(1)

The Council, by Regulation (EC) No 91/2009 (2), imposed anti-dumping measures on certain iron or steel fasteners originating in the People’s Republic of China. By Implementing Regulation (EU) No 723/2011 (3), the Council extended those measures to certain iron or steel fasteners consigned from Malaysia (‘the extended measures’) with the exception of imports produced by the Malaysian companies which are specifically mentioned in that Regulation.

(2)

The Commission received a request for an exemption from the extended measures pursuant to Articles 11(4) and 13(4) of the basic Regulation. The application was lodged by Andfast Malaysia Sdn. Bhd. (‘Andfast’), a producer in Malaysia.

(3)

The Commission examined the evidence submitted by Andfast and considered it sufficient to justify the initiation of an investigation pursuant to Articles 11(4) and 13(4) of the basic Regulation for the purposes of determining the possibility of granting Andfast an exemption from the extended measures. After consultation of the Advisory Committee, and after the Union industry concerned had been given the opportunity to comment, the Commission initiated, by Regulation (EU) No 1164/2011 (4) (‘the initiating Regulation’), a review of Implementing Regulation (EU) No 723/2011 with regard to Andfast.

(4)

The Regulation initiating the review repealed the anti-dumping duty imposed by Implementing Regulation (EU) No 723/2011 with regard to imports of the product under examination consigned from Malaysia and produced by Andfast. Simultaneously, pursuant to Article 14(5) of the basic Regulation, customs authorities were directed to take appropriate steps to register such imports.

(5)

The product concerned is certain iron or steel fasteners, other than of stainless steel, i.e. wood screws (excluding coach screws), self-tapping screws, other screws and bolts with heads (whether or not with their nuts or washers, but excluding screws turned from bars, rods, profiles or wire, of solid section, of a shank thickness not exceeding 6 mm and excluding screws and bolts for fixing railway track construction material), and washers, consigned from Malaysia, currently falling within CN codes ex 7318 12 90 , ex 7318 14 91 , ex 7318 14 99 , ex 7318 15 59 , ex 7318 15 69 , ex 7318 15 81 , ex 7318 15 89 , ex 7318 15 90 , ex 7318 21 00 and ex 7318 22 00 (‘the product concerned’).

(6)

The Commission officially advised Andfast and the representatives of Malaysia of the initiation of the review. Interested parties were invited to make their views known and informed of the possibility to request a hearing. No such request was received.

(7)

The Commission also sent a questionnaire to Andfast and received a reply within the relevant deadline. The Commission sought and verified all the information deemed necessary for the purposes of the review. A verification visit was carried out at the premises of Andfast.

(8)

The investigation covered the period from 1 October 2010 to 30 September 2011 (‘the IP’). Data was collected from 2008 up to the end of the IP to investigate any change in the pattern of trade.

(9)

The investigation confirmed that Andfast was not related to any of the Chinese or Malaysian exporters or producers subject to the anti-dumping measures and had not exported the product concerned to the European Union during the investigation period of the investigation that led to the extended measures, i.e. 1 January 2008 to 30 September 2010. Andfast’s first exports of the product concerned occurred subsequently to the extension of measures to Malaysia.

(10)

The processing activities of Andfast can be considered as a completion and assembly operation in the sense of Article 13(2) of the basic Regulation. Andfast imports blanks from the People’s Republic of China which are subsequently threaded, plated and put together with the nuts and the washers at its premises in Malaysia. The finished product is sold and exported to its related company in the Union.

(11)

This is not considered to be a process involving circumvention as it could be demonstrated that the value added to the parts brought in from the People’s Republic of China, during the assembly and completion operation, is greater than 25 % of the manufacturing costs.

(12)

No evidence was found that Andfast was purchasing the finished product concerned from the People’s Republic of China to resell or tranship to the European Union.

(13)

In accordance with the above findings that Andfast has not engaged in circumvention practices, the company should be exempted from the anti-dumping measures in force.

