COMMISSION OF THE EUROPEAN COMMUNITIES 
Brussels, 21.04.1997 
COM(97) 160 final 
Proposal for a 
COUNCIL REGULATION ŒO 
imposing a definitive anti-dumping duty on imports of unbleached (grey) cotton 
fabrics originating in the People's Republic of China, Egypt, India, Indonesia, 
Pakistan and Turkey 
(presented by the Commission) 

Explanatory Memorandum 
(1) The Commission, by Regulation (EC) No 2208/96 (1), imposed provisional anti­
dumping duties on imports of unbleached (grey) cotton fabrics originating from the 
People's Republic of China, Egypt, India, Indonesia, Pakistan and Turkey on 20 
November 1996. 
(2) After the imposition of provisional duties, interested parties were given the 
opportunity to submit their comments and, if requested, to be heard. 
(3) Following a number of requests by exporters and importers, the scope of the 
investigation was adjusted to exclude medical gauze, given its particular physical 
characteristics and its very specific final use. 
(4) Some claims submitted by exporters relating to the determination of dumping 
margins were accepted and the dumping calculations were amended accordingly, 
where appropriate. The effect of this was an overall reduction of dumping margins. 
The definitive average margins vary between 13 and 15%. The largest reduction in 
dumping margin was for Pakistan, where the average dropped from 27.9% to 
14.3%. 
(5) Following exporters' submissions, the method of calculating undercutting and 
underselling was changed to take account of the different product types existing. 
However, the new method confirmed the existence of substantial price 
undercutting. 
(1) Official Journal No L 295 of 20 November 1996, p. 3. 
(6) Given the sensitivity and the strategic location of the product in the production 
chain, and comments received from interested parties, the Community interest 
aspects of the proceeding were extensively investigated. The analysis confirmed 
that measures would have beneficial effects for the Community industry, in that 
they would allow it to increase production, reduce costs and re-establish 
profitability, while they would not unduly affect the downstream industry. 
Therefore, the provisional conclusions that anti-dumping measures are not against 
the interest of the Community as a whole were confirmed. 
(7) In accordance with Article 9 of Council Regulation (EC) No 384/96, the 
Commission therefore proposes that the Council impose definitive anti-dumping 
duties on imports of unbleached (grey) cotton fabrics originating from the People's 
Republic of China, Egypt, India, Indonesia, Pakistan and Turkey. In view of the 
extent of the injury, it is also recommended that the provisional anti-dumping 
duties should be definitively collected to the extent of the amount of the definitive 
duties imposed. 
COUNCIL REGULATION (EC) NO /97 
of.... 
imposing a definitive anti-dumping duty on imports of unbleached (grey) cotton 
fabrics originating in the People's Republic of China, Egypt, India, Indonesia, 
Pakistan and Turkey 
THE COUNCIL OF THE EUROPEAN UNION, 
Having regard to the Treaty establishing the European Community, 
Having regard to Council Regulation (EC) No 384/96 of 22 December 1995 on 
protection against dumped imports from countries not members of the European 
Community1, and in particular Article 9 thereof, 
Having regard to the proposal submitted by the Commission after consulting the 
Advisory Committee as provided for by the above Regulation, 
Whereas: 
A. PROVISIONAL MEASURES 
(1) Commission Regulation (EC) No 2208/962 (hereinafter referred to as 'the 
provisional Regulation') imposed a provisional anti-dumping duty on imports into 
1 OJ No L 56 of 6.3.1996, p. 1, referred to as the Basic Regulation 
2 OJ No L 295 of 20.11.1996, p. 3 
the Community of unbleached (grey) cotton fabrics falling within CN codes 5208 
11 to 5208 19 and 5209 11 to 5209 19 originating in the People's Republic of 
China, Egypt, India, Indonesia, Pakistan and Turkey. 
B. SUBSEQUENT PROCEDURE 
(2) The Commission continued to seek and verify all information deemed necessary for 
its definitive findings and carried out investigations at the premises of importers in 
the Community related to producers/exporters in the countries concerned: 
- Eurotex Trading Corp. GmbH, Hamburg, Germany 
- Mafatlal Limited, Romaga AG (UK and Switzerland), Lancashire, UK 
(3) As announced in recital (13) of the provisional Regulation, the Commission further 
investigated whether or not gauze should be excluded from the scope of this 
proceeding and carried out investigations at the premises of the following 
companies in the Community: 
- Torval, Torras Valenti S.A., Navarcles, Barcelona, Spain 
- Texpol, Textil Planas Oliveras S.A., Manresa, Barcelona, Spain. 
(4) Following the imposition of the provisional anti-dumping measures, certain 
interested parties submitted comments in writing. 
(5) Those parties who so requested were granted an opportunity to be heard by the 
Commission. 
(6) Upon request, parties were informed of the essential facts and considerations on the 
basis of which it was intended to recommend the imposition of definitive anti­
dumping duties and the definitive collection of amounts secured by way of 
provisional duties. They were also granted a period within which to make 
representations subsequent to this disclosure. 
(7) The oral and written comments submitted by the interested parties were considered 
and, where deemed appropriate, taken into account for the definitive findings. 
C. PRODUCT UNDER CONSIDERATION AND LIKE PRODUCT 
(8) It should be recalled that this proceeding covers all flat unbleached (grey) cotton 
fabrics containing at least 85% cotton. Grey cotton fabrics are produced in many 
different types or "constructions", which are defined by a combination of the count 
(weight) of the yarn used, and the number of threads used for both warp and weft 
and the way yarns are interlaced. Moreover, many producers can generally produce 
any construction of grey cotton fabrics on demand. 
(9) On the basis of the information available at the provisional stage, the Commission 
considered that domestic and export types from the countries concerned were like 
products within the meaning of Article 1 (4) of the Basic Regulation, as shown in 
recital (12) of the provisional Regulation. It also considered that the types sold on 
the domestic market in India and the types exported by Chinese companies were 
like products, as well as the types exported from all countries concerned and the 
types produced by Community producers. 
(10) Following the disclosure of provisional findings, several requests were presented 
for the exclusion of specific types of grey cotton fabrics from the scope of the 
proceeding. The types in question included fabrics of different constructions for 
various specific uses. These types included, inter alia, certain fabrics for use in 
embroidery, fabrics for use in polishing disks, and fabrics for the manufacture of 
bandages, dressings and medical gauze (referred to as "gauze"). 
(11) With regard to gauze, the Commission found that: 
- gauze fabrics have different physical characteristics, given their particularly light 
constructions which renders them generally unsuitable for any other purpose and 
therefore not interchangeable with the constructions used, for example, in the 
garment and household furnishing sectors; 
- gauze fabrics have a specific sanitary/pharmaceutical application, which is 
different from the other fabrics used in the textile industry, as the product can 
only be used to produce medical gauze, which is defined by the "European 
Pharmacopoeia" set by the Council of Europe (CN 3005 90 31), and has to 
comply with strict hygiene rules; 
- by virtue of their classification under an individual CN code 5208 1110, fabric 
for medical gauze is clearly identifiable as a specific product and can therefore 
be excluded without prejudicing the effectiveness of any measures imposed. The 
evasion of any measures by means of fraudulent product mis-descriptions would 
be difficult and easily detectable. 
Fabrics for the manufacture of bandages, dressings and medical gauze, classified 
under CN heading 5208 11 10, are excluded from the scope of this proceeding. Any 
provisional anti-dumping duty levied on this product should consequently be 
released or reimbursed. 
(12) With regard to all other types of fabrics for which requests for exclusion from the 
scope of this proceeding were received, it should be stressed that they clearly fall 
under the like product definition set out above. They are therefore included in the 
scope of the proceeding. 
D. EXPORTERS AND PRODUCERS IN THE COUNTRIES OF ORIGIN 
1. Individual examination in the context of sampling 
(13) Several Turkish parties argued that it was contradictory to consider that, on the one 
hand, a sample containing only two companies would still be representative of 
Turkish production and exports of the product concerned, but on the other hand to 
refuse to grant individual examination to the companies which so requested. 
The argument raised mixes up the question of the representativeness of the sample 
in Turkey with the question of whether requests for individual examination can be 
accepted, which depends on the burden represented by the number of individual 
requests received from all the countries subject to investigation. 
It should be recalled that in recital (26) to (28) of the provisional Regulation, it was 
already concluded that, having regard to Article 17 (3) of the Basic Regulation, no 
individual examination could be granted because the number of 
producers/exporters was so large, in a case including several hundred exporters in 
six countries, that individual examination would have been unduly burdensome and 
would have prevented completion of the investigation in good time. 
E. DUMPING 
1. Normal value 
(a) Market economy countries 
(i) Construction of normal value methodology 
(14) Two Egyptian producers/exporters questioned the use of constructed normal value 
where the domestic prices of another producer/exporter in the sample could have 
been used to establish normal value for similar constructions. 
It should be noted that, although some products had the same construction, the 
different spinning methods, the efficiency of the looms and the different qualities of 
cotton used in Egypt caused such a large variation in the cost of the end-product 
that using the price of another producer/exporter as a basis for normal value would 
not have been appropriate. 
(15) Two Indian producers/exporters claimed that normal value had been incorrectly 
determined because domestic sales of second quality products had been excluded 
from the calculation of normal value. 
Considering that exports to the Community were first quality products, normal 
value had to be calculated on the basis of the comparable product in accordance 
with Article 1 (2) of the Basic Regulation, i.e. first quality products sold on the 
domestic market of the exporting country. 
(16) Several parties challenged the use of two different thresholds, namely 5% and 10%, 
to assess representativeness of respectively domestic sales and profitability. One 
party argued that if domestic sales were considered unrepresentative in terms of 
profit, they should equally be considered unrepresentative in terms of SG&A. 
The argument raised appears to confuse the different thresholds used by the 
Commission in order to establish (i), whether domestic prices should be used as a 
basis for normal value and, (ii), whether domestic sales are profitable. Reference is 
made to recitals (29) to (36) of the provisional Regulation where the methodology 
followed by the Commission, in conformity with Article 2 of the Basic Regulation 
and its consistent practice, is explained in detail. For the sake of clarification, it 
should be noted that the fact that some sales, or indeed all sales, appear to be loss-
making does not render the SG&A unreliable when constructing an appropriate 
normal value. On the other hand, it is the Commission's practice to consider the 
entirety of domestic sales as not being in the ordinary course of trade if less than 
10% of the volume of such sales is profitable (see recital (33) of the provisional 
Regulation). This threshold is also used to determine whether the profit realised on 
the domestic market can provide an appropriate basis for the calculation of 
constructed normal value. 
(ii) Costs of manufacturing 
(17) Two Egyptian producers/exporters disputed the Commission's decision to increase 
the reported costs of raw cotton purchases. 
10 
In one case, this was done because the producer/exporter had failed to take into 
account the actual prices paid which reflected the exceptional increase in the 
market price of raw cotton in the course of the 1994/1995 season (which covered 
most of the investigation period). In the other case, an adjustment was made 
because the reporting of raw cotton costs was based on the financial year rather 
than on the investigation period. Provisional findings are therefore confirmed. 
