Commission Implementing Regulation (EU) 2026/1063 of 12 May 2026 imposing a provisional anti-dumping duty on imports of PET Spunbond originating in the People’s Republic of China

• (145) The analysis set out in this section, which includes an examination of all the available evidence relating to China’s intervention in its economy in general as well as in the sector of the product concerned showed that prices and costs of the product concerned, including the costs of raw materials, energy and labour, are not the result of free market forces because they are affected by substantial government intervention within the meaning of Article 2(6a)(b) of the basic Regulation as shown by the actual or potential impact of one or more of the relevant elements listed therein.

• (146) On that basis, the Commission concluded that it is not appropriate to use domestic prices and costs to establish normal value in this case.

• (147) Consequently, the Commission proceeded to construct the normal value exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks, that is, in this case, on the basis of corresponding costs of production and sale in an appropriate representative country, in accordance with Article 2(6a)(a) of the basic Regulation, as described in the following section.

3.2.6.   Representative country

3.2.6.1.   General remarks

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

• — A level of economic development similar to the PRC. For this purpose, the Commission used countries with a gross national income per capita similar to the PRC on the basis of the database of the World Bank [^ntr103-L_202601063EN.000101-E0103];

• — Production of the product under investigation in that country;

• — Existence of relevant readily available data in the representative country;

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

• (149) As explained in recital 39, the Commission issued two notes for the file on the sources for the determination of the normal value. These notes described the facts and evidence underlying the relevant criteria, and also addressed the comments received by the parties on these elements and on the relevant sources.

3.2.6.2.   A level of economic development similar to the PRC

• (150) In the First Note, the Commission informed interested parties on the relevant sources it intended to use for the determination of the normal value and provided a list of all factors of production such as raw materials, labour and energy. It also identified possible representative countries.

• (151) According to import statistics of raw materials, imports of the factors of production (‘FOPs’) necessary to produce PET Spunbond were found in Indonesia, Thailand and Türkiye, all of which met the criteria set out in 2(6a)(a), first indent of the basic Regulation. It is also considered likely that PET Spunbond is produced in those three countries.

• (152) No comments were received concerning the countries identified in the First Note regarding the level of economic development. However, several parties commented upon the reliability of prices for certain FOPs in each of the countries, which are addressed in the following recitals.

• (153) In the Second Note, the Commission informed interested parties of its intention to use Thailand as an appropriate representative country in the present case if the existence of significant distortions pursuant to Article 2(6a) of the basic Regulation would be confirmed.

3.2.6.2.1.   Thailand

• (154) In response to the First Note, Changde Tiandingfeng Nonwovens Co Ltd and Tiandingfeng Nonwovens Co Ltd, (the latter two referred henceforth as the ‘TDF Group’) argued in favour of Türkiye compared to Thailand as a representative country because the PET chip imports in Türkiye would be more diversified, higher in volume, and mostly sourced from market-economy countries, and therefore more representative of undistorted market prices.

• (155) Hubei Unibon nonwovens Co Ltd (‘Unibon’) argued that Thailand is not appropriate as a representative country as the PET chips imports into that country would be distorted because of the large portion of PET chip imports originating in China, with the average import price from other countries markedly higher than in the two other potential representative countries. Unibon claimed that those prices would indicate that Thailand’s non-Chinese imports are largely special-grade or atypical PET chips and cannot therefore be considered a standard benchmark for PET chips used in the production of the product under investigation.

• (156) In the Second Note, the Commission noted that both in Thailand and Türkiye, a significant amount of the total PET chips imported originated in China. However, as explained in the First Note, the Commission considered that import prices of PET chips into Türkiye from non-Chinese origin appeared affected by the large volume of Chinese origin PET chips at distorted prices, whereas in Thailand this did not appear to be case.

• (157) In response to the Second Note, Unibon repeated its argument that Thailand is not a suitable representative country, submitting that PET chips should be the decisive factor in that assessment. It argued that Thailand is a net exporter of PET chips, whereas Indonesia shows a more balanced trade position, and therefore would constitute a more appropriate benchmark. Unibon further claimed that the Commission should consider not only the share of imports originating from China but also the absolute import volumes. Finally, it alleged that the significantly higher import prices of PET chips into Thailand compared to Indonesia and Türkiye indicate that the products imported into Thailand belong to a specific category and are therefore not representative.

• (158) The Commission noted that the comparatively higher import prices of PET chips into Thailand are likely attributable to the lower proportion of imports originating from China, resulting in a greater share of imports from other third countries at market-based prices. In this regard, the relative share of imports from the rest of the world as compared to China is a more relevant indicator of price reliability than absolute import volumes. Since the import volumes of PET chips into Thailand remain reasonably high, a diversified sourcing structure with limited exposure to potentially distorted imports constituted a more appropriate basis for establishing an undistorted benchmark.

• (159) The Commission noted that the investigation did not identify any specific trade restrictions or distortions for PET chips that would render Thailand unsuitable as a representative country. The mere fact that Thailand is a net exporter of PET chips did not demonstrate that its import prices are abnormal or inappropriate for benchmarking purposes. Rather the contrary, as imports compete with domestically produced PET chips.

• (160) Unibon further argued that the benchmark prices used should exclude insurance and import duties. In its view, PET chips sold on the domestic market do not incur such costs, and the majority of PET chips sold in Thailand are domestically manufactured and therefore do not bear insurance and import duty costs.

• (161) As regard the exclusion of insurance and import duties, the normal value was based on import statistics from GTA while the applicable import duties were established using MacMap. By definition, such import prices include, where applicable, import duties and related import costs. Their inclusion is therefore inherent to the methodology applied.

• (162) Further, in response to the Second Note, the complainants argued that the labour benchmark derived from the Bank of Thailand and included in Annex V to the Second Note was unreasonably low and did not accurately reflect actual labour costs in Thailand. It submitted that this figure is significantly below labour costs applied by the Commission in other upper-middle-income representative countries. The complainants requested the Commission to adjust the labour cost benchmark by using higher labour cost data for ‘engineering positions’ published by the Thailand Board of Investment, which it considered a more appropriate and representative source.

• (163) The Commission noted that the benchmark was not unusually low in view of the functions actually performed by the labour concerned in the production process. Moreover, the level of the benchmark was broadly comparable to labour cost data reported by other international statistical sources and therefore could not be regarded as unrepresentative or inappropriate for the purpose of constructing normal value. The claim was therefore rejected.

