(1)

By Commission Implementing Regulation (EU) 2020/492 (2), the European Commission (‘the Commission’) imposed anti-dumping duties on imports of certain woven and/or stitched glass fibre fabrics (‘GFF’) originating in the People’s Republic of China (‘China’) and the Arab Republic of Egypt (‘Egypt’) (‘the original measures’). The investigation that led to the imposition of the original measures will hereinafter be referred to as ‘the original investigation’.

(2)

By Commission Implementing Regulation (EU) 2020/776 (3), the Commission imposed definitive countervailing duties on imports of GFF and amended the level of anti-dumping duties imposed by Implementing Regulation (EU) 2020/492.

(3)

By Commission Implementing Regulation (EU) 2022/806 (4), the Commission extended the anti-dumping and countervailing duties to GFF originating in China and Egypt, brought to an artificial island, a fixed or floating installation or any other structure in the continental shelf of a Member State or the exclusive economic zone declared by a Member State pursuant to the United Nations Convention on the Law of the Sea (‘UNCLOS’).

(4)

Following a first anti-circumvention investigation, by Commission Implementing Regulations (EU) 2022/302 (5) and (EU) 2022/301 (6), the Commission extended the anti-dumping and countervailing duties on imports of GFF originating in China consigned from the Kingdom of Morocco (‘Morocco’), whether declared as originating in Morocco or not.

(5)

Following an absorption reinvestigation, by Commission Implementing Regulation (EU) 2022/1233 (7), the Commission amended the level of the anti-dumping duties on imports of GFF originating in Egypt.

(6)

Following a second anti-circumvention investigation, by Commission Implementing Regulations (EU) 2022/1477 (8) and (EU) 2022/1478 (9), the Commission extended the anti-dumping and countervailing duties to imports of GFF consigned from Türkiye, whether declared as originating in Türkiye or not, with the exception of those exported by some specific Turkish companies.

(7)

Following a partial interim investigation, by Commission Implementing Regulations (EU) 2023/2169 (10) and (EU) 2023/2158 (11), an additional Turkish exporting producer was added to the exemption list of, respectively, Implementing Regulations (EU) 2022/1477 and (EU) 2022/1478.

(8)

Regarding companies in China, the anti-dumping duties currently in force are ranging between 34,0 % and 69,0 %.

(9)

Regarding companies in Egypt, the anti-dumping duties currently in force are 33,1 % for all exporting producers.

(10)

Following the publication of a notice of impending expiry (12), the Commission received a request for a review (or ‘the request’) pursuant to Article 11(2) of the basic Regulation.

(11)

The request for review was submitted on 3 January 2025 by Tech-Fab Europe e.V. (‘the applicant’) on behalf of the Union industry of GFF in the sense of Article 5(4) of the basic Regulation. The request for review was based on the grounds that the expiry of the measures would be likely to result in continuation of dumping and recurrence of injury to the Union industry.

(12)

Having determined, after consulting the Committee established by Article 15(1) of the basic Regulation, that sufficient evidence existed for the initiation of an expiry review, on 3 April 2025 the Commission initiated an expiry review with regard to imports into the Union of GFF originating in China and Egypt (‘the countries concerned’) on the basis of Article 11(2) of the basic Regulation. It published a Notice of Initiation in the Official Journal of the European Union (13) (‘the Notice of Initiation’).

(13)

On 13 June 2025, the Commission initiated an expiry review (14) of the anti-subsidy measures applicable to imports of GFF originating in China and Egypt.

(14)

The investigation of continuation or recurrence of dumping covered the period from 1 January 2024 to 31 December 2024 (‘review investigation period’). The examination of trends relevant for the assessment of the likelihood of a continuation and/or recurrence of injury covered the period from 1 January 2021 to the end of the review investigation period (‘the period considered’).

(15)

In the Notice of Initiation, interested parties were invited to contact the Commission in order to participate in the investigation. In addition, the Commission specifically informed the applicant, other known Union producers, the known producers in China and Egypt, known importers, distributors and users about the initiation of the expiry review and invited them to participate.

(16)

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

(17)

The Government of Egypt (‘GOE’) argued that the investigation should not have been initiated, claiming that there were deficiencies with the open version of the request for review as well insufficient evidence on dumping, injury, and causation.

(18)

First, the GOE argued that the assertion that the request for review was supported by producers representing over 50 % of the Union production was not verifiable, as volumes of production and sale in the open version of the request for review were presented as indexes only.

(19)

The Commission disagreed with this claim, as it had carried out a standing examination before initiation. For this purpose, all Union producers mentioned in the request for review and otherwise known to the Commission before initiation have been contacted and taken into consideration in the calculation of representativeness of the applicant.

(20)

In the context of this exercise, 11 Union producers submitted standing replies. In the open version of their standing replies, all of them indicated that they were in favour of the initiation. Those open versions of the standing replies also contained production volumes for each of those Union producers, usually expressed as ranges, thus permitting reasonable understanding of their relative size.

(21)

The Note on Standing, published on the open file on 27 March 2025 (15), indicated the total estimated Union production of the product under review based on these standing replies. The GOE did not make any comments on this note. Based on this information, it was possible to reasonably conclude that the Union producers had standing. The claim was therefore dismissed.

(22)

Second, the GOE claimed that the applicant should have used either the domestic prices in Egypt or the export prices to third countries, instead of constructing the normal value. The GOE added that the normal value was in any event constructed in violation of Article 2.2 and Article 2.2.1.1 of the Agreement on Implementation of Article VI of the General Agreement on Tariffs and Trade (GATT) 1994 (‘ADA’). According to the GOE, the applicant relied on consumption ratios of the Union producers and the data from public sources to estimate key cost elements (including costs of raw materials, labour, and electricity). Selling, general, and administrative expenses (‘SG & A’) and profit margins were also taken from publicly available records of companies in third countries. The GOE claimed that actual costs, SG & A, and profit of Egyptian producers should have been used instead.

(23)

As an additional point, the GOE added that the applicant used deficient data on export prices, which resulted in unfair comparison of the constructed normal value and export prices. The GOE took issue with the fact that the applicant used a variety of publicly available data (such as Eurostat, the Global Trade Atlas (‘GTA’), and price quotations from market intelligence), which were improperly adjusted, to make several calculations of the dumping margins. The GOE claimed that the applicant thus overstated the dumping margins in its request for review.

(24)

As a preliminary point, the Commission highlighted that the legal standard of evidence required for a request for review under Article 11 of the basic Regulation (i.e. ‘sufficient to justify the initiation of an investigation’) makes it clear that the quantity and quality of information in the request for review is not the same as the one on which the Commission bases its findings at the end of an investigation. In fact, the request for review needs to include sufficient evidence of likelihood of continuation of dumping and injury which is reasonably available to the applicant.

(25)

In the present case, the Commission’s analysis of the evidence provided by the applicant, in accordance with Article 11(2) of the basic Regulation, has shown that the request for review contained sufficient evidence of likelihood of continuation or recurrence of dumping and injury, as well as of a causal link between the allegedly dumped imports and the alleged injury for the proceeding to be initiated.

(26)

As concerns sales prices, costs of production, SG & A and profit levels of exporting producers of GFF in China and Egypt, the Commission pointed out that the applicant has in fact precisely met the standards of evidence required at the stage of request for review. Thise exact information are not available to the applicant. It was therefore necessary to estimate dumping margins on the basis of a constructed normal value. In constructing it, the applicant relied on multiple verifiable and publicly available international benchmarks to show that dumping exists under multiple scenarios.

(27)

The same applies to the applicant’s use of international trade statistics to determine export price, as these are the most reliable sources of information on export prices and the Commission considered were reasonably adjusted to ensure fair comparison of sales prices with normal value. These claims were therefore dismissed.

