Commission Implementing Regulation (EU) 2026/270 of 4 February 2026 imposing provisional anti-dumping duties on imports of 1,4-Butanediol originating in the People’s Republic of China, the Kingdom of Saudi Arabia and the United States of America

• (410) BDO is an intermediate chemical product with several downstream chemical products including PBT, PBAT, TPU, THF and GBL, which are then ultimately used in a wide range of applications, including in automotive, defence, textiles, plastics, electronics, construction, batteries and cosmetics (‘the BDO value chain’) in the Union market. Around 47 % of BDO was used captively by the Union industry, and 53 % sold onto the free market in the IP. Therefore, the Union industry is also a very large user of BDO themselves. Whether BDO is used captively or sold on the market the main downstream products are often themselves intermediate chemical products which can either be sold on the Union market or used captively.

• (411) The Union producers supported the initiation of the investigation and their comments since initiation showed that, in general terms, they support the imposition of anti-dumping measures. However, LCN do not support measures against the USA, where they have group production, while Novamont Italy expressed concerns as regard the impact of the duties on their downstream products as they are a big importer from China. Overall, Union producers have advocated for the imposition of duties to the main downstream products, in addition to the duties on BDO, as they fear they will lose competitiveness against Chinese competitors in the BDO value chain once duties are imposed on BDO. In addition, as discussed in section 2.4 ‘Claims regarding product scope’ of this Regulation, BASF submitted that bio BDO should be excluded from the definition of the product under investigation.

• (412) Given the finding of material injury to the Union industry described in section 4.2 ‘Conclusion on injury’ of this regulation, imposing measures would allow the Union industry to improve its profitability towards sustainable levels, increase investment, and thus regain a competitive position in their core market. The Union industry would also be able to regain lost market share by increasing production and sales volumes in the Union market.

• (413) The absence of measures is likely to have further negative and significant effects on the Union industry. The grave situation, described above in the ‘conclusion on injury’ section, threatens the existence of the whole Union industry, as the substantial and increasing losses made in the period considered and deepening in the IP are not sustainable in the short term and threaten the ability to continue producing BDO in the Union for both captive and free market use. Although, raw material and energy prices have fallen in 2024, the Union industry faced further BDO sales prices declines, and increasing dumped imports with continuously lower prices, resulting in an inability to raise prices and cover the lower production costs. Such price depression will continue in the absence of measures, including due to increasing and already substantial spare capacities in the countries concerned, leading to further volume and financial deterioration for the Union industry and jeopardizing its short-term future and employment. The Union industry has established an integrated chain for BDO, including for example PBAT and bio-compounding, which is maintained from investments over the years across various parts of the value chain. BDO producing capacity, and its supply chain, is enough to meet BDO demand in the Union. The Union industry has already been forced to replace part of its own production with cheap imports from the countries concerned. This was done to maintain their standing and reputation on the Union market by enabling them to continue to supply BDO to the captive BDO value chain, Union users and to supply other key producers using in the Union. However, the sourcing of cheap imports from the countries concerned is not a sustainable development for the Union industry which has a large BDO capacity and a long history of producing BDO to the Union market, whilst investing to maintain the efficiency of its production facilities, vertical integrated production of chemicals and complying with safety and environmental standards. Simply put – the situation observed in the IP is untenable as the Union industry cannot be expected to continue defending itself by replacing own production with dumped imports or selling in the Union to keep key BDO customers relationships alive, while making significant losses. Without measures the Union industry would be forced to close down its BDO production facilities and rely solely on imports.

• (414) The imposition of duties would allow the Union industry to source BDO for captive use from its own production or within the Union increased production, resulting in the protection of existing and recent investment of vertically integrated production infrastructure, expertise and jobs and the wide producing BDO related ecosystem within the Union, including the production of PBT, PBAT, TPU, THF and GBL for which BDO Union producers are also the main producers in the Union, and in some chemical products the only supplier in the Union. Measures would allow the sourcing of BDO for captive use within the Union industry, given the limited ability in the Union to store BDO or to have significant quantities of BDO as stocks which need also to be procured months in advance and usually under sales contracts rather than spot purchases. Measures therefore would result in a more stable, resilient and secure Union supply from Union producers, mitigating the supply or logistics risks such as observed in recital 293, that already affected the BDO Union supply in 2024 and which would have risked the ability to maintain or even produce by the Union industry captive products under the BDO value chain, if there was a lower or no Union production of the like product.

• (415) Furthermore, Novamont, BASF, INEOS and as well several BDO users, submitted comments for the need to protect and look to impose duties for additional products under the BDO value chain and not only the product concerned, in order to protect the existing substantial investments of vertical production facilities and the Union captive use and overall chemical ecosystem within the Union. The protection of the Union Industry would allow to continue the efficient operation of the integrated chemical production facilities, allowing to continue the sharing of fixed cost such as waste, electricity, transport, water or steam with the production and facilities for other chemicals, including the BDO downstream use, which is key for maintaining the overall efficiency of chemical production costs in the Union Industry.