• (164) Due to the lack to reliable import data for lignite coal in Thailand as imports are exclusively from Laos, the Commission indicated in the Second Note that it intended to establish the benchmark for lignite coal, by using the prices of lignite coal for companies (industrial users) in Thailand published by the Energy Policy and Planning Office of the Ministry of Energy. The Commission used as benchmark the most recent data relating to 2024.

• (165) In response to the Second Note, Unibon argued that the benchmark price for lignite coal should be based on Thai customs import data under HS 2702 10 rather than on the domestic coal statistics. Unibon claimed that the domestic statistics fail to distinguish lignite from other coal types and only provide an average price for a broad coal category, despite significant differences in calorific value and other properties that result in substantial price disparities. Unibon further claimed that the Commission’s consistent practice is to rely on publicly available customs data of the representative country for FOP valuation and alleged that there is no justification to depart from this approach in the present case, particularly given that Thailand maintains product-specific import statistics for lignite coal, records significant import volumes, and sources such imports from market economy countries, which, in its view, ensures that the prices are undistorted and representative.

• (166) The Commission noted that, while Thai customs data under HS code 2702 10 is available, the recorded imports originate almost exclusively in a single neighbouring country, namely Laos, and therefore could not be considered sufficiently representative of a competitive and diversified market. The high concentration of supply in one source country raised concerns as to the reliability of the import price as an appropriate benchmark. Moreover, given the specific physical characteristics of lignite, in particular its low calorific value and high moisture content, long-distance transportation is generally uneconomical [^ntr104-L_202601063EN.000101-E0104]. As a result, import statistics are likely to reflect limited cross-border transactions driven by geographic proximity rather than prices formed under broader market conditions. In these circumstances, the Commission confirmed that the import data did not constitute the most suitable basis for the valuation of this factor of production.

• (167) Finally, the complainants claimed that the Thai import prices of corn starch appeared too low to reflect the prices of modified corn starch used in PET Spunbond production. In this context, they argued that this is likely due to the product mix covered by the relevant CN code, which includes both modified corn starch (used in PET Spunbond) and non-modified corn starch (not used in PET Spunbond). The Union producers therefore maintained that the Commission should make appropriate adjustments to account for this difference.

• (168) The Commission noted the claim by the Union producers concerning the use of modified corn starch in PET Spunbond production and the level of Thai import prices. However, the Union producers did not provide sufficient evidence to substantiate these claims. Accordingly, no adjustments to the Thai import prices of corn starch were made.

3.2.6.2.2.   Türkiye

• (169) In response to the First Note, the TDF Group argued that Türkiye’s imports of key factors of production, in particular PET chips, are more representative and market-driven than those of Thailand. Chinese imports account for less than half of Türkiye’s PET chip imports, and sourcing from a wide range of market-economy countries would indicate that prices reflect international market conditions. TDF Group argued that price levels alone do not demonstrate a distortion and that representative import volumes should be the decisive factor in the Commission’s analysis, especially given that PET chips accounted for about 50 % of the total production cost of the product under investigation. It claimed that Türkiye’s higher and more diversified non-Chinese import volumes therefore provided a more reliable benchmark. The company also argued that the absence of lignite imports should not disqualify Türkiye, as such gaps could be addressed by using data from other countries.

• (170) Unibon, to the contrary, argued that Türkiye is not as appropriate as representative country due to highly distorted raw material environment, macroeconomic instability affecting unit labour costs, energy costs and financial expenses ratios, and lack of appropriate financial data.

• (171) In the Second Note, the Commission noted that both Thailand and Türkiye show similar import patterns, with significant PET chip imports originating from China. However, as explained in the First Note and also in recital 156 above, the Commission considered that import prices of PET chips into Türkiye from non-Chinese origin appear affected by the large volume of Chinese origin PET chips at distorted prices.

• (172) The Commission further analysed imports of the main raw material, PET chips, and examined the import data at a more granular level to identify the types of PET chips used in the production of PET Spunbond. However, unlike in Thailand and Indonesia, the Turkish tariff schedule does not distinguish between different 8-digit codes under HS 3907 69 .

• (173) After publication of the First Note, the Commission also identified that Türkiye has safeguard measures in place that cover imports of PET chips classified under HS-code 3907 69  [^ntr105-L_202601063EN.000101-E0105]. The measures have been in effect since 11 June 2020. The Commission found that these safeguard measures on PET chips distort the import prices of this key raw material, making Türkiye a less suitable option as a representative country.

• (174) In the First Note, the Commission noted that there were no imports of lignite coal into Türkiye. TDF Group argued that this should not preclude Türkiye from being selected as a representative country. TDF Group recalled that in previous cases where a representative country lacked import volumes of certain FOPs, it has addressed this issue by using import prices from another representative country to construct the normal value.

• (175) The Commission noted the comments by the TDF Group and agreed that in the absence of reliable import benchmark, undistorted international prices, costs, or benchmarks may be applied should Türkiye had been selected as the representative country.

3.2.6.2.3.   Indonesia

• (176) In response to the First Note, Unibon considered Indonesia to be the most appropriate representative country primarily claiming it has the most balanced and least distorted sourcing of the key factor of production, PET chips. It submitted that Indonesia’s import pattern is evenly split between Chinese and non-Chinese sources, reducing the risk that ‘rest-of-world’ prices are indirectly influenced by Chinese pricing. As opposed to Indonesia, Thailand’s PET chip imports would be heavily dominated by Chinese origin, while Türkiye’s structure includes non-WTO imports that would raise additional distortion concerns. However, Unibon did not substantiate this claim or provide additional evidence to support it.

• (177) Unibon further claimed that the gaps in Indonesia’s FOP data are limited and can be readily addressed, e.g. the absence of lignite coal imports reflects Indonesia’s self-sufficiency as a major coal producer rather than a data deficiency, and benchmark coal prices are available from recognised domestic market publications, while glass fibre imports excluding China are of sufficient commercial scale.

• (178) In the Second Note, the Commission noted that the rest of the world imports of glass fibre into Indonesia only represent 3,28 % of the total glass fibre imports while the remining 96,72 % are of Chinese origin. It is therefore clear that the glass fibre imports from the rest of the world are likely to have been influenced by imports from China. The claim by Unibon was therefore rejected.

• (179) The Commission noted the comments by Unibon and agreed that in the absence of reliable import benchmark undistorted international prices, costs, or benchmarks may be applied should Indonesia had been selected as the representative country.

3.2.6.2.4.   Conclusion on the level of economic development similar to the PRC

• (180) Taking the interested parties’ arguments to the First Note and the Second Note into account, the Commission considered that Thailand was the most appropriate representative country that met the criteria of having a level of economic development similar to the PRC.