(28)

Third, the GOE claimed that there was insufficient evidence of likelihood of continuation of dumping to initiate the review. The request for review showed that Egyptian exports to the Union had a low market share while their export prices increased over the period considered. In addition, the GOE claimed there was no evidence of predatory pricing or dumping, or that Egyptian exports would increase if the measures lapsed. The GOE further stressed that past dumping practices are not a justification for continuation of the measures.

(29)

The Commission also disagreed with the claim that there was insufficient evidence of likelihood of continuation of dumping. It is incorrect to claim that the past dumping practices were the factor which was considered to have met the standard of sufficiency of evidence. As explained in recitals (24) and (25) above, the applicant met the legal standard for initiation, relying on multiple publicly available benchmarks, to demonstrate that dumping continued. The Commission considered that the evidence in the request for review, showing the continuation of dumping, was reasonably available to the applicant and sufficient to justify the initiation of the investigation. This claim was therefore dismissed.

(30)

Fourth, the GOE claimed that the underlying reason of the request was protectionism rather than the elimination of alleged dumping and injury. However, in addition to the fact that the reason is not among the relevant legal criteria, the GOE provided no evidence to support this claim. The Commission found that the request contained sufficient prima facie evidence of dumping, injury and likelihood of continuation or recurrence of dumping and injury. The claim was therefore rejected.

(31)

Fifth, the GOE claimed that the applicant unfairly linked Egyptian exports to anti-circumvention and absorption practices allegedly attributed to China.

(32)

The request, however, explicitly referenced the relevant anti-circumvention and absorption regulations, which analysed the behaviours of Chinese and Egyptian exporters separately. In addition, contrary to the GOE’s assertion, no absorption practices were attributed to China. Instead, Egyptian exporting producers were found to be absorbing duties, as established in Implementing Regulation (EU) 2022/1233 (see Section 1.1). The claim was therefore rejected.

(33)

Sixth, the GOE further claimed that public statements by Chinese exporting producers regarding their strategies unfairly influenced the assessment of Egyptian exports. However, the GOE failed to demonstrate that the applicant had conflated the behaviours of exporters from the two countries. The claim was therefore rejected.

(34)

Seventh, the GOE claimed that the injury analysis in the request was deficient, as it did not address all injury indicators – specifically, return on investment, ability to raise capital, and wages.

(35)

The Commission pointed out that Article 5 of the basic Regulation does not require that all injury factors mentioned in Article 3(5) of the basic Regulation are analysed in a request for review or show deterioration to establish sufficient evidence of material injury. Indeed, the wording of Article 5(2) of the basic Regulation states that the request for review must contain information on changes in the volume of the allegedly dumped imports, the effect of those imports on prices of the like product on the Union market and the consequent impact of the imports on the Union industry, as demonstrated by relevant (but not necessarily all) factors and indices having a bearing on the state of the Union industry, such as those listed in Articles 3(3) and 3(5) of the basic Regulation. In addition, the request included an assessment of profitability, which is closely linked to return on investment and the ability to raise capital. The claim was therefore rejected.

(36)

Eighth, the GOE argued that Egyptian imports were minor and stable during the period considered in the request for review and thus could not have caused material injury. The GOE also claimed that the Union industry’s difficulties were structural (e.g. competition in the wind energy sector, imports from other countries, market saturation, and global supply shifts) and self-inflicted. Furthermore, the GOE claimed that the request was deficient because it did not isolate the effects of Egyptian imports from other injury factors.

(37)

The Commission pointed out that the request acknowledged that Egyptian imports represented a small share of Union consumption during the review investigation period, this is not uncommon in expiry reviews, where measures may impact imports. The key consideration in such cases is the potential impact if the measures were repealed, not the situation during the period considered. The presence of other injury factors than Egyptian imports does not automatically negate the possible material effect of these imports. Even if Egyptian imports had no injurious effect during the period considered – a claim the GOE did not substantiate – this would not undermine the argument that injury could recur if the measures were allowed to lapse. Also, the GOE did not provide evidence that the injury faced by the Union industry was self-inflicted. The claims were therefore rejected.

(38)

Ninth, the GOE claimed that the allegation in the request for review – that Egyptian exports would be redirected to the Union if the measures were removed – was speculative and unsubstantiated.

(39)

The Commission’s analysis, however, based on prima facie evidence in the request for review, indicated that Egyptian exporting producers had significant capacity which is mainly targeting the Union market and that the Union market remained attractive for exports. Thus, in the absence of measures, an increase in Egyptian imports appeared likely. The claim was therefore rejected.

(40)

Tenth, the GOE claimed that the request lacked sufficient evidence of undercutting and underselling, as it relied on broad market price comparisons rather than transaction-level data.

(41)

At the initiation stage, detailed import pricing per product type is unavailable. Such data becomes available only after verification of the sampled exporting producers’ questionnaire replies, assuming cooperation. It is therefore unrealistic to expect product-specific undercutting and underselling calculations in the request and even later in the investigation if there is no cooperation. At initiation stage, prima facie evidence based on Eurostat average data was deemed sufficient. The claim was therefore rejected.

(42)

Finally, the GOE submitted that the applicant failed to analyse or provide evidence that continuing the measures was in the Union’s interest.

(43)

While there is no legal requirement to examine Union interest in expiry review at the initiation stage, the available evidence did not indicate any Union interest considerations (e.g. adverse impact on users or other economic operators) that would justify terminating the case. This is a matter for the investigation itself to explore. Therefore, the claim was rejected.

(44)

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

(45)

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 volume of production and sales of the like product in the Union in the review investigation period. This sample consisted of two Union producers. The sampled Union producers accounted for more than 25 % of the volume of production and sales in the review investigation period. The sample was representative of the Union industry. In accordance with Article 17(2) of the basic Regulation, the Commission invited interested parties to comment on the provisional sample. No comments on sampling were received.

(46)

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

(47)

No unrelated importers provided the requested information and agreed to be included in the sample.

Sampling of exporting producers in China and Egypt

(48)

To decide whether sampling was necessary and, if so, to select a sample, the Commission asked all exporting producers in China and Egypt to provide the information specified in the Notice of Initiation. In addition, the Commission asked the Mission of People’s Republic of China to the European Union and the Mission of the Arab Republic of Egypt to the European Union to identify and/or contact other exporting producers, if any, that could be interested in participating in the investigation.

(49)

No exporting producers in the countries concerned provided the requested information. The Commission therefore decided that sampling was not applicable.

(50)

The Commission sent a questionnaire concerning the existence of significant distortions in China within the meaning of Article 2(6a)(b) of the basic Regulation to the Government of the People’s Republic of China (‘GOC’). The GOC did not reply to the questionnaire.

(51)

The Commission requested the sampled Union producers to complete the questionnaires, which were made available on its website (16) on the day of initiation.

(52)

Questionnaire replies were received from the two sample Union producers: Vitrulan Composites Oy and European Owens Corning Fiberglas sprl.

(53)

The applicant completed a macroeconomic questionnaire providing the macro indicators.

(54)

The Commission sought and verified all the information deemed necessary for the determination of likelihood of continuation or recurrence of dumping and injury and of the Union interest. Verification visits pursuant to Article 16 of the basic Regulation were carried out at the premises of the following companies:

Union producers:

(55)

On 16 April 2026, the Commission disclosed the essential facts and considerations on the basis of which it intended to maintain the anti-dumping duties in force. All parties were granted a period within which they could make comments on the disclosure.

(56)

No parties made comments on the disclosure, nor did any party request a hearing.