(14)

The registration of imports of certain iron or steel fasteners consigned from Malaysia by Andfast, as imposed by the initiating Regulation, should cease. In accordance with Article 14(5) of the basic Regulation, which provides that measures shall be applied against registered imports from the date of registration, and in view of the exemption of the company from measures, no anti-dumping duty should be collected on imports of certain iron or steel fasteners consigned from Malaysia by Andfast which entered the Union under registration imposed by the initiating Regulation.

(15)

The exemption from the extended measures granted to imports of certain iron or steel fasteners produced by Andfast shall, in accordance with Article 13(4) of the basic Regulation, remain valid on condition that the facts as finally ascertained justify the exemption and that it is not, for instance, established that the exemption was granted on the basis of false or misleading information submitted by the company concerned. Should prima facie evidence indicate otherwise, or should exports from Andfast to the European Union increase dramatically, an investigation may be initiated by the Commission to establish whether withdrawal of the exemption is warranted.

(16)

The exemption from the extended measures granted to imports of certain iron or steel fasteners produced by Andfast was established on the basis of the findings of the present review. This exemption is thus exclusively applicable to imports of certain iron or steel fasteners consigned from Malaysia and produced by that specific legal entity. Imported iron or steel fasteners, produced by any company not specifically mentioned in Article 1(1) of Implementing Regulation (EU) No 723/2011 with its name, including entities related to those specifically mentioned, shall not benefit from the exemption and should be subject to the residual duty rate as imposed by that Regulation.

(17)

It is considered that special measures are needed in this case in order to ensure the proper application of such exemptions. These special measures are the requirement of the presentation to the customs authorities of the Member States of a valid commercial invoice, which shall conform to the requirements set out in the Annex to Implementing Regulation (EU) No 723/2011. Imports not accompanied by such an invoice shall be made subject to the extended anti-dumping duty.

(18)

Andfast and all other interested parties were informed of the facts and considerations on the basis of which it was intended to grant an exemption to Andfast from the extended measures. No comments were received,

(1)

On 1 November 2011, the European Commission (‘the Commission’) announced, by a notice published in the Official Journal of the European Union (2) (‘the notice of initiation’), the initiation of an anti-dumping proceeding with regard to imports of certain tube and pipe fittings of iron or steel originating in Russia and Turkey (‘the countries concerned’).

(2)

The proceeding was initiated as a result of a complaint lodged on 20 September 2011 by the Defence committee of the Steel Butt-Welding Fittings Industry of the European Union (‘the complainants’) on behalf of producers representing a major proportion, in this case more than 40 % of the total Union production of certain tube and pipe fittings of iron or steel. The complaint contained prima facie evidence of dumping of the said product and of material injury resulting therefrom, which was considered sufficient to justify the initiation of a proceeding.

(3)

The Commission officially advised the complainants, other known Union producers, the known exporting producers and the representatives of the countries concerned, known importers and users, of the initiation of the proceeding. Interested parties were given an opportunity to make their views known in writing and to request a hearing within the time limit set in the notice of initiation.

(4)

All interested parties, who so requested and showed that there were particular reasons why they should be heard, were granted a hearing.

(5)

In view of the apparent large number of Union producers, sampling was provided for in the notice of initiation for the determination of injury, in accordance with Article 17 of the basic Regulation.

(6)

In the notice of initiation the Commission announced that it had provisionally selected a sample of Union producers. This sample consisted of three companies, out of the 22 Union producers that were known to produce the like product prior to the initiation of the investigation.

(7)

The sample was selected on the basis of volumes of sales and production that can reasonably be investigated within the time available. The sampled Union producers are based in four Member States and account for 48 % of total Union sales of all Union producers, and for 64 % of the producers who came forward. No interested party opposed to the proposed sample.

(8)

In view of the potentially high number of unrelated importers, sampling was envisaged in the notice of initiation in accordance with Article 17 of the basic Regulation. In order to enable the Commission to decide whether sampling would be necessary and, if so, to select a sample, all importers were asked to make themselves known to the Commission and to provide, as specified in the notice of initiation, basic information on their activities related to the product under investigation during the investigation period from 1 October 2010 to 30 September 2011.

