Commission Implementing Regulation (EU) 2026/831 of 14 April 2026 imposing a definitive anti-dumping duty on imports of certain continuous filament glass fibre products (GFR) originating in Bahrain, Egypt and Thailand

THE EUROPEAN COMMISSION,

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

Having regard to Regulation (EU) 2016/1036 of the European Parliament and of the Council of 8 June 2016 on protection against dumped imports from countries not members of the European Union⁽¹⁾ (‘the basic Regulation’), and in particular Article 9(4) thereof,

After consulting the Member States,

Whereas:

1. PROCEDURE

1.1. Initiation

(1) On 17 February 2025, the European Commission (‘the Commission’) initiated an anti-dumping investigation with regard to imports of continuous filament glass fibre products (‘GFR’) originating in Bahrain, Egypt and Thailand (‘the countries concerned’) on the basis of Article 5 the basic Regulation. It published a Notice of Initiation in the Official Journal of the European Union⁽²⁾ (‘the Notice of Initiation’).

(2) The Commission initiated the investigation following a complaint lodged on 3 January 2025 by Glass Fibre Europe (‘GFE’) (‘the complainants’). The complaint was made on behalf of the Union industry of GFR in the sense of Article 5(4) of the basic Regulation. The complaint contained evidence of dumping and of resulting material injury that was sufficient to justify the initiation of the investigation.

1.2. Registration

(3) The Commission made imports of the product concerned subject to registration by Commission Implementing Regulation (EU) 2025/890⁽³⁾ (‘the registration Regulation’).

1.3. Interested parties

(4) In the Notice of Initiation, the Commission invited interested parties to contact it in order to participate in the investigation. In addition, the Commission specifically informed other known Union producers, the known exporting producers as well as the authorities of the countries concerned, known importers, users as well as associations known to be concerned about the initiation of the investigation and invited them to participate.

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

1.4. Comments on initiation

(6) The Government of Egypt (GOE) argued that the initiation of the investigation did not comply with the requirements of Articles 5.3 and 5.4 of the WTO Anti-Dumping Agreement (‘ADA’). In particular, Egypt submitted that the complaint lacked sufficient, accurate and adequate evidence to justify the initiation of an investigation, as required under Article 5.3 ADA. Egypt further contended that the complaint failed to transparently identify the domestic producers supporting it and did not provide adequate non-confidential summaries of key information, thereby preventing interested parties from effectively exercising their rights of defence and from verifying whether the standing requirement under Article 5.4 ADA was met. Moreover, Egypt objected to what it considered an excessive use of confidentiality claims, arguing that this undermined transparency and meaningful participation in the investigation at the initiation stage. Finally, Egypt raised concerns regarding the risk of double remedies, noting that Egyptian exports are already subject to countervailing duties and that the initiation of a parallel anti-dumping proceeding could result in overlapping measures contrary to WTO rules.

(7) In the framework of the analysis of a complaint and in accordance with Article 5.4 of the ADA, the Commission services have carried out a standing examination before initiation. For this purpose, all Union producers mentioned in the complaint and otherwise known to the Commission before initiation have been contacted and taken into consideration in the calculation of representativeness of the complainants. This calculation was based on the quantities of the product concerned produced as outlined by individual declarations by such producers and associations of producers and on information contained in the complaint which also includes information on the total Union production. Therefore, at initiation stage, it was concluded that the conditions of Article 5.4 of the ADA were met. Therefore, the claim by the Government of Egypt was rejected.

(8) The Commission considered that the version open for inspection by interested parties of the complaint contained all the essential evidence and meaningful non-confidential summaries of data provided under confidential cover in order for interested parties to exercise their right of defence throughout the proceeding. In any event, the complainant has provided meaningful summaries of the contents of the confidential segments of the complaint. The information provided in the limited annexes to the complaint falls under these categories. The complainant has also provided a meaningful summary of the information contained in the limited annexes of the complaint so that interested parties may have a ‘reasonable understanding of the substance of the information submitted in confidence’ as set forth by Article 19(2) of the basic Regulation. Therefore, the claim by the Government of Egypt was rejected.

(9) In order to avoid double remedies, in cases of application of concomitant anti-dumping and countervailing measures, the Commission deducts from the actual anti-dumping duty the amount of subsidisation already offset by the countervailing measures (export subsidies). Thus, there is no double counting issue. Therefore, the claim was rejected.

(10) The Government of Egypt contested the allegations that GFR imports from Egypt have injured the Union industry, arguing that the conclusions were outdated and selective. They refuted claims of geographic relocation of production solely for duty circumvention. Egypt also asserted that the complaint lacked a comprehensive analysis of other factors affecting the Union market, like production costs and raw material price fluctuations. Data indicated that Egyptian export prices had followed market trends, contradicting claims of aggressive pricing. Import volumes have decreased between 2021 and 2023, challenging the assertion of significant market impact. The GOE argued that minor price changes in the Union did not display significant price depression, reflecting normal market conditions rather than injury from imports. They argued that these factors demonstrated that the complaint lacked objective evidence as required by the WTO Anti-Dumping Agreement.

(11) Contrary to the GOE’s claims, the Commission found that the complaint provided sufficient evidence demonstrating how imports of glass fibre products from Egypt have materially injured the Union industry. Moreover, the complaint’s comprehensive market analysis reinforced the link between Egyptian imports and injury to the Union industry as required by WTO regulations. Furthermore, the complaint provided sufficient evidence demonstrating that Egyptian imports caused significant price undercutting and significant price suppression and depression to the Union industry. The cited declines in import volumes by Egypt deemed to be temporary, as the complaint outlines broader demand contexts that do not diminish the impact of Egyptian imports. Therefore, the claim was rejected.

(12) The Government of Egypt contested the injury analysis in the complaint, stating that it failed to meet the requirements of Article 3.4 and Article 3.5 of the WTO Anti-Dumping Agreement by omitting several economic factors. It argued that the complaint lacked analysis on productivity, wages, return on investment, cash flow, ability to raise capital, inventory, and overall industry growth, all of which were necessary for a complete injury determination. Furthermore, the Government of Egypt pointed out that the analysis of the economic indicators such as production, capacity utilisation, profitability, and employment was misleading and incomplete. It emphasised that factors such as the global downturn and increased competition from other countries affected the Union industry, not just imports from Egypt. Additionally, it claimed that the decline in Union’s market share was minimal and not indicative of significant injury, as it reflected broader market dynamics, including reduced imports from other third countries that Egyptian imports filled, which aligns with Article 3.5 requirements to differentiate injury causes.

(13) The Commission disagreed with the GOE’s claims. The complaint provided sufficient evidence demonstrating the negative impact of Egyptian imports on the Union industry. It included a comprehensive analysis of economic indicators such as production levels, capacity utilisation, and profitability, clearly showing how these have been negatively affected by the influx of low-priced Egyptian imports. Contrary to Egypt’s assertions, the complaint contained sufficient evidence that these declines were not solely due to external economic conditions but were directly linked to aggressive pricing strategies of the imports. The complaint’s detailed evidence aligned with WTO requirements, substantiating the causal link between Egyptian imports and the material injury suffered by the Union industry, justifying the need for anti-dumping measures. Therefore, the claim by the Government of Egypt was rejected.

(14) HELM AG, a Union importer, on behalf of four other Union users (‘HELM’) argued that the Union industry was not suffering material injury from imported GFR from Bahrain, Egypt, and Thailand. It asserted that the industry’s performance in 2024 reflected stabilisation after the exceptional performance during 2021-2022 and was not indicative of material injury. The market share loss from 2023 to the first half of 2024 was only 1 %. Additionally, key indicators such as export sales, which increased by 29 % between 2021 and mid-2024, and substantial investments made by the Union industry during 2021-2023, suggested competitiveness and financial health. Despite a minor reduction in production capacity in 2023, due to facility closures, capacity utilisation remained stable, and stock levels decreased significantly. HELM emphasised that these factors illustrated a return to normal operating conditions rather than material injury.

(15) The Commission noted that HELM was factually correct in pointing out that not all injury indicators showed deterioration during the period considered. Indeed, certain indicators such as exports, which increased by 33 % between 2021 and the IP, and investments, which were substantial in 2021–2023, developed positively. However, these improvements do not outweigh the negative trends observed in the core indicators relevant for the injury assessment. In particular, sales volumes on the Union free market fell by 15 %, market share declined from 47 % in 2021 to 40 % in the IP, production dropped by 14 %, and profitability remained negative in three out of the four years of the period considered. The Commission recalls that under Article 5(2) of the basic Regulation, it is not necessary for all injury indicators to deteriorate for a finding of material injury to be established, as long as the evidence as a whole demonstrates injury. Furthermore, the deterioration of the Union industry’s situation coincided with the increased volumes and falling prices of dumped imports from Bahrain, Egypt and Thailand. These imports exerted strong price pressure, leading to undercutting and significant price suppression, thereby establishing a causal link between the dumped imports and the injury suffered by the Union industry. Therefore, HELM’s claim was rejected.

(16) CPIC Abahsain Fiberglass W.L.L. (‘CPIC Bahrain’) argued against using target profitability figures from 2016 as they are not representative of the typical profitability levels but to establish target profitability based on the actual economic conditions that prevailed during the period considered. Furthermore, CPIC Bahrain advocated for the analysis to rely on actual export prices rather than constructed prices for the purposes of undercutting or underselling calculations to accurately assess the impact of dumped imports on domestic market prices, ensuring a fair investigation process.

(17) The Commission noted that using target profitability figures from 2016 provides a reference point for understanding achievable profitability levels under fair competitive conditions as economic conditions in later years have been affected by the presence of dumped imports. While CPIC Bahrain suggested relying on actual export prices for analysis, doing so might not fully account for the distortions caused by these low-priced imports in the Union. Therefore, constructed prices could serve as a useful tool for assessing fair value, particularly when actual market prices may be influenced by external factors. Therefore, the claim by the CPIC was rejected.

(18) CPIC Bahrain countered the allegations in the complaint that the CPIC group uses its Bahrain plant to circumvent trade restrictions imposed on GFR imports from China as being both legally irrelevant and factually incorrect. They stressed that their acquisition was part of a long-term global strategy, unrelated to any circumvention schemes, as initial discussions began in 2007, well before any anti-dumping measures imposed on GFR imports from China in 2011. CPIC Bahrain highlighted improvements in operational efficiency and market positioning as evidence of their commitment to genuine business growth rather than evading Union trade restrictions. Additionally, they refuted claims of benefiting from subsidies, noting their operations are financed through private means without government aid. They clarified that supposed benefits under the Belt and Road Initiative lacked evidentiary support, given that their acquisition occurred well before a relevant 2018 Memorandum of Understanding. Lastly, CPIC Bahrain argued that subsidy allegations are irrelevant to anti-dumping investigations, as such claims should be tackled through distinct anti-subsidy complaints and requested that any demands for adjustments in dumping and underselling calculations be dismissed due to lack of legal basis.

(19) The Commission acknowledged the comments regarding subsidisation and circumvention but considered that these claims did not fall within the scope of the present investigation.

(20) HELM, CPIC Bahrain and Technical Secretariat of Anti-Injurious Practices in International Trade of the Gulf Cooperation Council (‘GCC-TSAIP’) argued at initiation that the alleged injury to the Union industry is not primarily caused by imports of GFR from Bahrain, Egypt, and Thailand. HELM emphasised that external factors such as changes in demand, particularly during and after the COVID-19 pandemic, increased energy costs due to the Union’s reliance on Russian imports, and significant industry investments are the main contributors to any perceived injury. CPIC Bahrain highlighted Bahrain’s small market share of 2-3 % in the Union, suggesting it’s unlikely these imports significantly impact the Union industry. They argue that internal and external factors like rising energy and labour costs, inflation, decreased domestic demand, and competition from China and Egypt are more influential. Both parties assert that the Union industry’s own inefficiencies and strategic decisions, along with the market’s stabilising demand, play a more substantial role in the industry’s challenges than the presence of imports from the three countries.

(21) The Commission considered that the argument put forward by HELM, CPIC Bahrain and GCC-TSAIP’s that other factors are responsible for the Union industry’s difficulties, is not capable of weakening the causal link between dumped imports and injury. The evidence provided in the complaint highlights above de minimis dumping margins from Bahrain and that that these imports are part of the cumulation contributing to the Union injury, thereby maintaining a genuine and substantial causal link between dumped imports and the injury sustained by the Union industry. All other known factors potentially affecting the situation of the Union industry are examined in detail in Section 5.2 of this Regulation. Therefore, the claims by the HELM AG, CPIC Bahrain and GCC-TSAIP were rejected.

(22) HELM claimed at initiation that the assessment of the impact of imports from other third countries is selective and flawed, failing to accurately represent the role of other significant suppliers like India. Despite being one of the largest suppliers of GFR to the Union, India’s contributions were omitted from the analysis, distorting its findings. Similarly, according to HELM the complainant inadequately considers the impact of imports from Türkiye, attributing their effects incorrectly to the imports from Bahrain, Egypt and Thailand. Despite notable increases in imports from both India and Türkiye, the Complaint focuses solely on the market shares of the three countries, leading to an incomplete and misleading analysis.

(23) In response to claims that the Commission should consider imports from other third countries like China, India and Türkiye in its analysis, the Commission maintains that these imports do not attenuate the causal link between the alleged injury to the Union industry and imports from the countries concerned. While imports from China have indeed contributed to the injury, this does not diminish the impact that imports from Bahrain, Egypt and Thailand have on the Union industry. At the same time, the anti-dumping and countervailing measures in place against imports from China were reviewed, and increased measures entered into force on 25 November 2025⁽⁴⁾, to remove the injury caused by the dumped imports from China. Regarding Türkiye, while its imports increased over the period considered, they are also influenced by the influx of cheaper imports from Egypt and Bahrain, potentially distorting the Turkish market. Based on publicly available information⁽⁵⁾, on 19 July 2025, the Turkish Ministry of Trade imposed anti-dumping measures on GFR from Egypt and Bahrain. Finally, concerning HELM’s claims about significant GFR imports from India, the Commission notes that the figures provided by Helm are unsupported by evidence. According to Eurostat, India’s GFR import volumes to the Union in 2024 were significantly smaller than both those claimed by Helm and the volumes imported from the countries, underscoring that these imports do not diminish the impact of imports from Bahrain, Egypt, and Thailand on the Union industry. Therefore, the claim by the HELM was rejected.

(24) CPIC Bahrain argued at the initiation that imports of GFR from Bahrain should not be combined with imports from Egypt in assessing the impact of the imports from the countries concerned on the Union industry. It referred to Article 3(4) of the basic Regulation, which allows cumulative assessments only if appropriate, considering the competition conditions between imported and domestic products. CPIC Bahrain highlighted that during the complaint period, Bahrain’s import volumes and market share were significantly lower than Egypt’s while prices were consistently higher than Egypt’s. Due to these significant differences in market share and pricing trends, CPIC Bahrain requested the Commission to separately consider imports from Bahrain in its analysis, as cumulating them with Egyptian imports could misrepresent their true impact on the domestic industry.