(57)

The product under review is the same as in the original investigation, namely fabrics of woven, and/or stitched continuous filament glass fibre rovings and/or yarns with or without other elements, excluding products which are impregnated or pre-impregnated (pre-preg), and excluding open mesh fabrics with cells with a size of more than 1,8 mm in both length and width and weighing more than 35 g/m2, currently falling under CN codes ex 7019 61 00 , ex 7019 62 10 , ex 7019 62 90 , ex 7019 63 00 , ex 7019 64 00 , ex 7019 65 00 , ex 7019 66 00 , ex 7019 69 10 , ex 7019 69 90 and ex 7019 90 00 (TARIC codes 7019 61 00 81, 7019 61 00 83, 7019 61 00 84, 7019 62 10 81, 7019 62 10 83, 7019 62 10 84, 7019 62 90 81, 7019 62 90 83, 7019 62 90 84, 7019 63 00 81, 7019 63 00 83, 7019 63 00 84, 7019 64 00 81, 7019 64 00 83, 7019 64 00 84, 7019 65 00 81, 7019 65 00 83, 7019 65 00 84, 7019 66 00 81, 7019 66 00 83, 7019 66 00 84, 7019 69 10 81, 7019 69 10 83, 7019 69 10 84, 7019 69 90 81, 7019 69 90 83, 7019 69 90 84, 7019 90 00 81, 7019 90 00 83 and 7019 90 00 84) (‘the product under review’).

(58)

The CN and TARIC codes are given for information only without prejudice to a subsequent change in the tariff classification.

(59)

GFF is used in a wide range of applications. For example, for the production of blades for wind turbines, in the boat, truck and sport equipment production, as well as in pipe rehabilitation system.

(60)

The product concerned by this investigation is the product under review originating in China and Egypt.

(61)

As established in the original investigation, this expiry review investigation confirmed that the following products have the same basic physical and chemical characteristics as well as the same basic uses:

(62)

These products are therefore considered to be like products within the meaning of Article 1(4) of the basic Regulation.

(63)

During the review investigation period, imports of GFF from both Egypt and China continued, albeit at lower levels than in the investigation period of the original investigation (i.e. from 1 January 2018 to 31 December 2018) (‘original IP’). According to Eurostat imports statistics, however, imports of GFF from both countries still retained a significant market share in the Union. Imports from China accounted for about 8 % of the Union market in the review investigation period, while imports from Egypt accounted for about 2 % (compared to 22 % and 9 % market shares during the original investigation, respectively). In absolute terms, imports from China and Egypt stood at 11 345 and 2 514 tons, respectively, in the review investigation period, compared to 37 558 and 15 334 in the original IP, respectively.

(64)

As mentioned in recital (49) above, none of the exporting producers from China or Egypt cooperated in the investigation. Therefore, the Commission informed the authorities of China and Egypt that due to the absence of cooperation, the Commission intended to apply Article 18 of the basic Regulation concerning the findings with regard to China and Egypt. The Commission did not receive any comments or requests for an intervention of the Hearing Officer in this regard.

(65)

Consequently, in accordance with Article 18 of the basic Regulation, the findings in relation to the likelihood of continuation or recurrence of dumping were based on facts available, in particular information in the request for review and information obtained from cooperating parties in the course of the review investigation (namely, the applicant and the sampled Union producers), supplemented with data from publicly available sources.

(66)

Given the sufficient evidence available at the initiation of the investigation tending to show, with regard to China, the existence of significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation, the Commission initiated the investigation on the basis of Article 2(6a) of the basic Regulation.

(67)

In order to obtain information, it deemed necessary for its investigation with regard to the alleged significant distortions, the Commission sent a questionnaire to the GOC. In addition, in point 5.3.2 of the Notice of Initiation, the Commission invited all interested parties to make their views known, submit information and provide supporting evidence regarding the application of Article 2(6a) of the basic Regulation within 37 days of the date of publication of the Notice of Initiation in the Official Journal of the European Union.

(68)

No questionnaire reply was received from the GOC and no submission on the application of Article 2(6a) of the basic Regulation was received within the deadline. Subsequently, the Commission informed the GOC that it would use facts available within the meaning of Article 18 of the basic Regulation for the determination of the existence of the significant distortions in China.

(69)

In the same point 5.3.2 of the Notice of Initiation, the Commission also specified that, in view of the evidence available, it may need to select an appropriate representative country pursuant to Article 2(6a)(a) of the basic Regulation for the purpose of determining the normal value based on undistorted prices or benchmarks.

(70)

On 27 September 2025, the Commission informed the interested parties by a note (‘the FOP Note’) on the relevant sources it intended to use for the determination of the normal value. In that note, the Commission highlighted the absence of cooperation from both the GOC and any exporting producers in China, which was communicated via a Note Verbale to the authorities of the People`s Republic of China (17). The FOP note highlighted that the Commission will therefore rely on facts available according to Article 18 of the basic Regulation.

(71)

In this context, the Commission informed the interested parties that it intended to use the information contained in the request for review to establish the sources that will be used to determine the normal value. The Commission selected Türkiye as an appropriate representative country.

(72)

In the FOP Note, the Commission provided a list of all factors of production such as raw materials, labour and energy used in the production of GFF. It also informed interested parties that it would establish SG & A costs and profit margin based on available information for the company TÜRKİYE ŞİŞE VE CAM FABRİKALARI A.Ş, (‘Şişecam’), a producer in the representative country.

(73)

The Commission received no comments on the FOP Note.

(74)

According to Article 2(1) of the basic Regulation, ‘the normal value shall normally be based on the prices paid or payable, in the ordinary course of trade, by independent customers in the exporting country’.

(75)

However, according to Article 2(6a)(a) of the basic Regulation, ‘in case it is determined […] that it is not appropriate to use domestic prices and costs in the exporting country due to the existence in that country of significant distortions within the meaning of point (b), the normal value shall be constructed exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks’, and ‘shall include an undistorted and reasonable amount of administrative, selling and general costs and for profits’.

(76)

As further explained below, the Commission concluded in the present investigation that, based on the evidence available, and in view of the lack of cooperation of the GOC and the exporting producers, the application of Article 2(6a) of the basic Regulation was appropriate.

(77)

The Commission examined the evidence on the file to decide whether significant distortions within the meaning of Article 2(6a)(b) of the basic Regulation exist in China, rendering the use of domestic prices and costs in that country inappropriate. That analysis covered the following evidentiary elements on the various criteria relevant to establish the existence of significant distortions.

(78)

First, the evidence contained in the request included the following elements pointing to the existence of significant distortions:

(79)

Second, in previous investigations concerning the glass fibre sector in China (29), the Commission found that significant distortions in the sense of Article 2(6a)(b) of the basic Regulation were present. In those investigations, the Commission found that there is substantial government intervention in China resulting in a distortion of the effective allocation of resources in line with market principles (30).

(80)

In particular, the Commission concluded that in the glass fibre sector, not only does a substantial degree of ownership by the GOC persists in the sense of Article 2(6a)(b), first indent of the basic Regulation (31) but the GOC is also in a position to interfere with prices and costs through State presence in firms in the sense of Article 2(6a)(b), second indent of the basic Regulation (32).

(81)

The Commission further found that the State’s presence and intervention in the financial markets, as well as in the provision of raw materials and inputs further have an additional distorting effect on the market. Indeed, overall, the system of planning in China results in resources being driven to sectors designated as strategic or otherwise politically important by the GOC, rather than being allocated in line with market forces (33).

(82)

Moreover, the Commission concluded that the Chinese bankruptcy and property laws do not work properly in the sense of Article 2(6a)(b), fourth indent of the basic Regulation, thus generating distortions in particular when maintaining insolvent firms afloat and when allocating land use rights in China (34).

(83)

In the same vein, the Commission found distortions of wage costs in the glass fibre sector in the sense of Article 2(6a)(b), fifth indent of the basic Regulation (35), as well as distortions in the financial markets in the sense of Article 2(6a)(b), sixth indent of the basic Regulation, in particular concerning access to capital for corporate actors in China (36).

(84)

Third, in the original investigation that led to the imposition of the original measures (37), the Commission concluded that significant distortions within the meaning of point (b) of Article 2(6a) of the basic Regulation were present. No major structural changes in China in general and/or in the relevant sector in particular, capable of affecting that conclusion, are known to the Commission.

