REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 43rd Annual Report from the Commission to the European Parliament and the Council on the EU’s Anti-Dumping, Anti-Subsidy and Safeguard activities and the Use of Trade Defence Instruments by Third Countries targeting the EU in 2024
Date: 2025-07-28
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: activity report, anti-dumping measure, anti-subsidy proceeding, countervailing charge, import (EU), import restriction, originating product, surveillance concerning imports, third country, trade dispute

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.7.2025  COM(2025) 428 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 43rd Annual Report from the Commission to the European Parliament and the Council on the EU’s Anti-Dumping, Anti-Subsidy and Safeguard activities and the Use of Trade Defence Instruments by Third Countries targeting the EU in 2024          {SWD(2025) 231 final}  
 
 
EXECUTIVE SUMMARY 

This is the 43rd Report on the European Union’s (EU) trade defence activity. It covers the EU’s 
anti-dumping,  anti-subsidy  and  safeguard  activities,  third  countries’  trade  defence  activities 
with respect to goods imported from the EU and the Hearing Officer’s activities in 2024. It is 
accompanied by a Commission staff working document providing more detailed information 
and statistics. 

The  year  2024  was  a  landmark  year  for  the  EU’s  trade  defence  activity.  The  Commission 
initiated 33 new investigations, which was a record number of new cases not seen since 2006. 
Considering the average of new cases initiated is traditionally around 12 annually, the level of 
activity  in  2024  was  indeed  significant.  Over  a  third  of  the  new  cases  initiated  were  in  the 
chemical sector. At the same time, the narrative on trade defence activity was largely dominated 
by  the  highly  politicised,  economically  important  and  much  publicised  anti-subsidy 
investigation into battery electric vehicles (BEVs) from China. Through that investigation, the 
Commission showcased its commitment to the rigorous application of EU and WTO rules. The 
steel  safeguard  also  featured  prominently  with  a  review  being  opened  in  view  of  the 
deterioration of the situation of the EU steel industry.   

Against a backdrop of an increase in unfairly traded imports hitting EU producers, in order to 
give a clear signal that the EU means business when tackling unfair competition from imports, 
the Commission decided in October 2024 to automatically register imports in all anti-dumping 
and anti-subsidy investigations.  Furthermore, on taking office, the new Commission openly 
reaffirmed  a  continued  commitment  to  robustly  tackle  unfair  competition  and  defend  EU 
industry.  

By the end of the year, the number of measures in place had grown to a total of 199 (definitive 
and provisional) up from 186 at the end 2023. The number of jobs protected by these measures 
increased exponentially going from almost half a million direct jobs at the end of 2023 to over 
625 000 by December 2024, with the measures on BEVs alone protecting over 115 000 jobs. 

Ensuring the effectiveness of the measures remains a high priority for the Commission as it is 
intrinsic to the strength of the instruments. Monitoring import levels and market developments 
in association with the industry and acting against circumvention continued throughout 2024. 
During the year, anti-circumvention investigations resulted in two measures being extended to 
stamp out duty evasion through instances of transhipment, both involving more than one other 
country. The anti-dumping measures on imports of birch plywood from Russia were extended 
to  Türkiye  and  Kazakhstan  and  the  anti-dumping  and  anti-subsidy  measures  on  imports  of 
stainless-steel  cold-rolled  flat  products  (SSCR)  from  Indonesia  were  extended  to  Taiwan, 
Türkiye and Vietnam.  Without  taking such action the measures in  place would be seriously 
undermined  and  the  EU  industry  exposed  again  to  the  damaging  effects  of  dumped  and 
subsidised imports.  

2024 brought important Court judgments, not least the confirmation by the Court of Justice of 
the findings of the General Court regarding cross border support, such as those granted by China 
under their ‘Belt & Road’ initiative, that it is possible to attribute the financial support of a third 
country to  the government  of the  country of origin  or export. The  Commission  approach  in 
relation to the construction of the normal value when there is a finding of significant distortions 

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according to Article 2(6a) of the basic Regulation was also confirmed in an important court 
ruling. These judgments reaffirmed the EU’s approach in tackling particularly damaging unfair 
trade practices.    

