Proposal for a Council Regulation extending the definitive anti-dumping duty imposed by Council Regulation (EC) No 1858/2005 on imports of steel ropes and cables originating, inter alia, in the People's Republic of China to imports of steel ropes and cables consigned from the Republic of Korea, whether declared as originating in the Republic of Korea or not, and terminating the investigation in respect of imports consigned from Malaysia
Date: 2010-05-10
Institutions: European Commission
Subjects: China, Malaysia, South Korea, anti-dumping duty, anti-dumping legislation, section

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EUROPEAN COMMISSION 

Brussels, 9.4.2010 
COM(2010)140 final 

2010/0078 (NLE) 

Proposal for a 

COUNCIL REGULATION 

extending the definitive anti-dumping duty imposed by Council Regulation (EC) No 
1858/2005 on imports of steel ropes and cables originating, inter alia, in the People's 
Republic of China to imports of steel ropes and cables consigned from the Republic of 
Korea, whether declared as originating in the Republic of Korea or not, and terminating 
the investigation in respect of imports consigned from Malaysia  

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EXPLANATORY MEMORANDUM 

Context of the proposal 

Grounds for and objectives of the proposal 

This  proposal  concerns  the  application  of  Council  Regulation  (EC)  No  1225/2009  of 
30 November 2009 on protection against dumped imports from countries not members 
of  the  European  Community  ('the  basic  Regulation')  in  the  investigation  of  possible 
circumvention of the anti-dumping measures imposed by Council Regulation (EC) No 
1858/2005 on imports of steel ropes and cables originating in the People's Republic of 
China by imports consigned from the Republic of Korea and Malaysia. 

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  and  in  particular  Article  13 
thereof. 

Existing provisions in the area of the proposal 

The  measures  currently  in  force  were  imposed  by  Council  Regulation  (EC)  No 
1858/2005  imposing  a  definitive  anti-dumping  duty  on  imports  of  steel  ropes  and 
cables originating, inter alia, in the People's Republic of China. 

Consistency with the other policies and objectives of the Union 

Not applicable. 

Consultation of interested parties and impact assessment 

Consultation of interested parties 

Interested parties concerned by the proceeding have 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. 

Legal elements of the proposal 

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Summary of the proposed action 

On  12  August  2009,  the  Commission  published  Regulation  (EC)  No  734/2009,  by 
which  it  initiated  an  investigation  concerning  the  possible  circumvention  of  anti-
dumping measures imposed by Council Regulation (EC) No 1858/2005 on imports of 
steel ropes and cables ('SWR') originating in the PRC by imports consigned from the 
Republic  of  Korea  and  Malaysia,  whether  declared  as  originating  in  the  Republic  of 
Korea  and  Malaysia  or  not.  The  initiation  followed  a  request  lodged  by  the  Liaison 
Committee of EU Wire Rope Industries claiming that measures are being circumvented 
by transhipment of products via the Republic of Korea and Malaysia.  

The  attached  proposal  for  a  Council  Regulation  is  based  on  the  findings  of  the 
investigation carried out. 

The investigation confirmed that transhipment of Chinese-origin SWR is taking place 
via  the  Republic  of  Korea  and  that  all  other  criteria  for  the  establishment  of 
circumvention  as  set  out  in  Article  13(1)  of  the  basic  Regulation  are  met.  No 
circumvention could be established as regards products consigned from Malaysia.  

It  is  therefore  proposed  to  extend  the  anti-dumping  measures  in  force  on  SWR 
originating in the PRC to imports of the same product consigned from the Republic of 
Korea.  The  duty  corresponds  to  the  country-wide  duty  on  imports  of  SWR  from  the 
PRC (60.4%). The duty shall be levied from the date of initiation of the investigation. 

Several  cooperating  producers  in  Korea  requested  exemption  from  the  possible 
extended measures. For the companies which cooperated fully and were found not to 
be circumventing the measures, it is proposed to grant exemptions.  

The  relevant  Council  Regulation  should  be  published  in  the  Official  Journal  of  the 
European Union no later than 11 May 2010. 

Legal basis 

Council  Regulation  (EC)  No  1225/2009  of  30  November  2009  on  protection  against 
dumped  imports  from  countries  not  members  of  the  European  Community  and  in 
particular Article 13 thereof.  

Subsidiarity principle 

The  proposal  falls  under  the  exclusive  competence  of  the  Union.  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  the  financial  and  administrative  burden  falling  upon  the  Union, 
national governments, regional and local authorities, economic operators and citizens is 

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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. 

Budgetary implication 

The proposal has no implication for the Union budget. 

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2010/0078 (NLE) 

Proposal for a 

COUNCIL REGULATION 

extending the definitive anti-dumping duty imposed by Council Regulation (EC) No 
1858/2005 on imports of steel ropes and cables originating, inter alia, in the People's 
Republic of China to imports of steel ropes and cables consigned from the Republic of 
Korea, whether declared as originating in the Republic of Korea or not, and terminating 
the investigation in respect of imports consigned from Malaysia  

THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union,  

Having regard to Council Regulation (EC) No 1225/2009 of 30 November 2009 on protection 
against dumped imports from countries not members of the European Community1 (the ‘basic 
Regulation’), and in particular Article 13 thereof, 

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

Whereas: 

1. 

PROCEDURE 

1.1. 

Existing measures and former investigations 

(1) 

(2) 

By Regulation (EC) No 1796/19992, (the ‘original Regulation’), the Council imposed 
definitive anti-dumping duties of 60,4% on imports of steel ropes and cables ('SWR') 
originating, inter alia, in the People’s Republic of China (the 'PRC' or 'China'). These 
measures will hereinafter be referred to as 'the original measures' and the investigation 
that led to the measures imposed by the original Regulation will be hereinafter referred 
to as 'the original investigation'. 