(Hi) Selling, General and Administrative expenses (SG&A) 
(18) Several parties challenged the inclusion of financing costs in the construction of 
normal value. 
In that respect, it should be noted that the Commission's consistent practice has 
been to include all costs incurred to produce and sell the product concerned on the 
domestic market, including financing costs, in the construction of normal value. 
Financing costs as reported were thus used in the construction of normal value. 
(19) Two Indonesian producers/exporters with related distributors on the domestic 
market argued that the Commission had wrongly accounted for the costs of these 
distributors and requested that the SG&A be reduced to reflect the limited activities 
of these related companies. 
11 
In this context, it should be noted that it is considered normal to treat sales 
companies and the producer/exporter with which they are associated as a single 
economic unit, in so far as the sales companies concerned in this case carry out 
functions on the domestic market which are essentially identical to those performed 
by a subsidiary or sales department. Given that the Commission considered that the 
above conditions were met in this ease with regard to these related distributors, 
their costs were calculated in accordance with Article 2 (5) of the Basic Regulation 
and taken into account in the construction of normal values for the two 
producers/exporters concerned. 
(iv) Domestic profit margin 
(20) With regard to the profit margin used in the construction of normal value, some 
producers/exporters argued that domestic profitability should have been assessed 
only on the basis of those constructions sold both domestically and on the 
Community market. 
It should however be recalled that Article 2 (2) of the Basic Regulation provides 
that the "sales of the like product intended for domestic consumption shall 
normally be used to determine normal value". Therefore, all domestic sales of the 
like product intended for domestic consumption were used to establish the domestic 
profit margin, whether or not the particular construction was also exported to the 
Community. 
12 
(21) The Pakistani producers/exporters argued that in calculating domestic profit for the 
only producer/exporter with domestic sales in the ordinary course of trade, the 
Commission erroneously excluded certain transactions, the effect of which was 
artificially to inflate the profit margin. In addition, they argued that this profit 
margin was not representative of the Pakistani market and should not have been 
used in the construction of normal value for the other three companies in the 
sample, since none of them made a profit on their domestic sales of the product 
concerned. 
Article 2 (3) of the Basic Regulation provides that the profit achieved on profitable 
domestic sales in the ordinary course of trade should be used in the construction of 
normal value for companies with no or insufficient domestic sales of the like 
product in the ordinary course of trade. In this respect, the methodology used for 
provisional determinations is confirmed. 
However, on reviewing its calculations, it became apparent to the Commission that 
certain transactions which had been excluded for provisional determinations should 
in fact be included in the turnover. A revised profit margin was thus calculated and 
applied in the construction of normal value for the producer/exporter concerned as 
well as the other three producers/exporters which had no or insufficient domestic 
sales. 
13 
(b) Non-market economy country: the People's Republic of China 
(22) The representatives of the Chinese producers/exporters argued that the People's 
Republic of China was now a market economy country and therefore the use of an 
analogue country to determine normal value was inappropriate as Chinese domestic 
prices and/or production costs should be considered reliable. 
The Commission recognises that economic reforms are under way in China, and the 
fact that the economy of the People's Republic of China is in transition from a 
planned, fully State-controlled economy to a partially market-oriented economy. 
However, in accordance with Article 2 (7) of the Basic Regulation which applies to 
the People's Republic of China, the request could not be granted and the 
conclusions of recital (47) of the provisional Regulation are therefore confirmed. 
2. Export price 
(23) It was argued, in respect of the sole Chinese related importer based in the 
Community that the dumping calculations were incorrect as they included all 
Chinese products sold by the related importer on the Community market, and not 
only those products purchased from its related producer/exporter in the sample. 
In this respect, it should be noted that, as all three Chinese producers/exporters in 
the sample were directly or indirectly related via the Chinese State, all their exports 
of the product concerned were treated as if they had emanated from one exporter. 
Consequently, all three producers/exporters were considered to be related to the 
importer in question, and all their export prices were reconstructed accordingly. 
14 
(24) It was also argued that, as the above related importer in the Community only acted 
as an agent, the profit margin of 5% used by the Commission for provisional 
determinations was too high. 
The functions performed by the related company were found to be those typically 
performed by an importer. For the purpose of definitive determinations, the 
average profit margin of 4.4% found for two unrelated importers in the Community 
was used. 
(25) Two Indian producers/exporters which formed part of the same group and sold part 
of their production to the Community through three related trading companies 
claimed that the Commission erroneously constructed export prices using profit and 
SG&A margins disproportionate to the mere trading activities of the related 
importers. 
Having verified the information provided by the three" related companies, the 
Commission constructed export prices on the basis of re-calculated costs incurred 
between importation and resale. This re-calculation was required because the three 
related companies were unable to demonstrate that the allocation of costs submitted 
to the Commission was historically utilised or properly reflected the costs relating 
to the product concerned. The Commission consequently made a new allocation of 
costs on the basis of turnover and a reasonable estimate of costs incurred for 
processed and non-processed textile goods sold in the Community. The profit 
margin provisionally estimated at 5% was changed to 4.4% to reflect information 
received from independent importers in the Community (see recital (24)). 
15 
(26) One Indian producer/exporter argued that the Commission should treat "master 
contracts" and not invoices as individual transactions, claiming that master 
contracts determined the export price, and that the prices agreed therein depended 
on the so called "ready quota" system existing in India. 
The verification revealed that 94 master contracts were applicable during the 
investigation period. Prices in the master contracts for identical grey cotton fabric 
types to the same customer varied to such an extent from master contract to master 
contract that they were completely unreliable. Moreover, a random check revealed 
that prices varied significantly between invoices and master contracts. It was 
therefore concluded that master contracts could not form a reliable basis to 
determine export prices, which were therefore established on the basis of the 
invoice prices paid or payable for the product when sold for export to the 
Community during the investigation period. 
3. Comparison 
(27) In accordance with recital (54) of the provisional Regulation, adjustments for the 
purpose of ensuring a fair comparison between normal value and export price were 
granted only when a claim was made within the time limits set for that purpose and 
when the party concerned could demonstrate the effect of any alleged difference on 
price and price comparability. 
(28) Several producers/exporters challenged the Commission's refusal to grant an 
adjustment for level of trade. 
16 
Article 2 (10) (d) of the Basic Regulation requires that it be shown that the 
difference in level of trade has affected price comparability, which is demonstrated 
by consistent and distinct differences in functions and prices of the seller for the 
different levels of trade in the domestic market of the exporting country. In the 
absence of substantiated evidence to this effect, the claims were rejected. 
(29) All Egyptian producers/exporters companies challenged the Commission's refusal 
to grant them an adjustment to normal value for credit costs. 
As mentioned in recital (57) of the provisional Regulation, no evidence was 
provided that the payment terms had been agreed at the time of sale, and no proof 
was provided that credit terms were a factor taken into account in the determination 
of the prices charged. Indeed, all three producers/exporters admitted that prices did 
not vary according to payment terms. Moreover, the claims were incorrect in 
respect of the number of days and interest rates, and consequently provisional 
findings are confirmed. 
(30) Three Indonesian producers/exporters claimed that they should have been granted 
an allowance for sales of second quality products to the Community. 
For one of them, this claim was taken into account by the calculation of an adjusted 
normal value comparable to export prices of second quality products to the 
Community. 
17 
For another producer/exporter, the investigation showed that export prices for 
products of printing quality showed no difference compared to prices of first 
quality products and an adjustment was consequently not required. 
A third producer/exporter requested either exclusion of its export sales of second 
quality products from the dumping calculation, or an adjustment for differences in 
physical characteristics. Considering that these second quality products fell within 
the definition of the like product, it was decided not to exclude the transactions 
concerned from the calculation of dumping, but to make an adjustment to normal 
value. 
(31) Several producers/exporters claimed that other dates, such as the date of order, the 
date of contract or the date of payment, should be used in preference to date of 
invoice in the dumping calculation which allegedly better reflected the material 
terms of sale. 
It should be noted that Article 2 (10) (j) of the Basic Regulation provides that the 
date of sale should normally be the date of invoice, unless the date of contract, 
purchase order or order confirmation more appropriately reflects the material terms 
of sale. The producers/exporters concemed did not demonstrate that the alternative 
date they proposed more appropriately established the material terms of sale. 
Therefore, there was no reason to depart from the consistent practice of using the 
date of invoice as the date of sale, and provisional findings are hereby confirmed. 
18 
4. Dumping margins 
(a) General methodology 
(32) Several parties claimed that the methodology used by the Commission to determine 
the provisional dumping margins, i.e. comparing the weighted average normal 
value to the prices of all individual export transactions to the Community, deviated 
from regular practice and was inappropriate. They stated that the Commission did 
not demonstrate that there was a pattern of export prices which differed 
significantly among different purchasers, regions or time periods, or that the 
weighted average to weighted average method did not reflect the full degree of 
dumping being practised. 
(33) According to Article 2 (11) of the Basic Regulation, the dumping margin should 
normally be established on the basis of a comparison of a weighted average normal 
value with a weighted average of prices of all export transactions to the 
Community. However, if there is a pattern of export prices which differ 
significantly among different purchasers, regions or time periods, and if the above-
mentioned methodology does not reflect the full degree of dumping being 
practised, the dumping margin should be calculated on the basis of a comparison of 
a weighted average normal value to prices of all individual transactions to the 
Community. 
19 
(34) Following the comments made by several producers/exporters, the Commission 
reviewed all dumping calculations for all producers/exporters investigated and 
came to the conclusion that establishment of the dumping margin on the basis of a 
comparison of the weighted average normal value to the weighted average export 
price reflected the full degree of dumping being practised by all 
producers/exporters in the People's Republic of China, Egypt, Pakistan and Turkey, 
and some producers/exporters in India and Indonesia. Provisional findings were 
amended accordingly. 
(35) With regard to all remaining producers/exporters in India and Indonesia, it was 
confirmed that there was a pattern of export prices to the Community which 
differed significantly among different purchasers, regions or time periods. It also 
established that the calculation of dumping margins on the basis of a comparison of 
the weighted average normal value to the weighted average export price did not 
reflect the full degree of dumping being practised. For those producers/exporters, 
provisional findings that dumping margins should be established on the basis of a 
comparison of a weighted average normal value to prices of all individual export 
transactions to the Community are confirmed. 
(b) Dumping margin for cooperating producers/exporters not investigated 
(36) The provisions of recital (67) of the provisional Regulation are hereby confirmed. 
The dumping margins for cooperating producers/exporters which were not 
investigated have been based on the average of the individual dumping margins 
calculated for the producers/exporters included in the sample, weighted on export 
turnover to the Communitv. 
20 
(c) Residual dumping margin 
(37) In view of the overall high level of cooperation in this proceeding, it was 
considered appropriate to amend provisional findings with regard to the calculation 
of the residual dumping margin, and to use the highest dumping margin found for 
the producers/exporters in the sample for non-cooperating producers/exporters. 
(d) Methodology for groups of companies 
(38) All three Egyptian producers/exporters questioned - but did not oppose - the 
provisions of recital (72) of the provisional Regulation whereby they were all 
treated as one group and subject to the general rule on groups of companies. 