• (416) In addition, measures would allow captive users to continue to source BDO in the Union. The Union producers claimed that Union production, of BDO generates less CO2 and this would not incur additional shipping, rail and transportation CO2 generation.

• (417) The imposition of measures on BDO from the countries concerned is therefore clearly in the interest of the Union industry.

7.2.   Interest of unrelated importers and traders

• (418) Most imports of BDO in the period considered were made directly to industrial users or to related companies in the Union such as BASF, LCN and BorsodChem. Some purchases of BDO by industrial users were made by unrelated importers or traders. However, no cooperation was received from unrelated importers/traders.

• (419) Several users that are also importers of BDO, including importing from the countries considered, submitted comments. However, as their main economic activity was rather to use BDO for production their comments are addressed below under ‘interest of users’.

• (420) Will & Co, a distributor of raw materials including BDO from Sipchem, submitted comments but did not provide minimum information, including requested to importers, to be able to establish the impact that the imposition of measures would have on its activities. Will & Co argued that there was an oversupply of BDO from China, and that Chinese and Taiwanese producers were offering aggressive prices, including below cost of production, during the period considered. In addition, it was submitted that 2021-2022 represented a period for which lower imports from these countries featured in the Union and for which market prices were at a sustainable level in the Union for BDO. However, from 2023 onwards increased competition from Chinese producers and at very aggressive prices meant that BDO Union prices collapsed to unsustainable levels, mainly as a result of the building of new production facilities and increasing additional capacity in the PRC, which is already larger than the total world BDO demand, and especially in the last two years for which China alone has added production capacity that is on the multiples to the overall global BDO demand. Will & Co also submitted that it is very important for Sipchem to continue supplying the Union for the stability of the market and that Saudia Arabia imports should not be cumulated. The latter point was already addressed under the section 4.3 ‘Imports from the countries concerned’.

• (421) In addition, Helm AG provided comments regarding the exclusion of bio BDO, which were addressed under section 2.4 ‘Claims regarding product scope’.

• (422) The Commission did not have information to precisely establish the impact that the imposition of measures would have on the activities of the unrelated importers/traders. The absence of cooperation suggests that importers do not consider that the imposition of anti-dumping measures would significantly affect their business. Importers were likely to be general importers of chemical products rather than focussing solely on BDO. In addition, whilst a reduction in imports and resale of goods affected by measures may be observed in a first step, any such negative effect on turnover could eventually compensated by increased resale of products purchased from other sources such as South Korea or Taiwan.

• (423) Therefore, the Commission concluded that the impact of measures would not be disproportionate for importers/traders.

7.3.   Interest of users

• (424) Whether BDO is used captively or sold on the market, the main Union users of BDO are immediate downstream products such as polybutylene terephthalate (PBT), polybutylene adipate terephthalate (PBAT), polyurethane (PU), saturated polyester (SAT), tetrahydrofuran (THF), n-methyl pyrrolidone (NMP), thermoplastic copolyester (TPC) and gamma-butyrolactone (GBL). These are in turn intermediate products which can either be sold on the Union market or used captively. The ultimate user industries of BDO are many and varied and include agriculture, automotive, chemical, cosmetics, pharmaceutical, plastics and textiles.

• (425) Nine Union industrial users in addition to three sampled integrated Union producers, which used BDO captively, co-operated with the investigation fully by submitting questionnaire replies and making their views on Union interest known. These industrial users represented about 25 % of the total BDO consumption in the Union in the IP whereas BDO users which are also BDO producers represent 100 % of the quantity of BDO used captively in the Union in the IP. Overall, cooperating industrial users together with Union producers using captively BDO represented about 65 % of total Union consumption of BDO in the IP. These users sourced BDO from own production, Union producers and/or imports. Most imports by users were from the countries concerned.

• (426) These twelve users are as follows:

• (a) Integrated BDO producers/captive users:

• — BASF SE

• — INEOS Solvents Marl GmbH

• — Novamont

• (b) Industrial Users:

• — BorsodChem z.r/t, Hungary (a user related to a Chinese exporting producer)

• — Chimica Organica Industriale Milanese spa – (COIM), Italy

• — Dow Europe GmbH, Switzerland (sourcing from Union BDO producers, and with production facilities in the Union)

• — Elachem SpA, Italy

• — Envalior BV, The Netherlands

• — Envalior GmbH, Germany

• — Performance Solutions Luxembourg Sarl (‘Celanese’), Luxemburg

• — Dubay Polymer GmbH, Germany (a joint venture between Celanese and Envalior)

• — Tosoh Europe BV, The Netherlands.

