## Report on Commission Implementing Regulation (EU) 2025/922 Regarding Softwood Plywood Imports from Brazil
**1. Executive Summary:**
This report analyzes Commission Implementing Regulation (EU) 2025/922, which subjects imports of softwood plywood originating in Brazil to registration. This regulation is a direct response to a complaint alleging dumping practices and initiates a process that could lead to the imposition of antidumping duties. The core purpose is to allow for the possible retroactive application of duties if an investigation confirms dumping. The key finding is that importers of Brazilian softwood plywood will need to register their imports, potentially facing future liabilities depending on the outcome of the ongoing antidumping investigation.
**2. Introduction:**
This report provides an informative overview of Commission Implementing Regulation (EU) 2025/922 of 20 May 2025. The analysis is based solely on the text of the regulation as provided and aims to inform affected industry stakeholders of its key provisions, potential impacts, and implementation aspects.
**3. Policy Overview:**
* This is a new policy.
* **Core Objective(s):** The primary objective, as inferred from the text, is to enable the European Commission to potentially levy antidumping duties retroactively on imports of softwood plywood originating in Brazil, should the ongoing investigation confirm the existence of dumping practices that harm the Union's softwood plywood industry. The registration of imports is a mechanism to facilitate this retroactive application.
**4. Background and Rationale:**
As this is a new policy, the regulation addresses the issue of potential unfair trade practices. The text indicates that a complaint was lodged by the Softwood Plywood Consortium alleging dumping of softwood plywood from Brazil. This complaint prompted the European Commission to initiate an antidumping proceeding. The registration of imports is a precautionary measure designed to protect the Union's industry from potential injury caused by dumped imports during the investigation period and, if dumping is confirmed, to allow for the recovery of lost revenue through retroactive duties.
**5. Key Provisions:**
The regulation establishes the following key provisions:
* **Subject of Registration:** Imports of plywood consisting solely of sheets of wood (other than bamboo), each ply not exceeding 6 mm thickness, with both outer plies of coniferous wood, whether or not coated or surface covered, currently classified under CN code 4412 39 00 and originating in Brazil, are subject to registration.
* **Mandatory Registration:** Customs authorities are directed to take the necessary steps to register these imports into the Union.
* **Legal Basis:** The registration is mandated under Article 14(5) of Regulation (EU) 2016/1036 (the basic Regulation) on protection against dumped imports.
* **Sunset Clause:** The registration requirement will expire nine months after the regulation's entry into force.
* **Personal Data Protection:** Any personal data collected during the registration process will be handled in accordance with Regulation (EU) 2018/1725 regarding the protection of personal data.
**6. Target Audience and Stakeholders:**
The primary target audience and stakeholders are:
* **Importers of softwood plywood originating in Brazil:** They are directly affected by the registration requirement and the potential for retroactive antidumping duties.
* **European Union customs authorities:** They are responsible for implementing the registration process.
* **European Union producers of softwood plywood:** Represented by the Softwood Plywood Consortium, they are the beneficiaries of the potential antidumping measures.
**7. Implementation Aspects (Inferred):**
* **Responsible Agency:** The European Commission is ultimately responsible for the overall implementation and enforcement. National customs authorities within the EU member states are responsible for the practical registration of imports.
* **Timeline:** The regulation enters into force the day after its publication in the Official Journal of the European Union. The registration requirement expires nine months after the entry into force. This implies that the investigation should be completed within this timeframe, or shortly thereafter, to determine whether duties will be imposed.
* **Procedure:** While the specific registration procedure is not detailed in this text, it can be inferred that importers will need to provide information to customs authorities about the imported softwood plywood, allowing for its identification and tracking.
**8. Expected Outcomes / Impact of Changes:**
The likely intended outcomes and potential impacts are:
* **Increased administrative burden for importers:** Importers will incur costs associated with complying with the registration requirements.
* **Potential financial risk for importers:** The possibility of retroactive antidumping duties creates financial uncertainty for importers. They may need to set aside funds to cover potential liabilities.
* **Protection for EU softwood plywood producers:** The antidumping investigation and potential duties aim to protect EU producers from unfair competition from dumped imports.
* **Data Collection for Antidumping Investigation:** The registration process will provide the Commission with accurate data on import volumes, aiding in its assessment of the alleged dumping and its impact on the EU market.
**9. Conclusion:**
Commission Implementing Regulation (EU) 2025/922 marks a significant step in the EU's response to alleged dumping of softwood plywood from Brazil. The registration requirement imposes immediate obligations on importers and creates the potential for significant financial liabilities, depending on the outcome of the antidumping investigation. This regulation highlights the EU's commitment to protecting its domestic industries from unfair trade practices and ensuring fair competition in the market. Importers should closely monitor the progress of the antidumping investigation and prepare for potential duties.
Key Entities Referenced
European Union: A political and economic union of member states located primarily in Europe.
L series 2025/922: Reference to the Official Journal publication series.
21.5.2025: Date of the Official Journal publication.
COMMISSION IMPLEMENTING REGULATION (EU) 2025/922: The title of the regulation being implemented.
20 May 2025: Date of the Commission Implementing Regulation.
Brazil: Country of origin of the softwood plywood imports subject to registration.
THE EUROPEAN COMMISSION: The executive branch of the European Union responsible for the regulation.
Treaty on the Functioning of the European Union: A primary treaty of the European Union.
Regulation (EU) 2016/1036: Regulation of the European Parliament and of the Council of 8 June 2016 on protection against dumped imports from countries not members of the European Union.