(25) The Commission services found that the conditions for cumulation of Bahrain and Thailand at the stage of the complaint were met on the basis of the available information and statistics. The dumping margins were found to be above de minimis. As shown by available official import statistics, dumped imports were not negligible (above de minimis) in terms of volumes for all countries concerned. Furthermore, the conditions of competition were considered similar, as there was a general overlap in terms of geographical presence among the products from the countries concerned and the Union industry’s, prices from all countries were below Union industry price and full cost levels and there had been a significant market presence of imports from all countries concerned during the period examined. Therefore, the claim by the CPIC was rejected.

(26) The Association of Independent EU Glass Fibre Weavers, the Government of Egypt, CPIC Bahrain and HELM all opposed an anti-dumping investigation on GFR imports from Bahrain, Egypt, and Thailand with the aim to impose duties, arguing this would not benefit the Union. The Association highlighted the Union’s inability to produce certain GFR products, like low-tex rovings, necessitating reliance on imports and risking competition by giving more market power to vertically integrated companies. The Government of Egypt argued that such duties would harm key sectors like automotive and renewable energy, which required a stable GFR supply to meet climate goals, thus advocating that maintaining Egyptian imports serves public interest. CPIC Bahrain added that the duties would lead to price increases and reduced welfare, especially impacting renewable energy industries, and suggested focusing on imports from established sources like Egypt and China due to their reliable supply. Additionally, HELM contended that these measures would disrupt supply, escalate costs, and threaten the viability of downstream industries dependent on GFR, further harming the Union’s competitiveness and innovation. Altogether, they argued that imposing such duties could jeopardise the Union’s competitiveness and profitability, potentially driving companies out of the market and contradicting broader strategic economic goals.

(27) The Commission noted that claims on Union interest are irrelevant with regard to initiation, as there is no Union interest test at pre-initiation stage. However, the Commission examined, in the course of the investigation, whether the imposition of measures is in the Union interest.

(28) The Government of Egypt also argued that the dumping calculation set out in the complaint was inconsistent with the WTO Anti-Dumping Agreement. In particular, the Government of Egypt submitted that the use of CIF Eurostat data and Article 14(6) data does not reflect actual ex-works export prices and results in an artificially low export price. The Government of Egypt further claimed that the normal value was improperly constructed by including import duties that Jushi Egypt for Fiberglass Industry S.A.E. (‘Jushi Egypt’) would not have incurred under the Suez Canal Economic Zone regulations, contrary to Article 2.2.1.1 of the WTO Anti-Dumping Agreement. The Government of Egypt also argued that the complaint failed to ensure a fair comparison between normal value and export price, notably as regards differences in sales terms, market conditions and levels of trade, and that the use of average monthly exchange rates rather than transaction-date rates distorted the comparison. Finally, the Government of Egypt submitted that the complaint lacked sufficient supporting evidence to substantiate many of its claims regarding currency conversions and cost adjustments and requested the termination of the investigation.

(29) In this regard, the Commission emphasised that an application must contain sufficient evidence for the existence of dumping, injury and causal link. In particular, according to settled case-law, the quantity and quality of the evidence necessary to meet the criteria of the sufficiency of the evidence for the purpose of initiating an investigation is different from that which is necessary for the purpose of a preliminary or final determination of the existence of dumping and injury⁽⁶⁾.

(30) As regards the export price, the Commission noted that the use of reasonably available statistical sources is appropriate at the stage of initiation, where transaction-specific ex-works prices are not publicly accessible. The precise determination of export prices and any necessary adjustments relate to the substantive assessment of dumping, which is carried out on the basis of verified data obtained during the investigation and not at the stage of initiation. Concerning the construction of normal value, the Commission considered that the evidence submitted demonstrated the existence of dumping irrespective of the specific treatment of certain cost elements. Similarly, the Commission noted that the arguments submitted by the Government of Egypt regarding comparability, levels of trade and exchange rate methodology related to the substantive dumping analysis and required information that is not public information available to complainants at the time of lodging the complaint. These issues were examined in detail in the course of the investigation and are addressed in recitals (81) to (151).

(31) Against this background, the Commission considered that the application provided sufficient evidence of dumping for the purpose of initiating the investigation. Therefore, the claims regarding the existence of dumping by the Government of Egypt were dismissed.

(32) Additionally, GCC-TSAIP provided comments on the methodology underlying the complaint after the expiry of the deadline for comments on initiation. In any event, as set out in recital (29), the Commission recalled that the evidentiary threshold at initiation requires sufficient evidence of dumping, injury and causal link, not a definitive determination. The issues raised by GCC-TSAIP pertaining to the construction of normal value, the calculation of export prices and possible adjustments for comparability related to the substantive assessment of dumping for Bahrain, which were duly examined in the course of the investigation and are addressed in recitals (55) to (80).

1.5. Sampling

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

Sampling of Union producers

(34) In the Notice of Initiation, the Commission stated that it had provisionally selected a sample of Union producers. The Commission selected the sample on the basis of production and sales, which consisted of three Union producers. The sampled Union producers accounted for more than 63 % of the estimated total volume of production and more than 70 % of the estimated total sales of the like product in the Union. The Commission invited interested parties to comment on the provisional sample. As no comments were submitted by interested parties, the Commission considered the sample to be representative of the Union industry.

Sampling of unrelated importers

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

(36) One unrelated importer provided the requested information and agreed to be included in the sample. In view of the low number of replies, the Commission decided that sampling was not necessary. No comments were received.

Exporting producers

(37) In view of the limited number of exporting producers concerned, in the Note of Initiation the Commission invited all exporting producers from the countries concerned to come forward and provide full questionnaire replies.

1.6. Questionnaire replies and verification visits

(38) The Commission published online⁽⁷⁾ the questionnaires for the exporting producers, users, unrelated importers and the Union producers.

(39) The Commission received questionnaire replies from one exporting producer in Bahrain, one exporting producer in Egypt and two exporting producers in Thailand.

(40) The Commission sought and verified all the information deemed necessary for a definitive determination of dumping, resulting injury and Union interest. Remote cross-checking (‘RCC’) pursuant to Article 16 of the basic Regulation were carried out for the Union producers. In case of exporting producers, verification visits were carried out for all cooperating exporting producers. For the exporting producer in Bahrain, an RCC was also conducted because the originally planned verification visit had to be postponed due to the situation in the Middle East in June–July 2025:

• Union producers:

  • 3B Fibreglass Company Sprl, Battice, Belgium,

  • European Owens Corning Fiberglas SPRL, Watermael-Boitsfort, Belgium,

  • Johns Manville Slovakia, Trnava, Slovakia.

• Exporting producers:

  • Bahrain:

    • CPIC Abahsain Fiberglass W.L.L, Muharraq, Bahrain (RCC and verification visit);

  • Related trader in the Union:

    • CPIC Europe BV, Rotterdam, the Netherlands;

  • Egypt:

    • Jushi Egypt for Fiberglass Industry S.A.E., Ain Sokhna, Egypt;

  • Thailand:

    • Asia Composite Materials (Thailand) Co., Ltd., Rayong, Thailand,

    • Wanda New Material (Thailand) Co., Ltd., Chonburi, Thailand.

(41) Asia Composite Materials (‘ACM’), one of the Thai exporting producers, claimed that Wanda New Material (Thailand) Co., Ltd. (‘Wanda’), the other Thai exporting producer, was not a GFR genuine producer because it produces only mats from imported glass fibre rovings. According to ACM, the operations carried out by Wanda would not amount to more than 20 % of the overall value of GFR produced in Thailand by Wanda and, therefore, the products exported by Wanda to the Union might not have Thai origin.

(42) The Commission found ACM’s claim to be incorrect. Wanda’s operations involves significant manufacturing, changes the product’s form and use, and results in a change of tariff classification. Therefore, in accordance with non-preferential rules of origin, Wanda’s operations constitute a substantial transformation, and the mats produced acquire Thai origin. Therefore, the Commission concluded that Wanda should be considered a genuine producer of the product concerned and found ACM’s claim unfounded.

1.7. Investigation period and period considered

(43) The investigation of dumping and injury covered the period from 1 January 2024 to 31 December 2024 (‘the investigation period’). The examination of trends relevant for the assessment of injury covered the period from 1 January 2021 to the end of the investigation period (‘the period considered’).

1.8. Non-imposition of provisional measures

(44) Pursuant to Article 7(1) of the basic Regulation, the deadline for the imposition of provisional measures was 17 October 2025. On 25 September 2025, in accordance with Article 19a(2) of the basic Regulation, the Commission informed the interested parties of its intention not to impose provisional measures.

(45) The Commission continued to seek and verify all the information it deemed necessary for its final findings.

1.9. Subsequent procedure

(46) On 23 February 2026, the Commission informed all interested parties of the essential facts and considerations on the basis of which it intended to impose a definitive anti-dumping duty on imports of certain continuous filament glass fibre products originating in Bahrain, Egypt and Thailand (‘final disclosure’). Comments submitted by parties after the disclosure were addressed in the relevant sections below. The parties who so requested were granted an opportunity to be heard.

(47) On 12 March 2026, following the comments received after the final disclosure, the Commission made an additional final disclosure to all interested parties. This additional disclosure contained the revised findings and considerations. Parties were given the opportunity to comment on this additional disclosure, and the comments received were addressed in the relevant sections below. The parties who so requested were granted an opportunity to be heard.

(48) On 13 March 2026, following the comments received after the additional final disclosure, the Commission made a second additional final disclosure to all interested parties. This second additional disclosure contained the revised findings and considerations. Parties were given the opportunity to comment on this second additional disclosure. No new comments were received. The parties who so requested were granted an opportunity to be heard.

2. PRODUCT UNDER INVESTIGATION, PRODUCT CONCERNED AND LIKE PRODUCT

2.1. Product under investigation

(49) The product under investigation is chopped glass fibre strands, of a length of not more than 50 mm; glass fibre rovings, excluding glass fibre rovings which are impregnated and coated and have a loss on ignition of more than 3 % (as determined by the ISO Standard 1887); and mats made of glass fibre filaments excluding mats of glass wool, currently falling under CN codes 7019 11 00, ex70191200 (TARIC codes 7019120022, 7019120025, 7019120026, 7019120039), 7019 14 00 and 7019 15 00. The CN and TARIC codes are given for information only without prejudice to a subsequent change in the tariff classification.

(50) The product under investigation is a raw material most often used to reinforce thermoplastic and thermoset resins in the composites industry. The resulting composite materials (filament glass fibre reinforced materials) find its use in a large number of industries: transportation (automotive, marine, aerospace, military), electric/electronics, wind energy, building and construction, tanks/pipes, consumer goods, etc.

2.2. Product concerned

(51) The product concerned is the product under investigation originating in Bahrain, Egypt and Thailand (‘the product concerned’).

2.3. Like product

(52) The investigation showed that the following products have the same basic physical chemical and technical characteristics as well as the same basic uses:

• the product concerned when exported to the Union,

• the product under investigation produced and sold on the domestic market of countries concerned, and

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

(53) The Commission decided at this stage that those products are therefore like products within the meaning of Article 1(4) of the basic Regulation.

2.4. Claims regarding product scope

(54) No claims regarding product scope were received.

3. DUMPING

3.1. Bahrain

3.1.1. Normal value

(55) To establish the normal value, the Commission first examined whether the total volume of domestic sales for the cooperating exporting producer was representative, in accordance with Article 2(2) of the basic Regulation. The domestic sales are representative if the total domestic sales volume of the like product to independent customers on the domestic market per exporting producer represented at least 5 % of its total export sales volume of the product concerned to the Union during the investigation period.

(56) On this basis, the total sales by the exporting producer of the like product on the domestic market were found not to be representative.

(57) In instances where there were insufficient sales of a product type of the like product in the ordinary course of trade or where a product type was not sold in representative quantities on the domestic market, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation. In instances where there were no sales of a product type of the like product in the ordinary course of trade, the Commission examined whether alternative sources for prices in the ordinary course of trade could be used as a basis for normal value. As there were no other cooperating or available domestic producers of the like product in the country concerned, no such prices were available. Consequently, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation.

(58) The normal value was constructed by adding the following to the average cost of production of the like product of the cooperating exporting producer during the investigation period per product type of the like product:

1. the weighted average selling, general and administrative (‘SG & A’) expenses incurred by the cooperating exporting producer on domestic sales of the like product, in the ordinary course of trade, during the IP; and

2. the weighted average profit realised by the cooperating exporting producer on domestic sales of the like product, in the ordinary course of trade, during the IP.

(59) The cooperating exporting producer claimed an adjustment to the cost of production on the basis of revenue derived from the sale of production waste. The company submitted that such revenue was recorded as other income in its accounts and provided calculations intended to demonstrate the impact on the average cost of manufacturing.

(60) The Commission found that the income concerned was received after the investigation period and was not recorded in the exporting producer’s accounts as income relating to the investigation period. In the absence of evidence that such income related to, or was recorded for, production during the investigation period, the Commission concluded that no adjustment to the cost of production was warranted for the purpose of constructing the normal value. Thus, the Commission rejected the claim.

(61) Upon final disclosure, GCC-TSAIP claimed that revenue deriving from the sale of production waste should have been taken into account by the Commission when calculating CPIC Bahrain’s cost of production. GCC-TSAIP argued that the production waste is an inherent outcome of the manufacturing process and that the sale of such waste constitutes a form of cost recovery, which should have been reflected in the total production cost structure. GCC-TSAIP further stated that the timing of revenue recognition should not automatically exclude such revenue from the calculation, as commercial considerations may delay the sale or recording of waste revenue. According to GCC-TSAIP, excluding this revenue from the cost of production artificially inflated manufacturing costs and resulted in an overstated normal value.

(62) The Commission rejected GCC-TSAIP’s claim. While the Commission acknowledged that the production waste is an inherent outcome of the manufacturing process and that the sale of such waste represents a form of cost recovery, the adjustment for CPIC Bahrain’s cost of production requested by GCC-TSAIP cannot be accepted in the absence of evidence demonstrating that the revenue related to production during the investigation period. Revenue recorded after the investigation period, even if commercially linked to production, cannot be used to adjust the cost of production during the investigation period for the purposes of constructing normal value.

3.1.2. Export price

(63) The exporting producer exported to the Union either directly to independent customers or through a related company located in the Netherlands acting as an importer. The related importer resold the product concerned to unrelated customers in the Union. The related importer was also involved in the direct sales to the Union.

(64) In case the exporting producer exported the product concerned directly to independent customers in the Union, 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.

(65) In case the exporting producers exported the product concerned to the Union through a related company acting as an importer, the export price was established on the basis of the price at which the imported product was first resold to independent customers in the Union, in accordance with Article 2(9) of the basic Regulation. In this case, adjustments to the price were made for all costs incurred between importation and resale, including SG & A expenses, and for profits accruing.

(66) Upon final disclosure, CPIC Bahrain claimed that the Commission had deducted certain amounts twice when constructing the export price for indirect sales made via the related importer pursuant to Article 2(9) of the basic Regulation. First, CPIC Bahrain argued that the allowances reported already included the EU import duty and that the subsequent separate deduction of the 7 % customs duty therefore resulted in double counting. Second, CPIC Bahrain argued that commissions paid by the related importer were accounted for in the reported allowances but had not been deducted from the related importer’s SG & A expenses when calculating the export price, resulting in double counting.

