Proposal for a Council Regulation imposing a definitive anti-dumping duty and collecting definitely the provisional duty imposed on imports of certain seamless pipes and tubes of iron or steel originating in the People's Republic of China
Date: 2009-09-07
Institutions: European Commission
Subjects: China, anti-dumping duty, import, originating product, piping, tube

EN 

EN 

   EN 

 
 
COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 7.9.2009 
COM(2009) 463 final 

Proposal for a 

COUNCIL REGULATION 

imposing a definitive anti-dumping duty and collecting definitely the provisional duty 
imposed on imports of certain seamless pipes and tubes of iron or steel originating in the 
People's Republic of China 

EN 

   EN 

 
 
 
  
 
 
EXPLANATORY MEMORANDUM 

1) CONTEXT OF THE PROPOSAL 

110 

•  Grounds for and objectives of the proposal 

This  proposal  concerns  the  application  of  Council  Regulation  (EC)  No  384/96  of 
22 December 1995 on protection against dumped imports from countries not members 
of  the  European  Community,  as  last  amended  by  Council  Regulation  (EC)  No 
2117/2005 of 21 December 2005 (the ‘basic Regulation’) in the proceeding concerning 
imports of certain seamless pipes and tubes of iron or steel originating in the People's 
Republic of China. 

120 

•  General context 

This proposal is made in the context of the implementation of the basic Regulation and 
is the result of an investigation which was carried out in line with the substantive and 
procedural requirements laid out in the basic Regulation. 

139 

141 

Existing provisions in the area of the proposal 

There are no existing provisions in the area of the proposal. 

•  Consistency with other policies and objectives of the Union 

Not applicable. 

2) CONSULTATION OF INTERESTED PARTIES AND IMPACT ASSESSMENT 

•  Consultation of interested parties 

219 

229 

230 

Interested  parties  concerned  by  the  proceeding  have  already  had  the  possibility  to 
defend their interests during the investigation, in line with the provisions of the basic 
Regulation. 

•  Collection and use of expertise 

There was no need for external expertise. 

•  Impact assessment 

This proposal is the result of the implementation of the basic Regulation. 

The  basic  Regulation  does  not  foresee  a  general  impact  assessment  but  contains  an 
exhaustive list of conditions that have to be assessed. 

3) LEGAL ELEMENTS OF THE PROPOSAL 

305 

•  Summary of the proposed action 

On  9  July  2008,  the  Commission  announced  by  a  notice  (‘notice  of  initiation’), 
published  in  the  Official  Journal  of  the  European  Union,  the  initiation  of  an  anti-
dumping proceeding concerning imports into the Community of certain seamless pipes 
and tubes of iron or steel originating in the People's Republic of China. 

The  anti-dumping  proceeding  was  initiated  following  a  complaint  lodged  on  28  May 

EN 

2 

   EN 

 
 
 
2008 by the Defence Committee of the Seamless Steel Tube Industry of the European 
Union  (‘the  complainant’)  on  behalf  of  producers  representing  a  major  proportion  of 
the  total  Community  production  of  certain  seamless  pipes  and  tubes  of  iron  or  steel 
containing evidence of dumping and of material injury resulting there from. 

On  8  April  2009,  the  Commission  imposed,  by  Regulation  (EC)  No  289/2009,  a 
provisional  anti-dumping  duty  on  imports  into  the  Community  of  certain  seamless 
pipes and tubes of iron or steel originating in the People's Republic of China ranging 
from 15,1 % to 24,2 %.  

The  enclosed  Commission  proposal  for  a  Council  Regulation  imposing  a  definitive 
anti-dumping duty ranging from 17,7 % to 39,2 % contains the definitive conclusions 
regarding dumping, injury, causation and Community interest. 

Member States were consulted during the Anti-Dumping Committee of 28 July 2009. 
12 Member States were in favour of the proposed course of action, 11 opposed and 4 
abstained. 

It  is  proposed  that  the  Council  adopt  the  attached  proposal  for  a  Regulation  which 
should be published in the Official Journal of the European Union by 7 October 2009 
at the latest. 

310 

•  Legal basis 

Council  Regulation  (EC)  No  384/96  of  22  December  1995  on  protection  against 
dumped  imports  from  countries  not  members  of  the  European  Community,  as  last 
amended by Council Regulation (EC) No 2117/2005 of 21 December 2005. 

329 

•  Subsidiarity principle 

The proposal falls under the exclusive competence of the Community. The subsidiarity 
principle therefore does not apply. 

•  Proportionality principle 

The proposal complies with the proportionality principle for the following reasons: 

The form of action is described in the above-mentioned basic Regulation and leaves no 
scope for national decision. 

Indication  of  how  financial  and  administrative  burden  falling  upon  the  Community, 
national governments, regional and local authorities, economic operators and citizens is 
minimized and proportionate to the objective of the proposal is not applicable. 

•  Choice of instruments 

Proposed instruments: regulation. 

Other means would not be adequate for the following reason: 

The above-mentioned basic Regulation does not foresee alternative options. 

331 

332 

341 

342 

EN 

3 

   EN 

 
 
 
4) BUDGETARY IMPLICATION 

409 

The proposal has no implication for the Community budget. 

EN 

4 

   EN 

 
 
Proposal for a 

COUNCIL REGULATION 

imposing a definitive anti-dumping duty and collecting definitely the provisional duty 
imposed on imports of certain seamless pipes and tubes of iron or steel originating in the 
People's Republic of China 

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 (‘the basic 
Regulation’) and in particular Articles 9 and 10 thereof, 

Having  regard  to  the  proposal  submitted  by  the  Commission  after  consulting  the  Advisory 
Committee, 

Whereas: 

A. 

PROCEDURE  

1. 

(1) 

(2) 

(3) 

2. 

(4) 

Provisional measures 
On  9  July  2008,  the  Commission  published  a  notice2  initiating  an  anti-dumping 
proceeding on imports into the Community of certain seamless pipes and tubes of iron 
or steel originating in the People's Republic of China (‘the PRC’).  On  8  April  2009, 
the  Commission,  by  Regulation  (EC)  No  289/20093  (‘the  provisional  Regulation’) 
imposed  a  provisional  anti-dumping  duty  on  imports  of  certain  seamless  pipes  and 
tubes of iron or steel originating in the PRC. 

The proceeding was initiated following a complaint lodged by the Defence Committee 
of  the  Seamless  Steel  Tube  Industry  of  the  European  Union  (‘the  complainant’)  on 
behalf of producers representing a major proportion, in this case more than 50 %, of 
the total Community production of certain seamless pipes and tubes of iron or steel. 

As set out in recital (13) of the provisional Regulation, the investigation of dumping 
and injury covered the period from 1 July 2007 to 30 June 2008 (‘investigation period’ 
or ‘IP’). The examination of trends relevant for the assessment of injury covered the 
period from 1 January 2005 to the end of the IP (‘period considered’). 

Subsequent procedure 

Subsequent to the disclosure of the essential facts and considerations on  the  basis of 
which  it  was  decided  to  impose  provisional  anti-dumping  measures  ('provisional 
disclosure'),  several  interested  parties  made  written  submissions  making  their  views 

1 
2 
3 

OJ L 56, 6.3.1996, p. 1.  
OJ C 174, 9.7.2008, p. 7. 
OJ L 94, 8.4.2009, p. 48.  

EN 

5 

   EN 

 
 
                                                 
known on the provisional findings. The parties who so requested were also granted the 
opportunity to be heard.  

(5) 

The Commission continued to seek and verify all information it deemed necessary for 
its definitive findings. In particular, the Commission sent an additional questionnaire 
to  the  sampled  Community  producers  to  collect  further  information  concerning  the 
market developments and the evolution of the main injury indicators after the end of 
the  IP.  Additional  verification  visits  were  carried  out  after  the  imposition  of  the 
provisional  measures  at  the  premises  of  the  following  producers  of  certain  seamless 
pipes and tubes in the EU: 

– 

– 

– 

– 

– 

Vallourec & Mannesmann Deutschland GmbH, Düsseldorf, Germany, 

Vallourec & Mannesmann France, Boulogne-Billancourt, France, 

Tenaris-Dalmine SpA, Dalmine, Italy, 

Tubos Reunidos SA, Amurrio, Spain, 

Productos Tubulares SA, Valle de Trapaga, Spain. 

In addition, a verification visit was carried out at the premises of the complainant at 
Boulogne-Billancourt, France. 

(6) 

The Commission also conducted a further desk analysis of the questionnaire replies of 
all  four  sampled  exporting  producers,  including  in  particular  the  verification  of  the 
transaction listing provided by the following exporters: 

– 

– 

– 

– 

Hubei Xinyegang Steel Co., Ltd., 

Hengyang Valin Steel Tube Co., Ltd.,  

Shandong Luxing Steel Pipe Co. Ltd., 

Tianjin Pipe International Economic & Trading Corporation. 

(7) 

(8) 

3. 

(9) 

All  parties  were  informed  of  the  essential  facts  and  considerations  on  the  basis  of 
which it was intended to recommend the imposition of a definitive anti-dumping duty 
on imports of certain seamless pipes and tubes of iron or steel originating in the PRC 
and  the  definitive  collection  of  the  amounts  secured  by  way  of  the  provisional  duty 
('final  disclosure').  They  were  also  granted  a  period  within  which  they  could  make 
representations subsequent to this disclosure. 

The  oral  and  written  comments  submitted  by  the  interested  parties  were  considered 
and, where appropriate, the findings were modified accordingly. 