(85)

Fourth, additional evidence available in the Report on Significant Distortions in the Economy of China (‘Report’) (38), prepared by the Commission pursuant to Article 2(6a)(c) of the basic Regulation, pointed to the existence of significant distortions also during the review investigation period.

(86)

Fifth, no evidence or arguments to the contrary have been adduced by the GOC or the exporting producers in the present investigation.

(87)

In view of the above, the evidence available showed that prices or costs of the product under review, including the costs of raw materials, energy and labour, are not the result of free market forces because they are affected by substantial government intervention within the meaning of Article 2(6a)(b) of the basic Regulation as shown by the actual or potential impact of one or more of the relevant elements listed therein.

(88)

On that basis, the Commission concluded that it is not appropriate to use domestic prices and costs to establish normal value in this case. Consequently, the Commission proceeded to construct the normal value exclusively on the basis of costs of production and sale reflecting undistorted prices or benchmarks, that is, in this case, on the basis of corresponding costs of production and sale in an appropriate representative country, in accordance with Article 2(6a)(a) of the basic Regulation.

(89)

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

(90)

As explained in recitals (70) to (73) above, the Commission published a note for the file on the sources for the determination of the normal value. This note described the facts and evidence underlying the relevant criteria and informed the interested parties of its intention to consider Türkiye as an appropriate representative country in the present case if the existence of significant distortions pursuant to Article 2(6a) of the basic Regulation would be confirmed. In recital (88) above the Commission concluded to the existence of significant distortions.

(91)

In the FOP note, the Commission identified Türkiye as country with a similar level of economic development as China according to the World Bank, i.e. they are all classified by the World Bank as ‘upper-middle income’ countries on a gross national income basis where production of the product under review was known to take place. The product under review was produced in Türkiye.

(92)

In the FOP note, the Commission explained that neither the GOC nor any exporting producers in China cooperated with the investigation. The FOP note highlighted that the Commission will therefore rely on facts available according to Article 18 of the basic Regulation, i.e., use the information contained in the expiry review request to select the representative country and establish the sources that will be used to determine the normal value.

(93)

The Commission thus considered Türkiye as an appropriate representative country.

(94)

In the FOP Note the Commission also indicated that relevant financial data of a GFF producer in Türkiye was also readily available.

(95)

In the light of the above considerations, the Commission informed the interested parties in the FOP note that it intends to use Türkiye as an appropriate representative country and the readily available financial statements of Şişecam in order to source undistorted prices or benchmarks and financial data for the calculation of normal value, in accordance with Article 2(6a)(a), first ident of the basic Regulation.

(96)

Interested parties were invited to comment on the appropriateness of Türkiye as a representative country and of Şişecam as a producer in the representative country. No comments were received.

(97)

The initial selection of potential representative country(ies) and of suitable companies with readily available data does not prevent the Commission from the possibility to supplement or refine such selection and its research at a later stage, including by putting forward new suggestions in terms of potential representative country and similar product. Indeed, it is the very purpose of the notes on factors of production, to invite interested parties to comment on the Commission services’ preliminary research and, if warranted, to receive alternatives for the Commission services’ further consideration. These notes even contain a specific annex to guide parties in submitting information on possible additional representative countries and/or companies for the purpose of Article 2(6a)(a) of the basic Regulation.

(98)

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

(99)

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

(100)

In the FOP Note, the Commission listed the factors of production such as materials, energy and labour used in the production of the product under review by the exporting producers and invited the interested parties to comment and propose readily available information on undistorted values for each of the factors of production mentioned in that note.

(101)

In the FOP Note the Commission stated that, in order to construct the normal value in accordance with Article 2(6a)(a) of the basic Regulation, it would use GTA to establish the undistorted cost for the main raw material, glass fibre rovings. In addition, the Commission stated that it would use the data from Turkish Statistical Institute (41) and Eurostat (42) for establishing undistorted costs of labour and energy, respectively.

(102)

Considering all the information based on the request for review, the following factors of production and their sources have been identified in order to determine the normal value in accordance with Article 2(6a)(a) of the basic Regulation:

Table 1

Factors of production of GFF

(103)

In order to establish the undistorted price of glass fibre rovings as delivered at the gate of a representative country producer, the Commission used as a basis the weighted average import price to the representative country as reported in the GTA to which import duties were added.

(104)

An import price in the representative country was determined as a weighted average of unit prices of imports from all third countries excluding China and countries which are not members of the WTO, listed in Annex I of Regulation (EU) 2015/755 of the European Parliament and the Council (46). The Commission decided to exclude imports from China into the representative country as it concluded in recitals (77) to (88) above that it is not appropriate to use domestic prices and costs in China due to the existence of significant distortions in accordance with Article 2(6a)(b) of the basic Regulation.

(105)

Given that there is no evidence showing that the same distortions do not equally affect products intended for export, the Commission considered that the same distortions affected export prices. After excluding imports from China into the representative country, the volume of imports from other third countries remained representative.

(106)

The Commission also found that more than 80 % of imports of the main raw material (glass fibre rovings) into Türkiye were coming from Egypt, with prices lower than any other source of imports.

(107)

In Commission Implementing Regulation (EU) 2020/870 (47), the Commission has found that the only GFR producer in Egypt, and, consequently, the only producer of glass fibre rovings, is Jushi Egypt. As established in that regulation, Jushi Egypt was owned by Chinese companies and was being subsidised by both China and Egypt. Implementing Regulation (EU) 2020/870 thus countervailed exports of GFR into the Union.

(108)

Given that Jushi Egypt continues to be the sole exporting producer of glass fibre rovings in Egypt, there is no reason to assume that the same subsidies do not equally affect prices of products exported to other markets, the Commission considered that the same distortions affected export prices of glass fibre rovings to Türkiye. After excluding imports from Egypt into the representative country, the volume of imports from other third countries still remained representative, at more than 10 000 tons.

(109)

With regard to import duties, the Commission noted that Türkiye imported glass fibre rovings from more than 20 countries, with a varying level of import duty rates and significant differences in volumes. The Commission calculated import duties for glass fibre rovings on the basis of the level of duties applicable to glass fibre rovings imports from each of these countries.

(110)

Normally, domestic transport prices should also be added to these import prices. However, considering the level of dumping margins calculated below, as well as the nature of this expiry review investigation, which is focused on finding whether dumping continued during the review investigation period or could reoccur, rather than finding its exact magnitude, the Commission decided that adjustments for domestic transport were unnecessary. Such adjustments would only result in an increase of the normal value and consequently a higher dumping margin.

(111)

Turkish Statistical Institute publishes detailed information on wages in different economic sectors in Türkiye. The Commission established the benchmark for the review investigation period based on the hourly average labour cost for the manufacturing sector under NACE (48) code C-23 for 2022, i.e. the economic activity ‘Manufacture of other non-metallic mineral products’ according to NACE Rev.2 classification. The values were further adjusted for inflation using the labour cost index published by the Turkish Statistical Institute (49) to reflect the costs in the review investigation period.

(112)

The price of electricity for companies (industrial users) in Türkiye is published by Eurostat. The Commission used the data on the industrial electricity prices in the corresponding consumption band in CNY/kWh for the RIP, as published on 10 September 2025 (50).

(113)

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

(114)

In order to establish an undistorted value of the manufacturing overheads and given the absence of cooperation from the exporting producers, the Commission used facts available in accordance with Article 18 of the basic Regulation. Therefore, based on the data provided by the applicant in the request for review, the Commission established the ratio of manufacturing overheads to the total manufacturing and labour costs. This percentage was then applied to the undistorted value of the cost of manufacturing to obtain the undistorted value of manufacturing overheads.

(115)

SG & A and profit were based on readily available information for the company Şişecam (see recital (118) below).