3.2.6.3.   Existence of relevant readily available data in the representative country

• (181) The Commission investigated which financial data was readily available for the three countries identified in the First Note, i.e. Indonesia, Thailand and Türkiye.

• (182) In the First Note, the Commission had identified readily available financial statements of three producers of the product under investigation in representative countries which showed a reasonable level of profitability for a period most recent to the investigation period.

• (183) The exporting producers Unibon and the TDF Group both argued that Thailand was not appropriate as a representative country because the two Thai companies considered, Thai Unitika Spunbond Co., Ltd. and Narula Nonwoven Co. Ltd., did not provide reliable data.

• (184) Unibon pointed out that Thai Unitika Spunbond showed extreme and irregular profitability, reflecting exceptional or non-operational items rather than normal industrial performance. Narula Nonwoven, in contrast, exhibited an extremely low profit margin. Unibon concluded that this stark contrast indicated that Thailand lacked stable and commercially reasonable financial data for PET Spunbond production, making any benchmark derived from these two companies highly distorted.

• (185) Similarly, TDF Group also argued that the 2025 financial data of Thai Unitika Spunbond Co., Ltd. should be disregarded because it was not an appropriate basis for benchmarks. TDF Group considered that the extraordinary increase in total revenue, more than three times its revenue from Sales & Services and its cost of goods sold, reflected exceptional other income rather than normal operational performance.

• (186) As an alternative, Unibon claimed that Indonesia provided reliable, product-specific financial data from an actual producer of PET Spunbond, PT Multi Spunindo Jaya Tbk, whose audited financial statements show commercially reasonable SG&A and profit levels consistent with normal industrial operations.

• (187) TDF Group claimed that Türkiye had a broader and more representative industry base, with eight identified producers of PET Spunbond compared to only two in Thailand and one in Indonesia. TDF Group acknowledged that company-specific financial data for Turkish producers may be limited, and it suggested the Commission to use sectoral financial data instead.

• (188) The Commission agreed with both the TDF Group and Unibon that the financial data relating to the Thai companies were not suitable. The financial data of Thai Unitika Spunbond Co., Ltd. and Narula Nonwoven Co., Ltd. were highly inconsistent and did not reflect normal industrial performances, with extreme fluctuations in profitability and revenue driven by exceptional items.

• (189) The Commission noted TDF Group’s comment on the use of sectoral data, however the sectoral data may include producers beyond those manufacturing PET Spunbond, such as textile producers with different product mixes or cost structures. Using such aggregated data risks misrepresenting the actual cost structure and profitability of the PET Spunbond segment.

• (190) The Commission agreed with Unibon’s claim that out of the PET Spunbond producers identified in the representative countries, PT Multi Spunindo Jaya Tbk (Indonesia) showed the most accurate SG&A and profit levels consistent with normal industrial operations.

• (191) In its response to the Second Note, Unibon argued that combining FOP data from Thailand with financial ratios from Indonesia was inappropriate, as using two different representative countries in their views breaks the internal consistency of the normal value construction and leads to a distorted result. It contended that the Commission should instead rely on a single representative country for both FOP prices and financial data and submitted that Indonesia would be the more appropriate choice.

• (192) In accordance with Article 2(6a)(a) of the basic Regulation, where the existence of significant distortions is confirmed, the Commission should construct the normal value using costs of production and sale reflecting undistorted prices and benchmarks. The sources the Commission may use include the corresponding costs of production and sale in an appropriate representative country, provided the relevant data are readily available. As explained in detail above, the Commission considered Thailand as an appropriate representative country which allowed it to rely on its costs and prices for all factors of production of the product under investigation. However, the Commission was unable to find readily available financial data from Thai PET Spunbond producers for the calculation of an undistorted and reasonable amount of SG&A expenses and profit. For this reason, the Commission considered it appropriate to establish an undistorted and reasonable amount SG&A expenses and profit on the basis of readily available financial data of a PET Spunbond producer in Indonesia.

3.2.6.4.   Level of social and environmental protection

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

3.2.6.5.   Conclusion

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

3.2.7.   Sources used to establish undistorted costs

• (195) In the First Note, the Commission listed the factors of production such as raw materials, energy and labour used in the production of the product under investigation by the exporting producers and invited the interested parties to comment and propose publicly available information on undistorted values for each of the factors of production mentioned in that note.

• (196) The Commission did not receive any objection to the list of factors of production in its the First Note.

• (197) Subsequently, in the Second Note, the Commission stated that, to construct the normal value in accordance with Article 2(6a)(a) of the basic Regulation, it would use GTA (for import prices) and MacMap (for import duties) to establish the undistorted cost of most of the factors of production, notably the raw materials.

3.2.7.1.   Factors of production

• (198) Considering all the information submitted by the interested parties and collected during the verification visits, the following factors of production and their sources have been identified in order to determine the normal value in accordance with Article 2(6a)(a) of the basic Regulation:

Table 1

Factor of Production	Commodity codes	Source of data the Commission intends to use	Value (CNY)	Unit of measurement*
Raw Materials	Raw Materials	Raw Materials	Raw Materials	Raw Materials
PET chips (viscosity number lower than 78 ml/g)	3907 69 10	Global Trade Atlas (GTA)[^ntr106-L_202601063EN.000101-E0106] / MacMap[^ntr107-L_202601063EN.000101-E0107]	11,17	Kg
Corn starch	1108 12	Global Trade Atlas (GTA) / MacMap	5,38	Kg
Glass fibre	701919	Global Trade Atlas (GTA) / MacMap	17,15	Kg
Acrylic ester emulsion	3906 90 99	Global Trade Atlas (GTA) / MacMap	21,11	Kg
Labour	Labour	Labour	Labour	Labour
Labour	[N/A]	Statistics published by the National Bank of Thailand[^ntr108-L_202601063EN.000101-E0108]	15,83	Working hours
Energy	Energy	Energy	Energy	Energy
Electricity	[N/A]	Metropolitan Electricity Authority of Thailand[^ntr109-L_202601063EN.000101-E0109]	1,15	KwH
Natural gas	[N/A]	Energy Policy and Planning Office of the Ministry of Energy[^ntr110-L_202601063EN.000101-E0110]	3,02	m3
Lignite Coal	[N/A]	Energy Policy and Planning Office of the Ministry of Energy	1,19	Kg
Semicoke	2704	Global Trade Atlas (GTA) / MacMap	3,72	Kg

[^ntr110-L_202601063EN.000101-E0110]: Ministry of Energy - Energy policy and planning office (Table 7.2-4) https://www.eppo.go.th/index.php/en/en-energystatistics/energy-economy-static.