• (427) Several users made comments on Union interest as part of their submissions. Elachem SpA, and Envalior BV & Envalior GmbH, were against the imposition of measures mainly because the measures against BDO would not include other chemical product derived from BDO and especially in the next downstream use of BDO, which would impact the raw material cost of these downstream products and reduce in turn their competitiveness against imports. This is because of a potential increase of cost of BDO in the Union following the imposition of measures. Performance Solutions Luxembourg Sarl, recognized the importance of a resilient and competitive BDO Union industry, but urged the Commission to consider the full value chain of BDO in the Union, as duties would dramatically increase manufacturing cost in the EU downstream industry whilst simultaneously increasing the competition from imports. This is because producers from the country concerned would move one step down the BDO value production chain and instead dump these imports into the Union, if these are not subject to measures. In addition, they argued that costs cannot be passed to customers due to the global and competitive nature of these BDO downstream markets, thereby threatening the financial viability of the Union producers, and that there is not enough capacity within the Union to satisfy the demand of BDO. In addition, they claimed that Union producers’ sales at an unsustainably high price level and that there is inadequate supply of BDO from countries other than the countries considered. COIM and BorsodChem were against all measures. These claims and the views of users are examined as part of the interest of users’ analysis below.

Analysis of the Industrial Users

• (428) Based on the data provided by the nine cooperating Union industrial users, during the IP they purchased around two thirds of their BDO from the Union industry and around one third from imports, mainly from the countries concerned.

• (429) The importance of BDO to industrial users varied widely and depending on the type of product and its application in the IP. For example, certain downstream products used less BDO than others: more BDO was used for immediate downstream products such as those usually categorised as ‘performance’ chemicals whereas less BDO was used in the ‘specialised’ chemical segments. In general the importance of BDO derived products as compared to the total turnover widely varied depending of the user. Thus for a small number of non-diversified industry users a BDO derived product was the only product or was more than 70 % of total sales. However, for the typical industrial users, which usually had a portfolio of performance and specialised products, the use of BDO derived products ranged from about 0,1 % to 25 % of the total sales of the company. On average, sales of products incorporating BDO represented 57 % of total turnover of the cooperating Union industrial users.

• (430) BDO was in some cases used to produce downstream products, that were then partly exported to third countries by the users in the IP. Such sales would not be affected by BDO duties provided that conditions for inward processing arrangements are met.

• (431) The cost of BDO as a raw material as compared to the total costs of the downstream products also varied in the IP. It was estimated from data submitted by the industrial users and captive producer/users that BDO accounted for an important percentage of the manufacturing cost of THF, PBT, PBAT and NMP (the latter being a derivative of GBL). However, the total cost of BDO could then reduce significantly depending on the degree of specialisation of the product, for example if derivatives required higher R & D input, or if BDO was combined with other raw materials for its production. These products were usually found under the ‘specialty’ and ‘performance’ segments. On average the cost of BDO as a raw material was 14 % of the total cost of the product for the cooperating users, but for the certain derivatives could be much higher.

• (432) The profitability margins of the industrial users (for products incorporating BDO) when provided, ranged between about 40 % to – 11 %, with an average profitability of 10 % in the IP. The profitability of some downstream products was negative, but for the majority was profitable. The most profitable products were usually found under the ‘specialty’ segment, for which price sensitivity was less important and margins could be high, as sales were not commodities and were subject to less competition even if quantities sold were usually more limited. However, the profitability data provided by cooperating industrial users, did not always relate to products containing BDO and the profitability of two users was not substantiated during the verification visit. Therefore, at the provisional stage of the investigation, the co-operating users have not substantiated their profitability of products containing BDO. The issue of profitability of users will therefore be examined further at the definitive stage of the investigation.

• (433) As regard the effect of the measures on the cooperating users, the Commission considered that their profits would be affected by the imposition of measures on BDO unless the increases in BDO purchase costs could be passed on to customers. This was due to the importance of BDO in the cost of production of the derivatives, especially for some immediate derivatives which are themselves commodities. However, certain factors would likely mitigate the impact of the measures for downstream products. Firstly, as explained above, the industrial users also produced products which did not contain BDO, as BDO downstream products formed only about of 57 % of their total sales as an average, but with a majority of users being diversified for which use of BDO derived products ranged from about 0,1 % to 25 % of the total sales of the company. Secondly, industrial users sourced more than half of their BDO from the Union, and less than half from the countries concerned and from third countries, such as South Korea or Taiwan. Although, BDO prices on the Union market would be likely to increase because of the measures, it would be possible for them to switch their sources of supply to minimise the impact of the measures such as South Korea or Taiwan. In addition, Union prices are not expected to increase severely given than the substantial additional production volume increase from the measures would allow to run the facilities more efficiently and reduce unit costs of production of BDO. Furthermore, BDO sales in the Union are typically done over long-term contracts which are also making reference to ICIS prices, including ICIS China in some cases. Therefore, Union BDO sales contract prices track global BDO prices, and a severe deviation in price would allow imports, not from the countries considered, to become more competitive in the Union and increase their sales to users. Thirdly, BDO as a raw material only accounted to about 14 % of the total cost of production for the downstream products, it then varied by product type and tended to be of far less importance for certain products under the ‘specialisation’ segment and even under the ‘performance’ segment for which BDO costs accounted for a much lower percentage of the total cost of production. Fourthly, some industrial users were profitable in production of BDO downstream products in the investigation period and would be able to either absorb the cost increases or pass them on to their customers, especially for products that were not price sensitive (or commoditised), commanded high margins and for which BDO as a percentage of total cost was limited which was usually found under the ‘specialised’ segment. Fifthly, the total capacity of the Union industry to produce BDO is about 470 200 and current total use was about 347 000 tonnes in the IP, allowing the Union industry to comfortably supply the whole Union demand and for users to source BDO within the union and not be subject to measures. Finally, some users exported sometimes most of the products containing BDO to third countries, meaning that they would be able to avoid the effect of anti-dumping duties due to inward processing arrangements with Union Customs authorities. Due to these mitigations, it was expected that the effect of the measures on users would not be disproportionate.