Sampling 

In the absence of any comments concerning the sampling of exporting producers in the 
PRC and of Community producers, the provisional findings in recitals (11) to (12) of 
the provisional Regulation are hereby confirmed.  

B. 

PRODUCT CONCERNED AND LIKE PRODUCT 

(10)  The product concerned is certain seamless pipes and tubes, of iron or steel, of circular 
cross-section,  of  an  external  diameter  not  exceeding  406,4  mm  with  a  Carbon 
Equivalent Value ('CEV') not exceeding 0,86 according to the International Institute of 

EN 

6 

   EN 

 
Welding (IIW) formula and chemical analysis4, originating in the People's Republic of 
China ('the product concerned') and currently falling within CN codes ex 7304 19 10, 
ex 7304 19 30, ex 7304 23 00, ex 7304 29 10, ex 7304 29 30, ex 7304 31 20, ex 7304 
31 80, ex 7304 39 10, ex 7304 39 52, ex 7304 39 58, ex 7304 39 92, ex 7304 39 93, ex 
7304 51 81, ex 7304 51 89, ex 7304 59 10, ex 7304 59 92 and ex 7304 59 935. 

(11)  After the publication of the provisional Regulation, a clerical mistake was found in the 
numbering  of  the  Technical  Report  mentioned  in  the  footnote  of  recital  (14)  of  the 
provisional Regulation for the determination of the Carbon Equivalent Value (CEV). 
The correct reference is Technical Report, 1967, IIW doc. IX-555-67 published by the 
International Institute of Welding (IIW). 

(12)  After  provisional  disclosure,  the  China  Iron  and  Steel  Association  (‘CISA’)  claimed 
that  the  CN  codes  covering  the  product  concerned  were  also  covering  a  number  of 
other products which would fall outside the scope of the investigation such as products 
with an outside diameter exceeding 406,4 mm or with a CEV exceeding 0,86 and, as a 
consequence, the import figures used in the investigation would be overstated. In this 
respect, it has to be noted that products with an outside diameter exceeding 406,4 mm 
or with a CEV exceeding 0,86 according to the IIW formula and chemical analysis are 
not concerned by these proceedings. Furthermore, no evidence was found at any of the 
sampled  exporting  producers  that  these  products  are  produced  in  the  PRC  in 
significant  quantities.  Therefore,  it  has  been  concluded  that  there  is  no  credible 
evidence regarding the import of any significant  quantities  of such  Chinese  products 
into the EC. 

(13)  Following the final disclosure, CISA reiterated the claim that oil country tubular goods 
(‘OCTG’)  should  be  excluded  from  the  definition  of  the  product  concerned  and 
pointed  out  that  other  countries,  including  the  USA,  treat  OCTG  as  belonging  to  a 
separate  market  for  the  purpose  of  anti-dumping  investigations.  Similar  claims  were 
also made by the Chinese government (‘MOFCOM’).  

(14)  The  above-mentioned  claims  have  been  analysed  in  detail  and  it  was  found  that  the 
different types of seamless pipes and tubes, including OCTG, included in the product 
definition share the same basic physical, chemical and technical characteristics, which 
means  that  they  belong  to  the  same  product  category.  The  fact  that  these  different 
product types differ to a certain extent in their characteristics, cost and selling prices is 
normal. Moreover, the fact that other investigating authorities carry out investigations 
into OCTG products only may well be due to the particularities of such investigations, 
i.e. the scope of the underlying complaint. Indeed, it was found that the US authorities 
did not have to investigate whether OCTG share the same basic characteristics as other 
seamless pipes and tubes. Furthermore, the Community industry provided evidence of 
the  interchangeability  between  plain-end  OCTG  and  other  products  subject  to  the 
investigation. 

4 

5 

The  CEV  shall  be  determined  in  accordance  with  Technical  Report,  1967,  IIW  doc.  IX-555-67, 
published by the International Institute of Welding (IIW). 
As defined in Commission Regulation (EC) No 1031/2008 of 19 September 2008 amending Annex I to 
Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common 
Customs  Tariff  (OJ  L  291,  31.10.2008,  p.  1).  The  product  coverage  is  determined  in  combining  the 
product  description  in  Article  1(1)  and  the  product  description  of  the  corresponding  CN  codes  taken 
together. 

EN 

7 

   EN 

 
                                                 
(15) 

It was also argued that in defining the product concerned undue importance was given 
to elements such as the wall thickness, external diameter, and CEV threshold, whilst 
no  proper  attention  had  been  paid  to  technical  properties  such  as  high  pressure  and 
high corrosion resistance and to the existence of special American Petroleum Institute 
('API') standards for OCTG. 

(16)  First of all, it must be noted that since the wall thickness is not used in the definition of 
the scope of the investigation, the external diameter and the CEV threshold remain the 
most appropriate elements to identify the product concerned. The external diameter is 
also an element used in distinguishing the product for statistical and customs purposes. 
As regards the CEV threshold, it defines the level at which a product can be welded 
and  the  threshold  is  set  at  0,86  in  order  to  separate  products  which  can  easily  be 
welded from those which can not. Secondly, information provided by the Community 
industry  shows  that  OCTG,  as  other  types  of  tubes,  may  have  both  high  and  low 
corrosion/pressure  resistance.  Thus  neither  the  corrosion  nor  the  pressure  resistance 
could  be  used  as  a  criterion  in  defining  the  product  concerned.  Third,  the  special 
American Petroleum Institute standards exist as regards OCTG and line pipes because 
they  are  used  in  the  petroleum  sector.  However,  tubes  used  in  other  sectors  are  also 
subject to similar standards, although issued by other organisations (e.g. ASTM). As a 
result, the fact that standards are issued by one or the other organisation cannot be an 
element to define  the  product  scope of an anti-dumping investigation. In conclusion, 
neither CISA nor MOFCOM have submitted valid alternative elements to better define 
the product scope, nor have they ever proposed criteria that would be more appropriate 
to  define  the  product  concerned,  apart  from  the  high  corrosion/pressure  resistance 
mentioned above. In addition, neither party proposed a different CEV level as a more 
appropriate threshold. Therefore, the claims on the definition of the product concerned 
are rejected. 

(17) 

1. 

(18) 

In  view  of  the  above,  it  is  definitively  concluded  that  the  product  concerned 
incorporates, inter alia, OCTG used for drilling, casing and tubing in the oil industry, 
and  recitals  (14)  to  (19)  of  the  provisional  Regulation  are  hereby  definitively 
confirmed.  

Market economy treatment (‘MET’) 

C. 

DUMPING 

In the absence of any comments, the content of recitals (20) to (27) of the provisional 
Regulation concerning MET findings is hereby definitively confirmed. 

2. 

Individual treatment (‘IT’) 

(19)  Further to provisional disclosure, the complainant claimed that one exporting producer 
provisionally  granted  IT  should  not  have  received  IT,  as  among  other  things,  it  was 
allegedly majority state owned. 

(20)  Further investigation showed that the Chinese state did (indirectly) have some stake in 
the said company, but during the IP the state was a minority shareholder. However, the 
shareholding changed significantly at the end of 2008 (post-IP) when the Chinese state 
acquired  more  shares  of  the  holding  company  and  the  state  thus  became  a  majority 
shareholder. Consequently, the Commission considered that the exporting producer in 
question would not fulfil the requirements of Article 9(5) of the basic Regulation and 
should not be granted IT. 

EN 

8 

   EN 

 
(21)  Following  the  final  disclosure,  the  said  company  reiterated  its  argument  that  the 
increased  shareholding  of  the  Chinese  state  occurred  after  the  IP.  Moreover,  the 
company argued that the increase in shareholding was clearly and solely intended to 
provide  financial  support  to  the  holding  company  because  of  the  financial  crisis.  In 
particular, the said company claimed that the increased shareholding had no impact on 
the  management  structure,  the  composition  of  the  Board  of  Directors  and  the 
commercial activities. It also claimed that the change in shareholding had no effect on 
the  company's  decisions  regarding  export  activities  that  remain  to  be  made 
independently from the State. The company also submitted that no evidence has been 
shown that in this case state influence would be such so as to permit circumvention of 
measures if the company would be given an individual rate of duty. 

(22) 

In order to be granted IT, exporting producers must demonstrate that they fulfil all the 
criteria enumerated in Article 9(5) of the basic Regulation. One of these criteria is that 
the  majority  of  shares  belong  to  private  persons.  However,  as  regards  the  said 
company, this criterion has not been met since the end of 2008. 

(23)  Consequently, despite the fact that the change of ownership happened only after the IP 
(but  still  before  the  conclusion  of  the  investigation)  and  considering  the  prospective 
nature of the findings with regard to IT, it is concluded that this company should not 
be  granted  IT,  as  it  did  not  fulfil  the  requirements  of  Article  9(5)  of  the  basic 
Regulation. 

(24) 

In  the  absence  of  any  other  comments  concerning  IT,  the  content  of  recitals  (28)  to 
(32)  of  the  provisional  Regulation,  other  than  those  concerning  the  company 
mentioned in recitals (19) to (23) above, is hereby definitively confirmed. 

3. 

Normal value 

3.1. 

Analogue country 

(25)  Following the provisional disclosure, three parties submitted that the USA was not an 
appropriate analogue country since the market conditions in the USA and in the PRC 
are significantly different. It was also submitted that the normal value calculation was 
based on the data of only one producer, related to a producer in the Community, and 
thus were not representative.  

(26) 

(27) 

3.2. 