(9)

Of the 38 unrelated importers that the Commission contacted, only 5 companies replied to the sampling questions within the deadline. One company turned out to be a user rather than an importer. Therefore it was considered that no sampling was necessary, and questionnaires were sent to all four importers that came forward. In the end, only two importers replied to the questionnaire and cooperated fully in the investigation.

(10)

In view of the apparent high number of exporting producers, sampling was envisaged in the notice of initiation for the determination of dumping, in accordance with Article 17 of the basic Regulation. In order to enable the Commission to decide whether sampling would be necessary and, if so, to select a sample, all exporting producers were asked to make themselves known to the Commission and to provide, as specified in the notice of initiation, basic information on their activities related to the product under investigation during the investigation period from 1 October 2010 to 30 September 2011. The authorities of the countries concerned were also consulted.

(11)

As concerns Russia, no exporting producers cooperated in the investigation. As regards Turkish exporting producers, three companies came forward; therefore the Commission decided that sampling was not necessary in respect of Turkey. The three cooperating Turkish companies represent the majority of Turkish exports to the Union during the investigation period.

(12)

In order to carry out its analysis, the Commission sent questionnaires to all three cooperating Turkish exporting producers as well as to the sampled Union producers and the cooperating unrelated importers and users.

(13)

Questionnaire replies were received from all three cooperating Turkish exporting producers, from all sampled Union producers, two unrelated Union importers and four users.

(14)

The Commission sought and verified all the information deemed necessary for the purpose of a provisional determination of dumping, resulting injury and Union interest. Verification visits were carried out at the premises of the following companies.

(15)

The investigation of dumping and injury covered the period from 1 October 2010 to 30 September 2011 (‘investigation period’ or ‘IP’). The examination of trends relevant for the assessment of injury covered the period from 2008 to the end of the investigation period (‘period considered’).

(16)

Anti-dumping measures are in force in respect of certain tube and pipe fittings of iron or steel originating in China, Malaysia, South Korea and Thailand, and following circumvention practices also in respect of certain tube and pipe fittings of iron or steel originating in China consigned from Indonesia, the Philippines, Sri Lanka and Taiwan (with certain exceptions) (3). The countries mentioned in the preceding sentence shall hereafter be referred to as ‘countries under anti-dumping measures’.

(17)

The product concerned is tube and pipe fittings (other than cast fittings, flanges and threaded fittings), of iron or steel (not including stainless steel), with a greatest external diameter not exceeding 609,6 mm, of a kind used for butt-welding or other purposes, currently falling within CN codes ex 7307 93 11 , ex 7307 93 19 and ex 7307 99 80 (‘the product concerned’).

(18)

The production process uses seamless or welded steel pipes for the production of elbows, reducers and tees, while for the manufacturing of caps, normally steel sheets are used as raw material. The elbows and reducers are made by cutting and forming, bending or reducing. Tees are made by using hydro-pressure, and caps are made by the forming of the sheets or plates. These are normally followed by chamfering and shot-blasting before the packaging. In certain cases also galvanisation is applied to the product. All types of products share the same basic physical, chemical and technical characteristics and same basic uses.

(19)

Tube and pipe fittings are used in the petrochemical industry, construction, energy generation, shipbuilding and industrial installations. They are used in order to connect tubes or pipes with each other in all the above applications.

(20)

The product concerned and certain tube and pipe fittings of iron or steel sold on the domestic market in the countries concerned as well as certain tube and pipe fittings of iron or steel sold in the Union by the Union industry were found to have the same basic physical, chemical and technical characteristics and the same basic uses. They are therefore provisionally considered to be alike within the meaning of Article 1(4) of the basic Regulation.

(21)

As mentioned in recital 11 above, no Russian exporting producer cooperated in this investigation. Therefore, in accordance with Article 18 of the basic Regulation, the dumping calculations for Russia were made on the basis of the facts available, as explained below.