The increase in EU investigations was matched by an increase in third-country cases against 
the EU or its Member States, with 34 cases initiated in 2024, up from 20 in 2023. While the EU 
does not dispute third countries’ right to use the trade defence instruments where warranted, 
regrettably  some  of  these  cases,  particularly  three  initiated  by  China,  were  unjustified  and 
motivated  by  retaliation  against  the  EU’s  legitimate  anti-subsidy  investigation  into  BEVs. 
While monitoring third country trade defence activity is already demanding, these unwarranted 
investigations  create  unnecessary  additional  challenges  for  exporters  concerned  and  are 
tantamount to unlawful barriers to market access. Nevertheless, faced with these challenges the 
Commission  strongly  defended  and  supported  the  exporters  affected  including  by  acting 
through the WTO Dispute Settlement channels on China’s provisional anti-dumping measures 
on brandy and the initiation of the anti-subsidy investigation on dairy products.   

Throughout  2024,  the  trade  defence  services  engaged  in  extensive  communication  and 
information  activities,  including  specific  information  sessions  on  the  BEVs  investigation  as 
well  as  presentations  designed  to  help  small  and  medium-sized  enterprises  navigate  the 
complexities of trade defence. Overall, the EU’s trade defence activity in 2024 demonstrated 
its commitment to fair trade, transparency, and the protection of EU industry and jobs. 

I 

1. 

APPLICATION OF TRADE DEFENCE INSTRUMENTS (TDI) IN 2024 

INVESTIGATIVE ACTIVITY 

1.1. 

General overview 

At the end of 2024, the EU had 192 definitive trade defence measures in force, composed of 
124  anti-dumping  (AD)  measures,  38  extensions  of  anti-dumping  measures  following  anti-
circumvention  investigations,  22  anti-subsidy  (AS)  measures,  7  extensions  of  anti-subsidy 
measures following anti-circumvention investigations and 1 safeguard (SFG) measure. There 
were also 7 provisional anti-dumping measures in place giving a total of 199 measures in place 
at the end of the 2024. These measures protect over 625 000 direct jobs in the EU. 

In 2024, the Commission worked on 33 new investigations and 31 reviews initiated as well as 
39 investigations which were ongoing at the start of the year. The Commission concluded 8 
new investigations and 34 reviews during the year.  

This report is accompanied by a Commission Staff Working Document which provides more 
information and statistics and includes annexes for the sections below. 

1.2. 

Anti-dumping (AD) and anti-subsidy (AS) investigations (see Annexes A to I) 

In 2024, the Commission initiated 33 new investigations (29 AD, 3 AS and 1 SFG). This is a 
record  number  of  investigations  going  back  as  far  as  2006  and  compares  to  12  new 
investigations initiated in 2023. Over a third of the new cases (12) concerned products in the 
chemical sector, all from China. This was a doubling of new cases in that sector compared to 
2023 and a significant contrast with previous years, when there were no new chemical cases in 
2022, and only one each in the years 2018 to 2021. This trend may be attributed to a build-up 
of massive overcapacities in that sector in China coupled with the removal of the pandemic 

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restrictions and logistical obstacles (shipping container crisis) which may have led to a flood of 
unfairly traded exports from Chinese to the EU.  

The Commission initiated 30 reviews in 2024, which was a slight drop compared to 31 in 2023. 
The majority (21) of these were expiry reviews and the remainder comprised 4 interim reviews, 
3 anti-circumvention investigations  and 2 safeguard reviews. The  increase in  the number of 
expiry reviews is linked to the 5-year lifecycle of measures. 

In total, 63 new and review investigations were initiated, which was a significant increase on 
the 43 investigations opened in 2023. 

The  Commission  imposed  10  provisional  measures  (9  AD  and  1  AS)  and  concluded  7  AD 
investigations by imposing definitive measures. The Commission terminated 1 AS investigation 
(Alkyl  Phosphate  Esters)  without  imposing  measures  as  the  complaint  was  withdrawn. 
However,  it  continued  the  AD  investigation  into  the  same  product  which  resulted  in  the 
imposition of definitive measures in September 2024.  

In 2024, 11 expiry reviews were concluded with the duty being confirmed. Two AD measures 
expired automatically at the end of the 5-year period of imposition. 

2020-2024 TDI Activity

45

40

35

30

25

20

15

10

5

0

2020

2021

2022

2023

2024

New investigations

Reviews

Definitive measures

1.3. 