In  2004,  after  it  was  found  that  the  original  measures  were  circumvented  by  the 
transhipment  of  Chinese-origin  SWR  via  Morocco  in  accordance  with  Article  13  of 
the  basic  Regulation,  the  measures  were  extended  by  Council  Regulation  (EC)  No 
1886/20043 to imports of the same SWR consigned from Morocco. Similarly, after it 
was found the circumvention of the original measures on imports from Ukraine took 
place  via  Moldova  following  an  investigation  pursuant  to  Article  13  of  the  basic 

1 
2 
3 

OJ L 343, 22.12.2009, p. 51. 
OJ L 217, 17.8.1999, p. 1. 
OJ L 328, 30.10.2004, p. 1. 

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Regulation, the measures were extended by Council Regulation (EC) No 760/20044 to 
imports of the same steel ropes and cables consigned from Moldova. 

(3) 

By  Regulation  (EC)  No  1858/20055  the  Council,  following  an  expiry  review  (the 
'expiry review'), imposed, in accordance with Article 11(2) of the basic Regulation, a 
definitive anti-dumping duty on imports of SWR originating, inter alia, in the People’s 
Republic  of  China,  at  the  level  of  the  original  measures.  The  duty  thus  imposed 
remains in force and will hereinafter be referred to as 'the measures in force'. 

1.2. 

Request 

(4) 

(5) 

(6) 

(7) 

On 29 June 2009, the Commission received a request pursuant to Article 13(3) of the 
basic  Regulation  to  investigate  the  possible  circumvention  of  the  anti-dumping 
measures imposed on SWR originating in the People's Republic of China. The request 
was submitted by the Liaison Committee of the EU Wire Rope Industries (EWRIS) on 
behalf of the Union producers of steel ropes and cables (the ‘applicant’).  

The  request  alleged  that,  following  the  imposition  of  the  anti-dumping  measures,  a 
significant  change  in  the  pattern  of  trade  involving  exports  from  the  PRC  and  the 
Republic  of  Korea  and  Malaysia  to  the  Union  took  place,  for  which  there  was 
insufficient  due  cause  or  economic  justification  other  than  the  imposition  of  the 
measures  in  force.  This  change  in  the  pattern  of  trade  stemmed  allegedly  from  the 
transhipment of SWR originating in the PRC via the Republic of Korea and Malaysia. 

The  request  further  alleged  that  the  remedial  effects  of  the  measures  in  force  were 
being undermined both in terms of quantity and price. In addition, there was sufficient 
evidence that these increased imports from the Republic of Korea and Malaysia were 
made  at  prices  well  below  the  non-injurious  price  established  in  the  original 
investigation. 

Finally, the applicant alleged that the prices of SWR consigned from the Republic of 
Korea and Malaysia were dumped in relation to the normal value established for the 
like product during the original investigation. 

1.3. 

Initiation 

(8) 

Having  determined,  after  consulting  the  Advisory  Committee,  that  sufficient  prima 
facie evidence existed for the initiation of an investigation pursuant to Article 13 of the 
basic  Regulation,  the  Commission  initiated  an  investigation  by  Regulation  (EC)  No 
734/20096  (the  ‘initiating  Regulation’).  Pursuant  to  Articles  13(3)  and  14(5)  of  the 
basic  Regulation,  the  Commission,  by  the  initiating  Regulation,  also  directed  the 
customs authorities to register imports of SWR consigned from the Republic of Korea 
and Malaysia. 

1.4. 

Investigation 

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6 

OJ L 120, 24.4.2004, p.1. 
OJ L 299, 16.11.2005, p. 1.  
OJ L 208, 12.08.2009, p. 7. 

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(9) 

the 

investigation.  Questionnaires  were 

The Commission officially advised the authorities of the PRC, the Republic of Korea 
and  Malaysia,  the  producers/exporters  and  the  traders  in  those  countries,  ,  the 
importers in the Union known to be concerned and the applicant Union industry of the 
initiation  of 
the  known 
producers/exporters  in  the  PRC,  the  Republic  of  Korea  and  Malaysia  known  to  the 
Commission  from the request or through the Missions of the  Republic of Korea and 
Malaysia  to  the  European  Union  or  which  made  themselves  known  within  the 
deadlines  specified  in  Article  3(1)  of  the  initiating  Regulation.  Questionnaires  were 
also sent to traders in the Republic of Korea and Malaysia and to the importers in the 
Union  named  in  the  request.  Interested  parties  were  given  the  opportunity  to  make 
their views known in writing and to request a hearing within the time limit set in the 
initiating Regulation. 

sent 

to 

(10)  Fifteen  producers/exporters  and  two  traders  in  the  Republic  of  Korea,  two 
producers/exporters  in  Malaysia,  five  producers/exporters  in  China,  two  related 
importers,  ten  unrelated  importers  in  the  Union  and  the  European  Wire  Rope 
Importers Association made themselves known. Several other companies claimed that 
they are not involved in the production or export of the product under investigation.  

(11)  The following companies submitted replies to the questionnaires and verification visits 

were subsequently carried out at their premises:  

Producers/exporters in the Republic of Korea: 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Bosung Wire Rope Co, Ltd., Kimhae-Si, 

Chung Woo Rope Co., Ltd., Busan, 

CS Co., Ltd, Yangsan-City, 

Cosmo Wire Ltd., Ulsan, 

Dae Heung Industrial Co., Ltd., Haman – Gun, 

DSR  Wire  Corp.,  Suncheon-City  and  its  related  company  DSR  Corp., 
Busan, 

Goodwire Mfg., Co., Ltd., Yangsan-city,  

Kiswire Ltd., Seoul, 

Line Metal Co., Ltd., Changnyoung-Gun,  

–  Manho Rope & Wire Ltd., Busan, 

– 

– 

– 

Shin Han Rope Co.,Ltd., Incheon, 

Ssang Yong Cable Mfg. Co., Ltd, Busan, 

Young Heung Iron & Steel Co., Changwon City 

Trader in the Republic of Korea: 

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– 

Trion Co Ltd., Busan 

Producers/exporters in Malaysia: 

– 

– 

Kiswire Sdn. Bhd., Johor Bahru, 

Southern Wire Industries (M) Sdn. Bhd., Shah Alam, Selangor  

Producers/exporters in the PRC: 

– 

– 

– 

Qingdao DSR, Qingdao,  

Kiswire Qingdao Ltd., Qingdao,  

Young Heung (TAICANG) Steel Wire Rope Co., Ltd., Tai Cang City  

Related importers: 

– 

– 

Kiswire Europe, the Netherlands, 

Verope AG, Switzerland. 

