Commission Implementing Regulation (EU) 2026/1857 of 27 July 2026 imposing a provisional anti-dumping duty on imports of benzyl alcohol originating in the People’s Republic of China

• (287) Imports from China into the Union exerted a major price and volume pressure on the EU market, which explains the fall of Union industry prices (below cost of production). Indeed, as a commodity, competition in the benzyl alcohol market is extremely price-sensitive and customers are likely to switch to alternative suppliers in response to minor price changes.

• (288) Undercutting is significant considering the price sensitive nature of an interchangeable homogenous commodity such as benzyl alcohol. This resulted in a strong price suppression on the Union market.

• (289) The reduction in sales opportunities undermined Union producers’ ability to operate efficiently. Union producers’ utilization of their capacities became far from optimal. The underutilization of production capacity in 2023, 2024 and the investigation period intensified the financial losses of the Union industry. With important production costs spread over a smaller output, unit costs increased significantly, worsening the injury caused by dumped imports.

5.2.   Effects of other factors

5.2.1.   Imports from third countries

• (290) The quantity of imports from other third countries developed over the period considered as follows:

Table 12

Imports from third countries

Country		2022	2023	2024	IP
India	Quantity (tonnes)	3 049	1 498	230	646
	Index	100	49	8	21
	Market share (%)	[8 – 11 ]	[3 – 7 ]	[0 – 4 ]	[0 – 4 ]
	Average price (EUR/tonne)	2 367	1 887	2 848	1 599
	Index	100	80	120	68
Other third countries	Quantity (tonnes)	804	556	674	624
	Index	100	69	84	78
	Market share (%)	[1 – 4 ]	[0 – 3 ]	[1 – 4 ]	[0 – 3 ]
	Average price (EUR/tonne)	6 072	6 902	6 635	6 477
	Index	100	114	109	107
Total of all third countries except the country concerned	Quantity (tonnes)	3 853	2 054	904	1 270
	Index	100	53	23	33
	Market share (%)	[9 – 13 ]	[6 – 10 ]	[2 – 5 ]	[3 – 5 ]
	Average price (EUR/tonne)	3 141	3 245	5 671	3 994
	Index	100	103	181	127
Source: Eurostat.	Source: Eurostat.	Source: Eurostat.	Source: Eurostat.	Source: Eurostat.	Source: Eurostat.

• (291) China has consistently accounted for the vast majority of imports into the Union. In the investigation period, its share of imports had grown to 91 % of all imports. Other third country imports were limited in volume and originated mainly in India, the UK and the US. In this respect, the investigation found that imports from certain origins were resales to the extent such imports originated in countries with no benzyl alcohol commercial production (e.g. from the UK or Norway).

• (292) All other third country imports (excluding China) represented a market share of 12,3 % in 2022 and barely 4 % in the investigation period.

• (293) Overall, imports from all other third countries were more expensive than imports from the country concerned. India, the main third country importer into the Union after China, had higher import prices into the Union compared to China during the period considered (with the exception of 2022). Although Indian import prices were below the Union industry’s cost of production in the investigation period, their volume and market share was low.

• (294) The Commission therefore concluded that, overall, other third country imports did not contribute to the material injury suffered by the Union industry.

5.2.2.   Export performance of the Union industry

• (295) The volume of exports of the Union producers developed over the period considered as follows:

Table 13

Export performance of the sampled Union producers

	2022	2023	2024	IP
Export volume to related and unrelated customers (tonnes)	[6 000 – 17 000 ]	[5 000 – 12 000 ]	[5 000 –16 000 ]	[4 000 – 14 000 ]
Index	100	68	93	79
Average price for sales to unrelated customers (EUR/tonne)	[2 600 – 2 900 ]	[2 300 – 2 500 ]	[1 900 – 2 100 ]	[1 900 - 2 100 ]
Index	100	85	73	70
Source: Macro-questionnaire questionnaire reply and questionnaire replies of sampled Union producers (EUR/tonne).	Source: Macro-questionnaire questionnaire reply and questionnaire replies of sampled Union producers (EUR/tonne).	Source: Macro-questionnaire questionnaire reply and questionnaire replies of sampled Union producers (EUR/tonne).	Source: Macro-questionnaire questionnaire reply and questionnaire replies of sampled Union producers (EUR/tonne).	Source: Macro-questionnaire questionnaire reply and questionnaire replies of sampled Union producers (EUR/tonne).