(67) The Commission examined the claims and confirmed that the separate deduction of the import duty and the lack of a corresponding adjustment for commissions in the SG & A expenses of the related importer led to double counting. Accordingly, the Commission corrected the calculation by removing the separate deduction of the customs duty and by deducting the reported commission amounts from the SG & A of the related importer when constructing the export price, in accordance with Article 2(9) of the basic Regulation.

3.1.3. Comparison

(68) 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. 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 normal value and the export price 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.

3.1.3.1. Adjustments made to the normal value

(69) In order to net the normal value back to the ex-works level of trade, adjustments were made on the account of: inland transportation, handling, loading and ancillary expenses.

(70) An allowance was made for credit cost to ensure price comparability.

3.1.3.2. Adjustments made to the export price

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

(72) Allowances were made for the following factors affecting prices and price comparability: credit cost and bank charges.

(73) The Commission noted that all the exporting producer’s sales to the Union were handled through a related trader, which performed all core sales functions similar to those of an agent working on a commission basis. In view of the involvement of the related trader in the direct sales to the Union, the Commission adjusted the sales under Article 2(10)(i) for a commission. Due to the relation between the trader and the producer and, in the absence of cooperation of unrelated importers in the present case the commission was estimated on the basis of the notional 5 % profit margin found for an unrelated imported in the original glass fibre fabrics (‘GFF’) investigation⁽⁸⁾ for a downstream glass fibre product and the actual selling, general and administrative costs of the trader in question.

(74) Upon final disclosure, CPIC Bahrain claimed that certain SG & A expenses incurred by the related importer in relation to direct sales should be allocated away from indirect sales to avoid double counting with the 5 % commission adjustment under Article 2(10)(i). CPIC Bahrain also disputed the Commission’s characterisation of the related importer as a sales agent for the purposes of the commission adjustment.

(75) In the absence of any justification as to why the related importer should not be treated as an agent working on a commission basis, the Commission confirmed its findings in recital (73) and maintained the adjustment for a commission pursuant to Article 2(10)(i), as described in recital (73).

(76) The Commission then examined CPIC Bahrain’s claim that the adjustment under Article 2(10)(i) for CPIC Bahrain’s direct sales required a reduction of the level of SG & A expenses deduction under Article 2(9) for indirect sales. The Commission noted that the SG & A expenses deducted for indirect sales pursuant to Article 2(9) are based on the actual costs recorded in the books of the related importer. These costs reflect expenses incurred for all sales and no portion of these costs can be artificially removed from the SG & A deducted for indirect sales. The Commission found that any attempt to reallocate some of the SG & A for indirect sales would not change the overall SG & A costs recorded. The Commission thus rejected CPIC Bahrain’s claim.

3.1.4. Dumping margins

(77) For the cooperating exporting producer, the Commission compared the weighted average constructed 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.

(78) On this basis, the definitive weighted average dumping margin expressed as a percentage of the CIF Union frontier price, duty unpaid, is as follows:

(79) The level of cooperation in this case is high because the exports of the cooperating exporting producer constituted 100 % of the total imports into the Union during the IP. On this basis, the Commission decided to establish the residual dumping margin at the level of the cooperating exporting producer.

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

3.2. Egypt

3.2.1. Normal value

(81) In order to determine the normal value, the Commission analysed the information provided by Jushi Egypt. Following the review of the information in its questionnaire reply and collected during the verification visit, the Commission noted the company’s exposure to foreign exchange rate fluctuations and the magnitude of costs and sales denominated in foreign currencies, which affected the reasonableness of the cost and sales information reported. In particular, the Commission noted that the liberalisation of the Egyptian pound (EGP) on 6 March 2024, mandated by the Egyptian government, and the prior discrepancy between the official and parallel market exchange rates, had affected the recording of costs during the investigation period. By letter, on 17 December 2025, the Commission informed the company about its doubts that Jushi Egypt’s records in EGP reasonably reflected the actual costs associated with the production and sale of the product under consideration within the meaning of Article 2(5) of the basic Regulation and requested additional information.

(82) In its response, Jushi Egypt claimed that the liberalisation of the exchange rate did not affect the reliability of the recorded costs and disagreed that Article 2(5) of the basic Regulation constituted an appropriate basis for disregarding its costs as recorded in its accounts. Jushi Egypt submitted that the divergence between the official and parallel market exchange rates only became significant from November 2023 onwards and that, consequently, the impact on the costs recorded during the investigation period was limited. Jushi Egypt further indicated that, following the liberalisation of the exchange rate in March 2024, non-monetary items, including inventories and fixed assets, were recorded at historical official rates, whereas monetary items, such as cash, receivables, payables, and borrowings, were retranslated at the prevailing spot rate on the balance sheet date, with any resulting differences recognised in profit or loss. Accordingly, Jushi Egypt maintained that, in light of these practices, only a limited number of cost entries for loans, inventories, energy consumption, and fixed assets, corresponding to the period from March 2023 to March 2024, could be affected by official and parallel exchange rate discrepancies relevant to the investigation period.

(83) Jushi Egypt further indicated that any foreign exchange losses arising from the retranslation of monetary items at the spot exchange rate on the balance sheet date following the liberalisation were accounted for in accordance with its standard accounting practices and had no material impact on the actual production costs. Accordingly, Jushi Egypt submitted that the reported foreign exchange losses did not undermine the reliability of Jushi Egypt’s cost reporting or its comparability with sales prices during the investigation period.

(84) Nevertheless, and without prejudice to these claims, Jushi Egypt provided adjusted cost and sales data calculated on the basis of the parallel market exchange rate.

(85) The Commission assessed the company’s submission of adjusted cost and sales data and concluded that the adjustments proposed by Jushi Egypt were still insufficient and did not reasonably reflect the actual costs associated with the production and sale of the product under consideration within the meaning of Article 2(5) of the basic Regulation. In particular, the adjusted data did not adequately address the impact of historical exchange-rate distortions on raw materials, depreciation, and other cost elements. Accordingly, the Commission informed Jushi Egypt that it might apply Article 18 of the basic Regulation to establish the normal value, on the grounds that the information necessary to calculate the normal value within the meaning of Article 18 of the basic Regulation was not provided.

(86) In response, Jushi Egypt submitted that recourse to facts available for the calculation of the normal value was unfounded as Jushi Egypt had fully cooperated with the Commission throughout the investigation and the Commission had not specified which necessary information had not been provided by the company. Jushi Egypt also requested a hearing with the Hearing Officer to address the alleged infringement of its rights of defence and the Commission’s intended application of facts available under Article 18 of the basic Regulation.

(87) On 4 February 2026, as a reaction to the Article 18 of the basic Regulation letter dated 27 January 2026, Jushi Egypt requested a hearing with the Hearing Officer to obtain clarification from the Commission regarding (i) the exact provision of Article 18 of the basic Regulation at issue (noting it had fully cooperated in the investigation); and (ii) the piece of information not adequately supplied by Jushi Egypt (noting that, without such crucial information, Jushi Egypt was left in the dark as to how to defend its interest). On 10 February 2026, the Hearing Officer informed Jushi Egypt that, since the service was still considering the various elements on file in order to make a decision, including those relating to the application of Articles 2(5) and 18 of the basic Regulation, the Hearing Officer considered any intervention premature. Jushi Egypt would still have the opportunity to make comments after the disclosure, allowing the interested party to fully exercise its procedural rights in this case.

(88) Additionally, Jushi Egypt claimed that resorting to Article 2(5) of the basic Regulation was unlawful because the exception to the general rule requiring the use of the exporting producer’s accounts for the calculation of the normal value should be interpreted narrowly. Accordingly, Jushi Egypt submitted that its records constitute the primary source for the determination of the normal value, and that it was for the Commission to demonstrate that the costs associated with the production and sale of the product under investigation were not reasonably reflected therein. Additionally, Jushi Egypt claimed that the factual elements underlying the Commission’s concerns were insufficient to justify the application of Article 2(5) of the basic Regulation.

(89) Jushi Egypt also argued that the Commission treated it differently from exporters in prior cases with similar foreign currency transactions and local devaluations, highlighting investigations where the Commission accepted reported costs using official rates, despite currency fluctuations or undervaluation claims, and rejected parallel market rates⁽⁹⁾.

(90) Jushi Egypt further argued that any application of facts available could not result in a normal value higher than one that would have resulted from the use of parallel market exchange rates. In any event, Jushi Egypt submitted that domestic transactions incurred in EGP were, by their nature, unaffected by the devaluation of the EGP and should therefore not be disregarded. Finally, Jushi Egypt argued that, should the Commission decided to adjust its accounts to reflect the devaluation of the EGP, it would be required to deduct from such adjustment the amount already countervailed through the countervailing duty addressing currency depreciation, in order to avoid a double imposition of measures contrary to Article 14(1), second paragraph, of the basic Regulation.

(91) Having thoroughly examined the arguments and the information submitted by Jushi Egypt, the Commission concluded that Jushi Egypt’s records do not reasonably reflect the actual costs associated with the production of the product under investigation, in accordance with Article 2(5) of the basic Regulation.

(92) The Commission observed that, between 2011 and 2024, Egypt experienced significant political and economic instability, which constrained foreign currency availability. Repeated capital controls prompted the emergence and persistence of parallel foreign exchange markets. These exchange rate developments, including the major devaluations and the gradual move towards a fully liberalised currency in March 2024 narrowed, but not fully eliminated the gap between official and parallel rates. These developments materially affected the economic environment in which Jushi Egypt operated, including asset valuation, cost recording, and exposure to foreign exchange fluctuations⁽¹⁰⁾.

(93) The Commission noted that, during the investigation period, the Egyptian economy was therefore characterised by significant exchange-rate distortions, culminating in the further liberalisation of the EGP on 6 March 2024. Specifically, at the beginning of the investigation period, the official exchange rate stood at approximately 30 EGP per USD, while the parallel market rate diverged at times by more than 100 %.

(94) The Commission further noted that, over the period 2016–2024, exchange rate developments in Egypt, materially affected the valuation of Jushi Egypt’s assets and related cost components. In this context, major historical cost elements, including depreciation, inventories and prior investments, continued to reflect values recorded at official exchange rates that were significantly below economic reality during the investigation period.

(95) Given that a substantial share of Jushi Egypt’s transactions, including sales, purchases of raw materials and energy, loans, investments, and other cost items, were denominated in foreign currency, which distinguishes the situation of this company from that in the other investigations referred to by Jushi Egypt, the use of the official exchange rate led to a systematic undervaluation of costs reported in EGP. In particular, investments and inventories acquired in foreign currency prior to and during the investigation period were recorded at historically low official exchange rates, resulting in understated asset values and, consequently, understated depreciation and other historical cost components. Similarly, purchases of raw materials sourced in foreign currency during the early months of the investigation period were recorded at low official exchange rates that did not reflect prevailing market conditions.

(96) Contrary to Jushi Egypt’s claims in its replies of 5 January 2026 and 3 February 2026, these factors demonstrated that a significant share of production and cost components were materially affected by the divergence between official and parallel exchange rates long before March 2023. While Jushi Egypt noted that non-monetary items were recorded at historical official rates and monetary items retranslated at the spot rate, the official rates historically understated the economic value of assets and costs, and the treatment of foreign exchange losses under other comprehensive income did not mitigate the distortion in operational production costs. The Commission further noted that Jushi Egypt’s claim that monetary items were unaffected is contradicted by its own adjustments, as mentioned in recital (84), which applied parallel market rates to monetary items, including receivables. The Commission noted that the treatment of monetary items in Jushi Egypt’s adjustments further confirmed that the distinction between monetary and non-monetary items is without practical significance, as both types of items were materially affected. Accordingly, the impact on inventories, fixed assets, depreciation, raw material costs, and other historical cost components was substantial throughout the investigation period, not limited to the last months as Jushi Egypt suggested.

(97) Moreover, significant foreign-exchange losses arising from the revaluation of monetary assets and liabilities following the March 2024 liberalisation, although recognised under other comprehensive income in accordance with Egyptian Accounting Standards, were not reflected in the costs of production reported to the Commission, which also distinguishes the situation of this company from that in other Commission investigations referenced by Jushi Egypt. In light of the scale of foreign-currency exposure and the magnitude of the divergence between the official and the parallel exchange rates, the Commission concluded that Jushi Egypt records did not reasonably reflect the costs associated with the production and sale of the product under investigation during the investigation period, within the meaning of Article 2(5) of the basic Regulation.

(98) In light of the above, and in accordance with Article 2(5) of the basic Regulation, the Commission examined whether the revised cost data submitted by Jushi Egypt, based on estimates of the unofficial/parallel exchange rates, could serve as an appropriate basis for the construction of the normal value. The Commission found that, while the adjusted data addressed certain distortions in the records of the company and more appropriately reflected the economic reality of production during the investigation period, it did not fully eliminate all remaining inconsistencies.

(99) Given that the proposed methodology and adjusted data partially addressed the identified distortions, the Commission decided to accept the proposed overall methodology and adjustments. The Commission, therefore, did not entirely disregard the adjusted cost data submitted by Jushi Egypt but used it as a basis for its calculations of normal value, in accordance with Article 18(3) of the basic Regulation. Specifically, the Commission carried out additional targeted adjustments to specific cost items not sufficiently addressed by Jushi Egypt, including raw materials, depreciation, and attrition of precious metals. These adjustments were applied to ensure that the costs ultimately used reasonably reflected the costs associated with the production and sale of the product under investigation, as required by Article 2(5) of the basic Regulation. The Commission concluded that this methodology and additional adjustments allowed it to base the normal value calculation on the company’s data, rather than having recourse, at this stage, to information from other representative markets.

(100) Additionally, the Commission noted that Jushi Egypt’s argument that Article 2(5) of the basic Regulation should be interpreted narrowly and that its accounts constitute the primary source for normal value failed to reflect the factual and legal context. Article 2(5) of the basic Regulation allows the Commission to adjust costs when the records of an exporting producer do not reasonably reflect the costs associated with the production and sale of the product under investigation. In the present case, the misalignment between official rates and economic reality, coupled with significant foreign-currency exposure, clearly triggers the need for such targeted adjustments. In any event, the Commission considered that the normal value calculation grounded in Jushi Egypt’s adjusted data, as submitted by the company on 5 January 2026 and reflecting its own methodology for addressing foreign exchange effects, more appropriately reflected the costs associated with the production and sale of the product under consideration during the investigation period. As noted in recital (99), the Commission considered it appropriate not to replace the company’s records in their entirety. Instead, targeted adjustments were made to Jushi Egypt’s revised dataset to ensure that the recorded costs reasonably reflected the actual costs associated with production and sale during the investigation period.

(101) Finally, Jushi Egypt’s assertion that the Commission’s practice in prior cases, where official rates were used irrespective of local devaluations, obliged the Commission to adopt the same approach is without merit. The Commission noted that each anti-dumping investigation must be assessed on its own specific facts and economic circumstances, and the lawfulness of Commission’s anti-dumping determination in the light of legal rules and not on the basis of the investigating authority’s alleged previous decision-making practice. The Commission further noted that its practice depends on whether, and to what extent, the exporting producer concerned was affected by exchange rate issue. Where warranted by the factual circumstances of a case, the Commission has relied on parallel market exchange rates in the past⁽¹¹⁾. In the present case, the prolonged and severe devaluation of the EGP, the persistent and substantial divergence between official and parallel market rates affecting assets valuation and consequently depreciation (constituting a significant component of manufacturing costs in capital-intensive industry), and the high share of transactions conducted in foreign currency collectively created a unique situation that was materially different from any prior investigations named by the party. Historical precedents in which official rates were accepted, being clearly distinguishable from the present circumstances, did not alter the need for targeted adjustments under Article 2(5) in the present case.