1.5. 

Investigation period 

(12)  The  investigation  period  covered  the  period  from  1  July  2008  to  30  June  2009  (the 
‘IP’). Data was collected for the period from 1999 up to the end of the IP to investigate 
the alleged change in the pattern of trade. 

2. 

RESULTS OF THE INVESTIGATION 

2.1. 

General considerations 

(13) 

In  accordance  with  Article  13(1)  of  the  basic  Regulation,  the  assessment  of  the 
existence of circumvention was made by analysing successively whether there was a 
change  in  the  pattern  of  trade  between  third  countries  and  the  Union,  if  this  change 
stemmed from a practice, process or work for which there was insufficient due cause 
or economic justification other than the imposition of the duty, if there was evidence 
of injury or that the remedial effects of the duty were being undermined in terms of the 
prices  and/or  quantities  of  the  like  product,  and  whether  there  was  evidence  of 
dumping in relation to the normal values previously established for the like product, if 
necessary in accordance with the provisions of Article 2 of the basic Regulation. 

2.2. 

Product concerned and the like product 

(14)  The  product  concerned  is,  as  defined  in  the  original  investigation,  steel  ropes  and 
cables, including locked coil ropes, excluding ropes and cables of stainless steel, with 
a maximum cross-sectional dimension exceeding 3 mm (in industry terminology often 
referred  to  as  SWR),  originating  in  the  People's  Republic  of  China,  currently  falling 
within CN codes ex 7312 10 81, ex 7312 10 83, ex 7312 10 85, ex 7312 10 89 and ex 
7312 10 98 ('the product concerned'). 

(15)  The product under investigation is steel ropes and cables including locked coil ropes, 
excluding  ropes  and  cables  of  stainless  steel,  with  a  maximum  cross-sectional 

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dimension  exceeding  3  mm,  consigned  from  the  Republic  of  Korea  and  Malaysia, 
whether  declared  as  originating  in  the  Republic  of  Korea  and  Malaysia  or  not  ('  the 
product  under  investigation'),  currently  falling  within  the  same  CN  codes  as  the 
product concerned. 

(16)  The investigation showed that the SWR exported to the Union from the PRC and those 
consigned from the Republic of Korea and Malaysia to the Union have the same basic 
physical and technical characteristics and have the same uses, and are therefore to be 
considered as like products within the meaning of Article 1(4) of the basic Regulation. 

2.3. 

Degree of co-operation and determination of the trade volumes  

(17)  As stated above in recital (11), fourteen exporters/producers in the Republic of Korea, 
one Korean trader, two exporting producers in Malaysia and three exporting producers 
in China co-operated by submitting questionnaire replies.  

Republic of Korea 

(18)  After  the  submission  of  its  questionnaire  reply,  one  Korean  company  notified  the 

Commission that it went bankrupt and therefore it withdrew its cooperation.  

(19) 

In the case of another Korean company the application of Article 18(1) was found to 
be warranted for the reasons explained below in recital (47).  

(20)  The cooperating Korean exporting producers covered 81% of the total Korean exports 
to the Union in the IP as reported in COMEXT. Therefore, even though cooperation 
was  high,  the  cooperating  producers/exporters  did  not  completely  cover  the  overall 
export volume of SWR from the Republic of Korea. The overall export volumes were 
thus based on COMEXT. 

Malaysia 

(21)  There  are  two  known  producers  in  Malaysia.  The  total  export  quantities  of  the  two 
cooperating companies in Malaysia exceeded the import volume of the product under 
investigation  recorded  in  COMEXT.  Therefore  the  exporting  producers  were 
considered to be reflecting the total exports of SWR from Malaysia to the Union. 

(22)  The applicant claimed that COMEXT data were unreliable and therefore total export 
volumes from Malaysia to the European Union should not be determined on this basis. 
However, during the investigation, import data were counter checked with Malaysian 
official  statistics  and  with  the  verified  questionnaire  replies.  This  analysis  did  not 
reveal  that  actual  exports  from  Malaysia  exceeded  the  exports  reported  by  the  co-
operating Malaysian companies. The applicant's argument had therefore to be rejected. 

People's Republic of China 

(23)  There was  a low level of co-operation  by  producers/exporters in the PRC, with only 
three  exporters/producers  submitting  a  questionnaire  reply.  Moreover,  none  of  these 
companies  exported  the  product  concerned  to  the  Union  and  only  in  very  minor 
quantities to Malaysia. The exports of the cooperating companies covered 41% of the 
total  Chinese  exports  to  the  Republic  of  Korea.  Therefore,  on  the  basis  of  the 

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information  submitted  by  the  co-operating  parties  no  reasonable  determination  could 
be made as to export volumes of SWR from the PRC.  

(24)  Given the above, findings in respect of imports of SWR into the Union and exports of 
SWR from the PRC to the Republic of Korea and Malaysia had to be made partially 
on the basis of facts available in accordance with Article 18 of the basic Regulation. 
COMEXT  data  was  used  to  determine  overall  import  volumes  from  the  PRC  to  the 
Union.  Chinese,  Korean  and  Malaysian  national  statistics  were  used  for  the 
determination of the overall imports to the Republic of Korea and Malaysia from the 
PRC.  Data  were  cross-checked  among  the  different statistical sources and confirmed 
by other statistical databases such as the Global Trade Atlas, China Export Database 
and  the  data  provided  by  the  customs  authorities  of  the  Republic  of  Korea  and 
Malaysia. 

(25)  The  import  volume  recorded  in  Korean,  Malaysian  and  Chinese  statistics  covered  a 
larger  product  group  than  the  product  concerned  or  the  product  under  investigation. 
Therefore, the statistics were adjusted accordingly based on the findings of the present 
investigation. 

2.4. 