• (296) Union producers and many of their customers are active globally, thus exports represent a significant share of the Union industry’s production during the period considered.

• (297) Over the period considered, the average export sales price shrank. Prices of the Union industry’s exports fluctuated in light of supply-demand and market conditions prevailing in the destination and product mix, while facing fierce competition by Chinese products.

• (298) In light of the above, the Commission concluded that the export performance of Union producers contributed to the injury suffered by the Union industry but did not attenuate the causal link between Chinese dumped imports and the resulting material injury suffered by Union producers in the Union market recognised in section 5.1.

5.2.3.   Fluctuation of prices of material factors of production

• (299) The cost of production of benzyl alcohol is primarily driven by the price of the main raw material, toluene. Energy costs, while representing a smaller share than toluene, still constitute a significant share of the overall cost of production. Following the start of Russia’s war of aggression against Ukraine, prices of energy increased considerably resulting in an increase of cost of production in the first part of the period considered.

• (300) The evolution of gas/energy prices and inputs in the period considered could not explain the massively shrinking profits in this case, as in 2022, when gas/energy prices and inputs peaked, the Union industry was profitable. The Union industry became loss-making at a time when gas/energy prices normalised and cost saving initiatives were implemented.

• (301) The Commission therefore concluded that the fluctuation of prices of main raw materials and energy prices did not attenuate the causal link between dumped imports and the material injury suffered by Union producers in the Union market. In a level playing field, Union producers should have been able to increase their sales prices to a sustainable/profitable level, which was not the case.

5.3.   Conclusion on causation

• (302) On the basis of the above, the Commission concluded at this stage that imports from the country concerned caused material injury to the Union industry. Whilst the export performance of Union producers might have contributed to it, this factor does not attenuate the causal link between the dumped imports and the injury. Other factors, considered individually or collectively, did not attenuate the causal link between the dumped imports and the material injury.

6. LEVEL OF MEASURES

• (303) To determine the level of the measures, the Commission examined whether a duty lower than the margin of dumping would be sufficient to remove the injury caused by dumped imports to the Union industry.

6.1.   Injury margin

• (304) The injury would be removed if the Union Industry were able to obtain a target profit by selling at a target price in the sense of Articles 7(2c) and 7(2d) of the basic regulation.

• (305) In accordance with Article 7(2c) of the basic Regulation, for establishing the target profit, the Commission took into account the following factors: the level of profitability before the increase of imports from the country under investigation, the level of profitability needed to cover full costs and investments, research and development (R&D) and innovation, and the level of profitability to be expected under normal conditions of competition. Such profit margin should not be lower than 6 %.

• (306) As a first step, the Commission established a basic profit covering full costs under normal conditions of competition on the basis of the profitability achieved by the Union producer for which data was available. The profit margin was established at 15,8 %. This was the level of profitability that the Union producer obtained in 2018, the most recent year in which the Union industry’s profitability was not affected by low-priced imports from the country under investigation.

• (307) One Union producer provided evidence that its level of investments, research and development (R&D) and innovation during the period considered would have been higher under normal conditions of competition. The Commission verified the reasons why an upstream investment had started and then abandoned. The claims were found to be warranted. To reflect this in the target profit, the Commission calculated the difference between investments, R&D and innovation ('IRI') expenses under normal conditions of competition as provided by the EU Industry and verified by the Commission with actual IRI expenses over the period considered. Such difference, expressed as a percentage of turnover, was less than 1 %.

• (308) For the relevant party, such percentage was added to the basic profit of 15,8 % mentioned in the recital 306, leading to a target profit of [15,9 – 16,5] %.

• (309) On this basis, the non-injurious price per tonne is [€2 350 - €2 950], resulting from applying the above-mentioned profit margin of [15,9 – 16,5] % to the cost of production of the sampled Union producer during the investigation period.

• (310) In accordance with article 7(2d) of the basic Regulation, as a final step, the Commission assessed the future costs resulting from Multilateral Environmental Agreements, and protocols thereunder, to which the Union is a party, and of ILO Conventions listed in Annex Ia that the Union industry will incur during the period of the application of the measure pursuant to Article 11(2). Based on the evidence provided along with the questionnaire reply, for one company the Commission established an additional cost of [€25 - €80] per tonne for indirect CO2 costs. This difference was added to the non-injurious price mentioned in recital 309.