Due to the fact, however, that all three producers/exporters investigated had 
common ownership, the State, provisional findings were confirmed and the three 
Egyptian producers/exporters treated as one group, in order to avoid circumvention 
of the anti-dumping measures by Egyptian producers/exporters channelling their 
exports to the Community through the producer/exporter with the lowest anti­
dumping duty. 
(39) One Indian producer/exporter challenged the application of the general rule to 
calculate a single dumping margin for companies belonging to the same group. It 
stated that, although technically related (common shareholding), the companies in 
the group were separate economic and legal entities. 
To avoid circumvention of the anti-dumping measures by producers/exporters in 
the group channelling their exports to the Community through the 
producer/exporter with the lowest anti-dumping duty, the Commission applied the 
general rule regarding groups of companies to the Indian group. 
21 
(40) One Indonesian producer/exporter requested that the assessment of dumping be 
made globally for the group, and not per producer/exporter as provided for in 
recital (69) of the provisional Regulation. 
Considering, however, that it has been the Community's consistent practice to 
calculate first a dumping margin for each producer/exporter in the group which 
was investigated, and subsequently to use the dumping margins found to calculate a 
single margin for the group as a whole, the request was rejected. 
(41) The methodology set out in recital (69) of the provisional Regulation is hereby 
confirmed. 
(e) Definitive dumping margins 
(i) The People's Republic of China 
(42) The methodology set out in recital (70) of the provisional Regulation is hereby 
confirmed. 
(43) The definitive dumping margin for the People's Republic of China, expressed as a 
percentage of the CIF import price at the Community border, is 18.9%. 
(ii) Egypt 
(44) The definitive dumping margin for Egypt, expressed as a percentage of the CIF 
import price at the Community border, is 13.0%. 
22 
(Hi) India 
(45) For the producers/exporters or groups of companies in the sample, the definitive 
dumping margins expressed as a percentage of the CIF import price at the 
Community border are: 
Century Textiles & Industries Limited 17.2% 
Coats Viyella India Limited 12.3% 
Vardhman Spinning & General Mills Limited 5.1% 
Mafatlal Industries 12.6% 
Mafatlal Fine Spinning & Manufacturing Producer/exporter Ltd. 12.6% 
(46) The definitive dumping margin for cooperating producers/exporters which were not 
investigated, expressed as a percentage of the CIF import price at the Community 
border, is 15.3%. 
(47) The residual dumping margin for India, expressed as .a percentage of the CIF 
import price at the Community border, is 17.2%. 
(iv) Indonesia 
(48) For the producers/exporters or groups of companies in the sample, the definitive 
dumping margins expressed as a percentage of the CIF import price at the 
Community border are: 
23 
P.T. Apac Inti Corpora / P.T. Kanindo Prima Perkasa 3.5% 
P.T. Argo Pantes 14.5% 
P.T. Daya Manunggal 14.5% 
P.T. Grand Textile Industries 14.5% 
P.T. Eratex Djaja 12.8% 
(4e*) The definitive dumping margin for cooperating producers/exporters which were not 
investigated, expressed as a percentage of the CIF import price at the Community 
border, is 13.5%. 
(50) The residual dumping margin for Indonesia, expressed as a percentage of the CIF 
import price at the Community border, is 14.5%. 
(v) Pakistan 
(51) For the producers/exporters or groups of companies in the sample, the definitive 
dumping margins expressed as a percentage of the CIF import price at the 
Community border are: 
Diamond Fabrics Ltd 9.0% 
Amer Fabrics Ltd 9.0% 
Kohinoor Raiwind Mills Ltd 22.9% 
Kohinoor Weaving Mills Ltd 22.9% 
Lucky Textile Mills 15.5% 
Nishat Mills Ltd 9.2% 
Nishat Fabrics Ltd 9.2% 
24 
(52) The definitive dumping margin for cooperating producers/exporters which were not 
investigated, expressed as a percentage of the CIF import price at the Community 
border, is 14.2%. 
(53) The residual dumping margin for Pakistan, expressed as a percentage of the CIF 
import price at the Community border, is 22.9%. 
(vi) Turkey 
(54) For the companies in the sample, the definitive dumping margins expressed as a 
percentage of the CIF import price at the Community border are: 
Birlik Mensucat Ticaret ve Sanayi Isletmesi A.S. 13.6% 
Sôktas Pamuk ve Tarim Uriinlerini Degerlendirme Ticaret ve Sanayi A.S. 17.5% 
(55) The definitive dumping margin for cooperating producers/exporters which were not 
investigated, expressed as a percentage of the CIF import price at the Community 
border, is 15.2%. 
(56) The residual dumping margin for Turkey, expressed as a percentage of the CIF 
import price at the Community border, is 17.5%. 
25 
F. COMMUNITY INDUSTRY 
(57) The Chinese exporters' questioned the Commission's methodology for determining 
the scope of the Community industry on the grounds that the representativeness of 
the complainant Community producers had been based on open-market sales of the 
like product only, whereas the production within the EU destined for captive use 
should also have been taken into consideration. Including production for captive 
use would include, for example, the production of the like product in integrated 
companies with operating weaving facilities which directly feed the requirements 
of in-house processing. 
The Commission examined this contention but cannot accept it. It is the practice of 
the Community institutions, confirmed by the European Court of Justice, to 
exclude captive production from the calculation of total Community production, 
where there is a clear separation between the 'captive' and 'free' markets. As the 
captive weaving to which the Chinese exporters' representative refers is not sold on 
the open market and does not compete directly with imports of the like product, the 
Commission concluded that the output of captive weaving in the EU should not be 
included in the calculation of Community production for the purpose of 
determining representativeness. 
26 
(58) After the imposition of provisional measures, the Commission received indication 
that a complaining producer was no longer supporting the complaint. The producer 
was accordingly excluded from the definition of Community industry, therefore 
reducing the representativeness of the complainant to 56% of Community 
production. However, following the disclosure of definitive findings, the producer 
in question wrote to the Commission declaring to be still supporting the complaint. 
After examining the evidence available, and after direct contacts with the producer, 
the Commission decided to re-integrate that producer in the definition of 
Community industry. 
It was therefore confirmed that the complainant represents a major proportion of 
around 70% of Community production of the product concerned. 
(59) Furthermore, as a result of the exclusion of medical gauze set out in recital (12) and 
of further investigation at the definitive stage, the relevant data relating to injury 
have been adjusted in order to take account of this exclusion. 
G. INJURY 
5. Preliminary remark 
(60) Following the changes to the like product definition set out above, some of the 
injury data from the provisional Regulation changed as outlined in the following 
recitals. All data which is not specifically recalled from the provisional Regulation 
is to be considered as having been confirmed by the Commission. 
27 
6. Community consumption 
(61) Community apparent consumption rose from 265,984 tonnes in 1992. to 266,158 
tonnes in 1993, to 304,660 tonnes in 1994 but dropped 10% to 274,282 tonnes in 
1995, the investigation period. Over the period 1992-1995, Community 
consumption rose by 3%. 
7. Volume and market share of the dumped imports 
(62) The aggregate volume of dumped imports of the product concerned into the 
Community originating in the countries subject to investigation increased by 16% 
between 1992 and 1994 from 104,330 tonnes in 1992, to 110,741 tonnes in 1993, to 
121,501 tonnes in 1994. The volume decreased 14% in 1995 to 104,987 tonnes, 
broadly in line with the development of Community demand. 
The development of import volumes, assessed in relation to Community 
consumption, led to a substantial share of the Community market being maintained 
by the countries concerned of 39.2% in 1992, 41.6% in 1993, 39.9% in 1994, and 
38.3% in the investigation period. 
28 
8. Prices of the dumped imports 
(63) In recital (102) of the provisional Regulation price undercutting was calculated by 
comparing weighted average EC producers' selling prices with weighted average 
export prices of all transactions by each producer-exporter concerned. This method 
was disputed by the exporters concerned as being imprecise. In order to achieve 
greater accuracy, the Commission used the following categories in its assessment 
of the extent of undercutting: Extra coarse (Counts 0-10 Ne), Coarse (Counts 11-20 
Ne), Medium (Counts 21-30 Ne), Higher Medium (Counts 31-40 Ne), Fine (Counts 
41-60 Ne) and Superfine (Counts 61 Ne and above). 
The results of the comparison showed margins of price undercutting for all the 
exporting producers investigated, with the exporters in each country having 
weighted average margins accross all categories ranging up to: 
-China 34% 
-Egypt 37% 
-India 42% 
- Indonesia 49% 
-Pakistan 30% 
-Turkey 21%. 
29 
9. Situation of the Community industry 
(a) Data relating to the Community industry as a whole 
(i) Sales and market share of the total Community industry 
(64) Total sales by the Community producers fell by around 10% over the period, from 
90,348 tonnes in 1992, to 80,692 in 1993, to 81,913 in 1994, and to 81,873 in the 
investigation period. Matching this decline, the corresponding market share went 
from 34% in 1992, to 30.3% in 1993, 26.9% in 1994, and 29.9% in the 
investigation period, a decline of 12% in relative terms over the period. 
(ii) Plant closures and reduction of employment 
(65) Recital (106) of the provisional Regulation referred to plant closures and job losses 
among manufacturers of the product concerned. Representations were made, 
however, which pointed out that the job losses mentioned include those suffered by 
integrated producers which, as explained in recital (57) above, are not included in 
the injury investigation. No accurate information is available however which would 
enable the Commission to estimate the proportion of this figure which could be 
ascribed to the Community industry as defined in recital (89) of the provisional 
Regulation. 
30 
(b) Data relating to the sampled Community producers 
(66) It will be recalled from recital (89) of the provisional Regulation that sampling was 
applied for the purpose of the investigation of injury. 
ft) Change in product mix 
(67) As mentioned in recital (112) of the provisional Regulation, the Commission 
examined the information on five reference constructions which had been used in 
order to avoid distortions to the price comparisons being caused by changes in the 
product mix. The advantage of continuing to use these five reference constructions 
together with the six product categories described in recital (63) above, is that data 
for the former is available for the period 1992-1995. Three of these five reference 
constructions fit into the fabric categories 'Coarse', 'Medium' and 'Higher 
Medium', and can be considered as basic constructions, with low value added but 
produced in high volumes. These three categories alone account for 80% of the 
imports from the countries concerned. The development over time of the quantities 
sold of these three reference constructions shows substantial decline, significantly 
greater than the fall in the total sales of the sampled producers. Sales of these three 
reference constructions, representing about 21% of sales in 1992, dropped 43% 
between 1992 and 1995. 
31 
The sampled Community producers had claimed that they had been forced to 
reduce the production of basic constructions and to move into the production of 
niche products as a result of the significant price undercutting of the dumped 
imports from the exporting producers. The smaller production runs of niche 
products imply lower volumes, longer machinery stand-still times between batches 
and consequently higher unit costs. 
10. Conclusions on injury 
(68) The above conclusions and those in recital (116) of the provisional Regulation are 
confirmed. 