• (199) The Commission included a value for manufacturing overhead costs to cover costs not included in the factors of production referred to above. To establish this amount, the Commission calculated the ratio between the respective sampled exporting producers’ indirect manufacturing costs in relation to their respective direct manufacturing costs (as listed in Table 1 above). This ratio was thereafter applied on the undistorted direct costs of manufacturing and added thereto.

3.2.7.1.1.   Raw materials

• (200) To establish the undistorted price of raw materials as delivered at the gate of a representative country producer, the Commission used as a basis the weighted average import price to the representative country as reported in the GTA to which import duties and transport costs were added.

• (201) An import price in the representative country was determined as a weighted average of unit prices of imports from all third countries excluding the PRC and countries which are not members of the WTO, listed in Annex 1 of Regulation (EU) 2015/755 of the European Parliament and the Council [^ntr111-L_202601063EN.000101-E0111].

• (202) The Commission decided to exclude imports from the PRC into the representative country as it concluded in Section 3.2.1 that it is not appropriate to use domestic prices and costs in the PRC due to the existence of significant distortions in accordance with Article 2(6a)(b) of the basic Regulation.

• (203) Given that there is no evidence showing that the same distortions do not equally affect products intended for export, the Commission considered that the same distortions affected export prices.

• (204) For a number of factors of production, the actual costs incurred by the sampled exporting producers represented a negligible share of total raw material costs in the investigation period. As the value used for these had no appreciable impact on the dumping margin calculations, regardless of the source used, the Commission decided to include those costs into consumables, as explained in recitals 221 and 222.

• (205) To determine the applicable import duties per goods code and country of origin, the Commission consulted MacMap. The import duties were added to the CIF value recorded in the Thai import statistics as available in the GTA database.

• (206) The Commission expressed the transport cost incurred by the sampled exporting producers for the supply of raw materials as a percentage of the actual cost of such raw materials and then applied the same percentage to the undistorted cost of the same raw materials in order to obtain the undistorted transport cost. The Commission considered that, in the context of this investigation, the ratio between the exporting producers’ raw material and the reported transport costs could be reasonably used as an indication to estimate the undistorted transport costs of raw materials when delivered to the company’s factory.

3.2.7.1.1.1.   PET Chips

• (207) PET chips are the main raw material in the production of PET Spunbond. In the First Note, the Commission had listed both the customs code for low-viscosity PET, i.e. HS code 3907 69 , and the customs code for high-viscosity PET, HS code 3907 61 . The Union producers provided comments on the First Note urging the Commission to carefully verify the exact raw material of each Chinese producer to ensure it uses the correct code for each producer. After the verification visits the Commission concluded that only low-viscosity PET, i.e. HS code 3907 69 , was relevant in the production of PET Spunbond and removed the high-viscosity PET (HS 3907 61 ) from the list of raw materials.

• (208) In the Second Note, the Commission further analysed the import of the main raw material PET Chips and decided to examine the import data at a more granular level to identify the types of PET chips used in the production of PET Spunbond.

• (209) The Thai tariff schedules distinguish between the following commodity codes under HS 6-digit code 3907 69 :

• — 3907 69 10 – Granules and similar forms

• — 3907 69 90 – Other

• (210) The PET chips used in the production of PET Spunbond fall under commodity code 3907.69.10, whereas commodity code 3907.69.90 may include special-grade or otherwise atypical polyethylene terephthalate. Using GTA data, the Commission was able to identify imports to Thailand under commodity code 3907.69.10, providing more detailed information.

• (211) For Thailand, the total import quantity was 23 411 tonnes, of which 33 % originated from China. Since imports originated from multiple sources and the proportion of imports from China was relatively low, the Commission concluded that import prices for PET chips under commodity code 3907.69.10 into Thailand from the rest of the world are not likely to have been influenced by imports from China, hence making imports to Thailand a reliable benchmark.

3.2.7.1.1.2.   Binders (Corn starch and acrylic ester emulsion)

• (212) As already described in recital 26, PET Spunbond production requires using starch-based binders, chemical (polymer-based) binders, or mixed binders as coating material.

• (213) In response to the First Note, the complainants claimed that Chinese producers mainly use starch-based binders for PET Spunbond sold on the Chinese domestic market, while products sold on the EU market are made using all three types of binders. The Union producers therefore maintained that, to ensure a fair comparison in the dumping calculations, the Commission should establish separate normal values for PET Spunbond produced with each type of binder or make appropriate adjustments to a normal value based on starch-based binder production.

• (214) The Commission noted the comments made by the Union producers concerning the different types of binders used in the production of PET Spunbond and their potential impact on price comparability. The Commission assessed whether differences in binder types may warrant consideration and, where appropriate, whether any adjustments were justified on the basis of the information available on the file. The outcome of this assessment is set out in recital 220.

• (215) In response to the Second Note, the complainants argued that they disagreed with the prices used in the FOP Note for corn starch. The complainants submitted that the type of corn starch used in the production of PET Spunbond is modified corn starch, the price of which is approximately double that of ordinary corn starch. In support of this claim, the complainants provided price quotations comparing modified and ordinary corn starch and requested the Commission to apply a corresponding mark-up to the GTA-based prices in order to reflect the higher cost of modified corn starch.

• (216) In response to the complainants’ argument, both exporting producers maintained, that for their own production, they use only ordinary corn starch. The exporting producers submitted that this is evidenced by the invoices collected during the verification of their raw material purchases, which refer to the type of corn starch purchased. Furthermore, TDF Group argued that, in China, modified corn starch is declared under a difference HS code 3505 10 , and claims that its purchases under HS code 1108 12 concern ordinary corn starch rather than modified corn starch.

• (217) The Commission noted that the complainants had not provided conclusive evidence that PET Spunbond producers, including the Chinese exporting producers, use modified corn starch. The price quotations submitted merely showed that modified corn starch may be more expensive than ordinary corn starch, but did not demonstrate that the investigated exporting producers use such product. By contrast, the verified technical specifications and price levels indicated that the exporting producers use ordinary corn starch.

• (218) In response to the Second Note, TDF Group claimed that the acrylic ester emulsion it uses was incorrectly classified under HS code 3903 90 , which covers polymers of styrene. TDF Group argued that although the product contains styrene, its main component is acrylic acid and it would therefore be more appropriately classified under HS code 3906 90 , covering acrylic polymers in primary forms. The Commission accepted TDF Group’s claim and revised the classification of the acrylic ester emulsion HS code.

• (219) In response to the Second Note, Unibon argued that material differences in binder types used in PET Spunbond production, namely starch-based, chemical acrylic-based, and mixed binders, lead to significant variations in production costs and market prices. The company argued that this must be duly reflected in the normal value construction. On this basis, Unibon requested the Commission to apply adjustments to account for binder-related cost differences.

• (220) The Commission rejected the claim. It noted that both Union and sampled Chinese PET Spunbond producers use a mixture of binders, all of which have similar uses and market prices. Therefore, a more detailed analysis distinguishing products by binder type, where there is no significant difference in use or price, would not have a significant effect on the normal value calculation.

3.2.7.1.1.3.   Consumables

• (221) In the Second Note, the Commission informed parties that, due to the negligible weight of some of the raw materials in the total cost of production, some of the factors of production were considered consumables.

• (222) The Commission calculated the percentage of the consumables in the total cost of production and applied this percentage to the recalculated cost of production based on benchmarks.

3.2.7.1.2.   Labour

• (223) Labour is a factor of production representing some 3 % of total cost of production. The Commission used the statistics published by the National Bank of Thailand [^ntr112-L_202601063EN.000101-E0112] to determine the wages in Thailand using the detailed information on wages in the producing sector for the investigation period, for the economic activity according to NACE Rev.2 classification.

3.2.7.1.3.   Electricity

• (224) The Commission used the quotation of the electricity price for business, industrial and state enterprises published by the Thailand Board of Investment [^ntr113-L_202601063EN.000101-E0113] using the Time of use tariff (TOU tariff) - Large General Service, Voltage level below 22 Kv in order to calculate the benchmark for electricity. This tariff is unchanged since 2018 and is updated on a monthly basis using the instrument called Ft surcharge. Electricity charges billed for each month are therefore calculated as:

• — an electricity base charge, according to the tariffs described above and which remained constant over the years,

• — an energy adjustment charge (Ft), which is periodically updated by the Thai Energy Regulatory Commission (ERC) and published by the Metropolitan Electricity Authority [^ntr114-L_202601063EN.000101-E0114]

• (225) The Commission established a benchmark for electricity for each sampled exporting producer based on the respective peak and off-peak consumption. The resulting usage was allocated to the peak and off-peak rates.

• (226) In addition, the Commission included both the demand charge and the service charge in the electricity rate benchmark, to fully reflect the cost of electricity in the representative country. The service charge was expressed as a fixed amount per month, while the demand charge was established, in kW, based on the conservative calculation of the electricity demand. This was established by dividing the total peak consumed energy by the number of production hours. The weighted average rate for both peak and off-peak was established as a respective benchmark for each sampled exporting producer.

• (227) The Commission established that electricity prices in Thailand were quoted exclusive of VAT.

3.2.7.1.4.   Natural Gas

• (228) The Commission used the prices of gas for companies (industrial users) in Thailand published by the Energy Policy and Planning Office of the Ministry of Energy [^ntr115-L_202601063EN.000101-E0115]. The prices differed per consumption volume. The Commission used the corresponding prices from Table 7.2-4: Final Energy Consumption Per Capita. The Commission used as benchmark the most recent data relating to 2024.

3.2.7.1.5.   Lignite Coal

• (229) As mentioned in the Second Note, the Commission established the benchmark for lignite coal, by using the prices of lignite coal for companies (industrial users) in Thailand published by the Energy Policy and Planning Office of the Ministry of Energy. As noted above in recital 166, the Commission considered that imports of lignite coal from Laos into Thailand could not be considered a reliable and reasonable corresponding cost in the appropriate representative country pursuant to Article 2(6a)(a) of the basic Regulation. The Commission found the alternative benchmark published by the Energy Policy and Planning Office of the Ministry of Energy to be more reasonable in view of the following elements. First, the official Thai statistics are gathered by national authorities responsible for collecting and overseeing energy and economic information in Thailand [^ntr116-L_202601063EN.000101-E0116], and therefore provide comprehensive macro-level coverage of energy consumption in the country. Second, the value of 1,19 CNY/kg found in the Thai statistics was found to be in line with the prevalent price levels for lignite coal in Southeast Asia during the investigation period (i.e. in the range of 1.15-1.23 CNY/kg) [^ntr117-L_202601063EN.000101-E0117].

3.2.7.1.6.   Semicoke

• (230) The Commission used import prices for semicoke under 2704 from the rest of the world to Thailand. The Commission explained that these import prices could be considered representative, as the volumes imported were substantial and originated in multiple undistorted sources. On this basis, the Commission considered that such data provided a sufficiently reliable benchmark for the determination of the normal value. No interested party raised objections to this approach.

3.2.7.1.7.   Waste

• (231) As mentioned in the Second Note, the Commission analysed the accounting practices of the sampled Chinese exporting producers pertaining to by-products and waste. As a result, the Commission adjusted the constructed cost of production in accordance with each companies’ accounting practices pertaining to by-products and waste.

3.2.7.1.8.   Manufacturing overhead costs, SG&A and profit

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

• (233) For establishing an undistorted and reasonable amount for SG&A costs and profit, the Commission relied on the financial data for year 2024 for PT Multi Spunindo Jaya Tbk as extracted from Orbis.

• (234) Manufacturing overheads are not separately identified in the available Profit and Loss account figures and are deemed to be included in the cost of goods sold. The manufacturing overheads incurred by the cooperating exporting producers are expressed as a share of the costs of manufacturing actually incurred by the exporting producers. This percentage was applied to the undistorted costs of manufacturing.

• (235) In the Second Note, with regard to the exporting producers’ respective costs for Research and Development, the Commission stated that those costs would be included in the manufacturing overheads, unless it was explicit from the published accounts of the producer in Indonesia that those costs were included in its SG&A.

• (236) In response to the Second Note, the exporting producer TDF Group stated that it followed from Indonesian accounting standards that costs for Research & Development should be classified under SG&A. While the annual report of PT Multi Spunindo Jaya Tbk did not explicitly list costs of Research & Development, another company - PT Bakrie Telecom, which followed the same Indonesian accounting standards – had specified its costs for Research & Development under its SG&A.

• (237) The Commission accepted the claim by the TDF Group and did not add the costs for Research & Development to the Manufacturing Overheads.