Safeguard investigations 

Two safeguard (SFG) investigations were initiated in 2024. One was a functioning review of 
the  steel  safeguard  measure  and  a  new  investigation  was  opened  concerning  imports  of  
manganese and silicon-based alloying elements. A review of the bilateral safeguard measures 
on Indica rice from Cambodia and Myanmar/Burma was also concluded in 2024.  

Functioning review  -  SFG measure concerning certain steel products  

The EU steel SFG measure was imposed in July 2018 with definitive measures in January 2019. 
Subsequently, the Commission carried out several reviews. The Commission concluded the last 
review in July 2024, which resulted in the prolongation of the measure to its maximum duration 
of 8 years, until July 2026.  

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In November 2024, the Commission received a request from several Member States to initiate 
a review of the steel SFG measure. The information provided showed that the situation of the 
EU steel industry had deteriorated since the previous review. In a situation of declining demand, 
the  market  share  of  imports  remained  stable  or  increased.  Moreover,  the  imports  exercised 
considerable  price  pressure.  The  review  investigation,  which  was  initiated  on  17  December 
2024,  showed  that  adjustments  to  the  quota  management  were  warranted  to  ensure  the 
effectiveness of the measure under current market circumstances. The review was concluded 
by the end of March 2025 with changes coming into effect on 1 April 2025.  

New SFG investigation concerning imports of manganese and silicon-based alloying elements 

On  13  December  2024,  the  Commission  received  a  request  from  several  Member  States  to 
initiate  a  SFG  investigation  on  imports  of  certain  silicon  and  manganese  based  alloying 
elements. The request provided sufficient evidence that the trend in imports of the products and 
the conditions under which they are imported appear to call for SFG measures. On that basis, 
the Commission initiated a SFG investigation on 19 December 2024. The investigation should 
normally  be  concluded  within  9  months,  i.e.  September  2025,  but  can  be  extended  until 
November 2025. 

GSP SFG measure on Indica rice  

The bilateral  SFG measures imposed in  2019 on imports of Indica rice from Cambodia and 
Myanmar  under  the  Generalised  Scheme  of  Preferences  (GSP)  expired  in  January  2022.  A 
review  to  implement  a  General  Court  judgment  was  concluded  in  March  2024  when  the 
Commission re-imposed SFG measures on imports of Indica rice originating in Cambodia and 
Myanmar/Burma  for  the  period  of  application  of  the  measures,  i.e.  18  January  2019  to  18 
January 2022.  

1.4. 

Verifications in investigations 

The Commission ensures that the information used in trade defence investigations is accurate 
and complete to ensure legally sound decisions and the correct imposition of measures.  

In 2024, the Commission verified data from 346 companies, 148 within the EU and 191 in third 
countries. Practically all these verification exercises took place on site at the companies. Only 
seven  companies’  data  was  verified  remotely,  a  process  introduced  in  2020  to  cope  with 
COVID-19 travel restrictions but increasingly no longer used. 

2. 

ASSERTIVE AND EFFECTIVE APPLICATION AND ENFORCEMENT OF TDI 

2.1. 

Commitment to Assertive use of trade defence instruments 

In the context of the new Commission taking office in 2024, there was a renewed commitment 
to  assertively  protect  EU  industry  from  unfair  competition  stemming  from  unfairly  traded 
imports. In President von der Leyen’s Mission letter to the then Commissioner-designate for 
Trade and Economic Security she reaffirmed the EU’s commitment to free and fair trade while 
committing to a more assertive stance against unfair competition.  

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In  turn,  in  his  hearing  before  the  European  Parliament,  Commissioner  Šefčovič  addressed 
defending  EU  businesses  against  unfair  practices  where  he  committed  to  safeguard  a  level 
playing field. He assured that, while the EU will continue to champion free and fair trade, it 
would make assertive use of the robust system of trade defence instruments in a legally sound 
way by being firm and forceful against unfairly traded imports.   

2.2. 

Registration of imports 

In October 2024, as part of its efforts to strengthen the trade defence instruments in tackling the 
effects  of  unfair  competition,  including  overcapacity,  the  Commission  started  automatically 
registering  imports  in  all  ongoing  anti-dumping  and  anti-subsidy  investigations.  Up  to  then, 
imports were registered only on receipt of a justified request from the industry. The purpose of 
registering imports is to enable the retroactive collection of duties if justified and where specific 
legal conditions are met. This change of practice does not mean that retroactive application of 
measures is automatic. That decision is taken only at the definitive stage of each investigation.   