• (311) On this basis, the Commission calculated a non-injurious price of [€2 375 - €2 995] per tonne for the like product of the Union industry by applying the basic profit of 15,8 % to one sampled Union producer and the above-mentioned target profit margin (see recital 308) to the cost of production of the second sampled Union producer during the investigation period. The adjustments under Article 7(2d) referred to in the previous recital concern the second sampled Union producer only.

• (312) The Commission then determined the injury margin level on the basis of a comparison of the weighted average import price of the sampled cooperating exporting producers in the country concerned, as established for the price undercutting calculations, with the weighted average non-injurious price of the like product sold by the sampled Union producers on the Union market during the investigation period. Any difference resulting from this comparison was expressed as a percentage of the weighted average import CIF value.

• (313) The injury elimination level for ‘other cooperating companies’ and for ‘all other imports originating in country concerned’ is defined in the same manner as the dumping margin for these companies and imports (see recitals 222 to 227).

Company	Dumping margin (%)	Underselling margin (%)
Hubei Greenhome Materials Technology, Inc.	71,2	93,4
Qianjiang Xinyihong Organic Chemical Co., Ltd.	52,6	97,9
Chongqing Zoteq Aroma Chemical Co.,Ltd	66,8	94,5
Hubei Kelin Bolun New Materials Co., Ltd,	66,8	94,5
Tianjin Dacals Chemical Co., Ltd.	66,8	94,5
All other imports originating in the PRC	71,2	97,9

• (314) In the present case, the complainant claimed the existence of raw material distortions within the meaning of Article 7(2a) of the basic Regulation. Thus, in order to conduct the assessment on the appropriate level of measures, the Commission first established the amount of duty necessary to eliminate the injury suffered by the Union industry in the absence of distortions under Article 7(2a) of the basic Regulation. Then it examined whether the dumping margin of sampled exporting producers would be higher than their injury margin.

6.2.   Examination of the margin adequate to remove the injury to the Union industry

• (315) As explained in the Notice of Initiation, the complainant provided the Commission sufficient evidence that there are raw material distortions in the country concerned regarding the product under investigation. Therefore, in accordance with Article 7(2a) of the basic Regulation, this investigation examined the alleged distortions to assess whether, if relevant, a duty lower than the margin of dumping would be sufficient to remove injury.

• (316) However, as the margins adequate to remove injury are higher than the dumping margins, the Commission considered that, at this stage, it was not necessary to address this aspect.

• (317) Following the above assessment the Commission concluded that it is appropriate to determine the amount of provisional duties in accordance with Article 7(2) of the basic Regulation.

7. UNION INTEREST

• (318) Having decided to apply Article 7(2) of the basic Regulation, the Commission examined whether it could clearly conclude that it was not in the Union interest to adopt measures in this case, despite the determination of injurious dumping, in accordance with Article 21 of the basic Regulation. The determination of the Union interest was based on an appreciation of all the various interests involved, including those of the Union industry, importers, users and suppliers.

7.1.   Interest of the Union industry

• (319) There are three companies under two groups producing benzyl alcohol in the Union directly employing [100-120] people. The plants are located in Germany and the Netherlands. All Union producers co-operated with the investigation and support the imposition of measures.

• (320) Bearing in mind the finding of material injury to the Union industry described in section 4.6 of this regulation, imposing measures would allow the Union industry improving its profitability towards sustainable levels, increasing investment, and thus regaining a competitive position in the Union market. The Union industry would also be able to regain lost market share by increasing production and sales volumes in the Union market. The injurious situation of Union producers threatens their ability to continue producing benzyl alcohol in the Union for both captive (limited volumes) and free market use.

• (321) The absence of measures is likely to have further negative and significant effects on the Union industry. The reliance on the product varies depending on the site, but, given the level of integration and interlinks amongst production steps, problems in one leg of production could hinder the viability of a whole plant. The existence of one of the sampled Union producers is already seriously threatened ¹²⁴, and the continued production of benzyl alcohol in the Union is at stake if measures are not imposed and the decline of the industry’s viability is not stopped. This would represent an irreversible loss of industrial capacity, knowledge and qualified jobs.