(102) In light of the findings set out in recitals (91) to (97), the Commission concluded that the costs recorded in the accounting records of Jushi Egypt did not reasonably reflect the costs associated with the production and sale of the product under investigation within the meaning of Article 2(5) of the basic Regulation.

(103) Accordingly, the Commission used the adjusted cost data submitted by Jushi Egypt as a basis for its calculations of normal value. The Commission accepted the overall methodology and adjustments proposed by the company but added additional targeted adjustments to items not sufficiently addressed by Jushi Egypt, but deemed necessary to arrive at a cost reasonably reflecting the cost associated with the production and sale of the product under consideration, as explained in recital (99). More details of the adjustments and the corresponding sources were provided to the exporting producer in an individual disclosure, given the confidential nature of the information.

(104) Regarding Jushi Egypt’s claim that the adjustment for the devaluation of the EGP would result in double counting due to the countervailing duty, the Commission failed to see how a tax benefit calculated by reference to the devaluation could constitute double counting. In the absence of further explanations and evidence demonstrating that the same element was addressed twice, the claim was rejected.

(105) On 26 February 2026, Jushi Egypt requested the Hearing Officer’s intervention, noting that it was still not made aware of what information was not provided or not ideally provided, as this was nowhere explained in the final disclosure. On the same date, the Hearing Officer replied to the company that the Commission had used the information provided by Jushi Egypt to the best extent possible, according to Article 18(3) of the basic Regulation. When the adjusted data provided was not appropriate (thereby causing undue difficulties in arriving at a reasonably accurate finding), the Commission made additional adjustments to specific costs items, as explained in the final disclosure and its annexes. The Hearing Officer encouraged Jushi Egypt to engage with the Commission’s service so that the company could provide the relevant data as part of its written comments to the final disclosure.

(106) The Hearing Officer organised a hearing with the interested party and the Commission’s service on 4 March 2026, so that Jushi Egypt could better understand what type of information the company could still provide for the Commission to make its normal value determination, and thus prepare its written comments accordingly. At the hearing chaired by the Hearing Officer, Jushi Egypt had the opportunity to further engage on some specific points with the service in time to get useful guidance to prepare the written comments on the final disclosure. The service also offered to have a hearing with Jushi Egypt on the final disclosure in a separate hearing. In view of this, the Hearing Officer concluded that Jushi Egypt’s rights of defence had been properly guaranteed.

(107) The Hearing Officer also rejected a request for extending the deadline provided to Jushi Egypt to make comments on the final disclosure. The service had already extended such a deadline from Friday 6 March 2026 to Monday 9 March 2026 by 13 h, and Jushi Egypt did not provide any additional circumstances warranting a further extension of the deadline.

(108) Upon final disclosure, Jushi Egypt reiterated its claim that the application of Article 18(3) of the basic Regulation was unfounded. Jushi Egypt argued that the provision addresses non-cooperation, and the Commission did not demonstrate how Jushi Egypt failed to cooperate or deficiently cooperated. In particular, Jushi Egypt argued that the Commission did not specify which information necessary for the investigation it had failed to provide, or which information had not been ideally provided. Additionally, Jushi Egypt argued that, by not specifying which information Jushi Egypt needed to provide, the Commission had reversed the burden on Jushi Egypt to establish and provide the necessary information that was missing. Jushi Egypt also claimed that, had the Commission requested it, it could have provided any necessary information to the Commission, including through ‘adjusting its accounts by bringing them back to USD or basing them on current EGP exchange rates’.

(109) Additionally, upon final disclosure, Jushi Egypt reiterated its claim that the application of Article 2(5) of the basic Regulation as a legal basis for cost adjustments is unwarranted, arguing that the Commission improperly relied on the existence of parallel market exchange rates and the devaluation of the EGP on 6 March 2024 without substantiating how these factors affected the reliability of its recorded costs. In particular, Jushi Egypt argued that the Commission conflated the effects of the March 2024 devaluation with the existence of parallel exchange rates prior to that date and failed to explain how any discrepancy between official and parallel exchange rates could affect non-monetary items. Jushi Egypt further submitted that certain adjustments made by the Commission were unsubstantiated, as they increased the value of assets, inventories and other cost items without isolating expenses incurred in EGP, which would not have been affected by exchange-rate fluctuations.

(110) Lastly, Jushi Egypt submitted several comments regarding the targeted adjustments the Commission applied to Jushi Egypt’s adjusted cost data, as described in recital (103). These comments included claims regarding the Commission’s adjustments for raw materials purchased during the first quarter of 2024, depreciation, attrition of precious metals, costs of raw materials and packaging, inventories of finished goods, and foreign exchange loss.

(111) Regarding Jushi Egypt’s claims on the application of Article 18(3) of the basic Regulation, the Commission noted that this provision does not impose an obligation on the Commission to guide an interested party as to what additional information should be provided. Article 18(3) of the basic Regulation merely provides that information submitted by an interested party shall not be disregarded where it is not ideal in all respects, provided that the deficiencies do not cause undue difficulties in arriving at a reasonably accurate finding, the information was submitted in good time, is verifiable, and the party acted to the best of its ability. The provision therefore establishes the conditions under which information that is not ideal should nonetheless be used by the Commission. Considering that, for the data in question, the Commission found that the conditions were met, it accepted the data submitted by Jushi Egypt. Consequently, Jushi Egypt’s claim that the Commission reversed the burden of proof by not specifying which information was missing is unfounded.

(112) In any event, the Commission noted that, throughout the investigation, it had informed Jushi Egypt of the issues identified in relation to its cost data. In particular, the Commission explained in its correspondence with Jushi Egypt on 17 December 2025 and 27 January 2026 the concerns regarding the reasonableness of certain cost elements recorded in the company’s accounts in light of the divergence between official and parallel exchange rates and the company’s significant foreign currency exposure. These issues were subsequently explained in greater detail in the specific final disclosure. The Commission therefore considered that Jushi Egypt was adequately informed of the nature of the issues identified and had several opportunities during the investigation to provide information addressing those concerns. The Commission further noted that the issue identified was structural, affecting the recording of several categories of costs in the company’s accounts. In these circumstances, it was for the company, which was in the best position to know the nature and extent of the information available in its own accounting system, to provide data capable of addressing those issues. The Commission therefore considered that Jushi Egypt’s claim that it could not anticipate which information might have been required was unfounded.

(113) The Commission also noted that, contrary to its claim upon final disclosure about its willingness to reconstruct its accounting records, Jushi Egypt had indicated in its reply of 3 February 2026 that it would impose an ‘impossible burden’ on the company to apply parallel market rates ‘to all of its transactions and accounts as from the start of its operations in 2014’. This statement further confirmed the structural nature of the issue identified by the Commission. Based on the information provided by the company, as described in recitals (103), the Commission subsequently relied on the adjusted data provided by the company, together with certain additional targeted adjustments.

(114) In this regard, the Commission noted that, contrary to Jushi Egypt’s claims, the application of Article 18(3) of the basic Regulation did not expand the Commission’s discretion but rather limited it. Absent the application of Article 18(3) of the basic Regulation, once the Commission concluded under Article 2(5) of the basic Regulation that the costs recorded in Jushi Egypt’s accounts did not reasonably reflect the costs associated with the production and sale of the product under investigation, the Commission could have departed entirely from the company’s cost information and determine the relevant costs on another reasonable basis in accordance with that provision. However, it is in fact Article 18(3) of the basic Regulation that creates the obligation for the Commission not to disregard information submitted by an interested party where the conditions set out in that provision are met. Accordingly, the application of Article 18(3) of the basic Regulation ensured that the Commission relied on the information submitted by Jushi Egypt to the extent that such information could still be used for the calculation of normal value.

(115) In any event, the Commission noted that, even in the absence of the application of Article 18(3) of the basic Regulation, the additional targeted adjustments on Jushi Egypt’s cost data would be fully justified on the basis of Article 2(5) of the basic Regulation alone. As indicated in recitals (91) to (97), the structural impact of Egypt’s exchange-rate developments, including recurrent devaluations, the persistence of parallel foreign exchange markets, and the liberalisation of the EGP on 6 March 2024, materially affected the recording of costs and the valuation of assets, particularly in view of Jushi Egypt’s significant exposure to foreign exchange rate fluctuations. Contrary to Jushi Egypt’s claims, as explained in recital (96), the Commission reiterated that the distinction between monetary and non-monetary items is without practical significance, as both types of items were materially affected.

(116) Finally, regarding Jushi Egypt’s comments on the Commission’s additional targeted adjustments, the Commission carefully considered the points raised and, where appropriate, recalculated the normal value to reflect any justified adjustments. Given the confidential nature of the underlying data, these recalculations were communicated to the company through an additional specific disclosure.

(117) Upon additional final disclosure, Jushi Egypt submitted several comments regarding the targeted adjustments the Commission applied to Jushi Egypt’s adjusted cost data, as described in recital (86) of the final disclosure document. These comments included claims regarding the Commission’s adjustments for depreciation and attrition of precious metals. The Commission carefully considered the points raised and, where appropriate, recalculated the normal value to reflect any justified adjustments. Given the confidential nature of the underlying data, these additional recalculations were communicated to the company through a second additional specific disclosure, after which no new comments were received.

(118) Upon final disclosure, the GOE argued that the Commission’s approach was inconsistent with Article 2.2.1.1 of the ADA, which establishes the records of the investigated producer as the preferred source for determining the cost of production unless those records are not in accordance with GAAP or do not reasonably reflect the costs associated with the production and sale of the product under investigation. According to GOE, the Commission did not allege that Jushi Egypt’s accounts were not GAAP-compliant or that they failed to record the actual costs incurred. Instead, the Commission rejected the records because they did not reasonably reflect the costs associated with the production and sale of the product under consideration due to macroeconomic factors such as currency devaluation and the prolonged and substantial divergence between the official and parallel exchange rates, which meant that the official exchange rate applied did not accurately represent the actual market conditions.

(119) GOE further argued that the Commission’s acceptance of the adjusted data submitted by Jushi Egypt confirmed that the underlying records were fundamentally reliable. In its view, where records can be used with adjustments, they cannot logically be considered incapable of reasonably reflecting costs. GOE also claimed that the Commission’s subsequent adjustments to fixed assets, inventories and depreciation resulted in a hybrid methodology that effectively reconstructed costs without a proper legal basis under Article 2.2 of the Anti-Dumping Agreement.

(120) Finally, GOE submitted that the accounting treatment applied by Jushi Egypt followed mandatory Egyptian accounting standards and was not discretionary. It further argued that macroeconomic exchange rate developments could not justify disregarding company records in the absence of a specific distortion affecting the producer’s costs. GOE also considered that the Commission’s approach was inconsistent with the parallel anti-subsidy investigation, where the same accounting framework was examined as potentially reducing costs, whereas in the present investigation it is treated as inflating or distorting them.

(121) The Commission thoroughly examined and rejected GOE’s claims. First, the Commission recalled that Article 2.2.1.1 of the ADA Agreement requires investigating authorities to base the calculation of costs on the records kept by the exporter or producer, provided that those records are in accordance with the generally accepted accounting principles of the exporting country and reasonably reflect the costs associated with the production and sale of the product under investigation. As indicated in recitals (91) to (98), while the Commission did not dispute that Jushi Egypt’s accounts were prepared in accordance with the applicable accounting standards, it established that the costs recorded in those accounts did not reasonably reflect the costs associated with the production and sale of the product under investigation during the investigation period. In particular, the prolonged and substantial divergence between official and parallel exchange rates, combined with the company’s significant exposure to foreign currency transactions, resulted in key cost elements such as fixed assets, depreciation, inventories and certain raw material purchases being recorded at historical official exchange rates that materially understated their economic value during the investigation period.

(122) Second, the Commission noted that its use of the adjusted data submitted by Jushi Egypt did not demonstrate that the original records reasonably reflected the relevant costs. As explained in recitals (94) to (98), the Commission concluded that the company’s records contained distortions arising from the exchange rate developments described above and did not reasonably reflect the costs associated with the production and sale of the product under investigation during the investigation period. The adjusted dataset submitted by the company, after being informed of the issue, partially addressed these distortions. The Commission therefore used that dataset as a basis for the normal value calculation, while applying targeted corrections to cost elements that remained inconsistent. This approach ensured that the costs used in the calculation reasonably reflected the costs associated with the production and sale of the product under investigation. Additionally, the Commission rejected the claim that its approach resulted in the replacement of the company’s actual costs with hypothetical costs. As explained in recital (99), the Commission relied on the company’s own adjusted data and methodology and made only targeted adjustments to specific cost times. The Commission therefore did not substitute the company’s costs with external reference values but ensured that the costs used in the calculation reasonably reflected the economic reality of production by Jushi Egypt during the investigation period.

(123) Finally, the Commission considered that the arguments concerning the mandatory nature of the accounting treatment under Egyptian accounting standards and the alleged inconsistency with the parallel anti-subsidy investigation are without merit. First, the Commission noted that the accounting treatments introduced under Egyptian Accounting Standard No 13 to address the effects of exchange rate adjustments were designed as optional, and not mandatory, mechanisms available to companies. In any case, the Commission emphasised that compliance with national accounting standards does not preclude an investigating authority from assessing whether the recorded costs reasonably reflect the costs associated with the production and sale of the product under investigation for the purposes of Article 2.2.1.1 of the ADA. Moreover, the Commission noted that the legal assessment carried out in a subsidy investigation concerned different legal provisions and did not affect the analysis carried out in the present investigation in accordance with the basic Regulation and ADA. Accordingly, the Commission rejected GOE’s claims.

(124) Having established the cost of production, the Commission examined whether the total volume of Jushi Egypt’s domestic sales was representative, in accordance with Article 2(2) of the basic Regulation. The domestic sales are representative if the total domestic sales volume of the like product to independent customers on the domestic market per exporting producer represented at least 5 % of its total export sales volume of the product concerned to the Union during the investigation period.

(125) On this basis, the total sales by the exporting producer of the like product on the domestic market were found to be representative.

(126) The Commission subsequently identified the product types sold domestically that were identical or comparable with the product types sold for export to the Union for the exporting producer with representative domestic sales.

(127) The Commission then examined whether the domestic sales by the exporting producer on its domestic market for each product type that is identical or comparable with a product type sold for export to the Union were representative, in accordance with Article 2(2) of the basic Regulation. The domestic sales of an identical or comparable product type are representative if the total volume of domestic sales of that product type to independent customers during the investigation period represents at least 5 % of the total volume of export sales of that product type to the Union.

(128) The Commission established that the domestic sales for certain product types were representative. For some of the product types, representing [50 %–60 %] of the export sales to the Union, there were no domestic sales, or the domestic sales were below 5 % and thus not representative. For these product types, no other sources for domestic prices were available. The normal value was constructed in line with the method below in recital (129).