Change in the pattern of trade 

Imports of SWR into the Union 

(26) 

Imports of SWR from China to the Union had first dropped close to zero subsequent to 
the  imposition  of  the  measures  in  1999.  After  a  gradual  increase  between  2003  and 
2006 – with imports peaking in the latter year at the level of 8.656 tonnes – the trend 
has reversed and imported amounts have fallen again by more than 40% between 2006 
and the IP.  

(27)  On  the  other  hand,  total  imports  of  Korean  SWR  to  the  Union  have  increased 
significantly  between  1999  and  2008  from  approximately  11.123  tonnes  to  48.214 
tonnes.  The  yearly  increase  in  absolute  terms  was  the  most  significant  in  the  years 
2002 and 2003 and more recently in 2006 and 2007.  

(28)  Based  on  information  in  the  complaint  and  that  provided  by  the  Mission  of  the 
Republic  of  Korea  to  the  European  Union,  the  present  investigation  is  considered  to 
have  covered  the  vast  majority,  if  not  all,  of  the  genuine  producers  of  the  product 
under  investigation  in  Korea.  Therefore  it  was  considered  that  the  exports  by  non-
cooperating Korean companies to the Union, which represented approximately 19% of 
the total exports in terms of quantity from the Republic of Korea, are, apart from the 
producers mentioned in recitals (18) and (47), mainly exported by traders. 

(29)  These  companies  have  visibly  increased  their  exports  to  the  EU  in  2006  and  2007. 
Exports  in  these  years  were  about  20%  higher  than  in  2005,  the  first  year  for  which 
data  at  this  level  is  available.  Exports  of  the  non-cooperating  companies  have  been 
diminishing starting from 2008 which is to be seen in light of the investigation of the 
Korean authorities in this period as described in recital (52). 

(30)  As  far  as  Malaysia  is  concerned,  both  COMEXT  data  and  the  total  export  of  the 
cooperating companies show that exports from Malaysia to the Union have also been 

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continuously increasing in the past. The increase was the most significant and steady 
between 2005 and the IP when Malaysian exports to the Union doubled. 

(31)  Table 1 shows import quantities of SWR from the above-mentioned countries into the 

Union since the imposition of the measures in 1999 until the IP: 

Table  1:  Evolution  of  imports  of  SWR  to  the  Union  since  the  imposition  of  the 
measures  

Import volumes given in 
tonnes. 

PRC 
Share of total imports  
Republic of Korea  

Share of total imports 
Malaysia 
Share of total imports 

1999 

2000 

2001 

2002 

2003 

2004 

N/A 
- 

414
1%

283
1%

394
1%

913 
2% 

2.809 
5% 

11.122 
- 
2.989 
- 

12.486 
29%
2.366
5%

13.280 
32%
4.171
10%

16.223 
37%
3.371
8%

22.302 
47% 
4.836 
10% 

31.862 
52% 
4.426 
7% 

Import volumes given in 
tonnes. 

PRC 
Share of total imports  
Republic of Korea  
Share of total imports 
Korean non-
cooperating 
companies 
Index (2005=100) 
Malaysia 
Share of total imports 
Malaysian cooperating 
companies (index, 
2006=100) 

2005 

2006 

2007 

2008 

IP 

4.945 
7% 
34.536 
50% 

8.656
11%
39.128
50%

11.577 
100 
5.123 
7% 
- 

14.042
121
7.449
10%
100

6.219
7%
45.783
55%

14.160
122
8.142
10%
102

6.795
7%
48.213
53%

10.287
89
9.685
11%
148

4.987 
6% 
43.185 
50% 

8.391 
72 
10.116 
12% 
144 

Source: COMEXT, Korean statistics (KITA)  

(32)  Looking at the pattern of the above three trade flows, it can be observed that especially 
since  2005,  Korean  exporters  and  partly  Malaysian  exporters  have  significantly 
outsold and to some extent replaced Chinese exporters on the Union market in terms 
of volume.  

(33)  Due to the global economic slowdown which coincides with the IP, traded volumes of 
SWR  have  decreased  or  the  increase  has  slowed  down  between  all  countries 
concerned. The decrease was however the most significant in the case of imports from 
the PRC to the Union (-27%).  

Chinese exports to the Republic of Korea and Malaysia 

(34)  A dramatic increase of exports of steel wire ropes and cables (all diameters) can also 
be  observed  from  China  to  the  Republic  of  Korea  within  the  same  period:  from  a 
relatively insignificant amount in 1999 (2.519 tonnes) they increased to 78.822 tonnes 
in  2008.  The  increase  was  most  significant  between  2005  and  2008  when  imports 

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quadrupled.  In  recent  years  China  was  the  largest  exporter  of  SWR  to  Korea 
representing 89% of the total imports of SWR in 2008. The estimated import for the 
product concerned only (products with a diameter above 3 mm), in 2008, was 58.885 
tons. 

(35)  Looking at imports of the non-cooperating Korean companies only, the same dramatic 
increase can be observed, i.e. imports from China by these companies have quadrupled 
by  2007  and  2008.  Although  imports  have  started  to  decrease  afterwards,  they 
remained  well  above  the  level  of  imports  in  2005  continuing  to  represent  very 
significant amounts. 

Table  2:  Import  of  Chinese  products into the Republic of Korea between 1999 and 
the IP 

1999  2000  2001  2002 

2003 

2004 

2005 

2006 

2007 

2008 

IP 

Import 
(tonnes,  all 
diameters) 

Yearly 
change (%) 

Imports  by 
Korean 
non-
cooperating 
companies 
(tonnes, 
product 
concerned 
only) 

2.519  6.764  6.044  7.740 11.421 14.120 19.933 36.531  69.620  78.822 66.099

169 

-11 

28 

48 

24 

41 

83 

91 

13 

-16 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

7.166 18.053  33.907  29.717 22.004

Index 
(2005=100)  N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

100

252 

473 

415

307

Source: Korean statistics (KITA), data provided by the Korean Customs Services, verified information 
provided by the cooperating producers  

(36)  To  establish  the  trend  of  the  China  to  Malaysia  trade  flow  of  SWR,  both  Malaysian 
and  Chinese  statistics  were  considered.  Both  of  these  data  are  only  available  at  a 
higher  product  group  level  than  the  product  concerned.  Furthermore  they  showed 
considerable  differences.  Therefore,  no  reliable  data  could  be  established  in  this 
regard. 