• (434) Given the major losses of the Union BDO industry and price depression on the market, it can reasonably be assumed that BDO prices will increase after measures are imposed. Nevertheless, the impact measures may have on certain users should be balanced against the risk of a discontinuation of Union industry activity as the current situation is not sustainable. Not imposing measures will lead to a discontinuation of production in the Union, and a far less reliable, resilient and stable sources of BDO supply, then inevitably to BDO price increases with more uncertainty in the sourcing of downstream production of BDO on the Union market which will be then only reliant on shipping to enter the Union combined with a very limited ability to safely and economically store BDO in the Union. Discontinuation of the Union industry would then in turn hamper the viability of production of BDO downstream products in the Union, as they need to source BDO on time, economically, with a continued resilient supply and with a diversified supply based (including Union sourced), to be able to produce at continuous levels and meet minimum efficiency production volume for the downstream products and allowing in turn to meet customers’ needs on time.

• (435) In addition, the Commission found that the production capacity of the Union industry was sufficient to meet the entire consumption in the EU market. During the IP, the Union industry had around 40 % of spare capacity and, if conditions of fair competition are restored, Union producers could increase production, and reduce the cost of production by spreading fixed costs over larger quantities, in order to meet the demand in the Union. In addition, as mentioned above industrial users could switch sources of supply to South Korea and Taiwan.

• (436) Therefore, the Commission concluded that imposing anti-dumping measures would not lead to a shortage of supply of BDO on the Union market.

• (437) Finally, as regards of the total users of the product concerned, which is the industrial users plus the captive use of BDO by the Union industry, 62 % of the total use of BDO in the Union that cooperated with this investigation were in favour of the imposition of duties, Union industry users were in favour of the measures as per further explained under the section of Interest of the Union industry.

7.4.   Conclusion on Union interest

• (438) On the basis of the above, the Commission concluded that there were no compelling reasons that it was not in the Union interest to impose measures on imports of product concerned originating in countries concerned at this stage of the investigation.

8. PROVISIONAL ANTI-DUMPING MEASURES

• (439) On the basis of the conclusions reached by the Commission on dumping, injury, causation, level of measures and Union interest, provisional measures should be imposed to prevent further injury being caused to the Union industry by the dumped imports.

• (440) Provisional anti-dumping measures should be imposed on imports of product originating in countries concerned, in accordance with the lesser duty rule in Article 7(2) of the basic Regulation. The Commission compared the injury margins and the dumping margins as shown in recital 407. The amount of the duties was set at the level of the lower of the dumping and the injury margins.

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

Country	Company	Provisional anti-dumping duty (%)
China	Xinjiang Markor Chemical Industry Co., Ltd.	105,6
China	Wanhua Chemical (Sichuan) Co., Ltd	113,7
China	Other cooperating companies in China	107,5
China	All other imports originating in China	113,7
Saudi Arabia	International Diol Company	52,4
Saudi Arabia	All other imports originating in Saudi Arabia	52,4
USA	Lyondell Chemical Company	135,7
USA	All other imports originating in the USA	142,5

• (442) The individual company anti-dumping duty rates specified in this Regulation were established on the basis of the findings of this investigation. Therefore, they reflect the situation found during this investigation with respect to these companies. These duty rates are exclusively applicable to imports of the product concerned originating in the countries concerned and produced by the named legal entities. Imports of the product concerned produced by any other company not specifically mentioned in the operative part of this Regulation, including entities related to that those specifically mentioned, should be subject to the duty rate applicable to ‘all other imports originating in country concerned’. They should not be subject to any of the individual anti-dumping duty rates.

• (443) To minimise the risks of circumvention due to the difference in duty rates, special measures are needed to ensure the application of the individual anti-dumping duties. The application of individual anti-dumping duties is only applicable upon presentation of a valid commercial invoice to the customs authorities of the Member States. The invoice must conform to the requirements set out in Article 1(3) of this regulation. Until such invoice is presented, imports should be subject to the anti-dumping duty applicable to ‘all other imports originating in country concerned’.

• (444) While presentation of this invoice is necessary for the customs authorities of the Member States to apply the individual rates of anti-dumping duty to imports, it is not the only element to be taken into account by the customs authorities. Indeed, even if presented with an invoice meeting all the requirements set out in Article 1(3) of this regulation, the customs authorities of Member States must carry out their usual checks and may, like in all other cases, require additional documents (shipping documents, etc) for the purpose of verifying the accuracy of the particulars contained in the declaration and ensure that the subsequent application of the lower rate of duty is justified, in compliance with customs law.