• (322) The imposition of measures on benzyl alcohol from the country concerned is therefore clearly in the interest of the Union industry.

7.2.   Interest of unrelated importers

• (323) The product concerned is imported to the Union mainly by users but also by some distributors. Few distributors came forward although none submitted questionnaire replies. Gadot Belgium B.V., offering chemical value chain management solutions, welcomed the investigation.

• (324) An unrelated importer, Fenchem Biochemie GmbH, submitted an incomplete questionnaire response and stopped cooperation thereafter. The deficiencies in the response did not allow to conclude on the effects (if any) of the measures on its business.

• (325) The investigation did not identify any negative consequences on unrelated importers in the Union that could outweigh the positive impact of the imposition of measures on the Union industry. The Commission concluded that importers in the Union should continue to be able to import benzyl alcohol from China as the objective of the investigation was not to block imports from China but to raise their prices to non-dumped levels.

7.3.   Interest of users

• (326) One user submitted a questionnaire reply and opposed to measures. The party noted that its Austrian affiliate uses benzyl alcohol as an essential raw material in the production of various resins. The party anticipated a significant increase in the cost of benzyl alcohol because of anti-dumping measures and of Union suppliers of benzyl alcohol subsequently adjusting their prices upwards as competitive pressure from imports decreases. This would result in a shift to imported resins produced with lower-priced benzyl alcohol outside the Union. Resin producers in the Union would thus suffer from a dual impact: higher input costs and increased competition from more cost-advantaged imports, i.e. from a transfer of the competitive imbalance one step further down the value chain. The party alleged that any further increase in raw material costs would erode its competitiveness and threaten the profitability—and in some cases the viability—of its downstream products.

• (327) The questionnaire reply of this small user, accounting for less than 1 % of imports from China, does not suggest that an increase in benzyl alcohol purchase price would have a material impact on its operations. For a portion of its products, benzyl alcohol costs represent a variable share of the costs of final products (i.e. between 1 % and 20 %, depending on the products). (Potential) cost implications for specific products of the co-operating user were not found to justify refraining from duties that will protect Union benzyl alcohol manufacturers, demonstrably suffering from unfair competition. The Commission further noted that anti-dumping measures are not intended to confer an advantage to EU producers. Anti-dumping measures aim at halting certain illegal unfair trading practices that distorted market conditions and caused injury to the Union industry.

• (328) As a whole, the investigation did not identify negative consequences on users in the Union that could outweigh the positive impact of the imposition of measures on the Union industry. On the contrary, measures would ensure local supply and avoid reliance on Chinese imports. Such a reliance could have devastating effects in case, for instance, of changes in strategic measures or logistics problems affecting Chinese imports.

7.4.   Interest of suppliers

• (329) No (associations representing the interests of) suppliers submitted questionnaire replies.

• (330) Nonetheless, the Commission considered that measures would be beneficial for suppliers in the Union as local demand for raw materials such as toluene and chlorine will be secured. The continuation of the benzyl alcohol plants in the Union will support local companies providing services (to Union producers) such as maintenance, spare parts and machinery.

7.5.   Conclusion on Union interest

• (331) 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 benzyl alcohol originating in the country concerned at this stage of the investigation.

8. PROVISIONAL ANTI-DUMPING MEASURES

• (332) 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.

• (333) Provisional anti-dumping measures should be imposed on imports of benzyl alcohol originating in the PRC, in accordance Article 7(2) of the basic Regulation.

• (334) 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:

Company	Provisional anti-dumping duty (%)
Hubei Greenhome Materials Technology, Inc.	71,2
Qianjiang Xinyihong Organic Chemical Co., Ltd.	52,6
Chongqing Zoteq Aroma Chemical Co.,Ltd	66,8
Hubei Kelin Bolun New Materials Co., Ltd,	66,8
Tianjin Dacals Chemical Co., Ltd.	66,8
All other imports originating in the PRC	71,2

• (335) 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 those specifically mentioned, should be subject to the duty rate applicable to ‘all other imports originating in the People’s Republic of China’. They should not be subject to any of the individual anti-dumping duty rates.

• (336) 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 the People’s Republic of China’.

• (337) 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.

• (338) 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, 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

• (339) 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.