H. CAUSATION 
11. Effect of the dumped imports from the countries concerned 
(69) The exporters alleged that for injury to exist, significant changes must be seen in 
both the volume of imports and their market share, and there should also be a 
decline in export prices of the product concerned. Since the product concerned is 
subject to quotas and voluntary export restraints, some of the above elements did 
not change significantly. It was therefore submitted that there could have been no 
injury. 
32 
In this respect, it should be borne in mind that, according to Article 3 (2) and 3 (3) 
of the Basic Anti-Dumping Regulation none of the factors concerning import 
volumes, market shares and prices listed in this provision can necessarily give 
decisive guidance in an injury analysis. 
As far as the volumes and market share of imports in the present case are 
concerned, they actually did not significantly increase. This situation has to be seen 
in the light of the existence of a quota system limiting imports, which, as has been 
found, has been consistently utilised at high rates (the weighted average utilisation 
rate for the countries concerned was 95% in 1995) during the period under 
consideration. Statistics show that some exporting countries have even borrowed 
quantities from other textile categories for their exports of the product concerned. 
However, given the absolute level of the imports concerned and the level of import 
prices, in the present case and in accordance with Article 3 (2) and 3 (3) of the 
Basic Anti-Dumping Regulation, injury has consisted in insufficient profitability 
being the result of price depression and price suppression (see recital (116) of the 
provisional Regulation and recital (67) above). These price levels are explained by 
the characteristics of the quota system in place, which gives companies within the 
exporting countries the incentive to compete for the allocation of quotas, and 
consequently for export customers. 
33 
Furthermore, it is considered that injury can be caused even where export prices are 
rising, since these prices must be seen in relation to the Community producers' 
prices. In the presence of significant price undercutting, as in this case, and given 
that the exporters concerned have around 40% of the Community market, it is clear 
that whether the prices of the dumped exports are rising or not, they will still be 
exerting price suppression or price depression or both, and injury can be suffered as 
a result. 
(70) The Commission's examination of the basic constmctions, as described in 
recital (66) above, provides further evidence on the effects of the dumped imports. 
The data clearly show that the sales of the constructions which are closest in type to 
those widely imported fell much more sharply than total sales, thus demonstrating 
the direct effect of the substantial price undercutting established for these product 
types. 
12. Effects of other factors 
(71) Various exporters and downstream users of the product concerned have contested 
the findings relating to causation in the provisional Regulation, citing other factors 
as being behind the injury suffered by the Community industry. 
34 
ft) Fall in apparent consumption 
(72) Some exporting countries submitted that it was the decline in consumption of the 
like product between 1994 and 1995 which was the single most important cause of 
material injury to the Community industry. 
The Commission has examined this argument. Consumption of the product 
concerned fell by 10% between 1994 and 1995; imports also declined. 
Nevertheless, over the period 1992-1995, the dumped imports from the countries 
subject to this proceeding remained relatively stable with a high (around 40%) 
market share in 1995, and were sold at prices that undercut Community producers' 
prices to a significant extent. While it is clear, therefore, that the Community 
industry was not immune to the effects of the fall in demand for the like product, 
the dumped imports caused material injury to Community producers. 
(ii) Imports from other third countries 
(73) Certain interested parties made reference to the effect of imports from third 
countries as a cause of material injury, but no information was provided that would 
cause an alteration to the findings at recitals (120) to (123) of the provisional 
Regulation. These findings are therefore confirmed. 
35 
(Hi) Increase in raw cotton prices 
(74) The Commission's findings at recital (124) of the provisional Regulation were 
questioned by certain exporters on the grounds that the rise in the price of raw 
cotton did not affect all of the Community industry in the same way, with some 
producers allegedly less affected than others. Furthermore, it was claimed that the 
raw cotton price rise appeared to have been partially absorbed by the spinning 
sector, which supplies the Community industry with cotton yam. (For a description 
of the spinning sector, see recital (80)). 
The Commission has examined these arguments. Although the impact of the rise in 
the price of raw cotton on the Community industry may have been felt differently 
by individual producers across the Community, it was considered to have been 
significant overall. This conclusion is supported by the finding that certain of the 
sampled Community producers experienced increases in the cost of yam of around 
50% between 1992 and 1995. 
As to partial absorption of the increased raw cotton prices by the spinning sector, 
no evidence was presented to the Commission in this context. 
13. Conclusion on causation 
(75) The findings presented in recital (125) of the provisional Regulation are confirmed. 
36 
I. COMMUNITY INTEREST 
14. The Community interest investigation 
(76) Based on the information available, and taking account of the possible price and 
quantity changes of the dumped imports following imposition of definitive 
measures, the Commission examined the impact of anti-dumping measures on the 
various sectors of the Community cotton textiles industry. 
To this end, and in order to obtain the clearest possible overview, the Commission 
services sent a questionnaire to all the parties (users, suppliers, importers) who had 
made themselves known in the course of the proceeding, to various trade 
associations, which forwarded it to their members, as well as to other parties who 
requested it. 
(77) It should be noted that, where appropriate, statistics relating to cotton textiles with a 
cotton content of at least 50% were used in the absence of more accurate statistics 
relating to the product concerned, which has a cotton content greater than 85%. 
Fabrics with a cotton content exceeding 50% are hereinafter referred to as 'majority 
cotton fabrics'. 
The economic operators concerned in this analysis 
(78) The various parts of the Community cotton textiles production chain are listed in 
the four main categories below. 
(79) A significant proportion of the industry is vertically integrated to include at least 
two of the activities in the following four categories. 
37 
ft) Suppliers 
(80) Spinners: the primary raw material, raw cotton, is imported from the producing 
countries and is spun into yam. Spinning is a highly automated process, and EU 
yam producers have reached a high level of efficiency, largely due to the 
widespread use of open-end spinning technology. 
(ii) The Community Industry 
(81) Weavers: grey (i.e. unbleached) yam is woven into fabric. This grey cloth has then 
to undergo an additional, separate finishing stage where it is bleached and printed 
or dyed. 
(Hi) Users 
(82) Finishers: the bleaching, printing and dyeing of unbleached cotton fabrics is carried 
out by finishers. The grey cloth is first washed and bleached to prepare it for the 
absorption of dye or printing inks, then it is printed or dyed. These activities are 
generally, but not always, performed by the same company. 
(83) Makers-up: the finished cloth is cut and sewn to make garments, household goods, 
or industrial goods by makers-up. This is the most labour intensive stage, especially 
in the clothing industry where the production processes are not normally 
automated. 
38 
ftv)Importers/Con verters 
(84) Importers/converters: the operators who supply the Community's makers-up with 
cloth are the converters who purchase grey cloth, often imported, and who recruit 
the services of finishers to have the fabric processed to the maker-up stipulations. 
15. The Community industry 
(a) Nature and structure of the Community industry 
(85) Total production of the product concerned in the Community was around 94,000 
tonnes in 1995. It will be recalled from recital (58) that the Community industry 
accounts for around 70% of this figure. 
(86) The Community industry is composed mainly of small and medium-sized 
enterprises. Production is capital intensive and highly automated. It should be noted 
that grey cotton fabric is an intermediate product, with a high degree of 
standardisation and price sensitivity in the basic, most common constmctions, but 
subject to fashion changes, particularly in niche areas of the market. 
(87) The cotton weaving industry as a whole, including the Community industry and 
integrated producers (as discussed below), employs 115,000 people. It is not 
possible to exactly allocate employees to the product concerned, as it is produced 
by the same companies and on the same machines which produce the majority 
cotton fabrics. 
39 
(b) Viability of the Community industry 
(88) It will be recalled from recital (108) of the provisional Regulation that, during the 
period considered for the analysis of injury, the domestic industry rationalized its 
production process, with a high level of machinery replacement. 
(89) Though the Community industry is mainly oriented towards the Community 
market (less than 15% of total sales of the product concerned are exported), their 
export performance improved 12% between 1992-1995, from 10,904 to 12,247 
tonnes. The Commission considers this as an important indication that the 
Community weaving industry is viable and internationally competitive. 
(c) Expected effects of the imposition of anti-dumping measures on the 
Community industry 
(90) The Commission based its analysis of the impact of the anti-dumping measures on 
Community industry on the data provided by the sampled Community producers. 
(91) To assess the effects of the anti-dumping measures on the Community industry, it 
is necessary to examine first of all the possible reactions of the exporting producers 
in the countries concerned. This has been done on the assumption of constant 
demand conditions. 
(92) Following the imposition of duties, the prices of the imported like product can be 
expected to rise. This price rise would be reflected in a fall in the volumes 
imported, thus leading to a reduction in market supply, allowing the Community 
industry to increase output, particularly of those basic constmctions most subject to 
40 
pressure from the dumped imports, as explained in recital (67) and (70) above. The 
Community industry's prices could be expected to increase to some extent, but 
certainly not by anything like the level of the duty. The increases in volume, 
however, would serve to reduce unit costs of production and enable the Community 
industry to restore its financial situation. 
(d) Comments received 
ft) Comments received from the Community industry 
(93) The Community industry has stressed the importance for the Community cotton 
textiles industry of a viable Community cotton-weaving industry. This would 
maintain competition, employment levels, and prevent dependence on imports. The 
industry has also argued that its continued existence would be of benefit to the 
upstream spinning industry by assuring an important source of demand for yam. It 
is also argued that there would be benefits for the downstream sectors arising from 
diversity of supply. 
(94) Many claims were also submitted from users and importers relating to the effect of 
the measures on the Community industry. In summary, it was alleged that the 
measures would have no substantial positive outcome on their situation. 
41 
(ii) Competition from other imports 
(95) It was contended that if the anti-dumping measures bring about a shift in the 
demand away from the import of the dumped products, there would be an increase 
in the demand for imports of grey cotton fabrics from other third countries. 
(96) Regarding imports of grey cotton fabrics from other third countries, it was found 
that it cannot be excluded that, within the limits of the existing trade arrangements 
they may increase following the imposition of measures; about 30% of the market 
is supplied by imports which will not be subject to the anti-dumping measures. 
Exporters in these countries would presumably try to increase their market share at 
the expense of their competitors from the countries concerned by this proceeding. 
Some users pointed out that other third countries are at the moment not able to 
supply fabrics of the same quality as those produced by Community industry and 
by the exporting producers in the countries concerned. Although no evidence was 
supplied on this point, it would appear that imports from other third countries will 
not, therefore, prevent the Community industry from taking advantage of the anti­
dumping measures. 
(Hi) Community industry's production capacity and supply shortage 
(97) It was alleged that the anti-dumping measures would have the effect of creating 
supply shortages since the Community industry does not have the capacity to 
satisfy Community demand for the product concerned. 
42 
(98) The Commission established that the Community industry was indeed operating at 
a high rate of capacity utilisation during the period under consideration. It should 
be noted, however, that, over this period, the Community industry also reduced its 
maximum capacity in terms of machine hours per year. This was due, among other 
factors, to a reduction in working hours, which means that the Community weavers 
would be able to increase capacity by increasing the number of hours worked in the 
case of an increase in demand. * • 
It should also be mentioned that, since production of grey cotton fabrics uses the 
same equipment and labour as other kinds of fabrics, the Community producers 
could switch productive capacity towards the product concerned after any demand 
increase subsequent to the imposition of measures. 