• (445) Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume after the imposition of the measures concerned, a percentage may be introduced, depending on the case, although not advisable such an increase in volume could be considered as constituting in itself a change in the pattern of trade due to the imposition of measures within the meaning of Article 13(1) of the basic Regulation. In such circumstances and provided the conditions are met an anti-circumvention investigation may be initiated. This investigation may, inter alia, examine the need for the removal of individual duty rate(s) and the consequent imposition of a country-wide duty.

9. REGISTRATION

• (446) As mentioned in recital 3, the Commission made imports of the product concerned subject to registration. Registration took place with a view to possibly collecting duties retroactively under Article 10(4) of the basic Regulation.

• (447) No decision on a possible retroactive application of anti-dumping measures can be taken at this stage of the proceeding.

10. INFORMATION AT PROVISIONAL STAGE

• (448) In accordance with Article 19a of the basic Regulation, the Commission informed interested parties about the planned imposition of provisional duties. This information was also made available to the general public via DG TRADE's website. Interested parties were given three working days to provide comments on the accuracy of the calculations specifically disclosed to them.

• (449) Lyondell Chemical Company provided comments on the calculations. In view of these comments, the Commission revised its dumping and injury calculations for Lyondell Chemical company. The rest of comments received from interested parties did not relate to the accuracy of the calculations itself but to the methodology used by the Commission and were thus outside of the scope of pre-disclosure.

11. FINAL PROVISIONS

• (450) In the interests of sound administration, the Commission will invite the interested parties to submit written comments and/or to request a hearing with the Commission and/or the Hearing Officer in trade proceedings within a fixed deadline.

• (451) The findings concerning the imposition of provisional duties are provisional and may be amended at the definitive stage of the investigation,

HAS ADOPTED THIS REGULATION:

Article 1

Country of origin	Company	Provisional anti-dumping duty (%)	TARIC additional code
People’s Republic of China	Xinjiang Markor Chemical Industry Co., Ltd.	105,6	88AL
People’s Republic of China	Wanhua Chemical (Sichuan) Co., Ltd	113,7	88AM
People’s Republic of China	Other cooperating companies listed in the Annex	107,5
People’s Republic of China	All other imports originating in the People’s Republic of China	113,7	8999
Kingdom of Saudi Arabia	International Diol Company	52,4	88AN
Kingdom of Saudi Arabia	All other imports originating in the Kingdom of Saudi Arabia	52,4	8999
United States of America	Lyondell Chemical Company	135,7	88AO
United States of America	All other imports originating in the United States of America	142,5	8999

Article 2

Article 3

Article 4

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 4 February 2026.

For the Commission

The President

Ursula VON DER LEYEN

[^ntr1-L_202600270EN.000101-E0001]: OJ L 176, 30.6.2016, p. 21, ELI: http://data.europa.eu/eli/reg/2016/1036/oj.

[^ntr2-L_202600270EN.000101-E0002]: Notice of initiation of an anti-dumping proceeding concerning imports of 1,4-Butanediol originating in the People’s Republic of China, Saudi Arabia and the United States of America (OJ C, C/2025/3135, 6.6.2025, ELI: http://data.europa.eu/eli/C/2025/3135/oj).

[^ntr3-L_202600270EN.000101-E0003]: Commission Implementing Regulation (EU) 2025/1718 of 5 August 2025 making imports of 1,4-Butanediol originating in the People’s Republic of China, Saudi Arabia and the United States of America subject to registration (OJ L, 2025/1718, 6.8.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/1718/oj).

[^ntr4-L_202600270EN.000101-E0004]: LYB hearing presentation dated 17 July 2025.

[^ntr6-L_202600270EN.000101-E0006]: Commission Implementing Regulation (EU) 2024/1959 of 17 July 2024 imposing a provisional anti-dumping duty on imports of erythritol originating in the People’s Republic of China (OJ L, 2024/1959, 19.7.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/1959/oj); Commission Implementing Regulation (EU) 2023/2180 of 16 October 2023 amending Implementing Regulation (EU) 2021/607 imposing a definitive anti-dumping duty on imports of citric acid originating in the People’s Republic of China as extended to imports of citric acid consigned from Malaysia, whether declared as originating in Malaysia or not, following a new exporter review pursuant to Article 11(4) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L, 2023/2180, 17.10.2023, ELI: http://data.europa.eu/eli/reg_impl/2023/2180/oj); Commission Implementing Regulation (EU) 2023/752 of 12 April 2023 imposing a definitive anti-dumping duty on imports of sodium gluconate originating in the People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 100, 13.4.2023, p. 16, ELI: http://data.europa.eu/eli/reg_impl/2023/752/oj); Commission Implementing Regulation (EU) 2021/441 of 11 March 2021 imposing a definitive anti-dumping duty on imports of sulphanilic acid originating in the People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 85, 12.3.2021, p. 154, ELI: http://data.europa.eu/eli/reg_impl/2021/441/oj).

[^ntr7-L_202600270EN.000101-E0007]: Implementing Regulation (EU) 2024/1959, recitals 161-162; Implementing Regulation (EU) 2023/2180, recitals 89-90; Implementing Regulation (EU) 2023/752, recital 70.