(129) The Commission next defined the proportion of profitable sales to independent customers on the domestic market for each product type during the investigation period in order to decide whether to use actual domestic sales for the calculation of the normal value, in accordance with Article 2(4) of the basic Regulation.

(130) The normal value is based on the actual domestic price per product type, irrespective of whether those sales are profitable or not, if:

1. the sales volume of the product type, sold at a net sales price equal to or above the calculated cost of production, represented more than 80 % of the total sales volume of this product type; and

2. the weighted average sales price of that product type is equal to or higher than the unit cost of production.

(131) If both tests are met, the normal value is the weighted average of the prices of all domestic sales of that product type during the IP.

(132) The normal value is the actual domestic price per product type of only the profitable domestic sales of the product types during the IP, if:

1. the volume of profitable sales of the product type represents 80 % or less of the total sales volume of this type; or

2. the weighted average price of this product type is below the unit cost of production.

(133) The analysis of domestic sales showed that [2 %–5 %] of all domestic sales were profitable and that the weighted average sales price was lower than the cost of production. Accordingly, the normal value was calculated as a weighted average of the prices of profitable domestic sales during the IP.

(134) In instances where there were insufficient sales of a product type of the like product in the ordinary course of trade or where a product type was not sold in representative quantities on the domestic market, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation. In instances where there were no sales of a product type of the like product in the ordinary course of trade, the Commission examined whether alternative sources for prices in the ordinary course of trade could be used as a basis for normal value. As there were no other cooperating or available domestic producers of the like product in the country concerned, no such prices were available. Consequently, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation.

(135) In this case the normal value was constructed per product type by adding the following to the average cost of production of the like product of the investigated exporting producers during the investigation period:

1. the weighted average selling, general and administrative (‘SG & A’) expenses incurred by the investigated exporting producer on domestic sales of the like product, in the ordinary course of trade, during the investigation period; and

2. the weighted average profit realised by the investigated exporting producer on domestic sales of the like product, in the ordinary course of trade, during the investigation period.

(136) For the product types not sold in representative quantities on the domestic market, the average SG & A expenses and profit of transactions made in the ordinary course of trade on the domestic market for those types were added. For the product types not sold at all on the domestic market, or where no sales were found in the ordinary course of trade, the weighted average SG & A expenses and profit of all transactions made in the ordinary course of trade on the domestic market were added.

(137) Upon final disclosure, Jushi Egypt submitted that the Commission had wrongly increased its domestic SG & A by allocating trademark costs and realised foreign exchange losses. Jushi Egypt argued that the trademark costs recorded in its accounts represented an intra-group payment to its parent company, which did not correspond to any service rendered and would ultimately be eliminated in the consolidated financial statements. Jushi Egypt further noted that all domestic sales were carried out in EGP and therefore did not give rise to foreign exchange gains or losses.

(138) The Commission examined these claims and rejected them. The Commission found that the amounts reported as trademark costs did not constitute a cash transfer. If they did, they would not be reflected in the profit and loss account but merely in the balance sheet. Thus, the Commission found that these costs represented a remuneration to the parent company booked as a cost and their exclusion from the normal value calculation was not justified. With respect to domestic sales, the Commission observed that Jushi Egypt’s assertion that realised foreign exchange losses should not be allocated was unfounded. While domestic sales were conducted in EGP, a substantial share of raw materials was purchased in foreign currency. Consequently, fluctuations in the exchange rate materially affected the costs of production, including those attributable to domestic sales. The Commission therefore rejected the claim that foreign exchange losses did not have an effect on domestic sales, as the profitability of such sales was influenced by currency movements on imported inputs.

3.2.2. Export price

(139) The exporting producer exported to the Union either directly to independent customers or through related companies located in France, Italy and Spain acting as importers. The related importers resold the product concerned to unrelated customers in the Union.

(140) In case the exporting producer exported the product concerned directly to independent customers in the Union, 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.

(141) In case the exporting producers exported the product concerned to the Union through a related company acting as an importer, the export price was established on the basis of the price at which the imported product was first resold to independent customers in the Union, in accordance with Article 2(9) of the basic Regulation. In this case, adjustments to the price were made for all costs incurred between importation and resale, including SG & A expenses, and for profits accruing.

(142) Upon final disclosure, Jushi Egypt claimed that certain direct selling expenses for related traders had been deducted twice. The Commission examined these claims and accepted that, for Jushi Italia and Jushi Spain, the bank charges and insurance expenses, respectively, had indeed been deducted twice and corrected these errors. With respect to Jushi France, the Commission rejected Jushi Egypt’s claim, noting that the depreciation of stock value relates to the product under investigation recorded during the investigation period and was allocated by the company itself. Consequently, these costs are appropriately included in SG & A costs for the calculation of the export price.

3.2.3. Comparison

(143) 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. 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 normal value and the export price 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.

3.2.3.1. Adjustments made to the normal value

(144) In order to net the normal value back to the ex-works level of trade, adjustments were made on the account of inland transportation.

(145) An allowance was made for credit cost to ensure price comparability.

3.2.3.2. Adjustments made to the export price

(146) In order to net the export price back to the ex-works level of trade, adjustments were made on the account of: customs duty, inland transportation, ocean freight and insurance, and handling, loading and ancillary expenses.

(147) Allowances were made for the following factors affecting prices and price comparability: credit cost, commissions, discounts and bank charges.

3.2.4. Dumping margins

(148) For the cooperating exporting producer, the Commission compared the weighted average constructed 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.

(149) On this basis, the definitive weighted average dumping margin expressed as a percentage of the CIF Union frontier price, duty unpaid, is as follows:

(150) The level of cooperation in this case is high because the exports of the cooperating exporting producer constituted 100 % of the total imports into the Union during the IP. On this basis, the Commission decided to establish the residual dumping margin at the level of the cooperating exporting producer.

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

3.3. Thailand

3.3.1. Normal value

(152) To establish the normal value, the Commission first assessed whether the total domestic sales volume of the sampled exporting producers was representative, in accordance with Article 2(2) of the basic Regulation. Domestic sales are considered representative if the total volume of sales of the like product to independent customers per exporting producer represents at least 5 % of the total export sales volume of the product concerned to the Union during the investigation period.

(153) On this basis, domestic sales were found to be representative for Asia Composite Materials (Thailand) Co., Ltd. (‘Asia Composite’), whereas the total domestic sales of Wanda New Material (Thailand) Co., Ltd. (‘Wanda’) did not meet the representativity threshold.

(154) In instances where there were insufficient sales of a product type of the like product in the ordinary course of trade or where a product type was not sold in representative quantities on the domestic market, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation. In instances where there were no sales of a product type of the like product in the ordinary course of trade, the Commission looked for alternative sources for prices in the ordinary course of trade. Since there were no domestic sales of other sampled producer or the domestic sales price of other sampled producer for that product type could not be disclosed in a meaningful manner without breaching the confidentiality of that producer, and no other sources of prices for the particular product types were available, the Commission constructed the normal value for the relevant product types in accordance with Article 2(3) and (6) of the basic Regulation.

(155) Where a product type was not sold on the domestic market, normal value was constructed by adding the following to the average cost of production of the like product of the cooperating exporting producer during the investigation period:

1. the weighted average selling, general and administrative (‘SG & A’) expenses incurred by the cooperating exporting producer on domestic sales of the like product, in the ordinary course of trade, during the IP; and

2. the weighted average profit realised by the cooperating exporting producer on domestic sales of the like product, in the ordinary course of trade, during the IP.

(156) Where a product type was sold on the domestic market but not in representative quantities, normal value was constructed by adding the average SG & A expenses and profit of transactions made in the ordinary course of trade on the domestic market for that product type.

(157) With regard to Asia Composite, which had representative domestic sales, the Commission identified domestic product types that were identical or directly comparable with those exported to the Union.

(158) The Commission then assessed, in accordance with Article 2(2) of the basic Regulation, the representativeness of the exporting producer’s domestic sales of each product type identical or comparable to a product type sold for export to the Union. The domestic sales of an identical or comparable product type are deemed representative if the total volume of domestic sales of that product type to independent customers during the investigation period represents at least 5 % of the total volume of export sales of that product type to the Union.

(159) The Commission established that the domestic sales for a large amount of product types were representative. For some product types however, representing 38 % of export sales to the Union, domestic sales were either non-existent or below the 5 % threshold and therefore not representative. For these product types, the normal value was constructed in accordance with the methodology described in recitals above (155) and (156).

(160) The Commission then determined, in accordance with Article 2(4) of the basic Regulation, the proportion of profitable sales made to independent customers on the domestic market for each product type during the investigation period, for the purpose of deciding whether actual domestic sales could be used to calculate the normal value. The normal value is based on the actual domestic price per product type, irrespective of whether those sales are profitable or not, if:

1. the sales volume of the product type, sold at a net sales price equal to or above the calculated cost of production, represented more than 80 % of the total sales volume of this product type; and

2. the weighted average sales price of that product type is equal to or higher than the unit cost of production.

(161) If both tests are met, the normal value is the weighted average of the prices of all domestic sales of that product type during the IP.

(162) The normal value is the actual domestic price per product type of only the profitable domestic sales of the product types during the IP, if:

1. the volume of profitable sales of the product type represents 80 % or less of the total sales volume of this type; or

2. the weighted average price of this product type is below the unit cost of production.

(163) The analysis of domestic sales of Asia Composite showed that the volume of profitable sales of some product types during the investigation period represented less than 80 % of the total sales volume of those types. Accordingly, for these product types, the normal value was calculated as a weighted average of the profitable sales only. For all other product types, the scenario outlined in recitals (160) and (126) was applicable, and the normal value was calculated as a weighted average of the prices of all domestic sales during the investigation period.

(164) When a product type was not sold in representative quantities or not sold at all on the domestic market within the meaning of Article 2(3), first sentence of the basic Regulation, the Commission constructed the normal value in accordance with Article 2(3) and (6) of the basic Regulation.

3.3.2. Export price

(165) The two Thai exporting producers, Asia Composite and Wanda, exported the product concerned directly to independent customers in the Union. Hence, the export price was established as 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.

3.3.3. Comparison

(166) 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. In this case, 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 normal value and the export price 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.

3.3.3.1. Adjustments made to the normal value

(167) In order to establish the normal value at the ex-works level of trade, adjustments were made for inland transportation.

(168) Allowances were made for the following factor affecting prices and price comparability: credit cost and bank charges.

3.3.3.2. Adjustments made to the export price

(169) In order to net the export price back to the ex-works level of trade, adjustments were made on the account of: inland transportation, ocean freight and insurance, handling and loading.

(170) Allowances were made for the following factors affecting prices and price comparability: credit cost, bank charges, discounts and commissions paid to an unrelated agent.

3.3.4. Claims made after final disclosure

(171) Further to final disclosure, the Commission addressed ACM’s claim that Wanda’s normal value should be based on ACM’s domestic sales. The Commission recalled that the arguments relating to the approach followed in Hansol Paper had already been addressed in the above recital (154). The Commission recalled that when submitting domestic sales data with their reply to the anti-dumping questionnaire ACM declared this data to be confidential within the meaning of Article 19 of the basic Regulation. ACM provided non-confidential summaries of the data to be placed on the open case file in accordance with Article 19(2) of the basic Regulation. The Commission accepted this claim. At no point during the investigation did ACM argued that it no longer considers its domestic sales data as confidential, authorised the Commission to disclose it on the open case file instead of the summaries and explained why the reasons for which the relevant information was considered by ACM as confidential no longer apply. As explained in recital (154), since the domestic sales of other sampled producers for the relevant product types could not be disclosed without breaching the confidentiality of the producer concerned, and since no other reliable sources of prices were available, the Commission constructed the normal value for the relevant product types in accordance with Article 2(3) and Article 2(6) of the basic Regulation. Therefore, the Commission considered that this claim was unfounded.

(172) With regard to the claim made by ACM concerning the allegedly erroneous use of credit costs for export sales to the Union, the Commission noted that the credit costs used in the calculation were based on the information submitted by ACM in Exhibit 5 during the verification visit. The interest rates of 4,9 % for sales in USD and 3,75 % for sales in EUR were introduced by ACM in that exhibit. As the mission report did not raise any issues regarding these rates, the Commission considered the information provided in Exhibit 5 to be accepted. Therefore, ACM’s claim concerning the allegedly erroneous use of these credit costs cannot be accepted.

(173) With regard to the claim made by ACM concerning the allegedly erroneous use of credit costs for domestic sales, the Commission noted that both the anti-dumping questionnaire reply and the information submitted in Exhibit 5 during the verification visit indicated the credit cost rate used for the calculation. ACM did not indicate any change/correction to this rate during the verification, as reflected in the company’s mission report, or questioned them once the mission report was disclosed to them. The alleged rate could not be considered as verified, unlike those in mission Exhibit 5. Therefore, the claim was rejected.

(174) Wanda claimed also that bank charges and credit costs should have been deducted from the normal value. The Commission confirms that the normal value used in the comparison was indeed calculated after deducting these alleged allowances. However, the impact of such deductions is negligible, visible only from the third decimal place, and therefore does not materially affect the dumping margin, which remains at 15,3 %.

(175) ACM further claimed that the Commission should increase the CIF value for sales made through unrelated traders outside the Union by adding amounts for SGA expenses and profit of those traders, arguing that this would better reflect the CIF value at the Union border. In this respect, the Commission noted that those companies were not acting like traders but as agents arranging sales on behalf of ACM. Under this commission model, the producer invoices the final customer directly (direct sales), while the ‘trader’ receives only a commission for arranging the transaction. Therefore, the Commission considered that the CIF value should be based on the price invoiced to the final customer and no adjustment for the agents’ SG & A expenses or profit was warranted.

(176) Finally, ACM claimed that it had made a clerical error in the calculation of domestic freight for export invoice ACM24NCM007 and submitted data based on a revised calculation. The Commission noted that this information was submitted at a very late stage of the investigation (after final disclosure) and therefore could not be confirmed. In any event, the impact of the proposed correction is immaterial; the adjustment would only lower the result by a few cents, leaving the overall dumping margin at the same level. Consequently, the Commission rejected the claim.

3.3.5. Dumping margins

(177) For the two Thai 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.

(178) On this basis, the definitive weighted average dumping margin expressed as a percentage of the CIF Union frontier price, duty unpaid, are as follows:

(179) The level of cooperation is considered high, given that the exports of the cooperating exporting producer accounted for all imports into the Union from Thailand during the IP. On this basis, the Commission decided to establish the residual dumping margin at the level of the highest established margin of the cooperating exporting producers.

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

4. INJURY

4.1. Definition of the Union industry and Union production

(181) The like product was manufactured by ten producers in the Union at the beginning of the period considered, while two of them ceased production during the IP. They constitute the ‘Union industry’ within the meaning of Article 4(1) of the basic Regulation.

(182) The total Union production during the investigation period was established at 529 828 tonnes. The Commission established the figure on the basis of the available information concerning the Union industry as provided by Glass Fibre Europe (‘GFE’). As indicated in recital (34), three Union producers were selected in the sample, representing 69 % of the total Union production of the like product.

4.2. Union consumption

(183) The Commission established the Union consumption on the basis of (i) the volume of sales of the Union industry on the Union market based on data provided by GFE; and (ii) imports from third countries based on data extracted from Eurostat (Comext).