(28) 

It is noted that the basic Regulation requires that the analogue country be selected in a 
not unreasonable manner. The parties mentioned above failed to provide substantiated 
evidence  that  the  choice  of  the  USA  was  unreasonable.  In  particular,  they  did  not 
question the competitiveness of the US market, the lack of which for example could 
have  an  impact  on  the  level  of  prices  established.  It  is  also  noted  that  none  of  the 
parties in question suggested any alternative choice for the analogue country. 

In  view  of  the  above,  it  is  definitively  concluded  that  the  USA  is  an  appropriate 
analogue  country  and  recitals  (33)  to  (38)  of  the  provisional  Regulation  are  hereby 
confirmed. 

Determination of normal value 

In  the  absence  of  any  comments  concerning  the  determination  of  normal  value,  the 
provisional  findings  in  recitals  (39)  to  (44)  of  the  provisional  Regulation  are  hereby 
confirmed. 

EN 

9 

   EN 

 
4. 

(29) 

Export Price 

In  the  absence  of  any  comments  concerning  the  determination  of  export  price,  the 
content of recital (45) of the provisional Regulation is hereby confirmed. 

5. 

Comparison 

(30)  Following  provisional  disclosure,  one  exporting  producer  pointed  out  that  the 
simplification applied to the product control number (in order to increase the level of 
comparability between the product concerned and the like product from the analogue 
country)  resulted  in  an  unfair  comparison  as  it  treated  several  types  of  the  seamless 
pipes and tubes as one product category. Following this comment, it was decided that 
a different  regrouping  of the product control numbers that would allow for a similar 
level of comparability can be applied – namely with regard to pipe diameter and wall 
thickness.  

(31)  Following  provisional  disclosure,  Chinese  export  prices  at  ex  works  level  have  been 
revised downwards in order to take into account all transport costs. At the same time, 
normal value was revised upwards due to some corrections concerning allowances for 
transport and discounts.  

(32) 

6. 

(33) 

In the absence of any other comments in respect of comparison, the content of recitals 
(46) and (47) of the provisional Regulation is hereby confirmed. 

Dumping margin 

In  the  absence  of  any  comments  concerning  the  dumping  margin  calculation,  and 
subject to the changes mentioned at recitals (30) and (31), the content of recitals (48) 
to (51) of the provisional Regulation is hereby confirmed. 

(34)  The amount of dumping finally determined, expressed as a percentage of the CIF net 

free-at-Community-frontier price, before duty, is as follows: 

Company 

Definitive 
dumping margin 

Shandong Luxing Steel Pipe Co. Ltd 

Other cooperating companies 

Residual 

64,8 % 

48,6 % 

73,1 % 

D. 

INJURY 

1. 

Community production, Community industry and Community consumption 

(35)  CISA  claimed  that,  according  to  information  released  by  a  specialised  agency  (Steel 
Business  Briefing),  there  were  at  least  40  Community  producers  in  2007  of  the  like 
product in the EU-27 with a production of around 5,8 million tonnes and this would 
contradict  the  relevant  data  contained  in  the  provisional  Regulation.  CISA  also 
claimed  that,  according  to  information  released  by  the  World  Steel  Association, 
Community consumption was of around 4,6 million tonnes in 2007, i.e. far higher than 
what was reported in recital (57) of the provisional Regulation. A Chinese exporting 
producer also made similar claims.  

EN 

10 

   EN 

 
(36)  The examination of the information provided showed that the figures reported refer to 
all seamless pipes and tubes and not to the like product as defined in the provisional 
Regulation and in recitals (10) to (17) above, and include other products such as large 
pipes  and  tubes  (i.e.  with  a  diameter  exceeding  406,4  mm)  and  stainless  steel  pipes 
and tubes. This explains the discrepancy between the information mentioned in recital 
(35)  above  and  that  contained  in  the  provisional  Regulation.  It  should  also  be  noted 
that names and locations of all known Community producers of the product concerned 
were  contained  in  the  non-confidential  version  of  the  complaint.  If  CISA  had 
considered that there were any other producers of the product concerned in the EU, it 
should  have  provided  in  due  course  sufficient  evidence  to  identify  them,  so  that  any 
such company would also have been considered.  

(37)  The claims mentioned above are therefore dismissed and the content of recitals (53) to 

(58) of the provisional Regulation is hereby confirmed. 

2. 

Imports from the country concerned 

(a)  Volume, market share of the imports concerned and import prices 

(38)  Following  comments  submitted  by  CISA,  it  is  clarified  that  recital  (60)  of  the 
provisional  Regulation  should  be  intended  as  meaning  that  the  OCTG  and  power 
generation market segments represented each less than 5 % of total imports from the 
PRC.  In  the  absence  of  any  claims  or  other  comments,  recitals  (59)  to  (63)  of  the 
provisional Regulation are hereby confirmed.  

(b)  Price undercutting 

(39)  An  exporting  producer,  three  Community  producers  and  the  complainant  submitted 
comments  relating  to  the  calculation  of  the  undercutting  and  injury  margins.  These 
comments were analysed and, where appropriate, the calculations were amended. 

(40)  One exporting producer claimed that the adjustments made to compare on a fair basis 
the  prices  of  the  Chinese  imports  and  the  prices  of  the  corresponding  product  types 
sold  by  the  Community  industry  were  not  adequate,  since  they  did  not  include  an 
amount  for  the  SG&A  and  profit  of  an  independent  importer.  On  the  contrary,  the 
complainant claimed that the level of these adjustments was excessively high. As for 
the  claim  of  the  exporting  producer,  it  was  found  that  often  Chinese  exporting 
producers  and  Community  producers  were  selling  to  the  same  customers.  Thus,  a 
further  adjustment  to  import  prices  was  not  justified.  After  examination  of  the 
evidence provided, it was concluded that the claims should be dismissed and the two 
parties were informed of the reasons thereof. 

(41)  The complainant claimed that the calculation of the differences in level of trade was 
incorrect  since  Chinese  exporting  producers  also  directly  sold  to  users  and  that  for 
such  sales  no  level  of  trade  adjustment  is  warranted.  This  claim  was  found  to  be 
correct  for  some  Chinese  exporting  producers  and  the  level  of  trade  adjustment  was 
accordingly  revised.  Furthermore,  the  exporting  producer  mentioned  in  recital  (40) 
above argued that, because of significant differences in sales volumes between its own 
imports  and  the  sales  of  the  Community  industry,  the  difference  in  level  of  trade 
should  not  be  established  by  simply  comparing  the  respective  percentage  of  sales  to 
users  and  suggested  another  formula  for  the  calculation  of  the  revised  level  of  trade 
adjustment.  However,  the  suggested  formula  was  not  considered  appropriate  since  it 
would distort the result. Therefore, the claim was rejected. 

EN 

11 

   EN 

 
(42)  On the basis of the above, the methodology described in recital (64) of the provisional 
Regulation is hereby confirmed and the undercutting margin calculated as explained in 
recital (65) of the provisional Regulation is established at 29 %. 

3. 

Situation of the Community industry 

(43)  CISA  claimed  that  a  number  of  sampled  Community  producers  had  not  submitted 
completed  replies,  so  that  the  representativeness  of  the  sample  would  be  impaired 
because of the low level of cooperation. It should be pointed out that, apart from the 
company indicated at point ii) of recital (66) of the provisional Regulation, which only 
submitted partial information, all other companies in the sample have provided by the 
definitive  stage  of  the  investigation  all  the  information  requested.  Even  when 
excluding  the  sole  company  that  had  only  provided  partial  information,  the 
representativeness of the sample would in any case remain at about 60 % of the total 
Community production. The claim was therefore rejected. 

(44)  CISA  also  claimed  that,  contrary  to  what  is  stated  at  recital  (86)  of  the  provisional 
Regulation, one major Community producer group had made, after the IP, substantial 
investments in expanding its production capacity for tubes in the nuclear power sector. 
This information was verified and it was found that the above-mentioned investments 
were  made  in  order  to  increase  the  production  capacity  for  other  products  (stainless 
steel  or  welded  pipes  and  tubes)  than  the  like  product.  The  claim  was  therefore 
rejected.  

(45)  CISA  and  a  Chinese  exporting  producer  claimed  that  recital  (87)  of  the  provisional 
Regulation was incorrect in saying that the Community industry was still recovering 
from the past effect of dumping since there were at least three Romanian companies 
supporting  the  complaint,  which  were  until  mid  2006  themselves  subject  to  anti-
dumping  measures.  However,  the  statements  in  recital  (87)  clearly  refer  to  the 
Community  industry  considered  as  a  whole  and  not  to  individual  companies.  It  is 
therefore  normal  that  the  situation  of  individual  companies  may  differ  one  from 
another, without the general finding for the Community industry being put in question. 
The claim was therefore rejected.  

(46) 

In the absence of any other claims or comments, recitals (66) to (87) of the provisional 
Regulation are hereby confirmed.  

4. 