[^ntr8-L_202600270EN.000101-E0008]: Implementing Regulation (EU) 2024/1959, recitals 103-113; Implementing Regulation (EU) 2023/2180, recitals 46-50; Implementing Regulation (EU) 2023/752, recital 49.

[^ntr9-L_202600270EN.000101-E0009]: Implementing Regulation (EU) 2024/1959, recitals 114-122; Implementing Regulation (EU) 2023/2180, recitals 51-55; Implementing Regulation (EU) 2023/752, recitals 50-54. While the right to appoint and to remove key management personnel in SOEs by the relevant State authorities, as provided for in the Chinese legislation, can be considered to reflect the corresponding ownership rights, CCP cells in enterprises, state owned and private alike, represent another important channel through which the State can interfere with business decisions. According to the PRC’s company law, a CCP organisation is to be established in every company (with at least three CCP members as specified in the CCP Constitution) and the company shall provide the necessary conditions for the activities of the party organisation. In the past, this requirement appears not to have always been followed or strictly enforced. However, since at least 2016 the CCP has reinforced its claims to control business decisions in SOEs as a matter of political principle. The CCP is also reported to exercise pressure on private companies to put ‘patriotism’ first and to follow party discipline. In 2017, it was reported that party cells existed in 70 % of some 1,86 million privately owned companies, with growing pressure for the CCP organisations to have a final say over the business decisions within their respective companies. These rules are of general application throughout the Chinese economy, across all sectors, including to the producers of the product under review and the suppliers of their inputs.

[^ntr10-L_202600270EN.000101-E0010]: Implementing Regulation (EU) 2024/1959, recitals 123-133; Implementing Regulation (EU) 2023/2180, recitals 65-65; Implementing Regulation (EU) 2023/752, recitals 55-63.

[^ntr11-L_202600270EN.000101-E0011]: Implementing Regulation (EU) 2024/1959, recitals 134-138; Implementing Regulation (EU) 2023/2180, recitals 66-69; Implementing Regulation (EU) 2023/752, recital 64.

[^ntr12-L_202600270EN.000101-E0012]: Implementing Regulation (EU) 2024/1959, recitals 139-142; Implementing Regulation (EU) 2023/2180, recitals 71-72; Implementing Regulation (EU) 2023/752, recital 65.

[^ntr13-L_202600270EN.000101-E0013]: Implementing Regulation (EU) 2024/1959, recitals 143-152; Implementing Regulation (EU) 2023/2180, recitals 72-81; Implementing Regulation (EU) 2023/752, recital 66.

[^ntr14-L_202600270EN.000101-E0014]: Commission Staff Working Document on Significant Distortions in the Economy of the People’s Republic of China for the purposes of Trade Defence Investigations, 10 April 2024 (SWD(2024) 91 final), available at: https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2024)91&lang=en, including the previous version of the document: Commission Staff Working Document on Significant Distortions in the Economy of the People’s Republic of China for the purposes of Trade Defence Investigations, 20 December 2017 (SWD(2017) 483 final/2), available at: https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2017)483&lang=en.

[^ntr15-L_202600270EN.000101-E0015]: See page 18 the complaint (open version).

[^ntr16-L_202600270EN.000101-E0016]: See pages 19-23 of the complaint (open version).

[^ntr17-L_202600270EN.000101-E0017]: See pages 20-22 of the complaint (open version).

[^ntr18-L_202600270EN.000101-E0018]: See page 23 of the complaint (open version).

[^ntr19-L_202600270EN.000101-E0019]: See pages 22-23 of the complaint (open version).

[^ntr20-L_202600270EN.000101-E0020]: See page 24 of the complaint (open version).

[^ntr21-L_202600270EN.000101-E0021]: See pages 26-27 of the complaint (open version).

[^ntr22-L_202600270EN.000101-E0022]: See pages 24- 26 of the complaint (open version).

[^ntr23-L_202600270EN.000101-E0023]: See at: https://en.yuanlichem.com.cn/ (accessed on 4 November 2025).

[^ntr24-L_202600270EN.000101-E0024]: See Shandong Yuanli Annual report, p. 69, available at: https://static.sse.com.cn/disclosure/listedinfo/announcement/c/new/2025-04-25/603217_20250425_I1XA.pdf (accessed on 4 November 2025).

[^ntr25-L_202600270EN.000101-E0025]: See at: http://www.dongyuantech.com/page101?article_id=74 (accessed on 4 November 2025).

[^ntr26-L_202600270EN.000101-E0026]: See at: http://www.dongyuantech.com/ (accessed on 5 November 2025).

[^ntr27-L_202600270EN.000101-E0027]: See at: http://www.wuhai.gov.cn/wuhai/whyw75/qyjj/1932832/index.html (accessed on 5 November 2025).

[^ntr28-L_202600270EN.000101-E0028]: See at: https://www.whchem.com/column/84/ (accessed on 4 November 2025).