(116)

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

(117)

First, the Commission established the undistorted manufacturing costs. In the absence of cooperation by the exporting producers, the Commission relied on the information provided by the applicant in the review request on the usage of each factor (materials and labour) for the production of GFF. The Commission multiplied the weighted average of consumption ratios of the main product categories by the undistorted costs per unit observed in the representative country (Türkiye), as described in Section 3.2.5 above.

(118)

Once the undistorted manufacturing cost was established, as noted above, the Commission added the manufacturing overheads, as well as SG & A costs and profit margin. Manufacturing overheads were determined based on the data provided by the applicant. SG & A costs and profit margin were determined based on the financial statements of Şişecam for the year 2023, as reported and adjusted for inflation in the company’s audited accounts for year 2024 (51) (see Section 3.2.5).

(119)

Specifically, the Commission added the following items to the undistorted costs of manufacturing:

(120)

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

(121)

In the absence of cooperation by exporting producers from China, the export price was determined based on CIF Eurostat data corrected to ex-works level. Thus, the CIF price was reduced by the (sea) freight and insurance cost and domestic transport cost.

(122)

The Commission compared the constructed normal value established in accordance with Article 2(6a)(a) of the basic Regulation and the export prices established on an ex-works basis as described above.

(123)

No adjustment was made to the normal value and/or the export price for differences affecting prices and price comparability, in accordance with Article 2(10) of the basic Regulation.

(124)

The Commission compared the weighted average normal value of the like product with the weighted average export price of the product under review, in accordance with Article 2(11) and (12) of the basic Regulation.

(125)

On this basis, the weighted average dumping margins expressed as a percentage of the CIF Union frontier price, duty unpaid, was 59,0 % for exports from China. It was therefore concluded that dumping continued during the review investigation period.

(126)

As already indicated in recital (49) above, no Egyptian exporting producer cooperated in the investigation. Therefore, the Commission based its findings on dumping on facts available, in accordance with Article 18 of the basic Regulation.

(127)

As there was no available information on domestic prices of GFF in Egypt for Hengshi Egypt or Jushi Egypt, the Commission constructed the normal value for Egypt on the basis of Article 2(3) of the basic Regulation using data indicated in the request for review.

(128)

Specifically, for raw materials, the applicant used export statistics of glass fibre rovings from Comtrade database (52). The reason why this approach was chosen instead of relying on imports of glass fibre rovings into Egypt is because almost the entirety of those imports was coming from China, and were likely intra-company transfers of Jushi group.

(129)

For electricity, electricity prices for businesses in Egypt from Global Petrol Prices (53) were used. For labour costs, salaries published by Salary Explorer (54) for the ‘Factory and Manufacturing’ sector in Egypt were used.

(130)

Appropriate amounts for manufacturing overheads, SG & A and profits were added to such costs of manufacturing, which were based on the data provided by the applicant.

(131)

The same share of manufacturing overheads in the direct costs of manufacturing calculated on the basis of data provided by the applicant as for the normal value in China, 16,8 %, was added (see recital (119) above).

(132)

Hengshi Egypt’s financial statements were not readily available, and Jushi China’s financial statements did not provide information about the SG & A costs of Jushi Egypt. The applicant therefore used the SG & A data of the Turkish producer of GFF-Şişecam. The Commission followed the same approach and applied Şişecam’s SG & A of 11,24 % of COGS as indicated in recital (119) above.

(133)

Profit margin of 20,1 % was also added to the cost of manufacturing, as submitted in the request for review. The applicant used the publicly available financial statements of Jushi China to source the profit.

(134)

In the absence of cooperation by exporting producers from Egypt, the export price was determined based on CIF Eurostat data corrected to ex-works level. Thus, the CIF price was reduced by the (sea) freight and insurance cost and domestic transport cost.

(135)

The Commission compared the constructed normal value established in accordance with Article 2(3) of the basic Regulation on the basis of facts available and the export prices established on an ex-works basis as described above.

(136)

No adjustment was made to the normal value and/or the export price for differences affecting prices and price comparability, in accordance with Article 2(10) of the basic Regulation.

(137)

The Commission compared the weighted average normal value of the like product with the weighted average export price of the product under review, in accordance with Article 2(11) and (12) of the basic Regulation.

(138)

On this basis, the weighted average dumping margins expressed as a percentage of the CIF Union frontier price, duty unpaid, was 100,26 % for exports from Egypt. It was therefore concluded that dumping continued during the review investigation period.

(139)

Further to the finding of the existence of dumping during the review investigation period, the Commission investigated, in accordance with Article 11(2) of the basic Regulation, the likelihood of continuation of dumping, should the measures be repealed. The following additional elements were analysed: the production capacity and spare capacity in Egypt and China, the attractiveness of the Union market, and circumvention and absorption practices.

(140)

Due to total absence of cooperation from Egypt, China, and exporting producers in both countries, the findings on production capacities and spare capacities were based on facts available, specifically, the information provided in the expiry review request.

(141)

The applicant provided evidence that total production capacity of GFF in China was about 1 400 000 tonnes in the RIP, with around 800 000 tons of overcapacity. After deduction of domestic demand and total exports, the Chinese producers’ free capacity available for the Union market was estimated at about 700 000 tonnes, which is 5 times more that the total Union consumption.

(142)

As concerns Egyptian capacities, evidence shows that the only two GFF producers in Egypt (Hengshi Egypt and Jushi Egypt) were set up with the aim to supply the Union market. Hengshi Egypt and Jushi Egypt belong to the same group of companies incorporated in China, and they are both located in the China-Egypt Suez Economic and Trade Cooperation Zone. They are ultimately controlled by a Chinese government agency and were set up under a strategy to foster China’s outward expansion.

(143)

While Jushi Egypt was set up with the primary goal to export GFR to the EU, Hengshi Egypt was subsequently set up to complement its product portfolio with GFF. As of 2017, Hengshi’s GFF capacity, estimated by the applicant, stands at 30 000 tons, or at 22 % of total Union consumption.

(144)

In addition, the applicant has shown that the Union has been one of the main destinations for Egyptian GFF from 2022 onwards, while Egyptian domestic market for GFF is minimal, with a demand of no more than 1 500 tons annually.

(145)

The Commission therefore concluded that Chinese and Egyptian producers have sufficient capacities that they would be ready to deploy to sharply increase their exports to the Union market if the measures are allowed to lapse.

(146)

Despite both anti-dumping and countervailing duties in force, which come in addition to the conventional import duties for imports from China (ranging between 5 % and 7 % for different customs codes which the product concerned falls under), Chinese and Egyptian exporting producers continue to export to the Union. Import volumes from both countries have even increased in absolute terms during the period considered: Chinese import volumes increased by 102 % and Egyptian by 115 %.

(147)

GTA export data showed that the prices of Chinese exports to the Union, before shipping costs and duties, were around 15 % higher than the weighted average export prices to the ten largest export markets. Considering the importance of the Union market for Chinese and Egyptian exporting producers, and that Chinese exporting producers are able to sell at such prices to the Union even despite the measures in force, it is clear that the Union market remains highly attractive.

(148)

In addition, the existence of circumvention and absorption practices, which were addressed by amendments to the measures outlined in Section 1.1 above, further shows the attractiveness of the Union market.

(149)

As outlined above, continuation of dumping was found, with significant dumping margins for both Egypt and China. Considering the significant spare capacity in China and size of capacities in Egypt, as well as the attractiveness of the Union market and previous circumvention practices, the Commission concluded that allowing measures to lapse would likely lead to the continuation of dumping, with dumped exports entering the Union market in substantial quantities.

(150)

Based on information available to the Commission, the like product was manufactured by 18 producers in the Union during the period considered. They constitute the ‘Union industry’ within the meaning of Article 4(1) of the basic Regulation.

(151)

The total Union production during the review investigation period was established at 100 653 tonnes. The Commission established the figure on the basis of all the available information concerning the Union industry, such as:

As indicated in recital (45), two Union producers were selected in the sample. They represented [30 %–40 %] of the total Union production of the like product.