• (238) In response to the Second Note, the exporting producer TDF Group argued that the Commission should not rely on Spunindo’s 2024 consolidated financial statements to determine SG&A and profit, as those accounts include data from three subsidiaries whose activities are unrelated to the product under investigation and, in some cases, had not commenced commercial operations. In light of this, TDF Group submitted that only the standalone financial data of the parent company should be used to establish reasonable amounts for SG&A and profit when constructing normal value. The Commission accepted this claim and used the profit and SG&A of the parent company when constructing normal value.

3.2.8.   Calculation

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

• (240) First, the Commission established the undistorted manufacturing costs. The Commission applied the undistorted unit costs to the actual consumption of the individual factors of production of the sampled exporting producers. These consumption rates were verified during the verification. The Commission multiplied the usage factors by the undistorted costs per unit observed in the representative country.

• (241) Then the Commission added manufacturing overheads to the undistorted cost of manufacturing to arrive at the undistorted costs of production.

• (242) To the costs of production established as described in the previous recital, the Commission applied SG&A and profit from the PET Spunbond producer in Indonesia referred to in recital 233.

• (243) SG&A expressed as a percentage of the Costs of Goods Sold (‘COGS’) and applied to the undistorted costs of production, amounted to 12,03 %. The profit expressed as a percentage of the COGS and applied to the undistorted costs of production, amounted to 11,14 %.

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

3.3.   Export price

• (245) The sampled exporting producers exported to the Union directly to independent customers.

• (246) The export price was the price actually paid or payable for the product concerned when sold for export to the Union, in accordance with Article 2(8) of the basic Regulation.

3.4.   Comparison

• (247) Article 2(10) of the basic Regulation requires the Commission to make a fair comparison between the normal value and the export price at the same level of trade and to make allowances for differences in factors which affect prices and price comparability.

• (248) In the case at hand the Commission chose to compare the normal value and the export price of the sampled exporting producers at the ex-works level of trade. As further explained below, where appropriate, the export prices were adjusted in order to: (i) net them back to the ex-works level; and (ii) make allowances for differences in factors which were claimed, and demonstrated, to affect prices and price comparability.

3.4.1.   Adjustments made to the normal value

• (249) As explained in Section 3.2 above, the normal value was established at the ex-works level of trade by using costs of production together with amounts for SG&A and for profit, which were considered to be reasonable for that level of trade. Therefore, no adjustments were necessary to net the normal value back to the ex-works level.

• (250) The Commission found no reasons for making any allowances to the normal value, nor were such allowances claimed by any of the sampled exporting producers.

3.4.2.   Adjustments made to the export price

• (251) In order to net the export price back to the ex-works level of trade, adjustments were made on the account of: customs duty, other import charges, freight, insurance, handling loading and ancillary expenses.

3.5.   Dumping margins

• (252) For the sampled exporting producers, the Commission compared the weighted average normal value of each type of the like product with the weighted average export price of the corresponding type of the product concerned, in accordance with Article 2(11) and (12) of the basic Regulation.

• (253) On this basis, the provisional weighted average dumping margins expressed as a percentage of the CIF Union frontier price, duty unpaid, are as follows

Company	Provisional dumping margin
— Hubei Unibon nonwovens Co Ltd	45,6  %
— Changde Tiandingfeng Nonwovens Co Ltd — Tiandingfeng Nonwovens Co Ltd	50,0  %

• (254) For the cooperating exporting producers outside the sample, the Commission calculated the weighted average dumping margin, in accordance with Article 9(6) of the basic Regulation. Therefore, that margin was established on the basis of the margins of the sampled exporting producers.

• (255) On this basis, the provisional dumping margin of the cooperating exporting producers outside the sample is 49,4 %.

• (256) For all other exporting producers in the PRC, the Commission established the dumping margin on the basis of the facts available, in accordance with Article 18 of the basic Regulation.

• (257) To this end, the Commission determined the level of cooperation of the exporting producers. The level of cooperation was calculated on the basis of the volume of exports of the cooperating exporting producers, sampled and non-sampled, to the Union expressed as proportion of the total imports from the PRC to the Union in the investigation period, that was established on the basis of 2024 import statistics from Eurostat for the CN codes listed in recital 24.

• (258) The level of cooperation in this case was high because the exports of the cooperating exporting producers constituted around 87 % of the total imports during the investigation period. On this basis, the Commission found it appropriate to establish the dumping margin for non-cooperating exporting producers at the level of the cooperating sampled individually examined company with the highest dumping margin.

• (259) The provisional dumping margins, expressed as a percentage of the CIF Union frontier price, duty unpaid, are as follows:

Company	Provisional dumping margin
— Hubei Unibon nonwovens Co Ltd	45,6  %
— Changde Tiandingfeng Nonwovens Co Ltd — Tiandingfeng Nonwovens Co Ltd	50,0  %
Other cooperating companies	49,4  %
All other imports originating in country concerned	50,0  %

4. INJURY

4.1.   Definition of the Union industry and Union production

• (260) The like product was manufactured by three producers in the Union during the investigation period, two of which belong to the same group. They constitute the ‘Union industry’ within the meaning of Article 4(1) of the basic Regulation.

• (261) The total Union production during the investigation period was established at around [52 000 - 63 600] tonnes. The Commission established the figure on the basis of all the available information concerning the Union industry, such as data contained in the questionnaire replies received from the Union producers. As indicated in recital 16, the cooperating Union producers represented 100 % of the total Union production of the like product.

• (262) As the data relating to the injury assessment was derived from three Union producers, two of them belonging to the same group, the figures for the injury analysis are given in ranges for reasons of confidentiality. However, the indexes are based on actual data and not on the ranges.

4.2.   Union consumption

• (263) The Commission established the Union consumption on the basis of: (a) data submitted by the Union producers and verified by the Commission concerning the Union industry’s sales of the like product to unrelated customers in the Union; and (b) imports of the product under investigation from all third countries into the Union, based on data reported in Eurostat, verified data of the sampled Chinese exporting producers and data provided by the non-sampled exporting producers [^ntr118-L_202601063EN.000101-E0118].

• (264) The approach to estimate imports and Union consumption was set out in a Note to the File on 4 March 2026 [^ntr119-L_202601063EN.000101-E0119]. CCCT commented on the Commission’s approach. CCCT fully acknowledged the practical challenges faced by the Commission in determining imports and consumption, but raised concerns about the reliability of figures due to the assumptions in the methodologies described in the Note. CCCT’s three main concerns were (i) that the calculation of imports from China used a fixed ratio based on the investigation period data without evidence it was representative across the period considered; (ii) that the estimation of imports from other countries for 2024 and the investigation period were based on Eurostat statistics despite the Commission’s findings that a significant part of the imports were not properly declared; and (iii) that the complicated price-range filtering methodology to estimate other countries’ imports for 2022 and 2023 introduced uncertainty. CCCT therefore questioned the reliability of these figures and claimed that they may potentially impact the analysis of injury indicators and the assessment of the link between imports and the Union industry’s economic situation.