(iv) Import substitution towards bleached, dyed and printed fabrics 
(99) It was claimed by some users that the anti-dumping measures will have no effect, 
as importers will simply switch to importing bleached and finished fabrics. 
However, no evidence was provided to support this allegation. Indeed it is worth 
recalling that bleached fabrics are also subject to international trade arrangements. 
As to bleached fabrics, the only data available to the Commission relating to the 
imports of bleached fabrics are Eurostat figures, which indicate that in 1995 the 
imports of bleached fabrics amounted to a negligible quantity (10,610 tonnes) 
43 
relative to the total size of the Community grey cotton fabric market, which was 
around 464,000 tonnes. Moreover, Eurostat figures also show an average value in 
1995 of 6.72 ECUs per tonne, which was almost twice the Eurostat average import 
value relating to unbleached fabric. In any event, indications are that finishers 
prefer to control the bleaching process themselves for quality control reasons. 
As to the switch towards finished fabrics, this is examined further below in recital 
(130)etseq. 
(e) Effect of non-imposition of the measures 
(100) As stated in recital (127) of the provisional Regulation, should definitive measures 
not be imposed, the negative trend of the Community industry would continue, 
with the possibility of its disappearance. The 6,200 people employed by the 
Community industry would be those most directly affected. In this context, the loss 
in employment among the sampled complainants mentioned in recital (115) of the 
provisional Regulation is noted. 
ft) Conclusions 
(101) The expected demand increase for the Community industry would enable it to 
choose a strategy for recovery from their current situation of financial losses. 
(102) While the industry's prices would not rise to the extent of the duty, the Community 
industry could be expected to improve its sales volume and recover market share in 
basic constmctions. This volume increase will reduce unit costs and increase 
profitability. 
44 
(103) In conclusion, the analysis of the Community industry shows that it is stmcturally 
viable and that measures would be effective in affording the industry the 
opportunity to recover from the injury suffered (see recital (130) of the provisional 
Regulation). Therefore, it is in the interests of the Community industry to introduce 
measures. 
16. The supplier industry 
(a) Situation of the Community spinning industry 
(104) Community spinners employed around 72,000 people in 1994 (the figure refers to 
EU 12). The total yam production in the Community, including all fibres, amounts 
to 1,2 million tonnes. An estimated 25% of this was used for the production of the 
like product, implying that 18,000 people are employed spinning yam destined for 
production of the product concerned. 
(105) Over the period 1992-1996 there was an 8% increase in cotton yam sales quantities 
for the companies examined. Production capacity increased by 8% and the rate of 
capacity utilisation, though slightly decreasing, was still about 81% in 1996. 
Insufficient information was provided to establish a trend in production costs, 
though there are indications of an increase in variable costs in 1995. This was most 
probably due to the growing raw cotton prices already examined in the injury 
analysis at recital (124) of the provisional Regulation and which was mentioned by 
some parties as a major factor of instability. Indeed, raw cotton represents about 
50% of spinners' total costs. This could also explain their poor profit performance 
(average return on sales -0.31% in 1995, -0.93% in 1996). Employment decreased 
bv about 9%. 
45 
(b) Effect of the imposition / non imposition of measures 
(106) If total Community cotton weaving, i.e. including integrated producers, is 
considered, the percentage of yam used in the production of the like product 
represents over 25% of spinners' output. This means that, though spinners can find 
other outlets for their production (mixed fabrics, knitting, etc.), a major decline in 
Community production of the product concerned would substantially affect them. 
(107) If anti-dumping measures are imposed, the improved situation of Community 
weavers will benefit spinners in that they will retain an important sales channel, 
with higher sales volumes and the possibility to negotiate more profitable prices. 
On the other hand, should measures not be imposed, spinners face the risk of a 
major fall in demand not only from the complainants, but also from the integrated 
weavers examined below. 
17. Users, Importers and Makers-up 
(108) The downstream sectors that will be examined below consist of integrated 
producers, converters/importers, finishers and makers-up. Although these parties 
may operate at different stages of the downstream production chain, given the 
degree of integration of this industry, it has been found appropriate to investigate 
them together. 
46 
(a) Integrated producers 
ft) Description 
(109) Integrated producers in this context are those who weave and finish and/or make up 
finished goods. They use all or most of their fabric production for their own 
internal downstream consumption or for sales to related companies, and only 
occasionally sell to unrelated customers. Although integrated producers are not part 
of the complaining Community industry, since they do not compete directly with 
the dumped imports, they can be considered to have an interest in the present 
proceeding, since they may also suffer from the competition of finished fabrics or 
made-up goods manufactured using grey fabrics sourced at dumped prices. 
(110) Total Community output of woven majority cotton fabrics was 464,000 tonnes in 
1995, of which, according to the industry's estimates, the output of the product 
concerned was 325,000 tonnes. The integrated producers represented an estimated 
72% of these figures. 
(ii) Effect of the imposition of measures 
(111)Since integrated producers are indirectly affected by the dumped imports, they 
could be expected to benefit indirectly from anti-dumping measures. The 
competitiveness of their finished fabrics and made-up goods is expected to improve 
relative to the goods produced using the dumped imports. Furthermore, as the 
prices of the dumped imports increase, it becomes more attractive for them to 
employ own-produced grey fabrics, with positive consequences for their weaving 
employment. 
47 
(112) However, some downstream-integrated weavers who concentrate on finishing 
and/or making-up, and source most of their grey fabric requirements from imports, 
oppose the imposition of measures. The impact of the measures on this part of the 
industry, however, varies according to each individual company's dependence on 
imports from the countries concerned, so no clear conclusion can be drawn as to the 
effect on this sector. 
Nevertheless, in view of the substantial part of the Community weaving used for 
internal consumption (72%), and of the considerable share that it has in the total 
Community finishing (48%, as described below), it can be concluded that the 
overall impact of anti-dumping measures on the integrated weavers would be 
positive. 
(Hi) Effect of the non-imposition of measures 
(113) If measures are not imposed, integrated producers would continue to suffer a cost 
disadvantage vis à vis any EU competitors who use the dumped imports. As a 
consequence, their in-house weaving could cease to be viable and they might be 
obliged to close down their weaving activities. 
In this respect, it should be noted that total majority cotton weaving output, captive 
and non-captive, in the Community shrunk from around 515,600 tonnes in 1992 to 
464,000 in 1995, and in the same period 88 weaving plants closed in Austria, 
France, Germany, Italy, Spain and the United Kingdom, with the loss of 8,625 jobs. 
The overall declining trend of the sector, in the absence of measures, would 
therefore continue, with consequent further losses of employment. 
48 
(b) Converters and finishers 
ft) Introduction 
(114) After the imposition of the provisional measures, many representations were 
received from users and importers, reiterating the claims in recital (128) of the 
provisional Regulation. The measures were alleged to severely affect the 
competitive position of Community finishers vis à vis third countries' exporters, 
with substantial losses in turnover and jobs, due to the substitution of fabrics 
imported in grey state and finished in the EU with fabrics imported in 'finished 
state. It was alleged that the consequence may even be the demise of Community 
finishing industry. 
(ii) Structure and size of the downstream industry 
(115) The investigation relating to users was based on the information submitted from 
finishers, whether independent or integrated in groups, importers and converters, as 
well as on general information relating to the sector. 
(116) The analysis of the impact of anti-dumping measures on the downstream industry 
has to take into account its particular structure. The grey fabric is not usually 
purchased directly by those who process it, but by a middleman (converter), who 
can source from EU weavers or from imports. The converter then passes the fabric 
to the finisher, who does not normally take ownership but works on commission. 
49 
(117) The finishing industry is capital intensive and highly price competitive. However, 
in comparison with unbleached fabric, the finished fabric has more possibilities of 
differentiation and a higher value added, and requires higher levels of know-how. 
Though there are some simple patterns and colours which are fairly standardized, 
the product is fashion-sensitive and the designs tend to vary from year to year. This 
enhances the importance of such factors as delivery speed and the possibility for 
the customer to discuss and modify the final output. According to the submissions 
received, these elements are, together with price, major factors in choosing the 
finisher. They explain why the fabrics finished in the Community, unlike grey 
fabrics, can be expected to maintain an advantage compared to imported finished 
fabrics. 
(118) The production of the finishing sector was estimated on the basis of the figure 
mentioned in recital (110) above at 464,000 tonnes of total output of majority 
cotton woven fabrics in the EU. Adding total imports of grey (221,000 tonnes) and 
bleached (10,000) fabrics and excluding exports (12,700 tonnes) of grey fabrics, the 
total of the majority cotton fabrics printed and dyed in the EU is 682,000 tonnes. 
The fabrics containing more than 85% of cotton accounts for 78% of this figure. 
(119) Imports of finished fabrics were 37,700 tonnes in 1995, with a growing trend in the 
period examined (+17% for Eurl2 from 1992 to 1995) representing a market share 
of 5% of the total market for finished goods. 
50 
(120) Total employment in the finishing sector was estimated at 150,000 people in 1995. 
The employment in the sector is declining, following the general trend of the textile 
industry (-9% between 1992 and 1994). Taking into account that the product 
concerned only represents a part of total Community finishing, and the size of 
integrated finishing, the number of jobs in independent finishing of the product 
concerned is estimated at around 23,000. 
(121) No estimate is possible of the personnel employed by the importers and converters. 
However, given that these companies are traders and service providers with 
minimal capital investment, their employment levels appear to be relatively low. 
(Hi) Effect of the anti-dumping measures on prices of finished fabrics 
(122) It is expected that the anti-dumping measures would increase the sales prices of 
finished fabrics, since the price of the raw material would have increased. 
(123) It is stated in recital (92) that the Community industry's price increase would be 
unlikely to reflect the full amount of the duty. Some importers and users claimed 
that, after the imposition of measures, the prices of grey cotton fabrics not subject 
to the measures would also increase by an amount close to the duty rate. This, 
however, appears unfounded as the high degree of competitiveness of the grey 
fabric market makes it unlikely that producers not subject to the measures 
(representing 60% of the market in 1995) would have the freedom to increase their 
prices. Consequently, it is concluded that the average price increase of grey fabrics 
will be considerably lower than the average duty rate. 
51 
(124) In order to estimate the impact of the measures on prices of the finished goods, the 
Commission calculated an average proportion of the grey fabric in the production 
cost and in the price of the finished fabric. The analysis of the questionnaire replies 
revealed a wide diversity of this ratio, depending on the weight and quality of grey 
fabric used and on the quality of finishing. An average proportion was calculated at 
45% for respondent companies for all finished fabrics. However, given the 
variation among companies (from 22 to 67%) and the diversity of the products 
involved, it was decided to base the Commission's conclusions on an average 
between 45% and a figure provided by the German finishers' association, which 
estimates the average proportion of the full cost attributable to grey fabric at 36%. 
A profit margin of 6% was added, estimated from the profit margins reported by 
the converters. 
(125) The analysis of the submissions showed an average profit on sales in 1995 of 
around 15% for finishers on commission, and of around 6% for converters. Both 
profit margins are considered to be adequate given the nature of the sectors (a 
capital intensive industry in the case of finishers; a trading, service-providing 
industry for converters), and allowing, if necessary, a partial absorption of the cost 
increase after the imposition of definitive anti-dumping measures. Therefore, the 
claim that both converters and finishers operate at low profit margins and cannot 
absorb any duty-induced cost increase was not confirmed. 