The move to automatically register imports helps not only in simplifying procedures, but also 
alleviates the burden placed on industry by removing the need to prepare requests. At the same 
time, it provides the Commission with precise and accurate information about the source and 
quantities of imports of a product under investigation, as well as broader market developments. 
The registration is carried out by Member State customs authorities as directed via individual 
Implementing Regulations. 

2.3.  Monitoring, surveillance and enforcement of measures (see Annexes J, K, M, Q) 

Where trade defence measures are evaded by economic operators, the strength of the system is 
eroded. For that reason, monitoring of imports after the imposition of measures is critical in 
ensuring the measures have the desired effect.  

Where indications of circumvention are found or presented by industry, the Commission takes 
prompt action to address the issue. Circumvention is defined as a change in the pattern of trade 
between third countries and the EU that stems from a practice, process or work for which there 
is  insufficient  cause  or  economic  justification,  other  than  the  imposition  of  the  duty.  The 
Commission  has  observed  a  variety  of  circumvention  practices,  though  the  transhipment  of 
goods through third countries still appears the most common. More complex practices concern 
assembly processes that require some level of industrial activity that may change the nature of 
the product while adding very limited value to the final goods. These further processed goods 
are  then  imported  into  the  EU,  normally  under  a  different  combined  nomenclature  (CN) 
heading, hence evading the payment of the duty in place.  

If the Commission has sufficient evidence that measures are being circumvented, it opens anti-
circumvention  investigations.  In  2024,  the  Commission  initiated  two  anti-circumvention 
investigations: 

•  Anti-dumping  measures  on  imports  of  monosodium  glutamate  from  China,  allegedly 
circumvented via Malaysia; and  
•  Anti-dumping  measures  on  imports  of  graphite  electrode  systems  from  China,  via  alleged 
circumvention practices taking place in the EU.  

5 

 
 
 
 
  
 
 
  
 
The Commission concluded three anti-circumvention investigations during the reporting year. 
The Commission extended the anti-dumping measures against imports of birch plywood from 
Russia to Türkiye and Kazakhstan and extended the anti-dumping as well as the anti-subsidy 
measures against imports of stainless-steel cold-rolled flat products (SSCR) from Indonesia to 
Taiwan, Türkiye and Vietnam. In these investigations the Commission found that goods were 
being transhipped via third countries, and, also, that the measures were being circumvented via 
further processing activities with limited added value in the investigated third countries. 

In the investigation regarding imports of SSCR, in light of the seriousness of the circumvention 
practices, for the purpose of monitoring, in addition to the compulsory commercial invoice and 
mill certificate, a declaration is required from the exporting producers that are exempted from 
the extended measures,  stating  whether the location  where the stainless steel  to  produce the 
SSCR was originally melted and poured, was the country subject to the original measures, i.e. 
Indonesia. 

In 2024, there was continued cooperation between the TDI services, other Commission services 
(DG  TAXUD),  relevant  EU  agencies  (OLAF)and  enforcement-oriented  national  authorities 
(customs authorities in Member States) as well as regular exchanges with the Union industry to 
keep track of market developments.  

Regular exchanges take place with DG TAXUD regarding the classification of goods subject 
to trade defence instruments (TDI). In addition, as soon as the relevant legislation is published 
in the Official Journal,  DG TAXUD promptly incorporates the corresponding measures into 
TARIC (the integrated Tariff of the European Union). This ensures the uniform application of 
TDI measures, as TARIC data is automatically transmitted daily to the import systems of the 
Member States.  

Whenever  the  Commission  receives  information  on  irregularities  from  the  Union  industry, 
either on an ad-hoc basis or in the framework of formal complaints, it informs OLAF. In the 
same vein, the Commission maintains regular contacts on these matters with Member States’ 
customs authorities, for example, by publishing specialised risk warnings in the EU common 
customs  risk management  system.  However, given that investigations by OLAF or Member 
States’ law enforcement authorities into above practices are confidential, no further information 
can be given. OLAF publishes an annual report presenting its activities of the previous year, as 
well as statistics of its investigative performance and examples of cases.  

The Commission carried out special monitoring tasks in 15 investigations in 2024, all of them 
relating to anti-dumping measures, 12 concerning imports from China, 2 from India and 1 from 
Egypt. The ex-post monitoring system on steel and aluminium imports continued in 2024 with 
the data published monthly on the trade section of the Commission website. 