(22)

In the absence of cooperation by any Russian exporting producer, the normal value for Russia was calculated on the basis of the facts available.

(23)

It should be recalled that the complaint contained prima facie evidence of dumping in respect of Russian imports of the product concerned. The calculation leading to that evidence was based on a constructed normal value for Russia, in the absence of more detailed information. Nevertheless, for the purpose of establishing a more precise normal value, the Commission provisionally decided that the normal value for Russia be constructed on the basis of information obtained during the investigation from those Turkish exporting producers that use Russian seamless steel pipes and tubes as input for the production of the product concerned. Indeed, the cost of raw material represents the vast majority of total manufacturing costs of the product concerned; therefore this method was considered as the most reasonable to establish the normal value for Russia on the basis of the available facts.

(24)

The normal value for Russia was thus calculated by determining the weighted average normal value of those cooperating Turkish exporting producers that purchase part of their raw material from Russia.

(25)

It is important to note that the resulting normal value was determined for the product type (elbows) representing the highest volume of imports, instead of all types of the product concerned, in order to allow a representative comparison with the export price (see in the following recitals).

(26)

In the absence of more detailed price information, the export price for imports of the product concerned originating in Russia was established on the basis of Eurostat import data. Given the large variety of the product mix declared under certain CN codes, the export price was determined by limiting the use of Eurostat data to the product type (elbows) representing the highest volume of imports, which is considered to be representative for all the product concerned. The export price was thus based on the CN code 7307 93 11 .

(27)

The above Eurostat import figures had to be adjusted in view of the fact that certain import transactions from Russia to Bulgaria, Estonia and Lithuania contained wrong declarations, most likely due to product misclassifications. These transactions were identified by using the imports statistics made available in the database pursuant to Article 14(6) of the basic Regulation and were removed from the calculation of the export price in order to avoid using a distorted export price in the dumping calculation.

(28)

The dumping margin was established by comparing the ex-works export price based on the Eurostat data with the normal value for Russia as established above.

(29)

In order to establish the ex-works export price, the CIF export price based on the Eurostat data (and corrected to remove the distortions as outlined above) was adjusted by the cost of transportation. For this purpose, the cost of transportation as calculated in the complaint was used since it was considered to be a reasonable estimate.

(30)

The country-wide dumping margin was expressed as a percentage of the CIF Union frontier price, duty unpaid.

(31)

On the basis of the above, the country-wide provisional dumping margin expressed as a percentage of the CIF Union frontier price, duty unpaid, is the following:

(32)

In accordance with Article 2(2) of the basic Regulation, the Commission first established for each of the three cooperating exporting producers whether its total domestic sales of the like product were representative, i.e. whether the total volume of such sales represented at least 5 % of its total volume of export sales of the product concerned to the Union. The investigation established that the domestic sales of the like product were representative for all cooperating exporting producers.

(33)

The Commission subsequently identified those product types sold domestically by the companies having overall representative domestic sales that were identical or closely resembling with the types sold for export to the Union.

(34)

For each type of the like product sold by the exporting producers on their domestic market and found to be comparable with the type of the product concerned sold for export to the Union, it was established whether domestic sales were sufficiently representative for the purposes of Article 2(2) of the basic Regulation. Domestic sales of a particular product type were considered sufficiently representative when the volume of that product type sold on the domestic market to independent customers during the IP represented around 5 % of the total volume of the comparable product type sold for export to the Union. The investigation established that in the case of each of the three companies, for the majority of product types there were representative domestic sales.

(35)

The Commission subsequently examined whether each type of the product concerned sold domestically in representative quantities could be considered as being sold in the ordinary course of trade pursuant to Article 2(4) of the basic Regulation. This was done by establishing for each product type the proportion of profitable sales to independent customers on the domestic market during the investigation period.

(36)

Where the sales volume of a 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 that type, and where the weighted average sales price was equal to or higher than the unit cost, normal value, by product type, was calculated as the weighted average of all domestic sales prices of the type in question.