• (340) In view of the findings at provisional stage, the registration of imports should be discontinued.

• (341) No decision on a possible retroactive application of anti-dumping measures has been taken at this stage of the proceeding.

10. INFORMATION AT PROVISIONAL STAGE

• (342) 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 the website of DG Trade and Economic Security. Interested parties were given three working days to provide comments on the accuracy of the calculations specifically disclosed to them.

• (343) Qianjiang Xinyihong submitted that the calculation of the benchmark for the by-products was erroneously increasing the cost of production, thus resulting in higher normal value. The Commission accepted the claim and revised the calculations accordingly.

• (344) Hubei Greenhome noted one clerical error related to the handling and auxiliary costs, as reported in the underlying transactions listing of the export sales. The Commission accepted the claim and revised the calculations accordingly.

• (345) In order to ensure effective monitoring of imports of the direct upstream product of benzyl alcohol i.e. benzyl chloride currently falling, among with other products, under CN code 2903 99 80 , the Commission considers appropriate to introduce a specific TARIC code for monitoring purposes. This measure will allow the Commission to gather accurate and detailed statistics on trade flows, assess market trends, and detect any potential circumvention of trade defence measures. The introduction of this TARIC code is for monitoring purposes only and does not impose any additional duties or restrictions on imports at this stage.

• (346) The specific TARIC code should be structured in a way that distinguishes benzyl chloride from other products under the same CN heading, ensuring precise data collection. The Commission should regularly review the data collected under this code to determine whether further action, such as the initiation of an anti-dumping or an anti-subsidy investigation, is warranted.

11. FINAL PROVISIONS

• (347) 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.

• (348) 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

Company	Provisional anti-dumping duty (%)	TARIC additional code
Hubei Greenhome Materials Technology, Inc.	71,2	88FF
Qianjiang Xinyihong Organic Chemical Co., Ltd.	52,6	88FG
Chongqing Zoteq Aroma Chemical Co.,Ltd	66,8	88FH
Hubei Kelin Bolun New Materials Co., Ltd,	66,8	88FI
Tianjin Dacals Chemical Co., Ltd.	66,8	88FJ
All other imports originating in the People’s Republic of China	71,2	8999

Article 2

2903	- Halogenated derivatives of aromatic hydrocarbons :
2903 99	- - Other:
2903 99 80 81	- - - Benzyl Chloride

Article 3

Article 4

Article 5

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, 27 July 2026.

For the Commission

The President

Ursula VON DER LEYEN

https://www.mof.gov.cn/zhengwuxinxi/caizhengxinwen/202503/t20250329_3961036.htm (accessed on 20 May 2026).

(accessed on 20 May 2026). The Plan instructs to ‘further implement the spirit embodied in General Secretary Xi Jinping’s keynote speech on advancing the reform of corporate governance of the financial sector’. Moreover, the Plan’s section II aims at promoting the organic integration of the Party’s leadership into corporate governance: ‘we shall make the integration of the Party’s leadership into corporate governance more systematic, standardised and procedure-based […] Major operational and management issues must have been discussed by the Party Committee before being decided upon by the Board of Directors or the senior management’.

https://doi.org/10.1787/eco_surveys-chn-2019-en (accessed on 20 May 2026).

(accessed on 20 May 2026).

[^ntc106-L_202601857EN.000101-E0106]  The Commission identified some discrepancies between the Second Note and its annexes. The correct values were provided originally in the annexes of Second Note and in the above table 1.

[^ntc107-L_202601857EN.000101-E0107] https://connect.spglobal.com/

[^ntc108-L_202601857EN.000101-E0108]  In Second Note, liquid chlorine was erroneously mentioned both in consumables and in annex I with the factors of production. Liquid Chlorine is treated as consumable.

[^ntc109-L_202601857EN.000101-E0109] http://www.turkstat.gov.tr => Press releases => select Producer Price Index.

[^ntc110-L_202601857EN.000101-E0110] epdk.gov.tr => Press releases => select Electricity Market board decisions.

[^ntc111-L_202601857EN.000101-E0111]  There was a clerical error in the calculation of the benchmark of steam in the Second Note. The benchmark of steam was established at 501,61CNY/tonne.

ELI: http://data.europa.eu/eli/reg_impl/2026/1857/oj

ISSN 1977-0677 (electronic edition)