This handbook expands EU anti-dumping duties: conditions, procedures, and defence strategies into an operational defence map for Chinese exporters and related importers facing anti-dumping (AD) and anti-subsidy / countervailing (CVD) investigations in the European Union—including sampling, questionnaires, injury, and post-measure options.
Parent: Going Global · EV context: EV outbound compliance.
AD vs CVD — different theories, similar project stress
- Anti-dumping — compares export price to normal value; focuses on price discrimination / constructed value themes under the EU basic anti-dumping regulation (Regulation (EU) 2016/1036, as amended—confirm consolidated text).
- Anti-subsidy / countervailing — focuses on countervailable subsidies and injury under the basic anti-subsidy regulation (Regulation (EU) 2016/1037, as amended).
Both can run in parallel or sequence on related products. Product scope (CN codes, product control numbers) decides whether your SKU is in the case. Read the notice of initiation before you reorganize sales.
Investigation phases (project view)
- Initiation — Official Journal notice; standing of complainants; product definition
- Registration / sampling — exporter sampling forms; miss the deadline and risk residual duty rates
- Questionnaire — company structure, domestic sales, export sales to the EU, costs, subsidies (CVD)
- Verification — on-site or remote verification of sampled companies
- Provisional measures — possible provisional duties; accounting and pricing decisions
- Definitive stage — definitive duties, price undertakings, or termination
- Reviews — expiry, interim, newcomer, anti-absorption, anti-circumvention
Calendar control is counsel’s job; commercial teams own clean data and decision rights on price undertakings.
Sampling and residual rates
In large exporter populations the Commission samples. Companies that fail to make themselves known or to submit complete sampling information often face residual duty levels based on available facts. Treat sampling forms as a hard stop: legal entity map, export volumes, and related importers must be accurate.
Defence data room
- Corporate chart and related-party list (link to transfer pricing where intra-group prices matter)
- Export sales listing to the EU by transaction (invoice, customer, Incoterms, rebates)
- Domestic sales and cost of production support for normal value
- Subsidy file for CVD (grants, preferential loans, tax programs, input pricing—facts only, no concealment)
- Product matching files (PCNs) aligned to the questionnaire
Translation quality and version control matter: verification will test whether the database matches books.
Injury, causation, and Union interest
Even where dumping or subsidisation is found, arguments on injury, causation, and Union interest can shape outcomes. Importers, users, and downstream EU manufacturers may participate. Coordinate public messaging with legal strategy; press narratives become case exhibits.
After measures — compliance and options
- Correct duty payment and customs declarations; avoid misdeclaration
- Evaluate price undertakings only with counsel modelling
- Watch anti-circumvention risk on third-country assembly—see origin notes in EV outbound
- Plan reviews with sales and cost data retained for years, not months
- Dispute clauses and arbitration for supply contracts under duty stress—forum guide
Next steps
Trade defence, investment screening, and host-country employment rules change by regulation and case practice. Confirm the instrument version and investigation notice that apply to your products or deal before you file, price, or ship.