(37)

Where the volume of profitable sales of a product type represented 80 % or less of the total sales volume of that product type, or where the weighted average price of that type was below the unit cost, normal value was based on the actual domestic price, which was calculated as the weighted average price of only the profitable domestic sales of the type in question.

(38)

The investigation established that the profitable sales of certain comparable product types were more than 80 % of total domestic sales and, thus, for these sales all domestic sales were used in calculating the average price for normal value. For the other product types also considered to be sold in the ordinary course of trade only the profitable sales were used.

(39)

Where the product types were all sold at a loss, it was considered that they were not sold in the ordinary course of trade. For product types not made in the ordinary course of trade, as well as for the product types that were not sold in representative quantities on the domestic market, normal value had to be constructed. All three investigated companies sold such product types for export to the Union, albeit in limited quantities.

(40)

To construct normal value pursuant to Article 2(6) of the basic Regulation, the selling, general and administrative (‘SG&A’) expenses incurred and weighted average profit realised by the cooperating exporting producers concerned on domestic sales of the like product, in the ordinary course of trade, during the investigation period, was added to their own average cost of manufacturing during the investigation period. For product types sold in non-representative quantities in the domestic market, the weighted average profit and SG&A in the ordinary course of trade of these non-representative sales were used to construct normal value.

(41)

In all cases the product concerned was exported to independent customers in the Union, and therefore, the export price was established in accordance with Article 2(8) of the basic Regulation, namely on the basis of export prices actually paid or payable.

(42)

One of the three cooperating Turkish companies had very limited export sales to the Union during the investigation period. The company concerned claimed that they would like to export more to the Union but were unable to offer low enough prices to importers, and requested that this fact be taken into account in our analysis.

(43)

However, as regards the dumping calculation for this company, it had to be based on their limited sales. Indeed even if the sales of the company to the Union were limited, they cannot be ignored and can be the sole basis for the calculation of an individual dumping margin for this company. In any event, the inability of the company to sell more due to its allegedly high prices cannot be viewed as a factor to influence the dumping calculation regarding this company.

(44)

The normal value and export prices were compared on an ex-works basis. For the purpose of ensuring a fair comparison between the normal value and the export price, due allowance in the form of adjustments was made for differences affecting prices and price comparability in accordance with Article 2(10) of the basic Regulation. Appropriate adjustments were granted in all cases where they were found to be reasonable, accurate and supported by verified evidence. In particular, an adjustment was granted for freight and insurance costs including freight in the exporting country, discounts, commissions, credit costs and bank charges.

(45)

The provisional dumping margins were expressed as a percentage of the CIF Union frontier price, duty unpaid.

(46)

Pursuant to Article 2(11) and (12) of the basic Regulation, the individual dumping margin for one of the three cooperating exporting producers was established on the basis of a comparison of a weighted average normal value with the company’s weighted average export price of the product concerned to the Union.

(47)

However, as concerns the other two cooperating Turkish producers, the dumping calculations in their respect showed that the companies conducted targeted dumping in terms of a given time period as well as in respect of given customers and regions. Indeed there was a clear pattern of their export prices which differed significantly among different purchasers, regions as well as time periods. Furthermore, the dumping calculation based on the comparison of a weighted average normal value to a weighted average of export prices did not reflect the full degree of dumping being practised by the two producers concerned.

(48)

Therefore, in order to reflect the full amount of dumping being practised by the two companies concerned, in accordance with Article 2(11) of the basic Regulation, the normal value established on a weighted average basis was compared in their case to prices of all individual export transactions to the Union.

(49)

As regards all non-cooperating Turkish exporting producers, a residual dumping margin was established. Given that the level of cooperation was considered to be relatively low (the volume of exports of the three cooperating Turkish companies represented less than 80 % of total Turkish exports to the Union during the IP), the residual dumping margin was based on a reasonable method leading to a margin which is higher than the highest among the individual margins of the three cooperating companies. This margin was established on the basis of the sales of representative product types made by the Turkish cooperating producer with the highest dumping margin of the three cooperating companies.