(152)

The Commission established the Union consumption on the basis of the macroeconomic questionnaire reply and Eurostat import data.

(153)

Union consumption developed as follows:

Table 2

Union consumption (in tonnes)

(154)

Union consumption increased by 11 % between 2021 and 2022, driven by the recovery and rebuilding of stocks at downstream industries after the pandemic.

(155)

Between 2022 and 2024, Union consumption evolved under the influence of two opposing trends. On the one hand, demand from wind turbine and blade manufacturers decreased, as those producers faced increased competitive pressure from Chinese imports in the Union. On the other hand, demand from other end-use markets, in particular the cured-in-place pipe lining (‘CIPP’) sector, increased. Overall, these opposing developments resulted in a stabilization of Union consumption, which fluctuated within a narrow range after 2021.

(156)

The Commission established the volume of imports on the basis of data from Eurostat. The market share of the imports was established on the basis of the import volume and the total Union consumption.

(157)

Imports into the Union from the countries concerned developed as follows:

Table 3

Import volume and market share

(158)

The volume of imports from China and Egypt increased respectively by 102 % and 115 % over the period considered.

(159)

During the period considered, the Union consumption increased by only 13 %. As a result, the countries concerned increased their market share: from 5 % to 8 % for China, from 1 % to 2 % for Egypt.

(160)

The Commission established the prices of imports from countries concerned on the basis of Eurostat import data.

(161)

The weighted average price of imports into the Union from the countries concerned developed as follows:

Table 4

Import prices (EUR/tonne)

(162)

The weighted average price of imports from the countries concerned on the Union market increased by 23 % from 2021 to 2022, stayed stable in 2023 and decreased in the review investigation period approximately to the level of 2021.

(163)

In relation to the consideration of price undercutting during the investigation period, the non-cooperation of exporting producers and the consequent lack of transactional data made the calculation of the actual price undercutting (type-by-type comparisons) impossible. In particular, given the statistical nature of the data, average import prices do not capture product mix differences, which are inherently substantial for the product under review. This is illustrated by the evidence obtained from Union producers, whose sales prices vary considerably across product types. Thus, the exporting producers’ failure to cooperate created the very evidential gap that prevented the Commission from calculating undercutting.

(164)

In these circumstances, since the import statistics could not be used to conclude that there was no undercutting during the investigation period, other elements had to be considered. In particular, the Commission could infer the existence of significant price effects of imports from the countries concerned from the facts available on the record.

(165)

During the period considered, the volume of imports from the countries concerned increased at a higher pace as compared to the moderate rise in Union consumption. The increase in imports from the countries concerned contributed to the erosion of the Union industry’s sales volume and market share, as well as to the Union’s industry chronic inability to raise its prices to cover its costs. In such a scenario, facts available thus point to the existence of price undercutting and price suppression.

(166)

Imports of GFF from third countries other than China and Egypt originated mainly in India, Türkiye and Thailand.

(167)

The aggregated volume of imports into the Union as well as the market share and price trends for imports of GFF from other third countries developed as follows:

Table 5

Imports from third countries

(168)

The Commission examined the evolution of the volumes, CIF prices and duty paid (‘DDP’) prices of imports from third countries. The duty paid price was obtained by adding the applicable conventional and anti-dumping duty to the CIF price.

(169)

Regarding India, the volume of imports increased significantly during the period considered and reached a market share of 11 % during the RIP. Throughout the period considered, the average CIF and DDP prices of imports from India were significantly lower than the average Union industry sales price and cost of production. In the review investigation period, the prices at DDP level were lower by 16 % and 24 %, respectively.

(170)

Regarding Türkiye, the volume of imports was multiplied by six between 2021 and 2022 to reach a market share of 15 % in 2022. In September 2022, following the anti-circumvention investigation mentioned in recital (6) above (55), the Commission extended the anti-dumping measures to imports of GFF consigned from Türkiye, whether declared as originating in Türkiye or not, with the exception of those exported by some specific Turkish companies. Imports from Türkiye started decreasing in 2023 but still represented a market share of 6 % during the RIP. Throughout the period considered, the average CIF and DDP prices of imports from Türkiye were significantly lower than the average Union industry sales price and cost of production. In the RIP, the prices at DDP were lower by 14 % and 22 % respectively.

(171)

Regarding Thailand, the volume of imports started from a very low base of 229 tonnes in 2021 and reached a market share of 3 % during the RIP. Throughout the period considered the average CIF and DDP prices of imports from Thailand were significantly lower than the average Union industry sales price and cost of production. In the RIP, the prices at DDP level were lower by 42 % and 48 %, respectively.

(172)

The total volume of imports from other third countries decreased over the period considered and their market share went from 10 % to 4 %. From 2022 to the RIP, the average CIF price of imports from other third countries was significantly higher than the average Union industry sales price and cost of production.

(173)

The assessment of the economic situation of the Union industry included an evaluation of all economic indicators having a bearing on the state of the Union industry during the period considered.

(174)

As mentioned in recital (45), sampling was used for the assessment of the economic situation of the Union industry.

(175)

For the injury determination, the Commission distinguished between macroeconomic and microeconomic injury indicators.

(176)

The Commission evaluated the macroeconomic indicators on the basis of verified data contained in the reply to the macroeconomic questionnaire submitted by the applicant. The Commission evaluated the microeconomic indicators on the basis of data contained in the questionnaire replies from the sampled Union producers. Both sets of data were found to be representative of the economic situation of the Union industry.

(177)

Taking into account that the micro indicators used in the injury analysis were sourced from only two sampled Union producers, the figures established on the basis of this data presented below are given in ranges in order to protect confidentiality of the Union producers’ data.

(178)

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.

(179)

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

(180)

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

Table 6

Production, production capacity and capacity utilisation

(181)

The production volume of Union producers fluctuated but showed an overall decline of 11 % during the period considered. This is due to a decrease in demand from wind blade makers who are themselves exposed to Chinese competition. This decrease in demand was partially compensated by demands in other sectors mentioned in recital (155). However, production runs to serve these other sectors are shorter, resulting in more frequent machine reconfiguration and longer machines idle time, which impacts negatively the capacity utilisation.

(182)

Production capacity globally decreased by only 2 % over the period considered and, consequently, capacity utilization decreased by 9 %. Low capacity utilisation, driven by the inability to sell sufficient volumes at viable prices, contributed to precarious situation of the Union industry.

(183)

The Union industry’s sales volume and market share developed over the period considered as follows:

Table 7

Sales volume and market share

(184)

The sales volume on the Union market remained stable in 2022 compared to 2021 and then increased by 10 percentage points in 2023. In the review investigation period, however, sales dropped by 8 551 tonnes or 9 percentage points on a yearly basis. Over the period considered, sales decreased by 2 % while the Union consumption increased by 13 %, which resulted in a decrease of Union industry’s market share from 76 % to 66 % over the period considered. Not only the Union industry did not benefit from the growing Union market, but it even lost a significant part of its market share.

(185)

The investigation showed that the Union industry could not maintain their market share in a context of growing demand, contrary to the countries concerned which gained market share during the period considered.

(186)

Employment and productivity developed over the period considered as follows:

Table 8

Employment and productivity

(187)

Employment remained relatively stable during the period considered.

(188)

With employment remaining broadly stable and production volumes declining, labour productivity deteriorated by 13 % over the period considered. As explained in recital (181), demand progressively shifted towards products manufactured in smaller series, requiring more frequent machine reconfigurations, which in turn increased idle time and also negatively impacted productivity.

(189)

Both the Chinese and Egyptian dumping margins were significantly above the de minimis level.

(190)

Volumes of imports from the countries concerned increased significantly during the period considered.

(191)

Despite the anti-dumping measures in place, most injury indicators deteriorated during the period considered and the Union industry was in a precarious situation during the review investigation period.