[^ntr29-L_202600270EN.000101-E0029]: See Wanhua Chemical Group Co., Ltd Annual report 2024, p. 5, available at: https://static.sse.com.cn/disclosure/listedinfo/announcement/c/new/2025-04-15/600309_20250415_5QB0.pdf (accessed on 4 November 2025).

[^ntr30-L_202600270EN.000101-E0030]: See at: http://www.markor.com.cn/ (accessed on 4 November 2025).

[^ntr31-L_202600270EN.000101-E0031]: See at: https://finance.sina.com.cn/roll/2024-11-14/doc-incvzfqs1332548.shtml (accessed on 4 November 2025).

[^ntr32-L_202600270EN.000101-E0032]: See at: https://www.lanshantunhe.com/ (accessed on 4 November 2025).

[^ntr33-L_202600270EN.000101-E0033]: See at: http://www.sinopecgroup.com/group/en/000/000/041/41558.shtml (accessed on 4 November 2025).

[^ntr34-L_202600270EN.000101-E0034]: See Xinjiang Zhongtai Group Ltd. Annual report 2024, p. 13 and 106, available at: https://www.shclearing.com.cn/xxpl/cwbg/nb/202504/t20250425_1577647.html (accessed on 4 November 2025).

[^ntr35-L_202600270EN.000101-E0035]: See at: https://www.lanshantunhe.com/ as well as at: https://www.xj-inv.com/jianjie/ (accessed on 4 November 2025).

[^ntr36-L_202600270EN.000101-E0036]: See at: http://wap.sasac.gov.cn/n2588045/n27271785/n27271792/c14159097/content.html (accessed on 4 November 2025).

[^ntr37-L_202600270EN.000101-E0037]: See at: http://lyxs.sinopec.com/lyxs/pro_presentation/profile/ (accessed on 4 November 2025).

[^ntr38-L_202600270EN.000101-E0038]: See Article 33 of the CCP Constitution, Article 19 of the Chinese Company Law. See also the Report, Chapter 3, p. 47-50.

[^ntr39-L_202600270EN.000101-E0039]: See at: https://finance.sina.com.cn/jjxw/2025-11-03/doc-infwckpi5523797.shtml?froms=ggmp (accessed on 5 November 2025).

[^ntr40-L_202600270EN.000101-E0040]: See at: http://www.cpcif.org.cn/list/40288043661dc14701661de581c4001c and also at: http://www.cpcif.org.cn/detail/e7d79e3b-8a8d-441e-b862-9836210774a3 (accessed on 4 November 2025).

[^ntr41-L_202600270EN.000101-E0041]: See CPCIF Articles of Association, Article 3, available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (accessed on 5 November 2025).

[^ntr43-L_202600270EN.000101-E0043]: See CPCIF Articles of Association, Article 36, available at: http://www.cpcif.org.cn/detail/40288043661e27fb01661e386a3f0001?e=1 (accessed on 5 November 2025).

[^ntr44-L_202600270EN.000101-E0044]: See at: http://www.cpcif.org.cn/list/40288043661dc14701661ddbe0980010 (accessed on 20 October 2025).

[^ntr45-L_202600270EN.000101-E0045]: See CCFA Articles of Association, Article 3, available at: https://www.ccfa.com.cn/3/202109/2260.html (accessed on 5 November 2025).

[^ntr47-L_202600270EN.000101-E0047]: See CCFA Articles of Association, Article 36, available at: https://www.ccfa.com.cn/3/202109/2260.html (accessed on 5 November 2025).

[^ntr48-L_202600270EN.000101-E0048]: See at: https://www.ccfa.com.cn/11/202404/4264.html (accessed on 5 November 2025).

[^ntr49-L_202600270EN.000101-E0049]: See Section III.8.3 of the 14th FYP on economic and social development and 2035 perspectives, available at: https://www.gov.cn/xinwen/2021-03/13/content_5592681.htm (accessed on 5 November 2025).

[^ntr50-L_202600270EN.000101-E0050]: See at: https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (accessed on 5 November 2025).

[^ntr51-L_202600270EN.000101-E0051]: Ibid., Section I.3.

[^ntr52-L_202600270EN.000101-E0052]: Ibid., Section III.4.

[^ntr53-L_202600270EN.000101-E0053]: See at: https://www.ndrc.gov.cn/xxgk/zcfb/tz/202307/t20230727_1358715.html (accessed on 5 November 2025).

[^ntr54-L_202600270EN.000101-E0054]: Ibid., Section II.

[^ntr55-L_202600270EN.000101-E0055]: See at: https://www.gov.cn/zhengce/zhengceku/202509/content_7042418.htm (accessed on 5 November 2025).

[^ntr56-L_202600270EN.000101-E0056]: Ibid., Section III.2.

[^ntr57-L_202600270EN.000101-E0057]: Ibid., Section III.4.

[^ntr58-L_202600270EN.000101-E0058]: See Section II.2.4, available at: https://huanbao.bjx.com.cn/news/20211201/1191133.shtml (accessed on 5 November 2025).

[^ntr59-L_202600270EN.000101-E0059]: Ibid., Section III.

[^ntr60-L_202600270EN.000101-E0060]: See at: https://www.gov.cn/zhengce/zhengceku/202411/content_6990315.htm (accessed on 5 November 2025).