• (265) The Commission considered that, first, while CCCT questioned the approach, they provided no evidence to support their position or that the Commission’s proposed methodology led to inaccurate or unreliable results, neither with regard to volumes, nor with regard to prices.

• (266) Second, the manifest discrepancies between the verified export data of the sampled exporting producers and the Eurostat data obliged the Commission to seek an alternative method to establish the import volumes of the product concerned into the Union. However, CCCT failed to provide an alternative approach or any additional data that would challenge or even amend the Commission’s methodology, in particular regarding the share of the exports of the sampled exporting producers in the total exports in years prior to the investigation period. Regarding the share of the exporting producers, neither the sampled, nor the non-sampled exporting producers commented on the sampling note, nor on the Note to the File on the determination of imports.

• (267) Third, the use of allocation keys to determine third country imports is a common practice when the product under investigation is classified in CN codes also covering other goods that fall outside the scope of the investigation. Again, CCCT did not provide an alternative approach or any data regarding the ratio or prices of imports from other origins in relation to total imports into the Union.

• (268) Fourth, the Commission’s findings on the Union market situation are in line with the evidence provided in the complaint, in particular in the consumption numbers set out in the market report of EDANA [^ntr120-L_202601063EN.000101-E0120] which was part of the complaint [^ntr121-L_202601063EN.000101-E0121]. This further supports the accuracy and appropriateness of the Commission’s methodology.

• (269) In view of the above, the Commission rejected CCCT’s comments.

• (270) Union consumption developed as follows:

Table 2

Union consumption (tonnes)

	2022	2023	2024	Investigation period
Total Union consumption	[58 000 - 71 000 ]	[51 700 - 63 200 ]	[72 500 - 88 700 ]	[66 700 - 81 600 ]
Index	100	89	125	115
Source: Union producers, exporting producers and Eurostat.	Source: Union producers, exporting producers and Eurostat.	Source: Union producers, exporting producers and Eurostat.	Source: Union producers, exporting producers and Eurostat.	Source: Union producers, exporting producers and Eurostat.

• (271) Consumption in the Union increased by 15 % during the period considered. A detailed analysis showed that the Union consumption decreased by 11 % from 2022 to 2023, followed by a significant increase in 2024. From 2024 to the investigation period, consumption decreased by 10 percentage points but remained at high levels, 15 % above the beginning of the period considered.

• (272) In the beginning of the period considered, the post-pandemic recovery supported the PET Spunbond consumption. Consumption decreased between 2022 and 2023, because of lower demand for bitumen membranes in the EU building and construction sector due to high interest rates, elevated energy prices, and geopolitical uncertainties. In 2024, Union consumption for PET Spunbond rebounded, reflecting the restocking of inventories by downstream bituminous membrane producers driven by increased demand for their product [^ntr122-L_202601063EN.000101-E0122]. Between the 2024 and the investigation period, consumption remained at high levels.

4.3.   Imports from the country concerned

4.3.1.   Volume and market share of the imports from the country concerned

• (273) The Commission established, as explained in detail in Section 4.2 above, the volume of imports of the product concerned into the Union on the basis of Eurostat data, on verified data of the sampled Chinese exporting producers and data provided by the non-sampled exporting producers. The market share of the imports was established by comparing the volume of imports with the Union consumption.

• (274) Imports into the Union from the country concerned developed as follows:

Table 3

Import quantity (tonnes) and market share

	2022	2023	2024	Investigation period
Volume of imports from the PRC (tonnes)	[3 400 - 4 200 ]	[7 100 - 8 700 ]	[20 800 - 25 400 ]	[17 600 - 21 500 ]
Index	100	210	611	517
Market share (%)	6	14	29	26
Index	100	235	488	452
Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.

• (275) Import volumes from the PRC increased by 417 % over the period considered, rising from [3 400 - 4 200] tonnes in 2022 to [17 600 - 21 500] tonnes in the investigation period. China’s market share grew significantly, from 6 % in 2022 to 26 % in the investigation period, representing a 352 % increase.

4.3.2.   Prices of the imports from the country concerned: price undercutting and price suppression

• (276) The Commission established the prices of imports on the basis of data provided by the sampled exporting producers, which represented 72 % of Chinese cooperating exporting producers’ imports to the Union in the investigation period. The prices of the imports were established in similar way as import volumes.

• (277) The weighted average price of imports into the Union from PRC developed as follows:

Table 4

Import prices (EUR/ tonne)

	2022	2023	2024	Investigation period
Price of imports from the PRC	[2 300 - 2 800 ]	[1 400 - 1 750 ]	[1 500 - 1 850 ]	[1 700 - 2 100 ]
Index	100	62	66	79
Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.	Source: Exporting producers and Eurostat.

• (278) Prices decreased significantly (-38 %) between 2022 and 2023. Subsequently, they increased in 2024 and the investigation period by 4 and 13 percentage points, respectively. Overall, they decreased by 21 % during the period considered from approximately 2 500 EUR/tonne in 2022 to approximately 2 000 EUR/tonne during the investigation period.

• (279) The Commission determined the price undercutting during the investigation period by comparing the weighted average sales prices per product type of the Union producers charged to unrelated customers on the Union market, adjusted to an ex-works level, and the corresponding weighted average prices per product type of the imports from the sampled Chinese producers to the first independent customer on the Union market, established on a Cost, insurance, freight (CIF) basis, with appropriate adjustments, where appropriate, for customs duties and post-importation costs.

• (280) The price comparison was made on a type-by-type basis for transactions at the same level of trade, duly adjusted where necessary, and after deduction of rebates and discounts. The result of the comparison was expressed as a percentage of the sampled Union producers’ theoretical turnover during the investigation period. It showed a weighted average undercutting margin of 26 % to 30 % for 100 % of the imported volumes of the sampled exporting producers.

• (281) In addition to price undercutting, there was also significant price depression within the meaning of Article 3(3) of the basic Regulation. Due to the significant price pressure caused by the low-priced dumped imports from the Chinese exporting producers, the Union industry reduced their average unit sales price in the Union by 21 % in the period considered, to a level far exceeding the decrease in costs (10 %) as set out in Table 8 below. The significant price depression is further confirmed by the price underselling found on the basis of the data provided by the sampled exporting producers.