(37)  The applicant claimed that the fact that no reliable data could be established would not 
be sufficient to conclude that no circumvention took place. As outlined in recitals (38) 
and  (55),  the  evidence  available  in  the  current  investigation,  i.e.  in  particular 
production volume of the cooperating Malaysian exporting producers as well as their 
export sales to the European Union showed that exports of SWR from Malaysia were 
of  genuine  Malaysian  origin  and  therefore  did  not  constitute  circumvention.  In  this 
case, it was therefore irrelevant whether there were imports from China to Malaysia or 
not. The applicant's claim was therefore rejected. 

Production volumes in the Republic of Korea and Malaysia 

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(38)  The evolution of the total production volume of cooperating producers in the Republic 
of Korea had remained stable between 2006 and the IP. Malaysian producers however 
have increased their output during the same period considerably. 

Table 3: Production of SWR of the cooperating companies in the Republic of Korea 
and Malaysia 

Production volumes given in 
tonnes. 

2006 

2007 

2008 

IP 

Republic of Korea  

152.657

159.584

160.113

142.413 

Index 

Malaysia (indexed) 

100

100

105

164

105

171

93 

157 

Source: Verified information provided by the cooperating producers  

2.5. 

Conclusion on the change in the pattern of trade 

(39)  The  overall  decrease  of  Chinese  exports  to  the  Union  as  from  2006  and  the  parallel 
increase of exports from the Republic of Korea and Malaysia and of exports from the 
PRC  to  the  Republic  of  Korea  after  the  imposition  of  the  original  measures  and  in 
particular  until  2008  constituted  a  change  in  the  pattern  of  trade  between  the  above 
mentioned countries on the one hand and the Union on the other hand. In the case of 
the  Republic  of  Korea,  this  conclusion  could  be  reached  both  globally  and,  for  the 
period between 2005 and 2007, also separately for the non-cooperating companies.  

(40)  Comments were received claiming that the increase of exports of Korean SWR to the 
Union  was  stable  over  the  years  without  any  sudden  increase;  such  an  increase 
allegedly  being  a  precondition  to  establishing  a  change  in  the  pattern  of  trade. 
Furthermore, it was claimed that the increase should be regarded rather as the natural 
development of the Korean SWR industry. 

(41)  Firstly, in accordance with Article 13 of the basic Regulation, a change in the pattern 
in trade is not exclusively defined as a sudden increase of imports of a country under 
investigation. Secondly, the investigation has shown that while Korean exports to the 
Union  in  the  years  2006  and  2007  increased  substantially,  the  output  by  Korean 
producers  was  stable  in  these  years.  It  could  thus  not  be  concluded  that  the 
development of the Korean export volumes was solely due to the natural development 
of  the  Korean  SWR  industry.  Finally,  for  the  most  part  opposite  trends  between  the 
China to Union trade flows and China to Korea and Korea to Union trade flows since 
2006  clearly  showed  a  change  in  the  pattern  of  trade  between  the  Union  and  third 
countries. These arguments therefore had to be rejected.  

2.6. 

Nature of the circumvention practice 

(42)  Article  13(1)  requires  that  the  change  in  the  pattern  of  trade  stems  from  a  practice, 
process  or  work  for  which  there  is  insufficient  due  cause  or  economic  justification 
other than the imposition of the duty. The practice, process or work includes, inter alia, 
the  consignment  of  the  product  subject  to  measures  via  third  countries  and  the 
assembly of parts by an assembly operation in the Union or a third country. For this 

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purpose  the  existence  of  assembly  operations  was  determined  in  accordance  with 
Article 13(2) of the basic Regulation. 

The Republic of Korea 

Transhipment 

(43)  The  global  analysis  of  the  final  destinations  of  steel  ropes  and  cables  produced  or 
imported  to  and  from  Korea  by  the  cooperating  and  non-cooperating  companies  – 
including imports to and from countries other than the PRC and the Union - showed 
that a certain amount of exports from Korea to the Union were Chinese-origin imports 
into  Korea,  because  these  imports  were  not  sourced  from  other  third  countries  or 
produced by the domestic producers in Korea.  

(44)  Moreover, the comparison of the total Korean export of SWR - as recorded in Korean 
statistics  -  and  the  verified  information  of  the  cooperating  exporting  producers 
concerning  their  production  showed  that  production  destined  for  export  by  Korean 
producers (118.856 tonnes) was significantly lower than the total exports from Korea 
(156.440  tonnes)  in  the  IP.  Given  the  high  cooperation  of  Korean  companies  in  this 
investigation, this difference cannot be explained by producers that may not have been 
cooperating in the investigation.  

(45)  The  investigation  also  revealed  that  some  importers  in  the  Union  sourced  Chinese 
origin SWR from Korean exporters not co-operating during the present investigation. 
This information was counter-checked with Korean trade databases which showed that 
at  least  some  of  the  SWR  exported  by  these  non-cooperating  companies  was  indeed 
sourced in China. 

(46)  As  for  the  cooperating  companies  it  could  be  established  that  none  of  them 
transhipped the product concerned via the Republic of Korea in the IP. Some of them 
imported  SWR  from  the  PRC,  but  these  were  found  to  be  exclusively  sold  on  the 
domestic and other export markets.  

(47) 

In  the  case  of  one  company  it  was  found  that  it  submitted  false  information  in  its 
questionnaire  reply.  Furthermore,  during  the  verification  visit  access  to  information 
was  partially  denied.  Therefore  in  accordance  with  Article  18(1)  of  the  basic 
Regulation,  findings  with  regard  to  this  company  were  based  on  facts  available.  In 
accordance with Article 18(4), the company was informed of the intention to disregard 
the  information  submitted  by  it  and  was  granted  a  time-limit  to  provide  further 
explanations.  

(48)  Subsequent to disclosure, the company admitted that it had circumvented the measures 
in the past by falsifying the origin of products purchased from the PRC. On the other 
hand  the  company  claimed  that  it  submitted  sufficient  information  regarding  the 
production,  sales  and  purchases  during  the  IP  which  was  verified  on-spot.  It  further 
argued  that  this  should  be  sufficient  to  determine  that  it  had  not  circumvented  the 
measures in force in the IP. 

(49)  However,  in  view  of  the  fact  that  circumvention  by  the  company  admitted  to  have 
engaged in circumvention practices and furthermore tried to mislead the investigation, 
it is considered appropriate to disregard the entirety of the company's submission and 

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not to exempt this company from the extended measures, as further outlined below in 
recital (77). .  

(50)  As  explained  in  recital  (18),  one  company  notified  the  Commission  that  it  went 
bankrupt  and  withdrew  its  cooperation.  As  above,  findings  with  regard  to  this 
company had to be based on the facts available within the meaning of Article 18(1) of 
the basic Regulation.  

(51)  On  the  basis  of  these  facts  it  was  concluded  that  although  none  of  the  co-operating 
Korean  producers  were  found  to  be  involved,  transhipment  was  taking  place  during 
the IP and the preceding years. This is also confirmed by the findings with regard to 
the change of the pattern in trade as described above in recitals (39). 

(52) 

It has to be noted that in 2007 OLAF started an investigation into transhipment of the 
same  product  through  Korea.  The  Korean  authorities  are  known  to  have  carried  out 
investigations  into  alleged  circumvention  practices  at  the  same  time  and  concluded 
that  several  companies,  mainly  traders,  committed  fraud  by  falsifying  the  origin  of 
SWR imported from the PRC to Korea when re-exporting the product. 

(53)  Therefore the existence of transhipment of Chinese-origin products via the Republic of 

Korea was confirmed. 

Assembly operation  

(54)  The  sources  of  raw  materials  and  the  cost  of  production  was  analysed  for  each 
cooperating  company  in  order  to  establish  whether  any  assembly  operation  in  the 
Republic  of Korea  is  circumventing the measures according to the criteria of Article 
13(2). In all cases the Chinese-origin raw material (wire rod or semi finished product) 
did  not  constitute  60%  or  more  of  the  total  value  of  the  parts  of  the  final  product. 
Therefore it was not necessary to examine whether the 25% threshold of value added 
was reached or not. 

Malaysia 

Transhipment 

(55)  The  investigation  established  that  none  of  the  cooperating  producers  in  Malaysia 

imported the product concerned from China during the IP.  

(56)  Based on the share of the exports by the cooperating companies to the Union within 
the  total  exports  from  Malaysia  to  the  Union  as  recorded  in  COMEXT,  it  could  be 
concluded  that  the  increase  of  imports  from  Malaysia  shown  in  the  statistics  can  be 
explained fully by the increase of the cooperating companies' exports. This conclusion 
is reinforced by the increase of the total production volume of the genuine Malaysian 
producers during the same period as described in recital (38). 

(57)  The  applicant  questioned  this  finding  without  providing  any  further  reason  or 

evidence. This argument had therefore to be rejected. 

Assembly operation  

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(58)  The  sources  of  raw  materials  and  the  cost  of  production  was  analysed  for  each 
cooperating  company  to  establish  whether  any  assembly  operation  in  Malaysia  is 
circumventing the measures according to the criteria of Article 13(2). In all cases the 
Chinese-origin raw material (wire rod or semi finished product) did not constitute 60% 
or  more  of  the  total  value  of  the  parts  of  the  final  product.  Therefore  it  was  not 
necessary to examine whether the 25% threshold of value added was reached or not. 

(59) 

It  could  therefore  be  concluded  that  the  change  in  the  pattern  of  trade  observed 
between the PRC, Malaysia and the Union did not stem from circumvention practices 
in  Malaysia.  Consequently,  the  investigation  concerning  imports  of  SWR  consigned 
from Malaysia should be terminated. 

2.7. 

Insufficient due cause or economic justification other than the imposition of the 
anti-dumping duty (Republic of Korea) 

(60)  The investigation did not bring to light any other due cause or economic justification 
for  the  transhipment  than  the  avoidance  of  the  anti-dumping  duty  in  force  on  SWR 
originating in China. 

2.8. 

Undermining of the remedial effect of the anti-dumping duty (non-cooperating 
Korean companies) 

(61)  To  assess  whether  the  imported  products  had,  in  terms  of  quantities  and  prices, 
undermined  the  remedial  effects  of  the  measures  in  force  on  imports  of  SWR  from 
China, COMEXT data  was  used  as the best data available concerning quantities and 
prices  of  exports  by  non-cooperating  companies.  The  prices  so  determined  were 
compared to the injury elimination level established for Union producers in the expiry 
review. 

(62)  The  increase  of  imports  from  Korea  was  considered  to  be  significant  in  terms  of 
quantities bearing in mind the size of  the market as determined in the expiry review 
(recital  99  of  Regulation  (EC)  No  1858/2005).  The  estimated  Union  consumption  in 
the  current  investigation  period  gives  a  similar  indication  about  the  significance  of 
these  imports.  The  comparison  of  the  injury  elimination  level  as  established  in  the 
expiry review and the weighted average export price showed significant underselling. 
It  was  therefore  concluded  that  the  measures  are  being  undermined  in  terms  of 
quantities and prices. 

2.9. 

Evidence of dumping (non-cooperating Korean companies) 

(63)  Finally,  in  accordance  with  Article  13(1)  and  (2)  of  the  basic  Regulation  it  was 
examined  whether  there  was  evidence  of  dumping  in  relation  to  the  normal  value 
previously established for the like or similar products. 

(64) 

In the expiry review the normal value was established on the basis of prices in Turkey, 
which in that investigation was found to be an appropriate market economy analogue 
country for the PRC. In the present investigation, it was established that the price of 
wire rod, the main input used in the production of SWR increased significantly since 
the expiry review. Therefore, and considering that the price developments of the raw 
materials were reflected in the export price during the IP, it was deemed appropriate to 

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up date the normal value as previously established by the development of raw material 
prices.  