(50)

On the basis of the above, the provisional dumping margins expressed as a percentage of the CIF Union frontier price, duty unpaid, are the following:

(51)

During the IP, the like product was manufactured by 22 producers in the Union. Within the meaning of Articles 4(1) and 5(4) of the basic Regulation, all 22 existing Union producers constitute the Union industry and they will therefore be hereafter referred to as the ‘Union industry’.

(52)

As indicated under recital 7 above, the three sampled Union producers represent around 50 % of the total Union sales of the like product.

(53)

Union consumption was established on the basis of the sales volumes of the Union industry on the Union market based on the information obtained from the questionnaire replies of the sampled companies, from the estimates provided in the complaint for the remaining Union producers and the import volumes data from Eurostat.

(54)

Union consumption dropped considerably by 40 % between 2008 and the IP. It has decreased by 44 % in 2009, remained at that level in 2010, before increasing slightly by 4 percentage points in the IP.

Table 1

Union consumption

(55)

The Commission examined whether imports of the product concerned originating in Russia and Turkey should be assessed cumulatively in accordance with Article 3(4) of the basic Regulation.

(56)

For both countries concerned, the investigation showed that the dumping margins were above the de minimis threshold as defined in Article 9(3) of the basic Regulation and the volume of dumped imports from these two countries was not negligible in the sense of Article 5(7) of the basic Regulation.

(57)

With regard to the conditions of competition between imports from Russia and Turkey and the like product, the investigation revealed that the producers from these countries use the same sales channels and sell to similar categories of customers. Moreover, the investigation also revealed that the imports from both these countries had an increasing trend in terms of market shares in the period considered.

(58)

Two cooperating Turkish exporters argued that accumulation of imports from Russia and Turkey is not appropriate in this case, as imports from these countries show different trends in terms of volume and prices.

(59)

It is noted in this regard that the investigation established that while imports from Turkey are relatively stable in terms of volumes, imports from Russia are increasing. However, given the contraction in demand in the period considered, the market shares of imports from both countries are increasing. At the same time their pricing does not appear to be substantially different, at least in the period between 2009 and the IP (the high average price of Russian imports in 2008 is likely to be due to incorrect reporting) with Russian average prices being somewhat lower but very close to the average Turkish prices.

(60)

In view of the above, it is provisionally considered that all the criteria set out in Article 3(4) of the basic Regulation were met and that imports from Russia and Turkey should be examined cumulatively.

(61)

The volume of dumped imports of the product concerned from the countries concerned into the Union market has increased over the period considered by 46 %. More specifically, imports decreased by 31 % in 2009, just before a massive increase in 2010 by 89 percentage points, followed by a slight decrease in the IP by some 12 percentage points. The volume of dumped imports in the IP was 2 935 tonnes.

Table 2

Dumped imports from the countries concerned

(62)

The corresponding market share of dumped imports from the countries concerned has more than doubled over the period considered, increasing from 2 % to 5 %.

(63)

The table below shows the average price of dumped imports from the countries concerned, at the Union frontier duty unpaid, as reported by Eurostat. During the period considered the average price of imports from the countries concerned remained generally stable at EUR 1 961 per tonne, with an exception in 2010 when they dropped by some EUR 150.

Table 3

Average prices of dumped imports

(64)

A type-to-type price comparison was made between the selling prices of the cooperating Turkish exporting producers and the sampled Union producers’ selling prices in the Union. Given that Russian exporters did not cooperate with the investigation, the undercutting calculation was performed using average CIF prices reported in Eurostat and average Union producers’ selling prices in the Union. Adjustments were applied where necessary with regard to both countries concerned to take account of the level of trade and post-importation costs, including the customs duty in the case of Russia.

(65)

The comparison showed that during the IP, the dumped product concerned originating in the countries concerned sold in the Union undercut the Union industry’s prices by up to approximately 30 %.

(66)

Pursuant to 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 factors and indices having a bearing on the state of the Union industry during the period considered.