4.4.   Economic situation of the Union industry

4.4.1.   General remarks

• (282) In accordance with Article 3(5) of the basic Regulation, the examination of the impact of the dumped imports on the Union industry included an evaluation of all economic indicators having a bearing on the state of the Union industry during the period considered.

• (283) For the injury determination, the Commission distinguished between macroeconomic and microeconomic injury indicators. The Commission evaluated both sets of indicators on the basis of the questionnaire replies of the known Union producers. As no other Union producers are known to the Commission, both sets of data were found to be representative of the economic situation of the Union industry. As explained in recital 262, the injury indicators are provided in ranges, as data relating to the injury assessment was derived from three Union producers, two of them belonging to the same group.

4.4.2.   Macroeconomic indicators

4.4.2.1.   Production, production capacity and capacity utilisation

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

Table 5

Production, production capacity and capacity utilisation

	2022	2023	2024	Investigation period
Production volume (tonnes)	[54 800 - 67 000 ]	[44 000 - 53 600 ]	[52 000 - 63 600 ]	[52 000 - 63 600 ]
Index	100	80	95	95
Production capacity (tonnes)	[70 000 – 85 000 ]	[64 400 - 78 200 ]	[64 400 - 78 200 ]	[64 400 - 78 200 ]
Index	100	92	92	92
Capacity utilisation (%)	78	68	81	81
Index	100	87	104	104
Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.

• (285) During the period considered, the Union industry’s production volume experienced a sharp reduction between 2022 and 2023, also due to the decline in Union consumption. In 2024 and the investigation period, despite the sharp increase in consumption (+25 % in 2024, +15 % in the investigation period, see Table 2) and due to the increasing presence of low priced imports from the PRC, the Union industry was unable to achieve the same production volumes, which resulted in a decrease of 5 % compared to 2022.

• (286) During the period considered, the Union industry’s production capacity experienced an overall reduction of 8 %. The loss, of about 7 000 tonnes, was caused by the termination between 2022 and 2023 of a tolling agreement on behalf of one of the Union producers, due to the situation in the market and the increasing presence of low-priced imports. The existence of that tolling agreement was also the reason of the lower capacity utilisation in 2022, that in turn leads to an apparent 3 % increase of capacity utilisation between 2022 and the investigation period. In other words, the Union industry retained their capacity utilisation at sufficient levels, but only at the expense of their capacity.

4.4.2.2.   Sales quantity and market share

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

Table 6

Sales quantity and market share

	2022	2023	2024	Investigation period
Total Sales volume on the Union market (tonnes)	[50 000 - 60 000 ]	[39 000 - 46 500 ]	[46 000 - 55 000 ]	[45 000 - 54 000 ]
Index	100	78	92	90
Market share (%)	86	75	63	67
Index	100	97	74	78
Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.

• (288) In the period considered, whereas the market expanded by 15 %, the total Union industry’s sales volume declined by 10 %, due to the increasing unfair competition of low-priced Chinese imports.

• (289) As a result, the Union industry’s market share declined sharply from 86 % in 2022 to 63 % in 2024, in line with the increasing presence of Chinese imports. Between 2024 and the investigation period, and despite the reduction in their sales, the Union industry regained 4 percentage points of market share, due to the decreased presence of Chinese imports.

4.4.2.3.   Growth

• (290) In the context of a significantly increasing Union consumption, the data indicate that the Union industry suffered significant losses in production, sales volume, and market share. Conversely, the market share of dumped imports from PRC increased by 352 %.

4.4.2.4.   Employment and productivity

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

Table 7

Employment and productivity

	2022	2023	2024	Investigation period
Number of employees (FTE)	[335 - 410 ]	[330 - 400 ]	[335 - 405 ]	[330 - 400 ]
Index	100	98	99	98
Productivity (tonnes/FTE)	[150 - 180 ]	[120 - 150 ]	[145 - 175 ]	[145 - 175 ]
Index	100	82	96	96
Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.	Source: Union producers.

• (292) The Union industry experienced a small decrease in employment of 2 % over the period considered, with the total number of employees declining by [5 - 10] during the investigation period.

• (293) The productivity of the Union industry’s workforce, measured in tonnes produced per employee per year, declined by 4 % closely following the trend in the decrease of production. The Union industry chose to retain their employees even in 2023, when production declined sharply due to a decline in consumption, mindful of the difficulty of replacing their skilled workforce.

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

• (294) All dumping margins were significantly above the de minimis level. The impact of the magnitude of the actual margins of dumping on the Union industry was substantial, given the volume and prices of imports from the country concerned.

• (295) This is the first anti-dumping investigation regarding the product concerned. Therefore, no data were available to assess the effects of possible past dumping.

4.4.3.   Microeconomic indicators

4.4.3.1.   Prices and factors affecting prices

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

Table 8

Sales prices in the Union

	2022	2023	2024	Investigation period
Average unit sales price in the Union on the total market (EUR/ tonne)	[3 300 - 4 000 ]	[2 900 - 3 600 ]	[2 600 - 3 200 ]	[2 600 - 3 200 ]
Index	100	90	79	79
Unit cost of production (EUR/ tonne)	[2 900 - 3 500 ]	[2 800 - 3 400 ]	[2 500 - 3 100 ]	[2 600 - 3 200 ]
Index	100	96	88	90
Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.

• (297) The sales prices of the Union industry to unrelated parties on the Union market decreased by 21 % between 2022 and 2024 and remained almost stable between 2024 and the investigation period.

• (298) The unit cost of production of the sampled Union producers decreased by 12 % between 2022 and 2024 and then increased slightly between 2024 and the investigation period. Thus, the presence of much lower priced Chinese imports, caused significant price depression, forcing the Union industry to reduce its prices to levels far exceeding the decrease in cost of production.

4.4.3.2.   Labour costs

• (299) The average labour costs of the sampled Union producers developed over the period considered as follows:

Table 9

Average labour costs per employee

	2022	2023	2024	Investigation period
Average labour costs per employee (EUR)	70 800 - 86 500	70 800 - 86 500	74 200 - 90 700	79 300 - 97 000
Index	100	100	105	112
Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.	Source: Sampled Union producers.

• (300) The average labour costs per employee increased by 12 % over the period considered. While labour costs remained relatively stable between 2022 and 2023, they experienced an increase in 2024 and during the investigation period, primarily due to inflation and in line with the seniority of the employees.

4.4.3.3.   Inventories

• (301) Stock levels of the sampled Union producers developed over the period considered as follows:

Table 10

Stocks