(65)  A significant part of Korean exports were found to be genuine Korean production. For 
this  reason,  for  establishing  the  export  prices  from  the  Republic  of  Korea  which  are 
affected 
non-cooperating 
the 
producers/exporters  was  considered  which  was  based  on  best  facts  available,  i.e.  on 
the average export price of SWR during the IP as reported in COMEXT.  

circumvention, 

exports 

only 

the 

by 

of 

(66)  For the purpose of a fair comparison between the normal value and the export price, 
due  allowance,  in  the  form  of  adjustments,  was  made  for  differences  which  affect 
prices  and  price  comparability  in  accordance  with  Article  2(10)  of  the  basic 
Regulation.  Accordingly,  adjustments  were  made  for  differences  in  indirect  taxes, 
transport  and  insurance  costs  based  on  the  average  costs  of  the  cooperating  Korean 
producers/exporters in the IP.  

(67) 

In  accordance  with  Articles  2(11)  and  2(12)  of  the  basic  Regulation,  dumping  was 
calculated  by  comparing  the  weighted  average  normal  value  as  established  in  the 
expiry  review  and  the  weighted  average  export  prices  during  this  investigation’s  IP, 
expressed as a percentage of the CIF price at the Union frontier duty unpaid. 

(68)  The  comparison  of  the  weighted  average  normal  value  and  the  weighted  average 

export prices so established showed dumping. 

3. 

MEASURES 

(69)  Given the above,  it  was concluded that  the  definitive  anti-dumping duty imposed  on 
imports  of  SWR  originating  in  China  was  circumvented  by  transhipment  via  the 
Republic of Korea pursuant to Article 13(1) of the basic Regulation. 

(70) 

In  accordance  with  the  first  sentence  of  Article  13(1)  of  the  basic  Regulation,  the 
measures in force on imports of the product concerned originating in the PRC, should 
be  extended  to  imports  of  the  same  product  consigned  from  the  Republic  of  Korea, 
whether declared as originating in the Republic of Korea or not. 

(71)  The measures to be extended should be the ones established in Article 1 paragraph 2 
of Regulation (EC) No 1858/2005, which are a definitive anti-dumping duty of 60,4% 
applicable to the CIF net, free-at-Union-frontier price, before customs duty. 

(72) 

In accordance with Articles 13(3) and 14(5) of the basic Regulation, which provides 
that  any  extended  measure  should  apply  to  imports  which  entered  the  Union  under 
registration imposed by the initiating Regulation, duties should be collected on those 
registered imports of SWR consigned from Korea. 

4. 

TERMINATION OF THE INVESTIGATION AGAINST MALAYSIA  

(73) 

In view of the findings regarding Malaysia, the investigation concerning the possible 
circumvention  of  anti-dumping  measures  by  imports  of  SWR  consigned  from 
Malaysia should be terminated and the registration of imports of SWR consigned from 
Malaysia introduced by the initiation Regulation should be discontinued. 

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(74)  The applicant  contested the proposal to terminate the investigation  against Malaysia. 
Having  already  addressed  all  its  arguments  above,  there  was  no  other  reason  to 
reconsider the proposal. 

5. 

REQUESTS FOR EXEMPTION 

(75)  The  fourteen  companies  in  the  Republic  of  Korea  submitting  a  questionnaire  reply 
requested  an  exemption  from  the  possible  extended  measures  in  accordance  with 
Article 13(4) of the basic Regulation. 

(76)  As explained in recital (18), one of these companies subsequently ceased co-operation. 
Its request for exemption in accordance with Article 13(4) had therefore to be rejected.  

(77)  Another  company  as  outlined  in  recital  (47)  submitted  false  information  and  denied 
access to information requested. Its request for exemption in accordance with Article 
13(4) could therefore not be granted. 

(78)  A third company in the Republic of Korea did not export the product either during the 
IP  or  after  that  period  and  no  conclusions  could  be  drawn  as  to  the  nature  of  its 
operations. Therefore, an exemption to this company could not be granted. However, 
should  it  appear,  after  extension  of  the  anti-dumping  measures  in  force,  that  the 
conditions  in  Article  11(4)  and  13(4)  of  the  basic  Regulation  are  fulfilled;  the 
company’s situation may be reviewed upon request. 

(79)  The company has objected and reiterated its request for an exemption. However, it did 
not  come  forward  with  new  information  and  evidence  that  could  have  altered  the 
above decision. Therefore, its request could not be accepted. 

(80)  None  of  the  other  cooperating  companies  in  the  Republic  of  Korea  were  found 
circumventing  the  measures.  Furthermore,  none  of  the  companies  requesting 
exemption are related to companies engaged in circumvention practices. In particular, 
it is noted that four of the producers concerned are related to PRC companies that are 
subject to the original measures. However, there is no evidence that such relationship 
was established or used to circumvent the measures in place on imports originating in 
China.  Exemptions  should  thus  be  granted  to  all  other  cooperating  companies  not 
mentioned in recitals (76) to (78). 

(81)  It  is  considered  that  special  measures  are  needed  in  this  case  in  order  to  ensure  the 
proper application of such exemptions. These special measures are the requirement of 
the  presentation  to  the  Customs  authorities  of  the  Member  States  of  a  valid 
commercial invoice, which shall conform to the requirements set out in the Annex to 
this Regulation. Imports not accompanied by such an invoice shall be made subject to 
the  extended  anti-dumping  duty  applicable  to  all  the  companies  in  the  Republic  of 
Korea that are not exempted. 

(82)  Other  exporters  concerned  which  were  not  contacted  by  the  Commission  in  the 
framework  of  this  proceeding  and  which  intend  to  lodge  a  request  for  an  exemption 
from the extended anti-dumping duty pursuant to Article 13(4) of the basic Regulation 
will  be  required  to  complete  a  questionnaire  in  order  to  enable  the  Commission  to 
determine whether an exemption may be warranted. The Commission would normally 

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also carry out an on-spot verification visit. The request would have to be addressed to 
the Commission with all relevant information. 

(83)  Where  an  exemption  is  warranted,  the  Commission  will,  after  consultation  of  the 
Advisory  Committee,  propose  the  amendment  of  this  Regulation  accordingly. 
Subsequently, any exemption granted will be monitored to ensure compliance with the 
conditions set therein. 