(184) As a part of the Union industry is vertically integrated and GFR is used as an intermediate material for the production of various downstream products, the captive and free market consumptions were analysed separately.

(185) The distinction between captive and free market is relevant for the injury analysis because products destined for captive use are not exposed to direct competition from imports, as they are sold within the same company or groups of companies on the basis of transfer prices set according to internal price policies thus not directly linked to prices on the free market. By contrast, production destined for free market sales is in direct competition with imports of the product concerned.

(186) To provide a picture of the Union industry that is as complete as possible, the Commission requested data for the entire activity of GFR and verified whether the production was destined for captive use or for the free market.

(187) The Commission examined certain economic indicators relating to the Union industry on the basis of data for the free market only. These indicators are: sales volume and sales prices on the Union market; market share; export volume and prices; profitability; return on investment; and cash flow. Where possible and appropriate, the findings of the examination were compared with data for the captive market in order to provide a complete picture of the situation of the Union industry.

(188) However, other economic indicators could meaningfully be examined only by referring to the whole GFR activity, including the captive use of the Union industry. These are: production; capacity and capacity utilisation; investments; stocks; employment; productivity; wages and ability to raise capital. This is because they depend on the whole production activity, whether GFR is kept for captive use or sold on the free market.

(189) Union consumption developed as follows:

(190) Table 1 shows that over the period considered, a maximum of 10 % of the Union consumption of GFR was dedicated to the captive market whilst the rest was sold on the free market.

(191) During the period considered, total Union consumption decreased by 2 %. Total union consumption first went up from 2021 to 2022 by 10 %, followed by a decrease of 12 % in 2023 and again an increase in the IP to a level nearly equal to the start of the period considered.

(192) The free market consumption followed practically the same trend as the total Union consumption, starting with an increase of 11 % from 2021 to 2022, followed by a decrease of 13 % and then an increase to the level of the start of the period considered. The increase observed in 2022 in free Union consumption was mainly due to the economic recovery following the lifting of the COVID-19 measures as users resumed placing orders to restock inventories and restarted production. However, demand for GFR in the Union decreased in 2023 due to a decline in consumption and subsequent poor recovery. In the IP Union consumption recovered to nearly to the level recorded in 2021.

(193) The captive consumption decreased over the period considered by 9 %. Since the captive consumption was relatively low, the impact of this decrease was not reflected in the total Union consumption.

4.3. Imports from the countries concerned

4.3.1. Cumulative assessment of the effects of imports from the countries concerned

(194) The Commission examined whether imports of product under investigation originating in the countries concerned should be assessed cumulatively, in accordance with Article 3(4) of the basic Regulation.

(195) The margin of dumping established in relation to the imports from Bahrain, Egypt and Thailand was above the de minimis threshold laid down in Article 9(3) of the basic Regulation. The volume of imports from each of the countries concerned was not negligible within the meaning of Article 5(7) of the basic Regulation. Market shares in the investigation period were 4 %, 18 % and 2 % respectively.

(196) The conditions of competition between the dumped imports of GFR from the countries concerned and between their imports and the like product sold by the Union industry were similar. More specifically, the investigation showed, based on questionnaire replies from sampled exporting producers, importers and Union producers, that the imported products and the like product were sold through comparable sales channels. Moreover, imports from the countries concerned all undercut the Union industry sales prices at a significant rate.

(197) Therefore, all the criteria set out in Article 3(4) of the basic Regulation were met and imports from the countries concerned were examined cumulatively for the purposes of the injury determination.

4.3.2. Volume and market share of the imports from the countries concerned

(198) The Commission established the volume of imports on the basis of Eurostat data. The market share of the imports was established by comparing the volume of imports with the Union consumption.

(199) Imports into the Union from the countries concerned developed as follows:

(200) The combined volume of imports from the countries concerned increased both in relative and in the absolute terms during the period considered and their combined market share increased from 14 % in 2021 to 24 % in the IP.

4.3.3. Prices of the imports from the countries concerned and price undercutting

(201) The Commission established the prices of imports on the basis of Eurostat data. The weighted average price of imports into the Union from the countries concerned developed as follows:

(202) The average price of imports into the Union from Bahrain decreased over the period considered by 8 % and stayed during this period well below the price level of the sales price of the Union industry, with the exception of 2022. The average price of imports into the Union from Egypt also decreased over the period considered by 10 % and were consistently below the Union industry level throughout this period. Average price of imports into the Union from Thailand decreased by 50 % during the period considered which was mainly due its price being relatively high in 2021 when import quantities were quite low. After 2021 the average price of imports into the Union from Thailand was well below the price level of the sales price of the Union industry.

(203) The Commission determined the price undercutting during the investigation period by comparing:

1. the weighted average sales prices per product type of the sampled Union producers charged to unrelated customers on the Union market; and

2. the corresponding weighted average prices per product type of the imports from the cooperating exporting producers in the countries concerned to the first independent customer on the Union market, established on a Cost, insurance, freight (CIF) basis, with appropriate adjustments for customs duties and post-importation costs.

(204) 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 that during the IP, imports of the product under investigation originating in the countries concerned undercut Union industry prices by 30,6 % to 39,0 %.

(205) In addition to price undercutting, it was established that there was also significant price suppression and depression. Due to the significant price pressure caused by the low-priced dumped imports from the countries concerned, the Union industry was forced to reduce its price in order to compete with the imports and was unable to raise its prices throughout the IP in line with the development of costs of production while trying to achieve a reasonable level of profit, as set out in Table 8 below. The significant price suppression and depression was confirmed by the data in Table 3 as well as the price underselling found on the basis of the data provided by the sampled exporting producers. As a result, the Union industry was forced to sell at prices insufficient to cover its costs, which contributed to the deterioration of its financial situation.

4.4. Economic situation of the Union industry

4.4.1. General remarks

(206) 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.

(207) As mentioned in recital (34), sampling was used for the determination of possible injury suffered by the Union industry.

(208) For the injury determination, the Commission distinguished between macroeconomic and microeconomic injury indicators. The Commission evaluated the macroeconomic indicators on the basis of information provided by GFE. The data related to all Union producers. The Commission evaluated the microeconomic indicators on the basis of data contained in the questionnaire replies from the sampled Union producers.

(209) The macroeconomic indicators are: production, production capacity, capacity utilisation, sales volume, market share, growth, employment, productivity, magnitude of the dumping margin, and recovery from past dumping.

(210) The microeconomic indicators are: average unit prices, unit cost, labour costs, inventories, profitability, cash flow, investments, return on investments, and ability to raise capital.

4.4.2. Macroeconomic indicators

4.4.2.1. Production, production capacity and capacity utilisation

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

(212) Production volume in 2022 increased slightly in comparison to 2021 following relaxation of the COVID-19 measures which facilitated more stable production. Furthermore, in 2022 several sampled Union producers increased production volume in order to accumulate inventories of finished products as they were heading into planned furnaces rebuilds. However, in 2023 and IP there was a significant drop in production volume as the Union producers were selling off accumulated inventories while at the same time Union industry was faced with increase in dumped imports of GFR.

(213) Production capacity declined consistently throughout the period considered and was reduced by 7 %. The decrease in production capacity from 2021 to the end of the IP was due to some Union producers ceasing production, with Krosglass S.A. halting GFR production in Poland and Electric Glass Fiber NL, B.V. entering bankruptcy proceedings.

(214) Capacity utilisation decreased by 7 percentage points over the period considered as production volume decreased more than production capacity.

4.4.2.2. Sales quantity and market share

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

(216) During the period considered, the sales volume on the Union free market of Union producers decreased by 15 %. In parallel, while free market consumption decreased only slightly by 2 % during the period considered, the sales volume of the Union industry decreased so that market share of the Union industry decreased from 47 % in 2021 to 40 % in the IP.

(217) As far as the captive market is concerned, captive volume and market share on the Union market developed over the period considered as follows:

(218) Captive market sales quantity on the Union market went down by 9 % over the period considered. While sales in both the free market and the captive market followed a similar trend from 2021 to the end of the IP, the decline in sales within the captive market was 6 percentage points less than in the free market.

(219) The Union industry’s captive market share (expressed as a percentage of total Union production) decreased slightly in 2022 then remained stable at around 18 % over the rest of the period.

(220) Therefore, it was concluded that the decline in Union industry’s sales on the free market was the result of increased pressure exerted by imports from the countries concerned.

4.4.2.3. Growth

(221) The Union consumption remained stable during the period considered however the sales volume of the Union industry on the Union market decreased by 15 %. The Union industry thus lost market share, contrary to the market share of the imports from the countries concerned which increased during the period considered.

4.4.2.4. Employment and productivity

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

(223) In the period considered, the number of employees in the Union industry exhibited both an initial slight increase and subsequent considerable decline. The initial increase of 2 % in 2022 in comparison to 2021 corresponded to the increased production and sales following the relaxation of COVID-19 restrictions. Subsequently, the Union industry had to reduce employment to adjust to the challenging market conditions and maintain operational efficiency resulting in an overall decrease of 17 % over the period considered. This reduction in employment was also linked to plant closures.

(224) Productivity decreased between 2021 and 2023 from 190 MT/employee to 166 MT/employee before picking up in the IP to 198 MT/employee after employment contracted significantly. The efficiency gains also followed investment performed on the furnaces by several Union producers of GFR.

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

(225) This is the first completed anti-dumping investigation regarding the product concerned from Bahrain, Egypt and Thailand. 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

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

(227) The average sales prices increased in 2022 in comparison to 2021 as sampled Union producers were able to pass the increase in costs driven by inflation onto customers due to uptick in demand. In 2023 and during the IP, however, average sales prices decreased due to a decline in demand on the Union market in 2023, its only partial recovery in the IP, and the increased price pressure from imports.

(228) Unit production costs increased by 26 % from 2021 to 2023 due to an increase in labour and raw material costs. Additionally, energy costs have been volatile, significantly impacting industries that rely heavily on energy. The unit cost of production reduced in the IP compared to 2023, but remained far above the 2021 level, thanks to a decrease in energy prices, improved energy efficiency and successful cost management strategies. Overall unit production costs increased by 24 % over the period considered.

4.4.3.2. Labour costs

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

(230) Average labour cost per employee followed a consistent upward trend with an overall increase of 14 % during the period considered. The increase was mainly due to labour market pressures, as companies raised wages to retain and attract employees in a tight post-COVID job market marked by high inflation.

4.4.3.3. Inventories

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

(232) The increase in inventories in 2022 was initially driven by a strategic stock buildup in anticipation of planned furnace rebuilds. This aligned with an earlier period during post-COVID-19 recovery when there was a significant surge in demand causing supply chain issues which prompted Union producers to overorder raw materials to meet production requirements. Following the completion of furnace rebuilds, inventories decreased as sampled Union producers managed to sell off existing stocks in 2023. However, in the IP we observed increase in inventories of 9,8 % in comparison to 2023 as consumption increased more strongly than Union sales, with imports gaining market share. As production exceeded sales growth, inventories accumulated. Profitability, cash flow, investments, return on investments and ability to raise capital.

(233) Profitability, cash flow, investments and return on investments of the sampled Union producers developed over the period considered as follows:

(234) The Commission established the profitability of the sampled Union producers by expressing the pre-tax net profit of the sales of the like product to unrelated customers in the Union as a percentage of the turnover of those sales. While the Union industry incurred losses in 2021, there was an increase in profitability in 2022 as the sampled Union producers could pass the increase in unit production costs onto customers thanks to favourable market conditions linked to high demand. In 2023 and in the IP, the profitability, however, dropped due to increased costs which could not be compensated with an increase in sales prices due to an increase in import volumes at dumped prices undercutting and suppressing the Union industry’s prices.

(235) Investments during the period considered increased. These investments mainly related to rebuilds of furnaces of the sampled Union producers aimed at ensuring the longevity of the equipment. These investments, planned long ahead, took place against the background of unfavourable market conditions prevailing in 2023 and in IP.

(236) The cash flow from 2021 to the IP showed significant fluctuations driven by volatile market conditions. During period considered, 2022 was the only year in which all sampled Union producers achieved significant profits, depleted partially in the build-up of inventories heading into planned furnaces rebuilds, which led to a positive cashflow. In 2023 and in IP, despite experiencing severe loss, cash flows remained positive. This seemingly contradictory situation could be largely attributed to the significant positive cash flow impact resulting from reductions in inventory levels that had been accumulated in 2022.

(237) The return on investments is the profit in percentage of the net book value of investments. The return on investment developed in line with the profitability. It first increased in 2022 before deteriorating in 2023 and even further in the IP, which made it more difficult for the Union industry to raise capital and grow.

4.5. Conclusion on injury

(238) During the period considered the Union industry was only profitable in 2022, after which it became loss making. In 2023 and in the IP, the lossmaking situation of the Union industry coincided with an increase of imports from Bahrain, Egypt and Thailand at prices below the Union industry’s average sales prices and costs of production.

(239) The Union industry was able to increase its price level in 2022 to achieve a profitable situation. However, in 2023 and in the IP, the difference between the Union industry sales prices and import prices from the countries concerned increased. Union prices increased by 7 % during the period considered while (i) import prices from Bahrain decreased by 8 %; (ii) import prices from Egypt decreased by 10 %; and (iii) import prices from Thailand decreased by 50 %. As a result, even though the Union industry was forced to sell at a loss, it lost market share between 2021 and the IP.

(240) Almost all injury indicators showed an overall negative trend throughout the period considered. Production, production capacity, capacity utilisation, profitability, return on investments all deteriorated, in line with decreased sales volumes and market share. In 2022 the Union was able to recover to a certain extent as demand for GFR increased again in the wake of the lifting of the COVID-19 measures. However, in 2023 and in the IP due to the increase in dumped import volume at decreasing prices, the Union industry’s situation deteriorated further as illustrated by its increased losses.

(241) As set out above, other economic indicators such as return on investment were negative during the period considered with the exception of the year 2022. This affected the ability of the Union industry to self-finance operations and to raise capital, thus impeding its growth and even threatening its survival in the medium to long term.

(242) On the basis of the above, the Commission concluded that the Union industry suffered material injury within the meaning of Article 3(5) of the basic Regulation.

5. CAUSATION

(243) In accordance with Article 3(6) of the basic Regulation, the Commission examined whether the dumped imports from the countries concerned caused material injury to the Union industry.

(244) In accordance with Article 3(7) of the basic Regulation, the Commission also examined whether other known factors could at the same time have injured the Union industry. The Commission ensured that any possible injury caused by factors other than the dumped imports from the countries concerned were not attributed to the dumped imports. These factors were imports from third countries other than countries concerned, the export performance of the Union industry, the increase in cost of raw materials and cost of energy on the Union industry and development on the captive market.

5.1. Effects of the dumped imports

(245) The Commission examined the evolution of the volume of imports from the country concerned and their impact on the Union industry as required by Article 3(6) of the basic Regulation.

(246) The investigation showed that the volume of dumped imports undercutting the Union industry’s prices from the countries concerned increased both in absolute and relative terms during the period considered as the combined market share of the countries concerned systematically increased from 14 % in 2021 to 24 % in the IP.

(247) At the same time, the Union industry saw its market share decrease by nine percentage points during the period considered.