European Parliament: One of the legislative bodies of the European Union.
Council: Refers to the Council of the European Union, another legislative body.
8 June 2016: Date of Regulation (EU) 2016/1036.
Article 14(5): Article within Regulation (EU) 2016/1036 that pertains to the registration of imports.
Member States: The countries that are members of the European Union.
6 March 2025: Date of the notice published in the Official Journal of the European Union initiating the antidumping proceeding.
Official Journal of the European Union: The official gazette of the European Union.
Softwood Plywood Consortium: The entity that lodged the complaint leading to the antidumping proceeding.
20 January 2025: Date the complaint was lodged by the Softwood Plywood Consortium.
Union: Refers to the European Union.
CN code 4412 39 00: The Combined Nomenclature code for the softwood plywood subject to registration.
1 July 2023: Start date of the period used to calculate dumping margins and injury elimination level.
30 June 2024: End date of the period used to calculate dumping margins and injury elimination level.
Article 7(2): Article of the basic regulation related to setting the amount of possible future liability.
Regulation (EU) 2018/1725: Regulation on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data.
European Parliament and of the Council: The two legislative bodies responsible for Regulation (EU) 2018/1725.
23 October 2018: Date of Regulation (EU) 2018/1725.
Regulation (EC) No 45/2001: A regulation repealed by Regulation (EU) 2018/1725.
Decision No 1247/2002/EC: A decision repealed by Regulation (EU) 2018/1725.
Brussels: Location where the regulation was done.
Ursula VON DER LEYEN: The President of the European Commission.
Official Journal EN
of the European Union L series
2025/922 21.5.2025
COMMISSION IMPLEMENTING REGULATION(EU) 2025/922
of 20 May 2025
making imports of softwood plywood originating in Brazil subject to registration
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2016/1036 of the European Parliament and of the Council of 8 June 2016 on protection
against dumped imports from countries not members of the European Union(1)(‘the basic Regulation’) and in particular
Article 14(5) thereof,
After informing the Member States,
Whereas:
(1) On 6 March 2025, the European Commission (‘the Commission’) announced, by a notice published in the Official
Journal of the European Union(2), the initiation of an anti-dumping proceeding with regard to imports into the Union
of softwood plywood originating in Brazil.
(2) This initiation followed a complaint lodged on 20 January 2025 by the Softwood Plywood Consortium on behalf of
producers representing more than 25 % of the total Union production of softwood plywood.
1. PRODUCT SUBJECT TO REGISTRATION
(3) The product subject to registration (‘the product concerned’) is plywood consisting solely of sheets of wood (other
than bamboo), each ply not exceeding 6 mm thickness, with both outer plies of coniferous wood, whether or not
coated or surface-covered, currently classified under CN code 4412 39 00 and originating in Brazil. The CN code is
given for information only and without prejudice to a subsequent change in the tariff classification.
2. REGISTRATION
(4) Under Article 14(5) of the basic Regulation, imports of the product concerned may be made subject to registration
for the purpose of ensuring that, if the investigation results in findings leading to the imposition of anti-dumping
duties, those duties can, if the necessary conditions are fulfilled, be levied retroactively on the registered imports in
accordance with the applicable legal provisions.
(5) The Commission has decided to make imports of the product concerned subject to registration on its own initiative
under Article 14(5) of the basic Regulation. The conditions for retroactive collection of duties will be assessed in the
regulation imposing definitive duties if any.
(6) Any future liability would emanate from the findings of the anti-dumping investigation.
(7) The calculations provided in the complaint requesting the initiation of an anti-dumping investigation estimate
dumping margins between 87 % and 131 % and an injury elimination level at 73 % for the product concerned for
the period from 1 July 2023 to 30 June 2024. The amount of possible future liability would normally be set at the
lower of those two levels according to Article 7(2) of the basic Regulation.
(8) However, at this stage the Commission is not in a position to estimate the amount of possible future liability. Thus,
the amounts mentioned in the complaint are only for information purposes and cannot create any expectations as to
the actual level of liability which will be established as a result of the investigation.
(1) OJ L 176, 30.6.2016, p. 21, ELI: http://data.europa.eu/eli/reg/2016/1036/oj.
(2) OJ C, C/2025/1490, 6.3.2025, ELI: http://data.europa.eu/eli/C/2025/1490/oj.
ELI: http://data.europa.eu/eli/reg_impl/2025/922/oj 1/2EN
OJ L, 21.5.2025
3. PROCESSING OF PERSONAL DATA
(9) Any personal data collected in the context of this registration will be treated in accordance with Regulation
(EU) 2018/1725 of the European Parliament and of the Council(3)on the protection of natural persons with regard
to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement
of such data,
HAS ADOPTED THIS REGULATION:
Article 1
1. The customs authorities are hereby directed, under Article 14(5) of Regulation (EU) 2016/1036, to take the
appropriate steps to register imports into the Union of plywood consisting solely of sheets of wood (other than bamboo),
each ply not exceeding 6 mm thickness, with both outer plies of coniferous wood, whether or not coated or surface-
covered, currently classified under CN code 4412 39 00 and originating in Brazil.
2. Registration shall expire nine months following the date of entry into force of this Regulation.
Article 2
This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 20 May 2025.
For the Commission
The President
Ursula VON DER LEYEN
(3) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons
with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of
such data data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://
data.europa.eu/eli/reg/2018/1725/oj).
2/2 ELI: http://data.europa.eu/eli/reg_impl/2025/922/oj