(67)

As explained above, the Commission had recourse to sampling of Union producers. For the purpose of the injury analysis, the injury indicators have been established at the following two levels:

(68)

The Union production decreased by 44 % between 2008 and the IP. More specifically, it decreased by 47 % in 2009 and by a further 2 percentage points in 2010 before increasing slightly by 5 percentage points in the IP, when it reached 53 653 tonnes.

Table 4

Production

(69)

The production capacity of the Union producers remained stable throughout the period considered at 179 912 tonnes.

Table 5

Production capacity and utilisation

(70)

Capacity utilisation was 53 % in 2008, decreased to 28 % in 2009 to 27 % in 2010 and slightly increased in the IP to 30 %. The development of the utilisation rate clearly reflects the production trend as the capacity remained stable.

(71)

The sales volume of the Union producers to unrelated customers on the Union market decreased by 38 % in the period considered. The sales decreased by 45 % in 2009, stayed at that level in 2010 and modestly increased in the IP by 7 percentage points. During the IP the Union sales were at 42 379 tonnes.

Table 6

Union sales

(72)

The market share of the Union producers was relatively stable in the period considered and even increased in the IP to 72 %. The increased market share is a reflection of the fact that the sales volumes of the Union producers dropped slightly less than the consumption in the period.

Table 7

Market share of the Union producers

(73)

Given that the consumption decreased by 40 % between 2008 and the IP, it is concluded that the Union producers could not benefit from any growth of the market.

(74)

The employment level of the Union producers shows a decrease of 18 % between 2008 and the IP. More specifically, the number of people employed decreased significantly from 982 in 2008 to 824 in 2009 or by 16 % and remained close to this level in 2010 before further dropping to 801 in the IP.

Table 8

Employment

(75)

Productivity of the Union producers’ workforce, measured as output (tonnes) per person employed per year, decreased by 31 % in the period considered. This reflects the fact that production decreased at a faster pace than the employment level.

Table 9

Productivity

(76)

The annual average sales prices of the Union producers on the Union market to unrelated customers decreased in the period considered by over 10 %. In detail, the average prices initially increased in 2009 by some 12 % only to fall sharply in 2010 by 23 percentage points and it remained at this level in the IP. In the IP the average price of the Union producers was at EUR 3 096 per tonne.

Table 10

Average prices of Union producers

(77)

As indicated above, the sales prices of the Union industry were undercut by the dumped imports from Russia and Turkey.

(78)

Given the volume, market share and prices of the imports from Russia and Turkey, the impact on the Union industry of the actual margins of dumping cannot be considered to be negligible. It is important to recall that as indicated in recital 16 above anti-dumping measures are in force against eight countries. Given that in the period considered by this investigation the Union industry lost sales and suffered losses, no actual recovery from the past dumping can be established and it is considered that Union production remains vulnerable to the injurious effect of any dumped imports on the Union market.

(79)

The level of closing stocks of the sampled Union producers decreased between 2008 and the IP by 18 %. In detail, stocks increased moderately in 2009 by 2 % and later decreased by 13 percentage points in 2010 and by further 7 percentage points in the IP. In the IP the closing stock of the sampled Union producers was at 5 338 tonnes.

Table 11

Closing stock

(80)

The annual labour cost decreased by 10 % between 2008 and the IP. More specifically, the labour cost decreased significantly in 2009 by almost 20 % (corresponding to the reduced employment) and later on increased in 2010 by 4 percentage points in 2010 and by further 5 percentage points in the IP.

Table 12

Annual labour cost

(81)

During the period considered, the profitability of the sampled producers’ sales of the like product on the Union market to unrelated customers, expressed as a percentage of net sales, decreased from healthy profits to significant losses. More specifically, the profits fell from 9,6 % in 2008 to – 1,2 % in 2009 and deteriorated further in 2010 by falling to – 7,8 %. The situation slightly improved in the IP when the losses were at – 7,0 %.

Table 13

Profitability and return on investments