(248) The average unit prices of the dumped imports from Bahrain, Egypt and Thailand decreased by 8 %, 10 % and 50 % respectively between 2021 and the IP and were lower than those of the Union industry during the same period.

(249) The investigation established that imports from the countries concerned consistently undercut Union industry sales prices during the investigation period, with undercutting margins ranging between 30,6 % and 39,0 %. At the same time, import prices were found to be significantly below the Union industry’s cost of production (COP). While the Union industry’s average unit costs increased by 24 % over the period considered, due primarily to higher energy and raw material costs, its sales prices could not be raised accordingly because of the price pressure exerted by dumped imports. As a result, even when sales prices rose temporarily in 2022, they remained closely aligned with or below cost levels in subsequent years, preventing the Union industry from covering its costs and achieving a reasonable profit margin. The combined effect of sustained price undercutting and the inability of the Union industry to increase its prices in line with costs led to significant price suppression.

(250) The Union industry was loss making in 2021, became profitable in 2022 and continued to be loss making from 2023 onwards. While profitability improved significantly in 2022, it deteriorated sharply thereafter, reaching –7,3 % in 2023 and –10,6 % in the investigation period. This deterioration coincided with a marked decline in import prices from the countries concerned after 2022. Although import prices increased in 2022 compared to 2021, they fell substantially in 2023 and decreased further during the investigation period. Import volumes from those three countries peaked in 2022, declined in 2023, and then increased strongly during the investigation period, reaching levels of around 65 % higher than in 2021. The combination of falling Union prices, increasing low-priced imports, and renewed growth in import volumes exerted downward pressure on the Union industry’s economic situation, contributing to the worsening of its profitability from 2023 onwards.

(251) In view of the above considerations, the Commission concluded that the increase over the period considered in dumped imports from the countries concerned lead to significant increase of their market share at the expense of the Union industry. These imports exercised a significant pressure on the Union industry as they were also undercutting and suppressing the Union industry prices, thereby leading to the significant deterioration of the situation of the Union industry over the period considered.

(252) In view of the above considerations, the Commission established that the material injury suffered by the Union industry was caused by the dumped imports from the countries concerned within the meaning of Article 3(6) of the basic Regulation.

5.2. Effects of other factors

5.2.1. Imports from third countries

(253) The volume of imports into the Union as well as the market share and price trends for imports of GFR from other third countries developed as follows:

(254) Chinese imports into the Union rose by 78 %, increasing their market share from 5 % to 10 % between 2021 and 2022 before decreasing to 9 % in 2023 and the IP. Chinese prices including duties in place were above the Union industry level in 2021 and 2022 however in 2023 and during the IP they were below the Union industry level and therefore also contributing to the material injury suffered by the Union industry during the investigation period. The prices of the imports from the countries concerned where however significantly lower than the import prices from the PRC during the period considered, with the exception of (the low volume of) imports from Thailand in 2021 and 2022. This while the import volumes from the countries concerned were consistently significantly above the import volumes from the PRC during the period concerned. The Commission therefore concluded that, while imports from China also contributed to the injury suffered by the Union industry, their presence does not attenuate the genuine and substantial causal link between the dumped imports from the countries concerned and the material injury established in this investigation.

(255) Imports of GFR from the United Kingdom (‘UK’) into the Union between 2021 and the IP showed a decrease in volume, and a relatively steady market share. Import volumes from the UK increased from 2021 to 2022, before declining by around 21 % in 2023 and a further 19 % by the IP. Market share decreased from 4 % to 3 % during period considered. The average price per metric tonne from the UK were at similar or higher levels than the average price of the Union industry, and above the price of imports from the countries concerned. Import prices from the UK first rose by 39 % from 2021 to 2023, before a decrease to EUR 1 244 in the IP. The Commission therefore concluded that, given their declining trend, limited market share and higher price levels, imports from the United Kingdom did not contribute to the material injury suffered by the Union industry and do not attenuate the causal link with the dumped imports from the countries concerned.

(256) The trend in Malaysian imports to the Union from 2021 to the IP showed a significant decline in both volume and market share, alongside fluctuations in pricing. Import volumes dropped sharply from 136 086 metric tonnes in 2021 to 76 909 metric tonnes in 2023, before a minor recovery to 86 303 tonnes by the IP. Correspondingly, the market share of Malaysian imports decreased from 16 % to 10 %. Although the average price per metric tonne initially rose by 32 % in 2022, there was a significant drop in 2023 and in IP. The Commission therefore concluded that imports from Malaysia may have contributed to some extent to the material injury suffered by the Union industry, notably because their import prices were below the Union producers’ unit cost of production. However, in view of their overall declining volumes and market share, these imports did not attenuate the genuine and substantial causal link between the dumped imports from the countries concerned and the material injury found.

(257) Imports of GFR from other third countries, excluding those previously specified, into the Union during the period considered experienced a decrease in volume of 2 % and a stable market share of 13 %. Average prices from these countries were higher than prices of imports from the countries concerned. The Commission concluded that imports from other third countries may have contributed to some extent to the material injury suffered by the Union industry, as their import prices were below the Union producers’ unit cost of production. However, due to higher price levels compared to the dumped imports from countries concerned, these imports did not attenuate the genuine and substantial causal link between the dumped imports from the countries concerned and the material injury found.

(258) The analysis of the import data for GFR originating UK, Malaysia and other third countries show a mixed picture. Imports from Malaysia decreased in absolute and relative terms during the period considered while priced below the Union industry’s prices. Imports from the United Kingdom showed downward trend since 2022 while priced above the Union industry’s prices. Imports volumes from other third countries decreased during the period considered. In view of all the elements, there were no significant imports from third countries that both increased their market share while priced below the Union industry prices during the period considered, and or in the IP in particular.

(259) While the Commission found that imports from China contributed to the injury found during the investigation period, the Commission concluded that this factor, though important, could not attenuate the genuine and substantial causal link between dumped imports from the countries concerned and the material injury suffered by the Union industry, because the increase in volumes and the sustained price pressure from the countries concerned coincided directly with the deterioration of the Union industry’s sales, market share, and profitability, thereby being a clear source of injury.

(260) Following final disclosure, GCC-TSAIP argued that the Commission had failed to conduct an adequate non-attribution analysis with regard to imports from other third countries. In particular, they claimed that the determination did not sufficiently explain how the Commission distinguished the injurious effects of the imports from the countries concerned from the effects of imports originating in other countries. According to GCC-TSAIP, the Commission’s findings contained only general statements that imports from other sources did not break the causal link, without providing a sufficiently detailed quantitative assessment of their volume, price levels and market share developments. They therefore argued that the determination did not demonstrate that the injury caused by other imports was properly distinguished from the injury allegedly caused by the dumped imports.

(261) The Commission rejected these claims. Reference is made to recitals (254) to (259), describing how the Commission examined other known factors which could have contributed to the material injury suffered by the Union industry, including imports from China, the United Kingdom, Malaysia and other third countries. The analysis of their volumes, market shares and price levels showed that, while some of these imports may have contributed to the injury suffered by the Union industry to a certain extent, they either had declining volumes, limited market shares or higher price levels than the dumped imports from the countries concerned. The Commission therefore concluded that, although some of these imports may have contributed to the injury suffered by the Union industry to a certain extent, none of these factors attenuated the genuine and substantial causal link between the dumped imports from the countries concerned and the material injury established in the investigation.

(262) In light of the above, the Commission concluded that imports from other third countries did not attenuate the genuine and substantial causal link between the injury suffered by the Union industry and the dumped imports from the countries concerned.

5.2.2. Export performance of the Union industry

(263) The volume of exports of the Union industry developed over the period considered as follows:

(264) Since 2021, the Union industry’s exports gradually increased, though remained small compared to total sales. These exports were largely composed of products of higher technical specifications, which shielded them from direct price competition. Consequently, the Union could achieve higher prices for these GFR products in international markets relative to the Union market. This reflected a strategic focus on niche markets abroad.

(265) Export sales allowed the Union industry to improve its overall financial situation thanks to the increased sales volume and achieved price levels, which were higher than on the Union market.

5.2.3. Energy and raw materials costs

(266) The average price of energy of the Union industry developed over the period considered as follows:

(267) The trend in energy prices in the Union during the period considered showed significant volatility and eventual stabilisation. The sharp increase in 2022, in comparison to 2021, was exacerbated by the consequences of the geopolitical tensions affecting energy supply mainly due to Russia’s unjustified and unprovoked war of aggression against Ukraine. The spike in energy prices significantly impacted production costs of the sampled Union producers. By 2023, prices of energy decreased.

(268) The investigation revealed that the cost of the main raw materials increased substantially in 2022, contributing to a significant rise in the unit sales price as the Union industry could pass these costs on to customers. To the contrary, whereas in 2023 raw material costs continued to increase, the unit sales price declined as the Union industry was unable to pass these additional costs on to customers. In the IP, while raw material costs decreased in comparison to the costs observed in years 2023 and 2022, the Union market prices dropped even further because Union industry was not able to maintain or increase its prices due to price pressure by dumped imports.

(269) Following final disclosure, GCC-TSAIP argued that the injury suffered by the Union industry was primarily caused by particular increases in energy, raw material and transportation costs rather than by dumped imports. In this regard, it submitted that the cost of production of Union producers increased significantly between 2022 and the investigation period, reflecting the sharp rise in energy prices following the energy crisis. The submission further referred to public statements by Union producers indicating that operating costs, including electricity and other energy inputs, had increased substantially and that this had led to price increases and financial difficulties for certain producers. According to GCC-TSAIP, these developments demonstrated that the deterioration in the economic situation of the Union industry was driven mainly by increased energy and input costs rather than by imports from the countries concerned.

(270) The Commission rejected this claim. Under fair competition conditions, such cost increases would typically be reflected in higher sales prices. However, the investigation showed that the Union industry was unable to fully pass on these cost increases to its customers due to the significant price pressure exerted by imports from the countries concerned, as explained in recitals (201) to (205). Consequently, while higher electricity and raw material costs may have contributed to increasing the production costs of Union producers, they do not attenuate the genuine and substantial causal link between dumped imports and the injury suffered by the Union industry. Rather, the presence of large volumes of dumped imports at low prices amplified the negative effects of rising costs and prevented the Union industry from restoring sustainable profitability.

(271) On this basis, the Commission concluded that the evolution of energy prices and costs of raw materials did not contribute to the material injury suffered by the Union industry.

5.2.4. Captive volume of the Union industry

(272) Sales in both the free and captive markets exhibited a similar trend over the period considered, with captive sales experiencing a slower decrease. Therefore, captive sales could not be viewed as a factor that undermined the causal relationship between the dumped imports from the countries concerned and their effect on the Union industry.

5.2.5. Conclusion on causation

(273) There was an overall deterioration of the Union industry’s financial situation in 2023 and in IP. These negative circumstances coincided in time with an increased market share of imports of GFR from the countries concerned, which were made at dumped prices undercutting and suppressing the Union industry’s prices and costs.

(274) Other factors which could have caused injury to the Union industry have also been analysed. In this respect, the Commission found that imports from other third countries, the export performance of the Union industry, the increase in energy prices and development on captive market did not contribute to the injury suffered by the Union industry.

(275) In addition, the market share in the investigation period from the countries concerned are above de minimis, exports from both countries are found to be dumped, their imports undercut the Union industry’s prices and price suppression has been established. Those elements show that even in the absence of other imports, whether dumped or not, the dumped imports from the countries concerned caused material injury to the Union industry.

(276) Following initiation, the Association of Independent EU Glass Fibre Weavers and GCC-TSAIP submitted that the alleged injury to the Union industry was not caused by imports from Bahrain, Egypt, and Thailand. These interested parties explained that the market share of these countries’ imports was relatively small and stable compared to the Union industry’s market share and argued that other factors, like increased exports and investments by the Union industry, played a role in the deterioration of their results. Additionally, they noted that imports from China, identified by the complainant as a major source of harm to the Union industry, should be considered as breaking the causal link between the alleged injury and imports from the countries concerned.

(277) The findings of the investigation demonstrated that the imports from Bahrain, Egypt, and Thailand have negatively impacted the Union industry by undercutting prices, gaining market share, and affecting overall performance, financial situation, and employment levels. The Association neglected to address the significant price suppression and depression caused by these imports, which have consistently been entering the Union market at much lower prices than those of the Union producers. The claim that other factors, such as imports from China or the Union industry’s investments and increased exports, are solely responsible for the injury, is not correct. This claim is not supported by evidence and is not capable of attenuating the genuine and substantial causal link established between the imports from the countries concerned and the material injury they caused. Therefore, the claim by the Association of Independent EU Glass Fibre Weavers was rejected.

6. LEVEL OF MEASURES

(278) 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

(279) 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.

(280) 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 countries 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 %.

(281) Regarding the level of profitability before the increase of imports from the countries concerned, it was not possible to establish a profit margin on the basis of any of the years prior to the increase of imports from those countries. Also, the year 2022 was found to be heavily influenced by the post-COVID-19 economic recovery and did not appear appropriate to set the target profit. Therefore, the Commission looked at the profit achieved by the sampled Union producers over a longer time period. In this regard, it considered that the year 2016 was appropriate as it was the most recent year when the Union industry operated under normal market conditions achieving a profit of 12,28 %.

(282) Following final disclosure, GCC-TSAIP argued that the Commission’s use of profitability levels from 2016 as the benchmark for establishing the target profit was not sufficiently justified. In particular, it claimed that the determination did not provide a detailed explanation demonstrating that 2016 reflected normal and undistorted market conditions. According to GCC-TSAIP, the Commission did not assess whether that year was affected by cyclical or structural factors unrelated to dumped imports, nor did it explain why alternative benchmark years or a multi-year average were not considered. GCC-TSAIP therefore argued that relying on a single historical year without a comparative assessment of other potential benchmark periods could lead to an unreliable estimation of sustainable profitability and might not meet the requirement of an objective examination based on positive evidence.

(283) The Commission rejected these claims. As explained in recital (281), the investigation showed that it was not possible to establish an appropriate benchmark profit level based on the years prior to the increase of dumped imports. The Commission therefore considered it appropriate to use the profitability level of 12,28 % achieved by the Union industry in 2016. Although dumped imports were present on the Union market in that year, the Union industry was still performing well and the profitability achieved in 2016 reflected a level of profit that the Union industry could reasonably attain under normal market conditions. In this regard, the Commission recalled that the purpose of the target profit is to approximate the level of profitability that the Union industry could achieve in the absence of injurious dumping. It is therefore not necessary that the benchmark year be entirely free from dumped imports, provided that the Union industry’s performance in that year reflects sustainable operating conditions. Consequently, the Commission concluded that the profitability achieved in 2016 constituted a reasonable and appropriate reference point for establishing the target profit and rejected the arguments raised by the interested party, which were, in addition, of a general nature and did not provide for a concrete method to calculate a better alternative for the target profit used.

(284) The Union industry 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 this information during the RCCs by checking the company’s internal records relating to investment plans, management decisions and financial statements. The claims of the Union industry 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 Union Industry and verified by the Commission with the actual IRI expenses over the period considered. Based on verified information regarding investments which could not be implemented during the period considered, the target profit margins were increased by up to 5,27 % depending on the sampled producers.