52 
(126) Different scenarios were envisaged, taking into account different options relating to 
the reactions of the market. A 'maximalist scenario' was considered which assumed 
a price increase by all suppliers by the full amount of the duty, which averages 
15.7%, and no absorption by the converters and finishers. The average price 
increase in this case is estimated at 7.1% with a ratio of 45% and 5.6% with a ratio 
of 36%/ 
(127) A 'minimalist scenario' was also estimated. It is based on the assumption of no 
price increase by the suppliers not affected by the anti-dumping duties, which 
brings the average price increase by suppliers down to 6.3%. Moreover, it assumes 
that both the converters and the finishers absorb a part of the duty with a decrease 
of their profit margin of 1 % each. The price increase so calculated on finished 
fabrics varies from 0.7% to 1.3%, according to the ratio used. 
(128) The two calculations above are considered to be the extremes of a range of 
possibilities. The Commission estimates as most probable an average scenario, 
implying a moderate price increase from the suppliers of grey fabrics not affected 
by the anti-dumping duties and the 1% duty absorption described above. 
The average price increase for Community producers was estimated at 2%, on the 
basis of the minimum price increase required to offset the losses referred to in 
recital (114) of the provisional Regulation. 
For other third country exporters, the Commission, on the assumption that they are 
not market leaders, used an increase of 10.2%, a weighted average of the average 
anti-dumping duty, 15.7% and the estimated price increase of 2% for the 
Community producers. 
53 
The subsequent price increase for the finished fabric is estimated as varying from 
2% to 3%, according to the cost ratio adopted. 
ftv) Impact on converters 
(129) The converters are those who directly bear the cost increase, and have to decide 
whether to pass it on to their customers or to absorb it, partly or totally. It was 
alleged that the converters, given the low profit margins and price competition in 
the sector, will be squeezed-between the inability to absorb the cost increase and 
the impossibility of passing it on to their customers. 
As to the possibilities of absorption, the Commission's view is set out in 
recital (125). Further, the converters' past behaviour suggests a considerable ability 
to pass on cost increases to their customers. Between 1994 and 1995, in response to 
a generalised increase in input costs and a decrease in demand (the cost of raw 
cotton increased of around 15%, and the Community weavers increased their prices 
of 8.6%) converters were able to increase their prices by 6.66%. Given the value 
added at this stage, this increase was enough to offset the cost increase, and to keep 
the sector profitable despite the fall in demand. 
An alternative course of action for converters could also be to switch to products 
which are not affected by the measures, such as Community production, imports 
from other third countries, or mixed fabrics. They also have the option of importing 
finished fabrics directly, although the analysis below suggests that this is unlikely. 
It is concluded that, as far as converters are concerned, therefore, anti-dumping 
measures may require some adaptation on their part, but are not expected to affect 
them unduly. 
54 
(v) Impact on finishers 
(130) Finishers, who are not going to be directly affected financially by the measures as 
they do not purchase the product concemed, could suffer a decrease in activity if 
there is a substantial switch in demand towards imports of finished fabrics (so-
called "substitution effects"). 
(131) The Commission evaluated, on the basis of the information submitted, the reaction 
of market demand to a price increase in the fabrics finished in the Community, in 
order to arrive at an estimate of any possible substitution effects. 
In the period 1992-96 the quantities finished by Community finishers increased, on 
an indexed basis, from 100 to 108 between 1992 and 1994 and then decreased to 99 
in 1995 and to 97 in 1996. The prices of the finished fabrics sold by converters in 
the same period increased from 100 in 1992 to 115 in 1995, then declined to 99 in 
1996. 
The figures show that no clear relationship exists between prices obtained and the 
level of activity of finishers. Indeed, while in 1995 the market reacted strongly to 
the increase in prices, in 1996 the price fall was not reflected in a quantity increase. 
Similarly, the moderate price increase in 1994 did not prevent a quantity rise of 
over 6%. 
55 
(132) As far as imports of finished fabrics from third countries are concerned, no clear 
link between the Community production of the product concerned and these 
imports can be identified from the data analysed. Imports show a steadily growing 
trend at falling prices. On the other hand, the quantities imported represent 5% of 
quantities finished in the Community. These figures do not support the allegations 
of the likelihood of a substitution effect. Indeed, the Commission received no 
evidence showing the existence of a sizeable spare finishing capacity in any third 
country, nor are there any indications that this capital- and know how-intensive 
industry could be built up in the foreseeable future. Furthermore, imports of 
finished fabrics are also subject to quota and licence arrangements, which means 
that their growth is necessarily restricted for the time being. 
In the light of the above, and contrary to the claims of major substitution effect, it 
was concluded that an estimated increase in the price of finished fabrics of between 
2% and 3% is not expected to cause a substantial shift in demand from Community 
finishing to imports from third countries. 
(133) It was also alleged that, for an industry as capital intensive as the finishing industry, 
even a moderate decrease in the quantities processed may raise unit costs to such an 
extent as to make continued production unprofitable. However, the finishers 
examined were able to maintain high profit margins even when the quantities 
processed decreased: in 1995 they had a 15% return on sales, despite a fall in the 
quantities processed of 9.7%. 
56 
(134) The Commission concludes, therefore, that the imposition of anti-dumping 
measures is not likely to cause a substitution of Community finished fabrics with 
imports. The claims, submitted by users, of significant disruptive effects on the 
Community finishing industry were therefore found to be highly exaggerated. 
(vi) Consequences for employment 
(135) In view of the above, no undue impact of the anti-dumping measures on the-activity 
and employment levels for converters and finishers can be expected. Nevertheless, 
the intensity of any effects will also depend on the strategy chosen by the 
converters: should they decide to significantly switch to trading finished fabrics, 
the impact on finishers would be stronger. But, as explained in recitals (132) to 
(134) above, the recourse to imports of finished fabrics does not appear to be a 
credible alternative for converters. 
(136) It can be expected, however, that some parts of the industry which rely more 
heavily on the dumped imports will suffer a loss of activity, the extent of which is 
very difficult to predict. It will depend on the possibilities of these parts of the 
industry to absorb the duty and on their ability to turn to different sources of 
supply. On the other hand, it also appears that any losses suffered by these finishers 
could be offset by improvements gained by integrated finishers or by those who 
mainly use Community grey fabrics, which would both become more competitive 
after the introduction of definitive measures. 
57 
(vii) Effects of non imposition of measures 
(137) In the event that definitive measures were not to be imposed, some users could 
continue to benefit from imports at dumped prices, with an advantage on those who 
use Community production or are integrated in weaving. Should the Community 
weaving industry be severely harmed, however, the whole finishing market would 
suffer, as Community grey production still feeds more than two thirds of total 
Community finishing. 
(c) Makers-up 
ft) Characteristics of the industry 
(138) Making-up is the segment of the cotton industry employing the largest number of 
people. It was estimated, on the basis of the total size of the sector and of the 
amount of cotton input, that 390,000 jobs are involved in the making-up of cotton 
goods. 
(139) Making-up is also the stage with, on average, the highest value-added, though this 
varies widely from product to product. For instance, the value added to the finished 
fabric can be very low for a basic bed linen set (only 25% of total cost, including 
cutting, hemming and packing), but much higher for a piece of clothing, such as a 
shirt, where it can amount to 70%. This creates a gap between low value-added, 
basic products, which are very price sensitive, and whose production is largely 
being relocated in low labour cost countries, and high value added, fashion 
products. 
58 
(H) Impact of the anti-dumping measures 
(140) It has been alleged by some users that the negative consequences of the imposition 
of measures would extend to makers-up, as they would face a cost increase with a 
consequent loss of competitiveness relative to imports of garments and of home 
textiles from third countries. 
(141) On the basis of the information submitted, a variable average ratio of the cost of 
finished fabrics in the sales prices up to 50% was found. With the average increase 
of 2 to 3% for finished fabrics estimated in recital (128) above, their price would 
rise by less than 2% at worst, without even considering the possibility of any 
absorption. 
(142) In the light of the above, and using the information available, the Commission 
services concluded that the anti-dumping measures will not negatively affect the 
economic position of Community makers-up. 
18. Conclusion 
(143) Information received from parties and information otherwise available allowed the 
Commission to evaluate the various interests involved, as stipulated in Article 21 
(1) of the basic Regulation, and the overall effect of the imposition or of the non-
imposition of anti-dumping measures. 
In carrying out this examination, the Commission gave special consideration to the 
need to eliminate the trade distorting effects of injurious dumping and to restore 
effective competition. 
59 
(144) As to the Community industry, the effects of the measures can be expected to 
afford it the opportunity to restore profitability and to remain active in the grey 
cotton sector, with consequent beneficial effects on employment and competitive 
conditions on the Community market. 
(145) Despite the claim of the Community spinners to be strongly dependent on 
Community weavers, this was not fully supported by the results of the analysis. 
Nevertheless, it was shown that any improvement to the Community weavers 
would be expected to have a positive impact on spinners. 
(146) It should be added that the positive impact of the measures would not be limited to 
the Community industry, but would extend to the whole of Community weaving 
and to the integrated downstream industry linked to it. 
(147) The allegations of dismptive effects on the downstream industries have either not 
been substantiated, or were found to be exaggerated, especially as to the alleged 
substitution effects, though some negative consequences on a part of the finishing 
industry cannot be excluded. 
(148) When the position of all sectors involved is considered, it cannot be clearly 
concluded, on the basis of all the information submitted, that the application of 
anti-dumping measures would be against the overall interest of the Community. 
(149) In the light of the above, the conclusions drawn in recital (130) of the provisional 
Regulation, concerning the Community interest, are confirmed. 
60 
J. DEFINITIVE DUTY 
(150) On the basis of the conclusions on dumping, injury, causation and Community 
interest set out above, the Commission considered the form and the level of the 
anti-dumping measures to be taken. 
(151) Given the wide variety of constmctions from the countries concerned, the 
Commission is of the opinion that an ad-valorem anti-dumping duty is the most 
appropriate form of measure. 
(152) For the purpose of establishing the level of the definitive duty, account has been 
taken of the dumping margins found and of the amount of duty necessary to 
eliminate the injury sustained by the Community industry. 
(153) It will be recalled from recital (133) of the provisional Regulation that since the 
injury consists principally of price suppression, loss of market share and, in 
particular, lack of profitability or losses, the removal of injury requires that the 
industry should be put in a position where prices can be increased to profitable 
levels. In order to achieve this, the prices of the imports concemed originating in 
the countries currently under investigation should be increased accordingly. 
(154) For calculating the necessary price increase, the Commission considered that the 
actual prices of these imports should be compared with a selling price which would 
more accurately reflect the costs of production of Community producers plus a 
reasonable profit. 