Conclusion on injury 

(47)  MOFCOM, CISA and two Chinese exporting producers claimed that the Community 
industry  was  not  in  a  vulnerable  state  at  the  end  of  the  investigation  period, 
particularly in view of its recent high levels of profit. The reasons why the Community 
industry was considered to be in a vulnerable situation at the end of the IP are detailed 
in recital (89) of the provisional Regulation. It was recognised therein that the injury 
suffered  during  the  IP  was  not  material,  but  it  was  also  explained  that,  given  the 
important  share  of  dumped  imports  in  the  Community  market,  the  Community 
industry  was  exposed  to  the  injurious  effects  of  such  dumped  imports,  in  case  of 
significant changes in the overall market situation. In this respect, it should be borne in 
mind  that  the  Community  industry  could  benefit  only  partially  from  the  substantial 
increase in consumption and that its market share had declined by 5 percentage points 
during the period considered, as indicated in recital (88) of the provisional Regulation. 
Moreover,  the  fact  that  an  industry  experiences  good  levels  of  profit  during  an 
exceptionally  favourable  period  of  very  high  market  demand  does  not  necessarily 
imply that it is structurally in a solid economic and financial situation, particularly if 

EN 

12 

   EN 

 
during previous periods the same industry was posting extremely low profits or even 
losses.  As  already  mentioned  at  recital  (86)  of  the  provisional  Regulation,  the  past 
poor economic performance caused by the existence of dumping practices had made it 
impossible to maintain the level of investments appropriate to ensure the viability of 
the  Community  industry  in  the  long  term  in  such  a  highly  capital  intensive 
manufacturing sector. Finally, the EC market was again characterised at the end of the 
IP by the presence of a significant proportion of very low-priced dumped imports. This 
market  situation  was  potentially  very  dangerous  since  already  in  past  years,  at  times 
when the level of demand was at normal levels, a similar market situation (which was 
analysed  in  Council  Regulation  (EC)  No  954/2006)  had  caused  significant  injury  to 
the Community industry. The claim is therefore rejected. 

(48)  One  Chinese  exporting  producer  also  claimed  that  recital  (89)  of  the  provisional 
Regulation  did  not  show  that  the  change  in  market  situations  referred  therein  was 
‘clearly foreseen and imminent’, as requested by the WTO Anti-dumping Agreement 
('ADA').  A  change  in  the  market  situation  was  foreseeable  because  consumption 
cannot  normally  remain  at  exceptionally  high  levels  for  a  long  period.  The  analysis 
carried  out  in  recitals  (90)  to  (126)  of  the  provisional  Regulation  shows  a  clear 
deterioration  which  in  fact  took  place  over  a  certain  period  of  time.  The  fact  that  a 
certain period of time is necessary for a number of elements and indicators to evolve 
from  positive  to  negative  values  is  not  inconsistent  with  the  fact  that,  in  the  light  of 
existing trends, such negative effects are already clearly foreseeable. At the end of the 
IP, the threat of injury was clearly foreseeable, and the starting of the negative trends 
which would lead to an injurious picture was imminent, since a certain slow down in 
demand had already taken place in the last months of the IP. The claim was therefore 
rejected. 

(49) 

In the absence of any other claim or comments, the conclusion on injury laid down in 
recitals (88) and (89) of the provisional Regulation is confirmed. 

E. 

THREAT OF INJURY 

1. 

Likely  developments  of  Community  consumption,  imports  from  the  country 
concerned and the situation of the Community industry after the investigation 
period  

1.1. 

Analysis carried out after provisional measures 

(50)  As  mentioned  in  recital  (5)  above,  an  additional  questionnaire  was  sent  to  sampled 
Community producers and to the complainant in order to obtain further information on 
the market developments and the evolution of the main injury indicators until March 
2009.  Latest  import  data  available  from  Eurostat  have  also  been  carefully  analyzed. 
For the sake of completeness the figures relating to the period between the end of the 
IP and March 2009 ('the post-IP period') are reported below. Since these figures relate 
to a period of nine months only, no index is given for volumes. 

(51)  After  the  IP,  the  Community  consumption  started  to  decrease  substantially  and  at  a 
faster  pace  than  what  was  indicated  in  recital  (91)  of  the  provisional  Regulation.  In 
fact,  the  Community  market  has  already  contracted  by  almost  30  %6  in  the  period 
between the end of the IP and March 2009. 

6 

On the basis of a comparison carried out between monthly average volumes 

EN 

13 

   EN 

 
                                                 
2005 

2006 

2007 

IP 

Post-IP period 

Community 
Consumption 

2 565 285 

2 706 560 

3 150 729 

3 172 866 

1 720 968 

(52)  At  the  same  time,  imports  from  the  PRC  also  decreased  significantly  but,  given  the 
steeper  decrease  of  Community  consumption,  the  market  share  of  these  imports  has 
increased to around 18 %. The prices of Chinese imports increased in line with what 
was indicated in recital (98) of the provisional Regulation. 

PRC 

2005 

2006 

2007 

IP 

Post-IP period 

Imports Volume 

26 396 

136 850 

470 413 

542 840 

306 866 

Market Share 

1,0 % 

5,1 % 

14,9 % 

17,1 % 

17,8 % 

Index (2005=100) 

100 

491 

1 451 

1 663 

1 733 

Export Price 

766,48 

699,90 

699,10 

715,09 

966,63 

Index (2005=100) 

100 

91 

91 

93 

138 

(53) 

In the same period, the production of the Community industry decreased significantly, 
so  that  the  capacity  utilisation  of  the  sampled  companies  dropped  to  60  %  in  March 
2009.  Sales  of  the  Community  industry  on  the  Community  market  decreased 
substantially  and  in  line  with  the  decrease  of  Community  consumption,  so  that  the 
market share of the Community industry remained stable. As for prices, after having 
increased  in  the  second  half  of  2008,  they  decreased  in  the  first  quarter  of  2009, 
though remaining at values higher than during the IP. 

Sampled 
Community 
producers 

2005 

2006 

2007 

IP 

Post-IP period 

Production 

2 022 596 

2 197 964 

2 213 956 

2 158 096 

1 477 198 

Capacity 

2 451 187 

2 469 365 

2 446 462 

2 398 283 

1 889 180 

Capacity 
Utilisation 

83 % 

89 % 

90 % 

Index (2005=100) 

100 

108 

110 

90 % 

109 

78 % 

88 

EN 

14 

   EN 

 
 
 
Community 
Industry 

2005 

2006 

2007 

IP 

Post-IP period 

EC sales Volume 

1 766 197 

1 907 126 

2 061 033 

2 017 525 

1 093 175 

Market Share 

68,8 % 

70,5 % 

65,4 % 

63,6 % 

63,5 % 

Index (2005=100) 

100 

102 

95 

92 

90 

Sampled 
Community 
Producers 

2005 

2006 

2007 

IP 

Post-IP period 

EC Sales Price 

Index (2005=100) 

983 

100 

1 047 

1 188 

1 192 

106 

121 

121 

1 415 

135 

(54)  Finally, the profitability of the Community industry has decreased substantially and at 
a quicker pace than indicated in recital (110) of the provisional Regulation, so that it 
was negative (-0,8 %) in the first quarter of 2009. 

Sampled 
Community 
Producers 

2005 

2006 

2007 

IP 

Post-IP period 

Profitability 

12,1 % 

17,3 % 

17,9 % 

15,4 % 

3,5 % 

Index (2005=100) 

100 

143 

147 

127 

20 

(55) 

In  conclusion,  the  information  additionally  collected  and  verified  at  the  definitive 
stage of the investigation confirms the analysis carried out in recitals (90) to (112) of 
the provisional Regulation.  

1.2. 

Comments submitted by parties  

(56)  One  exporting  producer  claimed  that  the  investigation  of  injury,  contrary  to  that  of 
dumping, had been extended beyond the IP, by basing the analysis also on information 
and data for the period after June 2008. 

(57) 

It is first of all recalled that the IP and the period considered are the basis on which the 
assessment of threat of injury was made in the provisional Regulation. However, in a 
threat of injury case, the injury found in the investigation period cannot – by definition 
– be material, otherwise that investigation would qualify as an investigation based on 
actual material injury. The investigating authority therefore needs to ascertain whether, 
although  the  injury  was  not  material  during  the  IP,  the  factors  referred  to  at 
Article 3(9)  of  the  basic  Regulation  lead  to  the  conclusion  that  there  is  a  threat  of 
material  injury.  Therefore,  the  investigating  authority  is  entitled  to  verify  that  the 
events taking place after the end of the IP do confirm the findings of threat of injury 
reached at provisional stage. 

EN 

15 

   EN 

 
 
 
(58)  MOFCOM,  CISA  and  one  Chinese  exporting  producer  considered  that  the  source  of 
the information used was not made clear in recital (91) of the provisional Regulation 
and that the forecasts and other information submitted by Community producers or the 
complainant  and  referred  to  in  recitals  (99),  (101)  and  (108)  of  the  provisional 
Regulation were not from an objective source of information. MOFCOM also claimed 
that  by  using  such  information,  the  investigating  authority  had  not  displayed  the 
‘special care’ requested by the WTO ADA in threat of injury investigations.  

(59) 

It is confirmed that the detailed evidence relating to the various sources of the public 
information  mentioned  in  recital  (91)  of  the  provisional  Regulation  was  made 
available  in  the  files  open  to  consultation  by  interested  parties  well  before  the 
publication  of  the  provisional  Regulation.  As  for  the  forecasts  and  other  information 
submitted by the Community industry, these were verified and were taken into account 
only  when,  and  to  the  extent  that,  such  information  was  considered  reliable  and 
accurate.  The  fact  that  the  information  submitted  had  been  verified  was  already 
specifically  mentioned  in  recital  (100)  of  the  provisional  Regulation,  and  additional 
verification  visits  were  carried  out  after  the  imposition  of  provisional  measures,  as 
indicated in recital (5) above.  

(60)  The claims referred to in recitals (56) and (58) above are therefore rejected. 

(61)  CISA claimed that in assessing the developments of the Chinese imports after the IP, 
account  should  have  been  taken  not  of  the  actual  imports  but  of  the  level  of  orders 
intake,  since  actual  imports  take  place  normally  after  3-4  months  from  the  order. 
Given  the  time  lag,  any  variation  in  the  level  of  the  EC  market  demand  would  be 
reflected  in  the  actual  imports  only  some  months  afterwards  and  this  would  explain 
why  Chinese 
in  November  and  December  2008, 
notwithstanding  the  fact  that  the  level  of  the  demand  in  the  EU  market  had  already 
started  to  decrease.  Similar  comments  were  also  made  by  a  Chinese  exporting 
producer. 

imports  were  still  high 

(62)  Actual imports are usually taken as the basis to assess the volumes and average prices 
of  imports  from  a  given  country.  Information  relating  to  order  intakes  may  be  taken 
into  account  in  order  to  support  other  information,  but  can  rarely  be  backed  up  by 
sufficiently verifiable evidence. In any case, the analysis of the claim has showed that 
Community  consumption  had  already  started  to  decrease  during  the  3rd  quarter  of 
2008. Thus, this fact should have already been reflected, in case of a 3-4 months gap, 
in  the  level  of  the  Chinese  imports  for  the  4th  quarter  2008,  which  was  instead 
relatively high. Moreover, should the above-mentioned 3-4 months gap be considered, 
the strong decrease in Chinese imports taking place in the first quarter 2009 could be 
in anticipation of anti-dumping measures rather than due to the slowdown in demand. 
In  fact,  importers  might  have  been  less  and  less  willing  to  place  orders  for  goods 
which  might  have  arrived  at  a  moment  when  anti-dumping  measures  could  possibly 
have already been imposed. In conclusion, it is considered that an analysis based on 
order  intakes  rather  than  on  actual  imports  would  have  only  added  elements  of 
uncertainty  to  the  investigation  without  leading  to  any  significantly  different 
conclusion. Therefore, the claim made by CISA in this respect is rejected. 

(63)  MOFCOM, CISA and a Chinese exporting producer claimed that, according to various 
press  releases  and/or  financial  statements  published  by  a  number  of  Community 
producers groups, 2008 remained a strong year in terms of their performance and this 
would therefore contradict the findings of threat of injury contained in the provisional 
Regulation, in particular recital (110) thereof. 

EN 

16 

   EN 

 
(64) 

In examining this claim it was found that the information CISA was referring to did 
not  specifically  relate  to  the  European  entities  involved  in  the  production  of  the 
product  concerned.  As  already  mentioned  at  recital  (44)  above,  a  major  group  of 
companies  is  composed  by  various  entities  often  manufacturing  very  different 
products. The general financial information relating to a company group as such may 
therefore  not  be  representative  of  the  economic  situation  relating  to  the  specific 
entities producing the like product and selling it in the Community market. Finally, it 
is  recalled  that  the  information  relating  to  the  companies  manufacturing  the  like 
product  used  during  the  investigation  had  been  duly  verified.  The  claim  is  therefore 
rejected. 

(65) 

In the absence of any other claim specifically concerning recitals (90) to (112) of the 
provisional Regulation, the findings contained therein are confirmed. 

2. 

Threat of injury 

2.1. 

Development of volumes of dumped imports 

(66)  CISA  claimed  that  the  increase  in  Chinese  imports  mentioned  under  recital  (114)  of 
the provisional  Regulation was the consequence of an increase in demand in the EU 
market. Similar comments were also submitted by MOFCOM and a Chinese exporting 
producer. CISA also rejected the assessment that the development of Chinese imports 
could be the result of a market penetration strategy and underlined that, since Chinese 
exports were made by a large number of Chinese producers, it was impossible to think 
of them as elaborating a coordinated strategy. 

(67) 

If it were true that the development of Chinese imports was correlated to the increase 
in  demand  in  the  EC  market  as  claimed  by  CISA,  the  market  share  of  such  imports 
would have remained substantially stable, and would not have increased from 1 % to 
17 % during the period considered. The substantial increase in the market share of the 
Chinese  imports  and  its  completely  different  evolution  from  the  evolution  of  the 
market shares of the Community industry and any other import source, clearly point to 
the  fact  that  other  elements  have  underpinned  the  increase  in  Chinese  imports.  This 
conclusion  is  further  supported  by  the  fact  that  Chinese  imports  have  consistently 
taken place at very low dumped prices, as it had been explained in recitals (63) to (65) 
of the provisional Regulation. Moreover, there is no need for exporters to coordinate a 
strategy in order to converge towards a similar behaviour. Once it becomes clear that 
to  penetrate  a  market  a  certain  very  low  level  of  prices  is  successful,  a  convergence 
towards such successful market strategy would probably take place without any need 
for exporters to coordinate. Therefore, the claims in recital (66) above are rejected and 
the findings in recital (114) of the provisional Regulation are confirmed. 

(68)  CISA also claimed that, contrary to the assessment made in recitals (115) and (116) of 
the provisional Regulation, imports from the PRC decreased significantly in the period 
after the IP. It is indeed true that, as indicated in recital (52) above, imports from the 
PRC  decreased  significantly  during  the  Post-IP  period.  However,  the  wording  of 
recital (116) of the provisional Regulation makes it clear that what matters is not the 
absolute  volume  of  such  imports,  but  their  relative  importance  in  relation  to 
consumption,  in  other  words,  their  market  share  in  the  total  Community  market.  As 
also indicated in recital (52) above, notwithstanding their decrease in absolute volume, 
Chinese  imports  of  the  product  concerned  have  slightly  increased  their  market  share 
during the Post-IP period. Therefore, considering the fact i) that the assessment at the 
basis  of  the  reasoning  in  recitals  (115)  and  (116)  of  the  provisional  Regulation  was 
made on the most recent reliable information concerning imports available at the time 

EN 

17 

   EN 

 
of  the  provisional  findings,  i.e.  imports  data  for  November  and  December  2008,  ii) 
that  this  data  was  coherent  with  the  evolution  of  the  Chinese  imports  until  that 
moment, and iii) that the reasoning was based on relative and not absolute volumes, it 
is  concluded  that  the  assessment  in  recitals  (115)  and  (116)  of  the  provisional 
Regulation is not in contradiction with the findings mentioned in recital (52) above. It 
is  in  any  case  worth  noting  that,  for  the  reasons  mentioned  in  recital  (134)  of  the 
provisional  Regulation,  the  level  of  Chinese  imports  might  be  considered  as  an 
element  of  threat  of  injury  even  in  the  case  that  volumes  would  start  to  decrease 
proportionally  more  than  the  decrease  in  consumption,  since  the  presence  itself  of 
substantial  volumes  of  low  priced  Chinese  goods  in  a  context  of  decreasing 
consumption will exert an important downward pressure on the general level of prices 
in  the  market.  In  any  case,  no  single  factor  mentioned  in  Article  3(9)  of  the  basic 
Regulation  can  necessarily  give  decisive  guidance  on  the  existence  of  a  threat  of 
injury.  Rather,  all  the  factors  must  be  considered  in  their  totality.  The  claim  is 
therefore  rejected  and  the  findings  in  recital  (115)  of  the  provisional  Regulation  are 
confirmed. 

2.2. 

Availability of free capacity of the exporters 

(69)  CISA  claimed  that  the  analysis  in  recital  (118)  of  the  provisional  Regulation  was 
based  on  data  from  the  sampled  exporters,  which  were  the  most  export-oriented 
companies,  so  that  their  data  would  not  reflect  correctly  the  overall  situation 
concerning  exports  from  the  PRC.  Instead,  it  is  claimed  that  the  share  of  Chinese 
exports  to  the  EC  out  of  the  total  Chinese  exports  indicated  in  recital  (119)  of  the 
provisional Regulation changed trend in 2008, decreasing from 15 % to 11 %. Finally, 
the  analysis  in  recitals  (117)  to  (119)  of  the  provisional  Regulation  ignored  the 
evolution in demand for the Chinese domestic market, which was forecast to absorb a 
significant  part  of  the  output  generated  by  the  existing  overcapacity.  In  this  respect, 
reference was made to a number of projects and plans by the Chinese government to 
sustain internal demand. MOFCOM also claimed that the development of the demand 
in the Chinese domestic market had not been examined in the provisional Regulation. 

(70)  The  findings  relating  to  the  sampled  companies  in  recital  (118)  of  the  provisional 
Regulation are clearly confirmed by the trends in the general export data referred to in 
recital  (119)  of  the  provisional  Regulation,  which  showed  a  even  more  significant 
increase  in  the  trend  of  exports  to  the  EC  for  the  period  considered.  As  for  the 
supposed  reversal  of  the  increasing  trend  in  exports  to  the  EC  as  regards  the  total 
Chinese exports of the product concerned in 2008, CISA failed to submit any decisive 
supporting  evidence  of  its  claim.  In  this  respect,  it  should  be  noted  that  the  data 
resulting from Chinese statistics clearly refer to a product scope significantly different 
from the product concerned; this clearly appears from the fact that exports to Europe, 
as  shown  in  these  statistics,  are  not  only  much  more  than  the  imports  registered  in 
Eurostat  for  the  product  concerned,  but  their  evolution  also  shows  a  completely 
different  trend.  The  evidence  provided  could  therefore  not  be  accepted.  As  for  the 
projected  actions  by  the  Chinese  government  to  stimulate  internal  demand,  the 
evidence  submitted  cannot  alter  the  analysis  since  the  effects  on  demand  cannot  be 
established  reliably.  Moreover,  it  is  unclear  for  most  of  the  projects  mentioned  that 
they will be completed. Finally, some large pipeline projects referred to by CISA seem 
to be projects built with large welded pipes and not with the seamless pipes that are the 
subject  of  the  present  proceeding.  The  claims  in  recital  (69)  above  are  therefore 
rejected. 

EN 

18 

   EN 

 
(71)  CISA  also  considered  that  the  re-direction  scenario  indicated  in  recital  (119)  of  the 
provisional Regulation was misplaced because the Chinese exports to the USA would 
mainly consist of products (OCTG) not widely imported in the EC. CISA also claimed 
that  prices  to  the  EC  were  not  necessarily  lower  than  in  other  countries  but,  on  the 
contrary, the EC has been an attractive market for Chinese exports so far. As regards 
this  claim,  it  must  be  stated  that  the  analysis  carried  out  in  recital  (119)  of  the 
provisional  Regulation  was  based  on  statistical  data  which  does  not  contain  detailed 
reference to specific product types. In any case, it should be noted that the production 
equipment necessary to manufacture the product concerned can, to a very large extent, 
be  used  for  the  production  of  various  product  types  of  seamless  pipes  and  tubes. 
Therefore, even if a specific type of tubes like OCTG is not extensively imported in 
the  EC,  this  fact  is  not  relevant  for  the  consideration  of  potentially  available  free 
capacities since the equipment used for manufacturing this type of tubes can easily be 
switched to produce other types of the product concerned, which are imported in much 
more  substantial  quantities  into  the  EC  market.  Therefore,  the  claims  in  recital  (66) 
above  are  rejected  and  the  findings  in  recitals  (117)  to  (119)  of  the  provisional 
Regulation are confirmed. 

2.3. 

Prices of the imports from the PRC 

(72)  CISA claimed that, after the IP, prices of Chinese imports have increased substantially 
whilst prices of the Community industry have not followed the same trend, so that the 
undercutting  existing  during  the  IP  would  have  been  substantially  reduced  or  even 
eliminated in the period after the IP. 

(73)  As  already  indicated  in  recitals  (98)  and  (122)  of  the  provisional  Regulation,  it  is 
confirmed that after the IP, the prices of imports from various sources, including from 
the  PRC,  increased  substantially,  as  did  the  prices  of  the  Community  industry.  An 
analysis  of  the  price  lists  of  Community  industry  after  the  IP  and  of  the  prices  of 
comparable products imported from the PRC has been carried out, and has shown that 
there has been a parallelism in price movements. In conclusion, no evidence was found 
to  support  the  allegation  that  the  undercutting  found  during  the  IP  would  have  been 
substantially reduced or even be eliminated. The findings in recitals (120) to (123) of 
the provisional Regulation are therefore confirmed. 

2.4. 

(74) 

Level of inventories 

In  the  absence  of  any  comments  on  this  point,  the  findings  in  recital  (124)  of  the 
provisional Regulation are hereby confirmed. 

2.5. 

Other elements 

(75)  CISA claimed that the possible intervention of the Chinese government referred to in 
recital  (125)  of  the  provisional  Regulation  was  a  pure  conjecture.  However,  the 
investigation has shown that the individual treatment granted to one Chinese exporting 
producer  at  the  provisional  stage  had  to  be  withdrawn  subsequently,  as  indicated  in 
recitals (19) to (23) above, because of the increased level of state intervention, which 
was  prompted  by  the  worsening  economic  situation  after  the  IP.  This  fact  clearly 
supports  the  finding  in  recital  (125)  of  the  provisional  Regulation  and  the  claim  is 
therefore rejected.  

EN 

19 

   EN 

 
2.6. 

(76) 

Conclusions 

It is first of all noted that the finding of threat of injury has been made after taking into 
consideration,  inter  alia,  the  totality  of  the  various  factors  referred  to  in  Article  3(5) 
and 3(9) of the basic Regulation. 

(77)  CISA  claimed  that  the  findings  in  the  provisional  Regulation  had  not  complied  with 
the standards required by the WTO for this type of investigation, i.e., that the findings 
should  be  supported  by  evidence  and  not  be  the  result  of  allegation,  conjecture  or 
remote possibility; that the projections and assumptions should show a high degree of 
likelihood and that alternative explanations in arriving to a given conclusion should be 
examined.  

(78)  The provisional Regulation indicates clearly on which basis the findings relating to the 
various elements of the investigation have been established. This was supported by the 
evidence  indicated,  such  as:  statistical  data  sourced  from  Eurostat,  questionnaire 
replies by cooperating companies, information on non sampled companies provided by 
the  complainant,  information  contained  in  submissions  made  by  interested  parties, 
other  information  found  in  the  internet  in  the  course  of  the  investigation.  All  this 
information,  where  non-confidential,  has  been  open  to  consultation  by  interested 
parties.  

(79)  The  elements  relating  to  the  threat  of  injury  examination  have  been  considered 
separately and in detail in the provisional Regulation and the degree of materialization 
of the assumptions and forecasts made at the provisional stage was re-examined and 
verified – to the extent possible – at the definitive stage of the investigation, as set out 
in  the  findings  in  this  Regulation.  No  facts,  evidence  or  indication  was  found  that 
would contradict the findings contained in the provisional Regulation. Therefore, the 
projections  and  assumptions  contained  in  the  provisional  Regulation  were  not 
conjectures or allegation, but the result of a thorough analysis of the situation. 

(80)  As for the alternative explanations and interpretations referred to in recital (78) above, 
including  those  presented  by  interested  parties  in  their  submissions,  they  have  been 
duly examined during the investigation and addressed in this Regulation as well as in 
the provisional Regulation. 

(81) 

1. 

(82) 

In conclusion, the examination of the facts taking place after the end of the IP as well 
as the analysis of the comments and observations made by the interested parties on the 
provisional  Regulation  and  on  the  disclosure  of  the  final  findings  have  not  revealed 
any evidence that would put in doubt the conclusion that the threat of material injury 
existed  as  of  the  end  of  the  IP.  Therefore,  the  claim  made  by  CISA  in  recital  (77) 
above  is  rejected  and  the  findings  in  recital  (126)  of  the  provisional  Regulation  are 
hereby confirmed. 

Effect of the dumped imports 

F. 

CAUSATION 

In  the  absence  of  any  specific  comments,  recitals  (128)  to  (135)  of  the  provisional 
Regulation are hereby confirmed. 

2. 

Effect of other factors 

(a) 

Import and export activity of the Community industry 

(83)  CISA claimed that the fact that Community industry imported the product concerned 
from the PRC and other countries demonstrated they did not have the capacity to meet 

EN 

20 

   EN 

 
the demand in the Community market. This was because the Community industry had 
not invested in new production capacity and concentrated heavily on the higher value 
segments of the market. In this respect, it should be recalled that it was explained in 
recital (136) of the provisional Regulation that such imports were estimated to be less 
than 2 % of the total imports from the PRC, and no evidence was provided to prove 
that this amount was higher. 

(84)  CISA also questioned the exact reasons why the company group mentioned in recital 
(138) of the provisional Regulation had to carry out the mentioned imports. The issue 
was  further  examined  and  it  is  confirmed  that  for  reasons  of  cost  efficiency,  the 
production  of  certain  product  types  had  been  carried  out  by  other  non  European 
entities  of  the  group.  As  already  mentioned  in  recital  (138)  of  the  provisional 
Regulation  however,  it  was  verified  that  such  imports  had  not  been  at  prices 
undercutting the Community price for the same product types. 

(85)  CISA  finally  pointed  at  an  apparent  inconsistency  between  the  relatively  positive 
estimation  of  the  Community  industry  concerning  their  future  export  sales  and  the 
general  economic  trends  for  third  country  markets,  which  were  instead  forecasted  to 
decline. In this respect, it is to be noted that the analysis of the export activity of the 
Community industry does not have any effect on the determinations relating to injury 
or threat of injury, which exclusively concern the activity of the Community industry 
for  the  like  product  in  the  EC  market.  If  some  of  the  Community  producers  have 
optimistic  views  about  their  export  activities  this  may  only  have  resulted  in  the 
overstatement  of  their  forecasted  general  economic  performance  but  not  on  their 
performance in the domestic market, which is kept separate in the analysis. 

(86)  Therefore,  the  claims  referred  to  in  recitals  (83)  to  (85)  above  are  rejected  and  the 
findings contained in recitals (136) to (141) of the provisional Regulation are hereby 
confirmed. 

(b) 

Imports from third countries 

(87)  Moreover,  CISA  claimed  that  it  is  not  sufficient  to  examine  the  average  price  of 
imports from other non-EU third countries, but that the exact nature of these products 
should also be considered. It is confirmed that a detailed analysis has been carried out 
in all instances where sufficiently detailed information on prices was made available 
by  importers.  Unfortunately,  trade  statistics  are  not  very  detailed  and,  given  the 
relatively low cooperation of importers in this investigation, little detailed information 
was available on prices on a product by product basis for imports from other countries. 
However,  no  substantiated  information  which  would  point  to  a  conclusion  different 
from  what  indicated  in  recitals  (142)  to  (145)  of  the  provisional  Regulation  was 
provided  by  any  party,  so  that  the  findings  contained  in  those  recitals  of  the 
provisional Regulation are hereby confirmed. 

(c)  Competition from other Community producers 

(88) 

In the absence of any specific comments on this point, recital (146) of the provisional 
Regulation is hereby confirmed. 