(285) Hence, the target profit which was established in this investigation and in accordance with Article 7(2c) of the basic Regulation ranged between 13,25 % and 17,55 % depending on the situation found in each of the sampled companies.

(286) On this basis, the Commission calculated a non-injurious price of the like product for the Union industry by applying the respective target profit margins to the cost of production of the sampled Union producers during the review investigation period.

(287) 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, that the Union industry will incur during the period of the application of the measure. Based on the submitted information, which was supported by the companies’ reporting tools and forecasts, the Commission established that there were no additional costs of compliance with such conventions during the IP.

(288) 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 countries concerned 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.

(289) The injury elimination level for ‘all other imports originating in the country concerned’ is defined in the same manner as the dumping margin for these companies (recitals (79) and (179)).

6.2. Conclusion on the level of measures

(290) Following the above assessment, definitive anti-dumping duties should be set as below in accordance with Article 7(2) of the basic Regulation:

7. UNION INTEREST

7.1. Interest of the Union industry

(291) The investigation established that the Union industry has suffered material injury caused by the dumped imports from the countries concerned during the IP. As explained in the recital (212), during the RIP two Union producers stopped production of GFR altogether due to unfavourable market conditions.

(292) The imposition of measures would allow the Union industry to maintain and/or regain its market share, increase production and capacity utilisation, increase prices to cover cost of production and achieve a level of profitability which would be expected under normal conditions of competition. On this basis, the Union industry would need to return to a sustainable situation which allow it to make future investments.

(293) The non-imposition of measures would likely lead to a further loss of market share and deterioration of profitability, which turned negative in 2023 and in the IP. This would possibly cause additional closures of production facilities and dismissals thus endangering the viability of the Union industry.

(294) The Commission therefore concluded that the imposition of anti-dumping measures on imports of GFR originating in the countries concerned would be in the interest of the Union industry.

7.2. Interest of users and users’ association

(295) During the investigation ten users came forward and provided deficient questionnaire replies. The Commission requested the parties concerned to provide the missing information. However, they did not comply with this request. Consequently, the Commission based its assessment on the limited information available from questionnaire replies and on comments submitted separately by the parties concerned.

(296) The users Rivierasca SpA (IT) and ATP s.r.l (IT) expressed their support for imposition of measures as they emphasised the importance of glass fibre as a crucial input for their products and the necessity of having reliable GFR production to maintain the mechanical integrity and availability of their laminates, which are essential for end-use applications.

(297) The association of users Tech-Fab Europe, which includes three Union producers with one being complainant, came forward in support of imposition measures. Tech-Fab Europe claimed that Union open-mesh glass fabrics (OMF) producers are facing competitive pressure from imports from neighbouring countries that purchase GFR (their raw material) from China and Egypt, without anti-dumping or anti-subsidy duties, are using Chinese technology, and export OMF to the Union at lower prices. Tech-Fab Europe also expressed its concerns about the outcome of the expiry of anti-dumping and anti-subsidy measures on GFF imports from China and Egypt, where they had requested reviews, as well as urged the Commission to impose safeguard measures. As claimed, these measures are crucial to address China’s and Egypt’s overcapacity, address circumvention risks, and maintain a balanced supply chain to protect the Union glass fibre value chain effectively.

(298) Kelteks expressed concerns regarding the potential impact of the anti-dumping measures on imports of GFR from the countries concerned. Kelteks highlighted that their production relies on access to competitively priced raw materials, which sometimes necessitates importing specific glass fibre fabrics not available in adequate specifications or volumes from the Union producers. They cautioned that imposing anti-dumping duties without careful calibration could disrupt supply chains, increase input costs and weaken the competitiveness of Union-based processors like themselves.

(299) Users Tolnatext Fonalfeldolgozo es Müszakiszovet-gyàrto Bt. (‘Tolnatext’) and Dr Günther Kast GmbH & Co. (‘Dr Günther’), which are part of the KAST Group, as well as Proxim Plewka I Wspólnicy sp. k. submitted that Union producers have not increased their capacity to supply the Union market with GFR, especially direct rovings, to adequately meet user demands although they were protected by existing anti-dumping and countervailing measures. They also noted that certain rovings such as low-tex rovings were not actively promoted and sold by Union producers, and, for some, the technical specifications required by users were not met by Union producers’, which makes users extremely dependent on the availability of specified products from alternative sources. Furthermore, users were negatively impacted with increasingly concentrated oligopoly of a few Union producers and that this created further risk of decreasing availability of low-tex rovings. These users (open-mesh glass fabrics (OMF) producers) also confirmed concerns about competition from neighbouring countries such as Moldova, Serbia, Kosovo and North Macedonia. Producers in those countries can freely purchase low-cost, often dumped raw materials (GFR), enabling them to manufacture OMF at significantly lower prices, with which the users (OMF producers) cannot compete.

(300) On 7 May 2025 a hearing took place with Proxim Plewka I Wspólnicy sp.k. who has expressed its disagreement with potential imposition of anti-dumping duties on imports from Bahrain, Egypt and Thailand. During the hearing, as well as in their questionnaire reply, they have raised similar concerts to the ones raised by Tolnatext and Dr Günther.

(301) On 8 May 2025 a hearing took place with HELM. In their presentation, they claimed that there was no causal link between GFR imports from the countries concerned and the situation of the Union industry. Furthermore, they also claimed that the anti-dumping duties would harm Union interest because it would create a supply crisis as considerable number of products imported from the countries concerned were not produced in the Union.

(302) On 11 September 2025 a hearing took place with Tolnatext and Dr Günther during which they reiterated their position with respect to the investigation and emphasised strong opposition to the imposition of the measures against imports from the countries concerned.

(303) On 16 October 2025 a hearing took place with Lamilux, which expressed its disagreement with the potential imposition of anti-dumping duties on imports of GFR originating from the countries concerned. During the hearing, as well as in its subsequent written replies to the Commission’s questions, Lamilux raised similar concerts to the ones made by Tolnatext, Dr Günther and HELM.

(304) The investigation determined that the allegation that Union producers have not increased their capacity to supply the Union market with GFR were unfounded. The Union industry has made substantial investments despite challenging market conditions and has spare capacity. However, further capacity expansion necessitates long-term capital commitments, which rely on maintaining a level playing field where competitive producers can anticipate a fair return on investments. The Union industry was also faced with unfair imports and difficult market conditions.

(305) The Commission further disagreed with the claim that Union producers do not produce certain specific types of GFR or lack sufficient capacity to supply them, or that certain technical requirements are not met. Specifically, the investigation confirmed that several Union producers have the technology and capacity to manufacture low-tex direct rovings, and that the Union industry has spare capacity that could be allocated to additional production. Two of the three sampled Union producers produce assembled rovings, and verification visits confirmed that the Union industry is capable of producing roving spray TEX filament windings, roving spray 2 400 TEX spray-up and woven rovings 600 GR. Different GFR types may have distinct technical specifications and are not fully interchangeable for all applications, they do share, however, the same basic physical, chemical and technical characteristics. The investigation also showed that imports of rovings from the countries concerned are sold at prices which are often below the Union industry’s cost of production, making it commercially unviable for the Union industry to compete at such price levels. Finally, the potential imposition of anti-dumping measures would not prevent exporting producers from continuing to supply the Union market at non-dumped prices, as evidenced by the continued presence of producers already subject to measures. On that basis, the Commission concluded that the Union industry has the technological capability and the capacity to supply the product types concerned.

(306) Concerns regarding market concentration and measures on imports from other countries were analysed. In this respect, the Commission noted that, in general, regulatory bodies carefully scrutinise mergers and acquisitions to prevent anti-competitive behaviour. Furthermore, the investigation did not confirm that the Union market is characterised by a lack of competitive pressure, as significant volumes of imports from third countries continue to be present on the Union market. The possible imposition of measures on imports from countries concerned would not remove these sources of supply but would address material injury to the Union industry. On this basis, these claims were rejected.

(307) Following final disclosure, Lamilux submitted that the imposition of anti-dumping duties on imports of GFR from Egypt would have a significant negative impact on its operations. In particular, it claimed that the Union industry did not offer the specific product type required for its manufacturing process, namely 15 tex chopped strand mats meeting a specific technical specification, including widths of up to 3 400 mm. According to Lamilux, this specification constituted the most important GFR input for its composite materials and it was therefore obliged to source it from Egyptian suppliers. Lamilux further submitted that the imposition of duties would increase its raw material costs significantly, which it would not be able to pass on to its customers given the competitive pressure from imported downstream products. On that basis, Lamilux requested a product-specific exclusion for 15 tex chopped strand mats meeting its specification profile, arguing that Union producers neither produce nor are able to produce and supply this specific product type.

(308) The Commission rejected this claim. The evidence submitted by Lamilux demonstrated only that Union producers do not currently offer the exact specification requested, but it does not establish that the Union industry lacks the technological capability to produce comparable low-tex products. In this regard, the investigation confirmed that Union producers possess the necessary technology and have available capacity that could be allocated to the production of such specifications should market conditions justify it. The Commission therefore considered that the request concerned a specific commercial specification required by an individual user rather than a distinct product type. Consequently, the request for a product-specific exclusion was rejected.

(309) Following final disclosure, Saertex and Amiblu argued that the imposition of anti-dumping measures on imports of GFR from Bahrain, Egypt and Thailand would not be in the Union interest because it would negatively affect downstream industries in the composite materials value chain. In particular, they claimed that Union users of glass fibre products rely on imported rovings to ensure supply security and competitive pricing and that the Union industry would not be able to meet demand if imports were subject to duties. They further argued that the proposed measures would significantly increase raw material costs for downstream manufacturers operating in highly competitive global markets, which would not be able to pass these cost increases on to customers. According to these parties, the resulting increase in production costs would weaken the competitiveness of Union-based manufacturers, encourage relocation of production outside the Union and allow foreign producers of finished composite products to gain market share in the Union. They also submitted that such measures would exacerbate existing cost pressures faced by Union producers, including high energy prices and inflation, and could negatively affect employment and investment decisions in the downstream sector.

(310) The Commission rejected these claims. The investigation demonstrated that imports from the countries concerned exerted significant price pressure on the Union industry thereby causing material injury. The Commission recalled that the objective of anti-dumping measures is to restore fair competition on the Union market by offsetting the injurious effects of dumped imports. The concerns raised by Saertex and Amiblu regarding potential supply shortages, structural market concentration and relocation of production were not substantiated by verifiable evidence. In particular, the investigation established that the Union industry retains spare production capacity and has the technological capability to supply the relevant product types. Moreover, anti-dumping measures do not prevent imports from entering the Union market but merely ensure that they are sold at fair prices. The Commission also noted that glass fibre reinforcements typically represent a limited share of the overall production costs of downstream composite products. Consequently, while the measures may have some impact on input prices, the overall effect on downstream users is expected to remain limited. Therefore, the Commission concluded that the arguments put forward by these parties did not outweigh the need to address the material injury suffered by the Union industry and did not alter the conclusion that the imposition of measures would be in the Union interest.

(311) Following final disclosure, GCC-TSAIP argued that the Commission did not provide a sufficiently detailed statement of reasons in its Union interest assessment. In particular, they claimed that the determination did not clearly explain how the Commission balanced the interests of the Union industry with those of importers, downstream users and other economic operators. According to these parties, the reasoning did not sufficiently specify the analytical framework or economic criteria used to assess whether the potential negative effects on downstream industries could outweigh the benefits of restoring fair competition.

(312) The Commission rejected these claims. The Commission noted that users did not provide complete questionnaire replies. As a result, the information available to the Commission was limited. Nevertheless, the investigation included an examination of the information that was available, including written submissions from users and their associations and the hearings held with several interested parties. The Commission analysed concerns raised regarding supply availability, product specifications, potential price increases and market concentration as described in recitals (304) to (306). The investigation confirmed that the Union industry has the technological capability and spare capacity to supply the relevant product types and that the imposition of measures would not prevent imports from continuing to supply the Union market at fair prices. Furthermore, the Commission found that the Union market remains open to imports from multiple third countries and therefore would not face a supply shortage. On that basis, the Commission concluded that the potential negative effects on downstream users did not clearly outweigh the benefits of restoring fair competition for the Union industry and that there were no compelling reasons against the imposition of measures.

(313) On the basis of the information available to the Commission and in the absence of meaningful reply by users and importers, there was no evidence contradicting the conclusion that any negative impact of the measures on unrelated importers and users is expected to be limited and will not clearly outweigh the positive effect of measures on Union producers.

7.3. Interest of suppliers and trade union

(314) Suppliers to the Union industry Kerkosand spol. s r.o., Westlake Epoxy BV, Minerali Industriali SRL, Spolek pro chemickou a hutní výrobu, akciová společnost and the association of suppliers European Lime Association expressed their support for the imposition of the measures. They emphasised the importance of having all key components and materials within this value chain located in the Union to ensure resilience in strategic sectors. Additionally, maintaining these resources locally would support the supply chain and improve the Union’s ability to come up with new ideas and meet market needs.

(315) Suppliers LB Minerals s.r.o. and Chimica Organica Industriale Milanese S.p.A. also came forward in support of the imposition of measures. In their comments, they highlighted the importance of GFR products as a crucial lightweight raw material that addresses current challenges by substituting for heavier raw materials or providing innovative solutions across various sectors, such as transport, energy, construction, and more.

(316) Trade union IndustriAll Europe representing workers among others in the GFR came forward in support of the imposition of anti-dumping measures, expressing concerns that without decisive action, the Union could face plant closures, undermining industrial efforts and the ambitions of the Green Deal Industrial Plan’s Net Zero Industry Act, which could threaten quality jobs in the GFR and downstream industries.

(317) The Commission therefore concluded that the imposition of anti-dumping measures on imports of GFR originating in the countries concerned would be in the interest of the suppliers and trade unions.

7.4. Conclusion on Union interest

(318) On the basis of the above, the Commission concluded that there were no compelling reasons that it was clearly not in the Union interest to impose definitive measures on imports of the product concerned originating in the countries concerned.

8. DEFINITIVE ANTI-DUMPING MEASURES

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

(320) Definitive anti-dumping measures should be imposed on imports of products originating in Bahrain, Egypt and Thailand, in accordance with the lesser duty rule in Article 7(2) of the basic Regulation. The Commission compared the injury margins established in recital (289) and the dumping margins established in recital (290). The amount of the duties was set at the level of the lower of the dumping and the injury margins.

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

(322) 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 country concerned’. They should not be subject to any of the individual anti-dumping duty rates.

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

(324) 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.

(325) Should 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

(326) 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.

(327) As provisional measures were not imposed in this proceeding, the conditions as set out in Article 10(4) of the basic Regulation for the retroactive application of the definitive anti-dumping duty were not met.

10. FINAL PROVISIONS

(328) In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council⁽¹²⁾, when an amount is to be reimbursed following a judgment of the Court of Justice of the European Union, the interest to be paid should be the rate applied by the European Central Bank to its principal refinancing operations, as published in the C series of the Official Journal of the European Union on the first calendar day of each month.

(329) The measures provided for in this Regulation are in accordance with the opinion of the Committee established by Article 15(1) of Regulation (EU) 2016/1036,

HAS ADOPTED THIS REGULATION: