitals (232) to (237) of the provisional Regulation.

5. CAUSATION

5.1.   Effects of the dumped imports

• (118) In recital (270) of the provisional Regulation, the Commission concluded that the material injury suffered by the Union industry was caused by the dumped imports of the product concerned originating in the country concerned.

• (119) The exporting producers represented by the CCCMC argued that the decrease in the Union industry’s production by 37 % is not causally related to the increase of Chinese imports. The exporting producers represented by the CCCMC claimed that the Union industry’s production volume dropped from 187 988 tonnes in 2022 to 139 354 tonnes in 2023 during a time where imports from China fell from 175 343 tonnes in 2022 to 151 650 tonnes in 2023.

• (120) The Commission noted that the argument does not take into account the variation in the size of the Union market between 2022 and 2023. As explained in recital (189) to (190) of the provisional Regulation, the Union consumption decreased from 367 672 tonnes in 2022 to 294 891 tonnes in 2023. When considering this reduction in market size, the Commission observed that, despite a decrease in import volumes from China between 2022 and 2023, China’s market share nevertheless increased from 48 % to 51 %, while the Union industry’s share declined from 38 % to 35 %. The Commission therefore rejected the claim in its entirety.

• (121) Additionally, Abranova argued that the fluctuations in Chinese import volumes during the period considered were not causally linked to dumped imports, but rather were the result of extraordinary external factors. In particular, Abranova claimed that imports declined during the COVID-19 pandemic when container shipping costs increased four to five times above normal levels. Conversely, imports rose markedly after the war in Ukraine due to the EU ban on Russian imports of fused alumina, lower freight rates, and insufficient production capacity of the Union industry. Therefore, Abranova claimed that the variations in import volumes between 2020 and 2024 were driven by unprecedented external developments, and that a proper comparison with pre-COVID levels would demonstrate that the observed import trends cannot be attributed to the effects of dumped imports.

• (122) The Commission acknowledged that external factors such as the COVID-19 pandemic and the war in Ukraine influenced overall trade flows. However, these developments do not call into question the existence of a causal link between the dumped imports from China and the material injury suffered by the Union industry. The investigation established that, irrespective of broader market disruptions, imports from China entered the Union in significant volumes, gained market share, and were consistently priced below the Union industry’s sales prices and cost of production. The Commission confirmed that these elements clearly demonstrated that the dumped imports were causally linked to the injury sustained by the Union industry, as the Union industry was unable to increase its sales prices in line with the increase in the cost of production, resulting in price suppression and a deterioration in profitability.

• (123) In the absence of any comments with respect to the effects of the dumped imports, the conclusions set out in recitals (239) to (242) of the provisional Regulation were confirmed.

5.2.   Effects of other factors

5.2.1.   Imports from third countries

• (124) The exporting producers represented by the CCCMC argued that imports from third countries attenuates the causal link between the dumped imports and the injury suffered by the Union industry. The CCCMC claimed that imports from third countries maintained a significant market share of around 15 % during the period considered and were consistently priced well below the Union industry’s sales prices.

• (125) The Commission noted that compared to China, other third countries had a limited presence on the Union market during the period considered. As explained in recital (244) of the provisional Regulation, the combined market share of imports from all third countries other than China decreased from 22 % in 2021 to 15 % in the investigation period. The main exporting third countries, namely Ukraine, the United States, Brazil and Bahrain, each accounted for between 2 % and 5 % of the Union market, and their respective market shares remained broadly stable over the period considered.

• (126) The Commission further observed that, although Ukraine and Bahrain sold at lower prices than China during the IP, their limited market shares meant that their overall effect on the Union market was minimal. Other third-country imports were generally priced above those from China. The Commission concluded that the impact of the imports from third countries does not attenuate the causal link between dumped Chinese imports and the material injury suffered by Union producers and confirmed the conclusions set out in recitals (243) to (246) of the provisional Regulation.

5.2.2.   Export performance of the Union industry

• (127) The exporting producers represented by the CCCMC, PRE, DFFI and Reckel submitted that the deterioration in the Union industry’s export performance attenuates the causal link between the dumped imports and the injury suffered by the Union industry. It was further claimed that the decrease in export performance could not have been caused by Chinese exports to third markets and the Union industry’s inability to at least maintain its volume of exports is not causally linked to the price pressure from Chinese exports.

• (128) The Commission confirmed that it did not attribute the deterioration in the Union industry's export performance to Chinese exports to third markets. The Commission noted that exports represented only around 14 % of the Union industry’s total sales through the period considered. Therefore, the Commission considered that exports to third countries could only have had a marginal effect on the injurious situation of the Union industry during the investigation period, and therefore could not break the causal link between the Chinese dumped imports and the material injury suffered by the Union industry.

• (129) The Commission concluded that the impact of the Union industry’s export performance does not attenuate the causal link between dumped Chinese imports and the material injury suffered by Union producers and confirmed the conclusions set out in recitals (247) to (250) of the provisional Regulation

5.2.3.   Union consumption

• (130) The exporting producers represented by the CCCMC, PRE, DFFI and Reckel submitted that the contraction in demand and the decrease in consumption in the Union breaks or considerably attenuates the causal link between the dumped imports and the injury suffered by the Union industry. PRE and DFFI argued that the substantial decrease in demand for fused alumina in the Union market was primarily attributable to adverse macroeconomic conditions since 2021. In particular, PRE and DFFI referred to the combined effects of a short-lived post-pandemic recovery, high energy costs, low growth, inflation, and geopolitical tensions, which significantly reduced demand in downstream sectors such as steel, construction and automotive.

• (131) The Commission noted, as per recital (252) of the provisional Regulation, that the Union consumption decreased by 20 % during the period considered and Union sales declined by 37 %, leading to a loss of 9 % of market share. Similarly, imports from all other third countries also declined significantly. In contrast, Chinese imports increased their market share by 16 % over the same period.

• (132) The Commission recalled that the existence of other factors affecting the Union industry does not break the causal link where dumped imports, taken in isolation, are found to have caused material injury. In the present case, although the contraction in consumption may have had some impact, it could only have played a limited role and cannot explain the magnitude of the deterioration observed.

• (133) The Commission concluded that the decrease in consumption in the Union does not attenuate the causal link between dumped Chinese imports and the material injury suffered by Union producers and confirmed the conclusions set out in recitals (252) to (253) of the provisional Regulation.

5.2.4.   Increased cost of production