(d)  Cost of Production/Raw Material Costs 

(89)  CISA claimed that the Community industry had modified its product mix in order to 
concentrate  on  product  types  having  a  higher  selling  price,  in  order  to  contain  the 
effects  of  an  increase  in  cost  of  production.  This  would  show  that  the  Community 

EN 

21 

   EN 

 
industry  had  sufficient  means  to  reflect  any  increase  in  costs  by  increasing  selling 
prices, contrary to what was indicated in recital (149) of the provisional Regulation. 

(90)  There  is  no  doubt  that  the  Community  industry  has  over  time  tried  to  maximise  the 
profit by reflecting increases in costs by increasing selling prices. This is however not 
an ever ending process, and there is a moment when such adjustments are no longer 
possible given the competition existing in the market. In a market where similar goods 
are  sold  at  substantially  lower  prices,  the  margin  to  operate  such  mark  up  becomes 
smaller the higher the market share of such low priced goods is. The comments made 
by  CISA  therefore  do  not  contradict  the  findings  in  recitals  (147)  to  (149)  of  the 
provisional Regulation which are therefore confirmed. 

(e) 

Shrinking  of  the  Community  market  of  seamless  pipes  and  tubes  due  to 
economic downturn 

(91)  MOFCOM, CISA and a Chinese exporting producer claimed that the global economic 
downturn  is  at  the  basis  of  the  economic  problems  suffered  by  the  Community 
industry and concluded that it has broken the causal link between Chinese imports and 
any alleged injury or threat of injury. In this respect, it should be noted that CISA itself 
has recognised that the market consumption prevailing between 2005 and the IP was at 
exceptional levels and that the decrease in demand experienced after the IP may – to a 
very large extent – just be attributed to the market for this product coming back to its 
normal conditions. It is not clear therefore whether the global economic downturn can 
be considered as a cause of injury, since the information available only shows that the 
level of EC market consumption in the Post-IP period has come back to levels already 
considered as normal in the past. This would also suggest that it was the existence of 
exceptional levels of Community consumption during the period considered that had 
allowed  the  Community  industry  not  to  suffer  material  injury  despite  the  significant 
market share and the substantial undercutting of dumped Chinese imports. In any case, 
recital (150) of the provisional Regulation does not exclude that the general economic 
downturn may have played a role in the injurious situation of the Community industry 
after the IP. However, it cannot be argued that the Community industry has only been 
negatively affected by the effects of the general economic crisis and that the dumped 
imports  had  no  effect,  when  it  is  clear  that  the  latter  held  a  very  substantial  market 
share and significantly undercut the Community industry's prices. The claim that the 
economic downturn has broken the causal link referred to in recitals (128) to (135) of 
the  provisional  Regulation  is  therefore  rejected,  while  the  issue  that  the  changed 
economic  environment  in  comparison  to  the  IP  may  have  an  effect  on  the 
determination of the level of the measures is addressed in recital (104) below.  

(92)  The claims were, therefore, rejected and recital (150) of the provisional Regulation is 

hereby confirmed. 

(f)  Other factors 

(93)  CISA  commented  that  some  Community  producers  have  concluded  framework 
contracts  with  customers  at  pre-agreed  prices  so  that  for  them  prices  would  have 
remained  stable.  At  the  same  time  they  would  have  concluded  similar  fix-price 
agreements with suppliers of iron ore and other major inputs so that they would not be 
able to profit from the very sharp decrease in costs that these raw material have been 
having since immediately after the IP. 

(94) 

It is first of all noted that the fixed prices agreements with customers was a practice 
limited in number of contracts and, given the periods covered, it cannot be considered 

EN 

22 

   EN 

 
as  having  had  significant  effects.  This  conclusion  is  confirmed  by  the  fact  that 
Community  industry  prices  also  have  increased  substantially.  As  for  the  fixed  price 
agreements  concerning  major  raw  materials,  this  appears  to  be  a  world-wide  spread 
practice which should therefore not put the Community producers at either advantage 
or  disadvantage  in  respect  to  any  other  producer  of  the  like  product  in  the  world 
market. Therefore, this cannot be seen as a cause breaking the causal link either. The 
claims in recital (93) above are therefore rejected. 

3. 

(95) 

Conclusion on causation 

In  the  absence  of  any  further  comments  on  this  point,  recitals  (151)  to  (153)  of  the 
provisional Regulation are hereby confirmed. 

1. 

Interest of the Community industry 

G. 

COMMUNITY INTEREST 

(96)  The  complainant,  as  well  as  a  number  of  Community  producers  reiterated  that  the 
existence of anti-dumping measures was an essential element for them to continue as a 
going  concern,  given  the  injurious  dumping  practiced.  In  the  absence  of  any  further 
comment, recital (155) of the provisional Regulation is hereby confirmed. 

2. 

(97) 

Interest of the other Community producers 

In the absence of any specific comment on this point, recital (156) of the provisional 
Regulation is hereby confirmed. 

3. 

Interest of unrelated importers in the Community 

(98)  A user of the product concerned, which is also an importer, came forward to point out 
that  the  CN  codes  of  the  product  it  was  importing  had  not  been  mentioned  in  the 
Notice of initiation and it only became aware that the investigation was also covering 
these product types after the imposition of provisional measures. It claimed that it had 
to  pay  unforeseen  anti-dumping  duties  for  that  reason.  This  importer  was  informed 
that  the  Notice  of  initiation  contained  a  clear  description  of  the  product  under 
investigation and that the CN codes were mentioned therein for information only. The 
correct customs classification of the product concerned is indeed one of the elements 
under investigation and it is therefore perfectly possible that the CN codes mentioned 
in  the  provisional  Regulation  differ  to  a  certain  extent  from  those  indicated  in  the 
notice of initiation of the proceeding. 

(99) 

In the absence of any further comments on this point recital (157) of the provisional 
Regulation is hereby confirmed. 

4. 

Interest of users 

(100)  The user mentioned at recital (98) above also claimed that, should definitive measures 
be imposed on the product concerned, this would create serious problems of supply for 
its company, given the fact that EC producers are reluctant to supply it. This claim was 
examined and it was found that the problems encountered by this party in sourcing the 
product  from  Community  producers  related  to  past  periods  when,  in  the  context  of 
very high market demand, the supply of very limited quantities of such products was 
not considered as economically viable by certain Community producers. However, in 
periods of normal market demand this constraint should disappear, particularly when 
considering  the  fact  that  other  users  or  importers  of  the  same  types  of  products  may 
increase  the  level  of  Community  demand  for  such  products,  given  the  imposition  of 
measures.  On  the  basis  of  these  considerations,  and  also  of  the  fact  that  the  uses  in 

EN 

23 

   EN 

 
question  only  represented  a  very  limited  fraction  of  the  total  consumption  of  the 
product concerned, it is concluded that the availability of sources of supply should not 
be an issue for the product concerned. 

(101)  One  other  user,  who  is  buying  the  like  product  exclusively  from  the  Community 
industry,  reiterated  its  support  for  the  imposition  of  measures.  No  other  users  came 
forward  to  comment  on  the  provisional  findings.  In  the  absence  of  any  further 
comment, recital (158) of the provisional Regulation is hereby confirmed. 

5. 

Conclusion on Community interest 

(102)  In the absence of any specific comment, recital (159) of the provisional Regulation is 

definitively confirmed.  

1. 

Injury elimination level 

H. 

DEFINITIVE MEASURES 

(103)  The  complainant  and  a  number  of  Community  producers  part  of  the  Community 
industry  claimed  that  the  3  %  profit  margin provisionally  used  for  the  calculation  of 
the  injury  elimination  level  referred  to  in  recitals  (161)  to  (163)  of  the  provisional 
Regulation  was  excessively  low,  when  considering  that  this  is  a  capital  intensive 
industry  with  high  fixed  costs,  and  that  the  average  profit  margins  achieved  by  the 
Community industry during the period considered were well above 3 %. 

(104)  It  is  recognised  that  the  like  product  requires  a  highly  capital  intensive  production. 
However  it  is  considered  that  the  current  market  situation  is  not  such  as  to  allow  to 
make a clear assessment about the capacity utilisation rates for the near future and in 
particular for the years during which the measures will be in force, and this may have 
an  impact  on  the  determination  of  the  margin  of  profit  which  should  normally  be 
achieved  in  a  given  market  in  the  absence  of  dumping  practices.  Under  these 
circumstances,  and  considering  the  fact  that  there  is  always  the  possibility  for  the 
Community  industry  to  request  a  review  of  the  measures  in  case  of  a  change  in 
circumstances, it was concluded that the moderate 3 % profit margin established at the 
provisional stage and in a previous investigation concerning the same product should 
be  maintained.  It  is  however  noted  that,  should  the  market  circumstances  change 
significantly, such 3 % profit margin may need to be revised. 

(105)  The  methodology  for  the  calculation  of  the  injury  elimination  level  indicated  in 
recitals (164) and (165) of the provisional Regulation was applied, subject to the small 
adjustment referred to in recital (41) above. The countrywide injury elimination level 
was  calculated  as  the  weighted  average  of  the  injury  margins  found  for  the  most 
representative product types sold by an exporting producer not granted IT.  

(106)  The injury margins thus established were lower than the dumping margins found. 

2. 

Definitive measures 

(107)  In  view  of  the  conclusions  reached  with  regard  to  dumping,  injury,  causation  and 
Community interest, and in accordance with Article 9(4) of the basic Regulation, it is 
considered  that  a  definitive  anti-dumping  duty  should  be  imposed  on  imports  of  the 
product concerned originating in the PRC at the level of the lowest of the dumping and 
injury margins found, in accordance with the lesser duty rule, which is in all cases the 
injury margin. 