[^ntr61-L_202600270EN.000101-E0061]: See at: http://wfrb.wfnews.com.cn/content/20210624/Articel05006TB.htm (accessed on 5 November 2025).

[^ntr62-L_202600270EN.000101-E0062]: See at: http://www.dongyuantech.com/page111?article_id=80 (accessed on 5 November 2025).

[^ntr63-L_202600270EN.000101-E0063]: See Wanhua Chemical Group Co. Ltd. annual report 2024, p. 37, available at: https://static.sse.com.cn/disclosure/listedinfo/announcement/c/new/2025-04-15/600309_20250415_CQ5Z.pdf (accessed on 5 November 2025).

[^ntr64-L_202600270EN.000101-E0064]: See at: http://www.sinopecgroup.com/group/gsglc/index.shtml, (accessed on 5 November 2025).

[^ntr65-L_202600270EN.000101-E0065]: See at: http://www.sinopecgroup.com/group/000/000/041/41878.shtml (accessed on 5 November 2025).

[^ntr66-L_202600270EN.000101-E0066]: The Report, Part III, Chapter 16.

[^ntr67-L_202600270EN.000101-E0067]: Ibid., Section 16.3.

[^ntr68-L_202600270EN.000101-E0068]: See Section IV.1.3, available at: https://www.gov.cn/zhengce/zhengceku/2021-12/29/content_5665166.htm (accessed on 5 November 2025).

[^ntr69-L_202600270EN.000101-E0069]: See at: http://gxt.shandong.gov.cn/art/2021/9/13/art_310618_10320587.html (accessed on 5 November 2025).

[^ntr71-L_202600270EN.000101-E0071]: See at: https://www.sohu.com/a/606540835_121106854 (accessed on 5 November 2025).

[^ntr72-L_202600270EN.000101-E0072]: Implementing Regulation (EU) 2024/1959, recitals 153-157 and Implementing Regulation (EU) 2023/2180, recitals 82-84; Implementing Regulation (EU) 2023/752, recital 67.

[^ntr73-L_202600270EN.000101-E0073]: See Section VIII.16, available at: https://www.gov.cn/zhengce/zhengceku/2022-04/08/content_5683972.htm#msdynttrid=WRmyf07ph0z74SHmXoOLKjRWl09BdZ4lGdYp9fiI9xU (accessed on 20 October 2025).

[^ntr74-L_202600270EN.000101-E0074]: World Bank Open Data – Upper Middle Income (https://data.worldbank.org/income-level/upper-middle-income).

[^ntr75-L_202600270EN.000101-E0075]: Commission Implementing Regulation (EU) 2021/1976 of 12 November 2021 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of mono ethylene glycol originating in the United States of America and the Kingdom of Saudi Arabia (OJ L 402, 15.11.2021, p. 17, ELI: http://data.europa.eu/eli/reg_impl/2021/1976/oj), recital 222.

[^ntr85-L_202600270EN.000101-E0085]: See the explanation of the methodology in recital 190.

[^ntr86-L_202600270EN.000101-E0086]: Regulation (EU) 2015/755 of the European Parliament and of the Council of 29 April 2015 on common rules for imports from certain third countries (OJ L 123, 19.5.2015, p. 33, ELI: http://data.europa.eu/eli/reg/2015/755/oj). Article 2(7) of the basic Regulation considers that domestic prices in those countries cannot be used for the purpose of determining normal value.

[^ntr96-L_202600270EN.000101-E0096]: Commission Implementing Regulation (EU) 2020/1336 of 25 September 2020 imposing definitive anti-dumping duties on imports of certain polyvinyl alcohols originating in the People’s Republic of China (OJ L 315, 29.9.2020, p. 1, ELI: http://data.europa.eu/eli/reg_impl/2020/1336/oj), recital 352.

[^ntr97-L_202600270EN.000101-E0097]: Basic chemicals, fertilisers and nitrogen compounds, plastics and synthetic rubber in primary forms.

[^ntr99-L_202600270EN.000101-E0099]: See recital 1.

[^ntr100-L_202600270EN.000101-E0100]: Independent Commodity Intelligence Services (ICIS) ICIS provides specialist information for the chemicals, energy, gas, carbon and coal markets via a fee.

[^ntr101-L_202600270EN.000101-E0101]: The Deepening Red Sea Shipping Crisis: Impacts and Outlook, World Bank Document, accessed on 16 October 2025.

ANNEX

Other cooperating exporting producers not sampled

Country	Name	TARIC additional code
People’s Republic of China	Shandong Yuanli Science and Technology Co., Ltd.	88AP
People’s Republic of China	Inner Mongolia Dongjing Biological Green Technology Co., Ltd.	88AQ
People’s Republic of China	Henan Kaixiang Fine Chemical Co., Ltd.	88AR
People’s Republic of China	Xinjiang Blue Ridge Tunhe Energy Co., Ltd.	88AS

ELI: http://data.europa.eu/eli/reg_impl/2026/270/oj

ISSN 1977-0677 (electronic edition)