(192)

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

Table 9

Sales prices and cost of production in the Union (EUR/tonne)

(193)

The average Union industry sales price was below the average unit cost of production during the entire period considered. The highest unit sales price was reached in 2023 because the price was quoted in agreements signed in 2022 on the basis of high energy costs.

(194)

During the period considered, the Union industry’s sales price increased by 9 %. This only partially offset the 20 % increase in the cost of production over the same period, leading to a deterioration of its profitability.

(195)

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

Table 10

Average labour costs per employee (EUR)

(196)

The average labour cost per employee increased by 6 % over the period considered.

(197)

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

Table 11

Inventories

(198)

Following a decrease in 2022 due to COVID-related rebalancing, stock level increased again reaching [20–25 %] of production by the end of the review investigation period. Increasing stock levels indicate that the Union industry was producing goods it could not sell at viable prices or in sufficient quantities. This directly reflects a deterioration in the competitive position of the industry.

(199)

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

Table 12

Profitability, cash flow, investments and return on investments

(200)

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. As shown in Table 9, the unit cost of production increased faster than the unit sales price and therefore profitability continuously and significantly deteriorated during the period considered.

(201)

The net cash flow is the ability of the Union producers to self-finance their activities. Except for 2022, where post-COVID rebalancing of stocks influenced cash flow positively, this injury indicator deteriorated during the period considered and ended significantly negative in the review investigation period. The decreasing cash flows also decreased the ability to raise capital.

(202)

Investment increased over the period considered by 25 %. They were found to be mainly related to replacement, rationalisation and compliance with environmental and social legislation.

(203)

The return on investments is the profit in percentage of the net book value of investments. It started positively in 2021, then fell continuously during the period considered and dropped below - 25 % in the review investigation period.

(204)

Despite the downward trend in cash flow and return on investment, the Union industry was able to finance the investments needed, as described in recital (202).

(205)

Most injury indicators showed a negative trend during the period considered.

(206)

The production of the Union industry declined over the period considered and the sales in the Union market decreased by 2 % despite the increase by 13 % of Union consumption. This resulted in a loss of market share, which fell from 76 % in 2021 to 66 % in the RIP. This loss in market share in a growing market benefitted China and Egypt and other third countries over the period considered.

(207)

The loss of market share for the Union industry on the Union market was aggravated by the decrease by 49 % of the export sales over the period considered as shown in Table 13 below.

(208)

The production capacity of the Union industry declined by 2 % over the period considered and capacity utilisation decreased from 45 % to 41 %, due to the decrease in production.

(209)

Employment remained stable over the period considered. Productivity developed in line with the changes in production and decreased by 13 % over the period considered.

(210)

The unit cost of production increased by 20 % over the period considered.

(211)

The average sales price of Union producers increased only by 9 % in a market subject to pressure from low prices, an insufficient increase to match the increase in production costs.

(212)

The profitability of the Union industry declined continuously during the period considered, reaching the range of [- 7 to - 10 %] in the review investigation period.

(213)

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 during the review investigation period.

(214)

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. 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.

(215)

As explained in Section 5.3.2, despite the anti-dumping and anti-subsidy measures, the volume of Chinese and Egyptian imports increased over the period considered, with their market share increasing from 6 % in 2021 to 10 % during the review investigation period.

(216)

The sustained increase in market share of imports at dumped prices from Egypt and China over the period considered placed the Union industry under compounding price and volume pressure. The consequent decline in sales volumes and price suppression is a direct cause of the injury suffered by the Union industry during the review investigation period.

(217)

The volume of imports from other third countries developed over the period considered as shown in Table 5.

(218)

Recitals (169) to (171) show that the average duty paid prices of imports from India, Türkiye and Thailand were significantly lower than the average duty paid prices of Chinese and Egyptian imports in 2023 and the review investigation period. In view of their large market share and their low average duty paid prices, the Commission concluded that the imports from India, Türkiye and Thailand also exerted a price pressure and contributed to the injury suffered by the Union industry. However, because the imports from China and Egypt almost doubled over the period considered, with significant increase particularly between 2023 and the review investigation period at prices exerting significant price pressure, the Commission concluded that imports from third countries did not change this fact and did not attenuate the causal link.

(219)

The total volume of exports of the Union industry and the average export sales prices of the sampled Union producers developed over the period considered as follows:

Table 13

Export performance of the sampled Union producers

(220)

On third-country markets, the Union producers were exposed to fierce competition regarding wind products and increasingly squeezed into narrower markets, such as the CIPP and the leisure (boat hulls, mobile home) markets, characterised by higher prices but also by higher costs of production.

(221)

Export performance deteriorated continuously during the period considered, resulting in 49 % decrease of the export volume.

(222)

Because the Union industry’s sales were largely geared towards the Union market and not predominantly towards exports, the Commission concluded that the export performance of the Union industry did not attenuate the causal link.

(223)

Based on the above, the Commission concluded that the Chinese and Egyptian dumped exports caused the material injury suffered by the Union industry. At the same time, third country imports also contributed to the injury suffered by the Union industry during the review investigation period. However, the Commission concluded that those factors, individually or collectively, did not attenuate the causal link between the dumped Chinese and Egyptian imports and the injury suffered by the Union industry during the review investigation period.

(224)

The Commission concluded that the Union industry suffered material injury during the review investigation period.

(225)

The Commission concluded that Chinese and Egyptian imports caused injury to the Union industry during the RIP with third country imports contributing to an extent to material injury. Therefore, the Commission assessed, in accordance with Article 11(2) of the basic Regulation, whether there would be a likelihood of continuation or recurrence of injury caused by the dumped imports from China and Egypt if the measures against these countries were allowed to lapse.

(226)

In this regard, the Commission examined the production capacity and spare capacity in the countries concerned, the attractiveness of the Union market and likely price levels of imports from the countries concerned in the absence of anti-dumping measures, and their impact on the Union industry.

(227)

As explained in recital (141) above, the total production capacity of GFF in China was about 1 400 000 tonnes in the review investigation period. After deduction of domestic demand and total exports, the Chinese producers’ free capacity available for the Union market is about 700 000 tonnes, which is five times more than the total Union consumption.

(228)

As explained in recitals (142) to (144) above, production capacity of GFF in Egypt is at least 30 000 tonnes, or around 22 % of total consumption in the Union, while Egyptian domestic market for GFF appears to be minimal.

(229)

Therefore, it can be concluded that there is substantial spare capacity in China and substantial capacity in Egypt that can be directed to the Union market in even larger quantities at dumped prices if anti-dumping measures are allowed to lapse.

(230)

As already explained in Section 4.2 above, the attractiveness of the Union market is proved by the fact that despite the relatively high level of anti-dumping duties in force, which come in addition to the conventional import duty ranging between 5 % and 7 % for imports from China, the Union remained one of the main export markets for Chinese and Egyptian exporting producers, and they even increased their export volume during the period considered, by 102 % for China and 115 % for Egypt, with Chinese exports to the Union able to fetch high prices compared to other markets, even despite the measures in force.

(231)

Further evidence of the attractiveness of the Union market is provided by the existence of the following circumvention and absorption practices during the period considered which were addressed by the Regulations referred to in Section 1.1 above:

(232)

As shown in Table 4, import prices at CIF level into the Union from China during the RIP were 1 744 EUR/tonne, which is lower than the average sales price of the Union industry [2 100–2 400] EUR/tonne shown in Table 9, and also below their cost of production [2 300–2 600] EUR/tonne.

(233)

In the absence of anti-dumping measures, with only anti-subsidy measures in place, Chinese imports would have entered the Union at even lower prices. The undercutting would in reality be expected to be even higher as explained in recital (165).

(234)

As shown in Table 4, import prices at CIF level into the Union from Egypt during the RIP were 1 431 EUR/tonne, which is lower than the average sales price of the Union industry [2 100–2 400] EUR/tonne shown in Table 9, and also below their cost of production [2 300–2 600] EUR/tonne.