EN 

24 

   EN 

 
(108)  On the basis of the above, the definitive duties should be as follows:  

Exporting producer 

Anti-dumping duty 

Shandong Luxing Steel Pipe Co., Ltd 

Other cooperating companies 

All other companies 

17,7 % 

27,2 % 

39,2 % 

(109)  The  individual  company  anti-dumping  duty  rates  specified  in  this  Regulation  were 
established  on  the  basis  of  the  findings  of  the  present  investigation.  Therefore,  they 
reflect  the  situation  found  during  that  investigation  with  respect  to  these  companies. 
These  duty  rates  (as  opposed  to  the  country-wide  duty  applicable  to  ‘all  other 
companies’)  are  thus exclusively applicable to imports of products originating in  the 
country  concerned  and  produced  by  the  companies  and  thus  by  the  specific  legal 
entities mentioned. Imported products produced by any other company not specifically 
mentioned in the operative part of this Regulation with its name and address, including 
entities  related  to  those  specifically  mentioned,  cannot  benefit  from  these  rates  and 
shall be subject to the duty rate applicable to ‘all other companies’. 

(110)  Any claim requesting the application of an individual company anti-dumping duty rate 
(e.g. following a change in the name of the entity or following the setting up of new 
production or sales entities) should be addressed to the Commission7 forthwith with all 
relevant information, in particular any modification in the company’s activities linked 
to  production,  domestic  and  export  sales  associated  with,  for  example,  that  name 
change  or  that  change  in  the  production  and  sales  entities.  If  appropriate,  the 
Regulation  will  then  be  amended  accordingly  by  updating  the  list  of  companies 
benefiting from individual duty rates. 

(111)  All  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. 
They  were  also  granted  a  period  within  which  they  could  make  representations 
subsequent  to  this  disclosure.  The  comments  submitted  by  the  parties  were  duly 
considered and, where appropriate, the findings have been modified accordingly.  

(112)  In  order  to  ensure  equal  treatment  between  any  new  exporters  and  the  cooperating 
companies  not  included  in  the  sample,  mentioned  in  the  Annex  to  this  Regulation, 
provision  should  be  made  for  the  weighted  average  duty  imposed  on  the  latter 
companies to be applied to any new exporters which would otherwise be entitled to a 
review  pursuant  to  Article  11(4)  of  the  basic  Regulation  as  Article  11(4)  does  not 
apply where sampling has been used. 

3. 

Undertakings 

(113)  Following the disclosure of the essential facts and considerations on the basis of which 
it  was  intended  to  recommend  the  imposition  of  a  definitive  anti-dumping  duty,  a 
number of non-sampled exporting producers in the PRC indicated their wish to offer a 
price  undertaking  in  accordance  with  Article  8(1)  of  the  basic  Regulation.  However, 
despite  the  fact  that  all  necessary  conditions  were  explained,  no  formal  undertaking 

7 

European  Commission,  Directorate-General  for  Trade,  Directorate  H,  Office  N105  04/092,  1049 
Brussels, BELGIUM. 

EN 

25 

   EN 

 
                                                 
offer  was  submitted  within  the  time  limit  set  for  this  purpose  by  Article  8(2)  of  the 
basic  Regulation  and  no  extension  of  this  time  limit  was  requested.  Under  these 
circumstances, it is not necessary to further consider the issue of undertakings in the 
framework of this investigation. 

J. 

DEFINITIVE COLLECTION OF THE PROVISIONAL DUTY 

(114)  Since the investigation has shown that the threat of injury was imminent at the end of 
the IP as indicated in recital (126) of the provisional Regulation, taking into account 
the findings in recital (50) to (55) above which confirm a negative evolution of several 
injury  indicators  after  the  IP,  and  in  view  of  the  magnitude  of  the  dumping  margin 
found,  it  is  concluded  that  injury  would  have  occurred  in  the  absence  of  provisional 
measures.  It  is  therefore  considered  necessary  that  the  amounts  secured  by  way  of 
provisional anti-dumping duty imposed by the provisional  Regulation be definitively 
collected, 

HAS ADOPTED THIS REGULATION: 

Article 1 

1. 

A definitive anti-dumping duty is hereby imposed on imports of seamless pipes and 
tubes, of iron or steel, of circular cross-section, of an external diameter not exceeding 
406,4 mm with a Carbon Equivalent Value (CEV) not exceeding 0,86 according to 
the  International  Institute  of  Welding  (IIW)  formula  and  chemical  analysis8, 
currently falling within CN codes ex 7304 19 10, ex 7304 19 30, ex 7304 23 00, ex 
7304 29 10, ex 7304 29 30, ex 7304 31 20, ex 7304 31 80, ex 7304 39 10, ex 7304 39 
52, ex 7304 39 58, ex 7304 39 92, ex 7304 39 93, ex 7304 51 81, ex 7304 51 89, ex 
7304 59 10, ex 7304 59 92 and ex 7304 59 939 (TARIC codes 7304 19 10 20, 7304 
19 30 20, 7304 23 00 20, 7304 29 10 20, 7304 29 30 20, 7304 31 20 20, 7304 31 80 
30, 7304 39 10 10, 7304 39 52 20, 7304 39 58 30, 7304 39 92 30, 7304 39 93 20, 
7304 51 81 20, 7304 51 89 30, 7304 59 10 10, 7304 59 92 30 and 7304 59 93 20) and 
originating in the People's Republic of China. 

2. 

The  rate  of  the  definitive  anti-dumping  duty  applicable  to  the  net,  free-at-
Community-frontier price, before duty, of the products described in paragraph 1 and 
produced by the companies below shall be as follows: 

8 

9 

The  CEV  shall  be  determined  in  accordance  with  Technical  Report,  1967,  IIW  doc.  IX-555-67, 
published by the International Institute of Welding (IIW). 
As defined in Commission Regulation (EC) No 1031/2008 of 19 September 2008 amending Annex I to 
Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common 
Customs  Tariff  (OJ  L  291,  31.10.2008,  p.  1).  The  product  coverage  is  determined  in  combining  the 
product  description  in  Article  1(1)  and  the  product  description  of  the  corresponding  CN  codes  taken 
together. 

EN 

26 

   EN 

 
                                                 
Company 

Shandong Luxing Steel Pipe Co., Ltd, Qingzhou City, PRC 

Other cooperating companies listed in the Annex 

All other companies 

Anti-
Dumping 
duty (%) 

TARIC 
Additional 
Code 

17,7 

27,2 

39,2 

A949 

A950 

A999 

3. 

Unless  otherwise  specified,  the  provisions  in  force  concerning  customs  duties  shall 
apply. 

Article 2 

The  amounts  secured  by  way  of  provisional  anti-dumping  duty  pursuant  to  Commission 
Regulation (EC) No 289/2009 on imports of certain seamless pipes and tubes of iron or steel 
originating in the People's Republic of China shall be definitively collected at the rate of the 
provisional duty. 

Where  any  new  exporting  producer  in  the  People’s  Republic  of  China  provides  sufficient 
evidence to the Commission that: 

Article 3 

– 

– 

– 

it did not export to the Community the product described in Article 1(1) during 
the investigation period (1 July 2007 to 30 June 2008), 

it is not related to any of the exporters or producers in the People's Republic of 
China which are subject to the measures imposed by this Regulation, 

it  has  actually  exported  to  the  Community  the  product  concerned  after  the 
investigation period on which the measures are based, or it has entered into an 
irrevocable  contractual  obligation  to  export  a  significant  quantity  to  the 
Community,  

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  the  new  exporting 
producer  to  the  cooperating  companies  not  included  in  the  sample  and  thus  subject  to  the 
weighted average duty rate of 27,2 %.  

This  Regulation  shall  enter  into  force  on  the  day  following  that  of  its  publication  in  the 
Official Journal of the European Union. 

Article 4 

This Regulation shall be binding in its entirety and directly applicable in all Member States. 

EN 

27 

   EN 

 
 
Done at Brussels, […] 

For the Council 
The President 
[…] 

EN 

28 

   EN 

 
 
 
 
List of cooperating producers referred to in Article 1(2) under TARIC additional code A950 

ANNEX 

Company Name 

City  

Handan Precise Seamless Steel Pipes Co., Ltd. 

Handan  

Hengyang Valin MPM Co., Ltd. 

Hengyang Valin Steel Tube Co., Ltd. 

Hubei Xinyegang Steel Co., Ltd. 

Hengyang 

Hengyang 

Huangshi 

Jiangsu Huacheng Industry Group Co., Ltd. 

Zhangjiagang  

Jiangyin City Seamless Steel Tube Factory 

Jiangyin Metal Tube Making Factory  

Jiangyin 

Jiangyin 

Pangang Group Chengdu Iron & Steel Co., Ltd. 

Chengdu 

Shenyang Xinda Co., Ltd.  

Suzhou Seamless Steel Tube Works 

Tianjin Pipe (Group) Corporation (TPCO) 

Wuxi Dexin Steel Tube Co., Ltd. 

Wuxi Dongwu Pipe Industry Co., Ltd. 

Wuxi Seamless Oil Pipe Co., Ltd. 

Shenyang 

Suzhou 

Tianjin 

Wuxi 

Wuxi 

Wuxi 

Zhangjiagang City Yiyang Pipe Producing Co., Ltd.  

Zhangjiagang 

Zhangjiagang Yichen Steel Tube Co., Ltd. 

Zhangjiagang 

EN 

29 

   EN