Commission Implementing Regulation (EU) 2025/1041 of 27 May 2025 making imports of adipic acid originating in the People’s Republic of China subject to registration

## Report on Commission Implementing Regulation (EU) 2025/1041 concerning Adipic Acid Imports from China **1. Executive Summary:** This report analyzes Commission Implementing Regulation (EU) 2025/1041 of 27 May 2025, which mandates the registration of imports of adipic acid originating in the People’s Republic of China. This regulation is a preliminary step in an antidumping proceeding initiated by the European Commission following a complaint from EU producers. The core purpose is to enable the potential retroactive imposition of antidumping duties if the investigation confirms dumping practices. Key findings include the specific product definition, the registration requirement for customs authorities, and the potential for future liability based on dumping margins and injury elimination levels. **2. Introduction:** The purpose of this report is to provide an informative overview of Commission Implementing Regulation (EU) 2025/1041 concerning the registration of imports of adipic acid originating in the People’s Republic of China. This analysis is based solely on the text of the regulation as provided. **3. Policy Overview:** This is a *new* policy. * **Core Objective(s):** The core objective of this regulation is to enable the potential retroactive application of antidumping duties on imports of adipic acid from China, should the ongoing antidumping investigation confirm the existence of dumping practices that are causing injury to the Union industry. This is achieved by mandating the registration of these imports. **4. Background and Rationale:** * **Problem/Issue Addressed:** The regulation addresses the potential harm to the European Union's adipic acid producers caused by alleged dumping practices of adipic acid imports from the People's Republic of China. The policy is initiated following a complaint by EU producers alleging dumping margins. The EU Commission has started an investigation and to prepare for the findings, they have decided to monitor imports in the meantime. **5. Key Provisions / Changes:** * **Main Components, Rules, and Actions Mandated:** * **Registration of Imports:** The core provision mandates that customs authorities register all imports of adipic acid (also known as hexanedioic acid, CAS number 124049, CN code 2917 12 00, TARIC code 2917 12 00 10) originating in the People's Republic of China. * **Legal Basis:** The regulation is based on Article 14(5) of Regulation (EU) 2016/1036, which concerns protection against dumped imports from countries not members of the European Union. * **Product Definition:** The product subject to registration is specifically defined as adipic acid, including its CAS number and CN/TARIC codes. * **Duration of Registration:** The registration requirement will expire nine months after the regulation's entry into force. * **Data Protection:** Any personal data collected during the registration process will be handled according to Regulation (EU) 2018/1725. * **Potential Future Liability:** The regulation acknowledges the possibility of retroactive antidumping duties based on the findings of the ongoing investigation. **6. Target Audience and Stakeholders:** Based on the text, the primary target audience and stakeholders are: * **Importers of adipic acid from the People's Republic of China:** They are directly affected by the registration requirement and the potential for retroactive duties. * **Customs authorities of the European Union member states:** They are responsible for implementing the registration of imports. * **EU producers of adipic acid (Lanxess Deutschland GmbH and Radici Chimica S.p.A.):** As the complainants, they have a vested interest in the outcome of the investigation and the potential imposition of antidumping duties. **7. Implementation Aspects (Inferred):** * **Responsible Agency/Bodies:** The European Commission is ultimately responsible for the regulation, while the customs authorities of EU member states are responsible for its implementation. * **Timelines/Procedures:** The registration requirement starts from the day following the publication of the regulation in the Official Journal of the European Union and lasts for nine months. Specific procedures for registration are not detailed in this text but would be expected to follow standard customs practices. **8. Expected Outcomes / Impact:** * **Likely Intended Outcomes:** * **Data Collection:** The primary intended outcome is to gather comprehensive data on the volume and value of adipic acid imports from China during the investigation period. * **Potential Retroactive Duties:** The regulation aims to enable the retroactive imposition of antidumping duties if the investigation confirms dumping and injury to the EU industry. This would potentially protect the EU adipic acid industry from unfair competition. * **Deterrent Effect:** The registration requirement may also have a deterrent effect on Chinese exporters, discouraging them from engaging in further dumping practices. **9. Conclusion:** Commission Implementing Regulation (EU) 2025/1041 is a significant step in the EU's response to alleged dumping of adipic acid from China. By mandating the registration of imports, the regulation allows for the potential retroactive application of antidumping duties, protecting the EU industry from unfair trade practices. Importers and EU producers of adipic acid should carefully monitor the progress of the antidumping investigation and prepare for potential financial implications.

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