6. 

DISCLOSURE 

(84)  All interested parties were informed of the essential facts and considerations leading to 
the above conclusions and were invited to comment. The oral and written comments 
submitted by the parties were considered. None of the arguments presented gave rise 
to a modification of the definitive findings.  

HAS ADOPTED THIS REGULATION: 

Article 1 

1. The definitive anti-dumping duty imposed by Regulation (EC) No 1858/2005 on imports of 
steel  ropes  and  cables  including  locked  coil  ropes,  excluding  ropes  and  cables  of  stainless 
steel, with a maximum cross-sectional dimension exceeding 3 mm, originating in the People's 
Republic of China, is hereby extended to imports of steel ropes and cables including locked 
coil  ropes,  excluding  ropes  and  cables  of  stainless  steel,  with  a  maximum  cross-sectional 
dimension  exceeding  3  mm,  consigned  from  the  Republic  of  Korea,  whether  declared  as 
originating in the Republic of Korea or not, currently falling within CN codes ex 7312 10 81, 
ex 7312 10 83, ex 7312 10 85, ex 7312 10 89 and ex 7312 10 98 (TARIC codes 7312 10 81 
13, 7312 10 83 13, 7312 10 85 13, 7312 10 89 13 and 7312 10 98 13), with the exception of 
those produced by the companies listed below: 

Country 

Company 

TARIC additional 
code 

The Republic 
Korea 

Bosung Wire Rope Co, Ltd., 972-5, Songhyun-Ri, Jinrae-Myeun, Kimhae-Si,
Gyeungsangnam-Do 

Chung Woo Rope Co., Ltd. 1682-4, Songjung-Dong, Gangseo-Gu, Busan 

CS Co., Ltd, 287-6 Soju-Dong Yangsan-City, Kyoungnam 

Cosmo Wire Ltd., 447-1, Koyeon-Ri, Woong Chon-Myon Ulju-Kun, Ulsan 

Dae Heung Industrial Co., Ltd., 185 Pyunglim - Ri, Daesan-Myun, Haman – 
Gun, Gyungnam 

DSR Wire Corp., 291, Seonpyong-Ri, Seo-Myon, Suncheon-City, Jeonnam 

Kiswire Ltd., 20t h Fl. Jangkyo Bldg., 1, Jangkyo-Dong, Chung-Ku, Seoul 

Manho Rope & Wire Ltd., Dongho Bldg, 85-2, 4 Street Joongang-Dong, Jong
gu, Busan 

Shin Han Rope CO.,LTD, 715-8, Gojan-dong, Namdong-gu, Incheon 

A969 

A969 

A969 

A969 

A969 

A969 

A969 

A969 

A969 

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Ssang Yong Cable Mfg. Co., Ltd, 1559-4 Song-Jeong Dong, Gang-Seo Gu, 
Busan 

Young Heung Iron & Steel Co., Ltd, 71-1 Sin-Chon Dong, Changwon City, 
Gyungnam 

A969 

A969 

2.  The  application  of  exemptions  granted  to  the  companies  specifically  mentioned  in 
paragraph  1  or  authorised  by  the  Commission  in  accordance  with  Article  3(2)  shall  be 
conditional  upon  presentation  to  the  customs  authorities  of  the  Member  States  of  a  valid 
commercial invoice, which shall conform to the requirements set out in the Annex. If no such 
invoice is presented, the anti- dumping duty as imposed by paragraph 1 shall apply. 

3. The duty extended by paragraph 1 of this Article shall be collected on imports consigned 
from the Republic of Korea, whether declared as originating in the Republic of Korea or not, 
registered  in  accordance  with  Article  2  of  Regulation  (EC)  No  734/2009  and  Articles  13(3) 
and  14(5)  of  Regulation  (EC)  No  1225/2009,  with  the  exception  of  those  produced  by  the 
companies listed in paragraph 1. 

4. The provisions in force concerning customs duties shall apply. 

Article 2 

The  investigation  initiated  by  Regulation  (EC)  No  734/2009  concerning  the  possible 
circumvention  of  anti-dumping  measures  imposed  by  Regulation  (EC)  No  1858/2005  on 
imports of steel ropes and cables, originating in the People's Republic of China by imports of 
steel ropes and cables consigned from Malaysia, whether declared as originating in Malaysia 
or not, and making such imports subject to registration, is hereby terminated. 

Article 3 

1. Requests for exemption from the duty extended by Article 1 shall be made in writing in one 
of the official languages of the European Union and must be signed by a person authorised to 
represent  the  entity  requesting  the  exemption.  The  request  must  be  sent  to  the  following 
address: 

European Commission 
Directorate-General for Trade 
Directorate H 
Office: N-105 04/92 
B - 1049 Brussels 
BELGIUM 
Fax (32 2) 295 65 05 

2. In accordance with Article 13(4) of Regulation (EC) No 1225/2009, the Commission, after 
consulting  the  Advisory  Committee,  may  authorise,  by  decision,  the  exemption  of  imports 
from companies which do not circumvent the anti-dumping measures imposed by Regulation 
(EC) No 1858/2005, from the duty extended by Article 1. 

Customs authorities are hereby directed to discontinue the registration of imports, established 
in accordance with Article 2 of Regulation (EC) No 734/2009. 

Article 4 

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

Article 5 

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

Done at Brussels, 

For the Council 
The President 

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Annex 

A  declaration  signed  by  an  official  of  the  entity  issuing  the  commercial  invoice,  in  the 
following format, must appear on the valid commercial invoice referred to in Article 1(2): 

(1) 

(2) 

The name and function of the official of the entity issuing the commercial invoice.  

The  following  declaration:  “I,  the  undersigned,  certify  that  the  (volume)  of  [product 
concerned]  sold  for  export  to  the  European  Union  covered  by  this  invoice  was 
manufactured  by  (company  name  and  address)  (TARIC  additional  code)  in  (country 
concerned).  I  declare  that  the  information  provided  in  this  invoice  is  complete  and 
correct.” 

(3) 

Date and signature 

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