61 
(155) A number of exporters questioned the profit margin of 8% on tumover which was 
mentioned in recital (133) of the provisional Regulation on the grounds that it was 
too high in relation to levels experienced in recent years: the most favourable profit 
margin for the sampled Community producers recently was around 2%. The 
Commission cannot accept this, however, because 2% is inadequate to ensure the 
financial viability of a capital-intensive industry. In the course of the proceeding, 
profit levels of 5% and upwards were observed in sectors of the cotton textiles 
industry with very low capital requirements. In the light of this, the Commission 
considers 8% to be a reasonable margin for the cotton weaving sector. 
(156) The average weighted selling prices charged during the investigation period of the 
Community industry for each of the six categories described in recital (63) above 
were increased in order to achieve the overall minimum amount of profit required. 
The resultant prices thus established were compared with the prices of the dumped 
imports used to calculate undercutting as outlined above. 
(157) The differences between these two prices, expressed on a weighted average basis 
and as a percentage of the free-at-the-Community-frontier price, were: 
- China 45% 
- Egypt 49% 
- India 34% to 73% 
- Indonesia 41% to 81% 
- Pakistan 46% to 54% 
- Turkey 11% to 25%. 
62 
(158) Where the margins of dumping found, in respect of a particular exporting producer, 
were below the corresponding increases in export prices necessary to remove the 
injury, as calculated above, the definitive duties imposed are to be limited to the 
dumping margin established. This was the case for all but one of the companies 
concerned. 
The anti-dumping duty proposed for companies which cooperated, but which were 
not investigated, is the average dumping margin for the sample or the average 
margin necessary to remove injury, whichever is lowest. 
The anti-dumping duty for non-cooperating companies is equivalent to either the 
highest dumping margin or the highest margin necessary to remove injury 
calculated for the producers/exporters in the sample, whichever is the lowest. The 
highest dumping margin was used for all countries. 
K. FINAL PROVISIONS 
(159) Several Turkish parties protested that Turkey has been treated as any third country 
despite the fact that it has a Customs Union with the Community. 
Article 44 (2) of Decision 1/95 of the EC/Turkey Association Council states that 
the modalities of implementation of anti-dumping measures set out in Article 47 of 
the Additional Protocol to the Association Agreement still apply. The procedure of 
Article 47 of the Additional Protocol to the Association Agreement was indeed 
applied, and the Association Council as well as the Customs Union's Joint 
Committee kept regularly informed. 
63 
(160) On 18 January 1996, the EC/Turkey Association Council was formally informed 
that the Commission had received a complaint alleging that imports of unbleached 
cotton fabrics from, inter alia, Turkey were being dumped and thereby causing 
injury to the corresponding Community industry. 
On 23 Febmary 1996, the EC/Turkey Association Council was further informed of 
the( initiation of the proceeding and given a copy of the non-confidential version of 
the complaint. It was also informed of the decision to apply sampling techniques. 
As provided for in Article 47 (1) of the Additional Protocol to the Association 
Agreement, an application was formally made to the Association Council on 8 
August 1996 after the investigation had shown that the Turkish producers/exporters 
were practising dumping. Should they wish to do so, the latter were also invited to 
give undertakings in accordance with Article 8 of the Basic Regulation. 
On 20 November 1996, after the tree month period provided for in Article 47 (2) 
(a) of the above Agreement had elapsed, the Commission notified the Council of 
Association of its decision to impose provisional anti-dumping measures. 
Moreover, on 19 November 1996, the Customs Union Joint Committee had also 
been informed of the Commission's intention to impose provisional anti-dumping 
measures. 
On 21 November 1996, a copy of the provisional Regulation was forwarded to the 
Association Council. 
64 
(161) Finally, the Association Council was notified and provided with full disclosure of 
the definitive facts and findings, as provided for in Article 47 (2) of the Additional 
Protocol to the EC/Turkey Association Agreement. The Customs Union Joint 
Committee was informed of the intention to impose definitive anti-dumping 
measures. 
(162) One Turkish party sought the annulment by the Court of First Instance of the 
initiation of the present proceeding3. In its Order of 16 December 1996, the Court 
of First Instance, dismissing the application, confirmed that the initiation of the 
proceeding against Turkey in the above circumstances was not incompatible with 
the provisions of the Association Agreement. 
(163) In their comments on the disclosure of provisional findings, several 
producers/exporters indicated that they might wish to propose undertakings before 
definitive anti-dumping measures were imposed. In the absence of any undertaking 
being offered, all producers/exporters are subject to the anti-dumping measures 
provided in this Regulation. 
3 Case T-75/96, Sôktas v. Commission 
65 
L. COLLECTION OF THE PROVISIONAL DUTIES 
(164) In view of the magnitude of the dumping margins found for the exporting 
producers and countries, and in the light of the seriousness of the injury caused to 
the Community industry, it is considered necessary that the amounts secured by 
way of provisional anti-dumping duties for transactions involving the product 
concerned should be definitively collected at the level of the definitive duties, 
HAS ADOPTED THIS REGULATION: 
Article 1 
1. Definitive anti-dumping duties are hereby imposed on imports of flat unbleached 
(grey) cotton fabrics, falling within CN codes 5208 11 90, 5208 12 to 5208 19 and 
5209 11 to 5209 19 and originating in the People's Republic of China, Egypt, India, 
Indonesia, Pakistan and Turkey. 
2. Save for the exporters listed in Tables 3 and 4 and in the Annex to this Regulation, 
the rate of the definitive anti-dumping duty applicable to the net, free-at-
Community-frontier price, before duty, shall be as follows: 
66 
TABLE 1: 
Country Rate of duty Taric additional 
code 
The People's Republic of China 18.9% 89ÔÔ 
Egypt 13.0% 89ÔÔ 
India 17.2% 8900 
Indonesia 14.5% 8900 
Pakistan 22.9% 89ÔÔ ' 
Turkey 17.5% 89ÔÔ" 
The exporters listed in the Annex to this Regulation shall be subject to the 
following rates of anti-dumping duty: 
TABLE 2: 
Country Rate of duty Taric additional 
code 
Tndïâ" ' TTS% 8909 
Indonesia 13.5% 89ÏÔ 
Pakistan 14.2% 89ÏÏ 
Turkey 152% 89Ï2 
The companies listed below shall be subject to the following rates of anti-dumping 
duty: 
67 
TABLE 3: 
Country 
India Manufacturer 
Coats Viyella India Ltd 
Vardhman Spinning & General Mills Ltd 
Mafatlal Industries 
Mafatlal Fine Spg. & Mfg. Rate of duty 
12.3% 
5.1% 
12.6% 
12.6% Taric additional 
code 
8914 
8915 
8916 
8917 
TABLE 4: 
Country 
Indonesia Manufacturer 
P.T. Apac Inti Corpora / P.T. Kanindo 
Prima Perkasa 
P.T. Eratex Djaja Rate of duty 
3.5% 
12.8% Taric additional 
code 
8918 
8922 
TABLE 5: 
Country 
Pakistan Manufacturer 
Diamond Fabrics Ltd 
Amer Fabrics Ltd 
Lucky Textile Mills 
Nishat Mills Ltd 
Nishat Fabrics Ltd Rate of duty 
9.0% 
9.0% 
15.5% 
9.2% 
9.2% Taric additional 
code 
8923 
8924 
8927 
8928 
8929 
68 
TABLE 6: 
Country 
Turkey Manufacturer 
Birlik Mensucat Ticaret ve Sanayi 
Isletmesi A.S. 
Sôktas Pamuk ve Tarim Degerlendirme 
Ticaret ve Sanayi A.S. Rate of duty 
13.6% 
11.4% Taric additional 
code 
8930 
8931 
3. Unless otherwise specified, the provisions in force concerning customs duties shall 
apply. 
Article 2 
1. The amounts secured by way of provisional anti-dumping duties under Regulation 
(EC) No 2208/96 shall be definitively collected. 
2. Amounts secured provisionally in excess of the definitive rate of anti-dumping duty 
shall be released. 
3. The amounts secured provisionally on unbleached gauze products falling under CN 
Code 5208 1110 shall be released. 
69 
Article 3 
Where any producer provides sufficient evidence to the Commission that it did not 
export the goods described in Article 1(1) during the investigation period, that it is 
not related to any exporter or producer subject to the measures imposed by this 
Regulation and that it has exported the goods concerned after the investigation 
period, or that it has entered into an irrevocable contractual obligation to export a 
significant quantity to the Community, then the Council, acting by simple majority 
on a proposal submitted by the Commission after consulting the Advisory 
Committee, may amend Article 1 (2) by adding that producer to the parties listed in 
the Annex. That producer would then be subject to the duties in Table 2 of Article 1 
above for producers in India, Indonesia, Pakistan and Turkey, or to the duties in 
Table 1 above for producers in China and Egypt. 
Article 4 
This Regulation shall enter into force on the day following its publication in the 
Official Journal of the European Communities. 
This Regulation shall be binding in its entirety and directly applicable in all 
Member States. 