(235)

In the absence of anti-dumping measures, with only anti-subsidy measures in place, Egyptian imports would have entered the Union at even lower prices.

(236)

Therefore, it is likely that without anti-dumping duties, the Chinese and Egyptian imports would have an even greater negative impact on the Union prices.

(237)

This finding clearly shows that in any case there would be likelihood of recurrence of injury caused by imports, which in addition would likely to arrive in significantly higher quantities should the measures lapse.

(238)

Based on the foregoing analysis, the Commission concluded that the Union industry has suffered material injury caused by dumped imports originating in China and Egypt. Furthermore, and without prejudice to that finding, the Commission established that there is a clear risk of recurrence of material injury caused by those imports if measures are allowed to lapse. Should measures not be extended, dumped imports from both origins would in all likelihood return in substantially higher volumes and at injurious prices. The extension of measures is therefore warranted both on the grounds of continued injury caused by imports form the countries concerned and, independently, on the grounds of risk of recurrence of such injury.

(239)

In accordance with Article 21 of the basic Regulation, the Commission examined whether maintaining the existing anti-dumping measures would be against the interest of the Union as whole. The determination of the Union interest was based on an appreciation of all the various interests involved, including those of the Union industry, importers, users and suppliers.

(240)

The investigation showed that, should the measures expire, this would likely have a significant negative effect on the Union industry. The Union industry’s situation, already in a precarious situation, would quickly deteriorate in terms of lower sales volumes and sales prices resulting in a strong decrease in profitability, potentially threatening its survival.

(241)

Therefore, maintaining the anti-dumping measures in force is in the interest of the Union industry.

(242)

The Commission contacted all known unrelated importers and invited them to cooperate in this investigation. No importer cooperated.

(243)

In the original investigation, a single importer cooperated and was found to import negligible volumes of GFF.

(244)

In the original as well as in this investigation, it was found that most high volume users are requiring specific GFF made to order and therefore GFF is not a commodity that is regularly imported in large volumes by independent importers.

(245)

Therefore, the Commission concluded that the measures currently in force had no substantial negative effect on the financial situation of importers and that the continuation of the measures would not, or only marginally, affect them.

(246)

The Commission contacted all known users in this investigation and invited them to cooperate. No user cooperated, which confirms that users were not very negatively impacted by the existing measures.

(247)

In the review investigation period, the production capacity of the Union industry (246 427 tonnes) is larger than Union consumption (136 112 tonnes). The global capacity utilization of the Union industry during the review investigation period was 41 %. In particular, the two sampled companies, which are certified suppliers of GFF for the wind industry, have both significant spare capacity and could serve additional demand. In addition, the Union industry is composed of more than ten groups or companies, which makes the Union industry competitive.

(248)

The investigation also showed that the anti-dumping measures did not block imports from China and Egypt which together represented a market share of 10 % during the review investigation period. In addition, other third countries increased their market share from 18 % to 24 % in the review investigation period.

(249)

The Commission therefore concluded that the continuation of measures would not jeopardise supply stability.

(250)

The original investigation showed (56) that GFF represented between 4 % and 14 % of the total cost of manufacturing of a turbine blade, and that blades are not sold separately but as part of wind turbines and that wind turbine producers regularly sell additional material and services to the wind park developers. Therefore, the Commission calculated the cost of GFF in proportion to the total cost of a wind turbine and in the total cost of building an entire wind park. Consequently, the proportion of GFF in the costs of wind turbine producers was established at between 0,1 % and 2 %. In the original investigation, the Commission concluded that any cost increase due to anti-dumping duties could either be passed on the wind park developers or could be absorbed by the wind turbine producers.

(251)

The present investigation showed that the Union industry price during the period considered was on average only [5-6 %] higher than the average price in the period considered of the original investigation i.e. between 2015 and 2018. It can therefore be concluded that the anti-dumping measure had a minor impact, if any, on the price of GFF.

(252)

The Commission therefore concluded that the continuation of measures would not affect the competitiveness of the wind energy industry.

(253)

Since the anti-dumping measures do not jeopardise GFF supply stability nor competitiveness as concluded in recitals (249) and (252), they are not expected to encourage production relocation and are compatible with the Union’s renewable energy objectives.

(254)

In the original investigation, several users from the ski industry argued that the existence of GFF producers in the Union was essential to their supply stability, as they required a local partner for close cooperation in designing tailor-made GFF.

(255)

Therefore, the Commission concluded that there were no compelling reasons not to maintain the measures as far as the interest of users are concerned.

(256)

The original and present investigations showed that the Union industry and users make use of the services of external service providers, commonly referred to as cutters and kitters. Cutting consists of receiving GFF in rolls and cutting the fabrics to required dimension. Kitting consists of assembling the cut GFF layers and packaging them in tailored kits that facilitate manufacturing in the downstream industry.

(257)

In the present investigation, no cutting or kitting service provider came forward.

(258)

The original investigation estimated employment at cutting service providers in the Union at approximately 2 000 and found that Chinese and Egyptian exporting producers increasingly integrated cutting and kitting services in their services. There was no indication that the situation changed. In case the measures were repealed, these service providers would therefore lose a substantial part of their business.

(259)

Therefore, the Commission concluded that the continuation of measures is in the interest of the Union cutting and kitting service providers.

(260)

Union producers of glass fibre rovings, i.e. the main raw materials to produce GFF, did not cooperate in this investigation. However, it is clearly in their interest that anti-dumping measures protecting their customers are maintained.

(261)

On the basis of the above, the Commission concluded that there were no compelling reasons of the Union interest against the maintenance of the existing measures on imports of GFF originating in the countries concerned.

(262)

On the basis of the conclusions reached by the Commission on continuation of dumping, continuation and recurrence of injury for China and continuation of injury for Egypt and Union interest, the anti-dumping measures on GFF from China and Egypt should be maintained.

(263)

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 and exemptions from extensions of the measures after anti-circumvention investigations. The application of individual anti-dumping duties or exemptions 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(7) of this regulation. Until such invoice is presented, imports should be subject to the anti-dumping duty applicable to ‘all other imports originating in the People’s Republic of China’ or ‘all other imports originating in the Arab Republic of Egypt’.

(264)

While presentation of this invoice is necessary for the customs authorities of the Member States to apply the individual rates of anti-dumping duty and exemptions 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(7) 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 or exemption is justified, in compliance with customs law.

(265)

Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume after the imposition of the measures concerned, such an increase in volume could be considered as constituting in itself a change in the pattern of trade due to the imposition of measures within the meaning of Article 13(1) of the basic Regulation. In such circumstances and provided the conditions are met an anti-circumvention investigation may be initiated. This investigation may, inter alia, examine the need for the removal of individual duty rates and the consequent imposition of a country-wide duty.

(266)

The individual company anti-dumping duty rates specified in this Regulation are exclusively applicable to imports of the product under review originating in China and Egypt and produced by the named legal entities. Imports of the product under review produced by any other company not specifically mentioned in the operative part of this Regulation, including entities related to those specifically mentioned, should be subject to the duty rate applicable to ‘all other imports originating in the People’s Republic of China’ or ‘all other imports originating in the Arab Republic of Egypt’. They should not be subject to any of the individual anti-dumping duty rates.

(267)

A company may request the application of these individual anti-dumping duty rates if it changes subsequently the name of its entity. The request must be addressed to the Commission (57). The request must contain all the relevant information enabling to demonstrate that the change does not affect the right of the company to benefit from the duty rate which applies to it. If the change of name of the company does not affect its right to benefit from the duty rate which applies to it, a regulation about the change of name will be published in the Official Journal of the European Union.

(268)

All interested parties were informed of the essential facts and considerations on the basis of which it was intended to recommend that the existing measures be maintained. They were also granted a period to make representations subsequent to this disclosure. No comments were received.

(269)

In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council (58) 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.

(270)

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,