Done at Brussels, 1997 
For the Council 
70 
Annex 
India 
A.S.P.G. Subbiah Nadar & Sons, Dhalavaipuram 
All India Handloom Fabrics Marketing Co-operative Society Ltd, Madras 
Alpha Mills Pvt Ltd, Karur 
Amex Exports, Karur 
Anglo French Textiles, Pondicherry 
Arcot Textile Mill Ltd, Madurai 
Arun Fabrics, Tirupur 
Amn Textiles, Rajapalayam 
Ashima Fabrics, Bombay 
A.S. Marimuthu, Samusigapuram 
Atlas Export Enterprises, Kamr 
Ayyappan Textiles Ltd, Madurai 
B.K.S. Mills, Tirupur 
B.N. Sardar & Sons, Calcutta 
Bharat Vijay Mills, Kalol 
Bhiwani Denim & Apparels Ltd, Faridabad 
Bonanza Overseas Pvt. Ltd, Bombay 
Chhaganlal Kasturchand & Co. Ltd, Bombay 
Emperor Trading Co., Timpur 
Esskay International, Bombay 
Forbes Gokak Ltd, Bombay 
Garden Weaves Pvt. Ltd, Timpur 
71 
GDJD Exports, Madras 
Govindji Trikamdas & Co., Bombay 
I A Intercontinental, Madras 
Ideal Expo Fabrics, Salem 
Inter Globe Services, Bombay 
Indra Exports, Jalandhar 
Kançria Chemicals & Industries Ltd, Ahmedabad 
Karamal Garment Exports, Madras 
Keshavlal Talakchand, Bombay 
Kishandas Kikani, Bombay 
Kothari Industrial Corporation Ltd, Madras 
Loyal Textile Mills Ltd, Kovilpatti 
M.S. Mathivanan, Komarapalayam 
M.U.A. Arumugaperumal & Sons, Chatrapatti 
Maharashta State Textile Corporation Ltd, Bombay 
Naatchiar Textile Producers/producer/exporters, Chatrapatti 
Navnitlal & Producer/exporter, Bombay 
Niyati Overseas, Madras 
Nowrosjee Wadia & Sons Ltd., Bombay 
N.W. Exports, Bombay 
Parag Trading Corporation, Bombay 
Patodia Syntex Ltd, Bombay 
Piramal Sons Ltd, Bombay 
Pothys Cotton Products PVT.LTD., Srivilliputtur 
Pradeep Investments Pvt. Ltd, Bombay 
Prathishta Weaving & Knitting Producer/exporter Ltd, Coimbatore 
72 
Preemier Textile, Timpur 
Preeti Impex, Tiruchengodu 
Premier Enterprises 
Premier Mills Ltd, Coimbatore 
Premier Textile Producers/producer/exporters, Chatrapatti 
R. D. Traders, Bombay 
Rajnarayan Hosiery Exports Pvt Ltd, Coimbatore 
Rama Qualitex Ltd, Bangalore 
Ramkumar Mills Ltd, Bangalore 
Rawsitasa Exports, New Delhi 
Rega Textiles, Komarapalayam 
Ruchi Fabrics Ltd, Indore 
S. Nikhil, Bombay 
Sadhaka Exports 
Sajjan Textiles Mills Ltd, Bombay 
Sajjan Udyog Export Ltd, Bombay 
Senthil Textiles, Timpur 
Shanker Kapda Niryat Pvt. Ltd, Bombay 
Sheela Apparel Exports Pvt. Ltd, Bombay 
Sheth Exports, Bombay 
Sheth Investments & Trading Producer/exporter Ltd, Bombay 
Singhania Exports, Bombay 
Sitalakshmi Mills Ltd, Madurai 
Sivakkumar Mills, Palladam 
Sree Rangsan Textiles Pvt. Ltd, Komarapalayam 
Sri Adhilakshmi Warping & Sizing Mills, Erode 
73 
Sri Balaji Fabric, Timpur 
Sri Dhavamani Textiles, Erode 
Sri Rajasekar Textiles, Chatrapatti 
Sri Rani Lakshmi Gng. Spg. & Wvg. Mills P. Ltd, Madurai 
Sri Saravanaa Exports Producer/exporter, Tamil Nadu 
Srinivasa Textiles, Chatrapatti 
Standard Industries Ltd, Bombay 
Sudha Mills (India) Pvt. Ltd, Bombay 
Supreme Bandages, Chatrapatti 
Tamarai Mills Ltd, Coimbatore 
Texcot Exports Pvt Ltd, Bombay 
The Bombay Dyeing & Manufacturing Co. Ltd, Bombay 
The Hindoostan Spinning & Weaving Mills Ltd, Bombay 
The Lakshmi Mills Producer/exporter Ltd, Coimbatore 
The Morarjee Gokuldas Spinning & Weaving Producer/exporter Ltd, Bombay 
The Ruby Mills Ltd, Bombay 
The Western India Cottons Ltd., Kerala 
Thiagarajar Mills Ltd, Madurai 
Trident Textile Mills Ltd, Madras 
Vadivel Sizing & Weaving Mills Pvt. Ltd, Timpur 
Varadhalakshmi Mills Ltd, Madurai 
Virudhunagar Textile Mills Ltd, Madurai 
World-Tex Limited, Chaziabad 
Yam Syndicate Ltd, Calcutta 
74 
Indonesia 
PT. Tyfountex Indonesia, Solo 
PT. Sandratex, Jakarta 
PT. Batik Keris, Jakarta 
PT. Danliris, Jakarta 
PT. Catur Jantra, Jakarta 
PT. Panca Bintang, Jakarta 
Gabungan Koperasi Batik Indonesia, Jakarta 
PT. Primatexco, Jakarta 
PT. Bina Nusantara Prima, Bandung 
PT. Batam Textile, Jakarta 
PT. Tata Adi Pratama, Bandung 
PT. Pacific Express, Denpasar 
PT. Bintang Agung, Jakarta 
PT. Adetex, Bandung 
PT. Maha Mujur Textile, Bandung 
PT. Five Star Industries, Bandung 
PT. Bandung Djaja Textile Mills, Bandung 
Pakistan 
• Abdur Rahman Corporation Ltd, Karachi 
• Adamjee Enterprise 
. ACME Mills (Pvt) Ltd, Karachi 
• Ajaz Enterprise 
• Akhtar Textile Industries 
75 
Al-Aziz Hosiery International, Faisalabad 
Al-Karam Textile Mills, Karachi 
Al-Shahid Weaving Industries 
Al-Rehmat Traders (Pvt) Ltd, Faisalabad 
Anjum Textile Mills (Pvt) Ltd, Faisalabad 
Arshad Corporation (Pvt) Ltd, Faisalabad 
Arzoo Textile Mills Ltd, Faisalabad 
Asjad Textile (Pvt) Ltd 
Associated Knitwear (Pvt) Ltd, Karachi 
Ayaz Textile Mills Ltd, Lahore 
Aziz Sons 
Be Be Jan Pakistan (Pvt) Ltd, Faisalabad 
Bismillah Fabrics (Pvt) Ltd 
Bismillah Textiles (Pvt) Ltd 
Chawala Enterprises 
Chenas Fabrics & Processing 
Colony Sarhad Textile Mills Ltd, Karachi 
Cotton Arts (Pvt) Ltd 
Dawood Textile Printing Indu 
Decent Industries, Faisalabad 
Decent Textiles, Faisalabad 
Elahi Enterprises Limited, Lahore 
Elahi Spinning & Weaving Mills Ltd, Lahore 
En Em Industries Ltd 
Excel Textile Mills, Karachi 
Fabrics International 
76 
Fabtex Corporation, Karachi 
Faizan Shehzad (Pvt) Ltd 
Falcon Textile Corporation 
Fazal Abdullah Exports (Pvt) Ltd, Faisalabad 
Fine Fabrics (Pvt) Ltd 
First Textile Ltd 
Ghazi Fabrics International Ltd, Lahore 
Globe Managements (Pvt) Ltd 
Gohar Enterprises 
Gul Ahmed Textile Mills Ltd, Karachi 
Gulistan Weaving Mills Ltd, Karachi 
Gulshan Weaving Mills Ltd, Karachi 
H.A. Industries (Pvt) Ltd, Faisalabad 
H.K. M. Exports (Pvt) Ltd 
Haji Khuda Bux Amir Umer 
Hajra Textiles, Karachi 
Husein Ind., Karachi 
ICC Textiles Ltd, Lahore 
Image Fabrics (Pvt) Ltd, Faisalabad 
Imran Textiles 
Ishan Yousuf Textile (Pvt) Ltd 
Ishaq Textile Mills Ltd, Faisalabad 
J.K. Brothers Pakistan (Pvt) Ltd, Faisalabad 
J.K. Sons (Pvt) Ltd, Karachi 
Jetex Industries (Pvt) Ltd, Karachi 
Kam International, Karachi 
77 
Kausar Textile Industries (Pvt) Ltd 
LatifHansel(Pvt)Ltd 
Linox International (Pvt) Ltd 
Lucky Impex, Karachi 
Lucky Tex,, Karachi 
M.A.S. Textiles (Pvt) Ltd 
M.F.M.Y. Industries Ltd, Karachi 
M.K. Sons (Pvt) Ltd, Faisalabad 
M.N. Textiles (Pvt) Ltd, Karachi 
Mabro Tex Industries 
Mahmood Textile Mills Ltd, Multan 
Majeeda Textiles (Pvt) Ltd, Faisalabad 
Master Textile Mills Ltd, Lahore 
Megatex Limited, Karachi 
Mian Textile Industries Ltd, Lahore 
Modem Textile Mills, Karachi 
Mohammad Farooq Textile Mills Ltd, Karachi 
Mohib Exports Ltd, Lahore 
Mohib Fabric Industries Ltd, Lahore 
Mohib Textile Mills Ltd, Lahore 
Mukati Corporation 
Mutual Trading Corporation, Karachi 
Nakshbandi Industries Ltd, Karachi 
Nash Garments (Pvt) Ltd, Karachi 
Naveed Industries (Pvt) Ltd, Karachi 
Naveena Industries (Pvt) Ltd, Karachi 
78 
Nisar Textiles Corporation 
Nishatex Enterprises 
Nu-Tex (Pvt) Ltd 
Oberoi Textile Mills, Lahore 
Orient Textile Pakistan (Pvt) Ltd 
Parsons Industries (Pvt) Ltd, Karachi 
Prosperity Weaving Mills Ltd, Lahore 
Regency Textiles Ltd, Lahore 
Reliance Weaving Mills Ltd, Multan 
Reliance Exports Ltd, Multan 
Rizwan Enterprises 
Roomi Enterprises (Pvt) Ltd, Multan 
S.S. Textiles 
Saaqis Fabrics 
Saba Textiles (Pvt) Ltd, Karachi 
Sadaqat Textile Mills (Pvt) Ltd, Faisalabad 
Sadiq Sons Textiles (Pvt) Ltd 
Sakina Textile Industries (Pvt) Ltd, Karachi 
Samin Textiles Ltd, Lahore 
Saya Weaving Mills (Pvt) Ltd, Karachi 
Service Fabrics Ltd, Lahore 
Shahzad Siddique (Pvt) Ltd, Faisalabad 
Shams Textile Mills Ltd, Karachi 
Shahraj Fabrics (Pvt) Ltd, Lahore 
Sharif Textile Industries (Pvt) Ltd, Faisalabad 
Sitara Textile Industries 
79 
Sleep & Style, Karachi 
Sumira Fabrics (Pvt) Ltd, Faisalabad 
Suraj Cotton Mills Ltd, Karachi 
Syncotex Agencies, Karachi 
Taha Textile (Pvt) Ltd, Karachi 
Tanveer Weavings (Pvt) Ltd, Lahore 
Tariq Enterprises 
Tex Arts, Faisalabad 
The Cresent Textile Mills Limited, Faisalabad / Karachi 
United Textile Printing Industries (Pvt) Ltd, Faisalabad 
Worldover Enterprises (Pvt) Ltd, Faisalabad 
Xebec Textiles, Faisalabad 
Yakoob Trading Co., Karachi 
Yousaf Weaving Mills Ltd, Lahore 
Yunus Brothers, Karachi 
Zahidjec Fabrics (Pvt) Ltd, Faisalabad 
Zahoor Industries (Pvt) Ltd, Faisalabad 
Zamzam Weaving & Processing Mills, Faisalabad 
Zaur Textile Mills, Karachi 
Zebtex Corporation 
80 
Turkey 
Bossa Ticaret ve Sanayi Isletmeleri T.A.S., Adana 
Exsa Export Sanayi Mamulleri Satis ve Arastirma A.S., Adana 
Teksmobili Tekstil Sanayi ve Ticaret A.S., Istanbul 
Kipas - Kahramanmaras Iplik Pamuk Ticaret ve Sanayi A.S., Kahramanmaras 
Kipas Textile Industries Inc., Kahramanmaras 
Burdur Mensucat Sanayii ve Ticaret A.S., Ulus/Ankara 
Ataç Anteks Dokuma Fabrikasi Hikmet Ataman ve Ortaklari Tic. ve San. A.S., 
Yenikôy/Antalya 
81 
ISSN 0254-1475 
COM(97) 160 final 
DOCUMENTS 
EN 02 11 
Catalogue number : CB-CO-97-148-EN-C 
ISBN 92-78-18330-X 
Office for Official Publications of the European Communities 
L-2985 Luxembourg 
?2L