Monitoring  of  undertakings  also  forms  part  of  the  enforcement  activities,  given  that 
undertakings allow for the suspension of AD or AS measures. The Commission accepts such 
undertakings  when  it  is  satisfied  that  they  can  effectively  eliminate  the  injurious  effects  of 
dumping or subsidisation and regularly checks the exporters’ compliance with the undertakings.  

At the start of 2024, there were 11 undertakings in force concerning two proceedings, biodiesel 
from Argentina and citric acid from China. As regards the undertakings in biodiesel, monitoring 
showed that the exporting producers were complying in full. However, regarding citric acid, 
the Commission found that certain conditions of the undertakings concerning citric acid from 

6 

 
 
 
  
 
 
 
 
 
China were breached by the China Chamber of Commerce of Metals, Minerals & Chemicals 
Importers & Exporters (‘CCCMC’) and as a result withdrew its acceptance of the undertakings 
from 3 companies in March 2024. 

There were no undertaking offers made in anti-dumping investigations concluded in 2024. In 
the  anti-subsidy  investigation  concerning  battery  electric  vehicles  from  China,  several 
exporting producers offered price undertakings which were found to be insufficient to offset 
the injurious subsidisation of Chinese exports. Nevertheless, the Commission remained open to 
continuing work to find agreement on WTO compatible and effective price undertakings. This 
complex process continued for the remainder of 2024. 

2.4. 

Judicial review by EU Courts (Annex S) 

In 2024, the General Court and the Court of Justice issued 25 judgments and orders in cases 
concerning trade defence measures. As in the previous year, the General Court handed down 
14 rulings whereas the Court of Justice decided on 10 appeals and one request for a preliminary 
ruling. Fewer new court proceedings concerning trade defence measures were lodged in 2024 
(ten in total) compared to the previous year (18 in total in year 2023). Out of ten new court 
cases six actions for annulment were lodged before the General Court and three appeals and 
one request for a preliminary ruling before the Court of Justice.  

The Commission prevailed in all but one judgement (case T-762/20 Sinopec Chongqing SVW 
Chemical and Others v Commission) which was subsequently appealed by the Commission and 
the appeal is currently pending.   

Last year’s jurisprudence confirms the discretion enjoyed by the Commission in relation to the 
determination of the normal value when there is a finding of significant distortions according 
to  Article  2(6a)  of  the  basic  anti-dumping  Regulation.  The  General  Court  endorsed  the 
Commission’s anti-circumvention practice, notably by upholding the approach that assembly 
operations include completion operations and confirming the application by analogy of Article 
13(2)  of  the  basic  anti-dumping  Regulation  to  circumvention  of  countervailing  duties  via 
assembly  operations  in  third  countries  (under  appeal).  In  several  judgements,  the  Court  of 
Justice upheld the Commission’s findings on important aspects of the trade defence practice, 
including:  

- 

- 

- 

that it is possible to attribute the financial support of a third country to the government 
of the country of origin or export of the subsidized goods,  

the legality of the Commission’s practice of adjusting costs which are not at arm’s length 
under Article 2(5) of the basic Regulation, and  

the application of Article 7(2a) of the basic Regulation concerning modulation of the 
lesser duty rule in case of raw material distortions to the full amount of dumping. 

3. 

SOCIAL AND ENVIRONMENTAL STANDARDS IN TDI 

The EU’s commitment to  high  social and environmental  standards was  reflected in  changes 
made to the trade defence legislation in 2017 and 2018. 

The  introduction  of  the  specific  dumping  calculation  methodology  in  2017,  where  state 
interference significantly distorts the market, meant that an appropriate representative country 

7 

 
 
 
 
must  be  selected  to  establish  an  undistorted  normal  value.  In  selecting  such  a  country,  the 
Commission  may  consider  differences  in  the  levels  of  social  and  environmental  protection 
where there is more than one country to choose from. 

In 2024, the Commission  used  the significant  distortions  methodology  in four anti-dumping 
investigations where definitive measures were imposed. However, in all the cases there was 
only one potential representative country which had the appropriate available data and hence 
the issue of social and environmental standards did not come into play in the selection process.  

In 2018, the modernisation of the trade defence instruments saw a further endorsement of the 
EU’s commitment to  social and environmental standards. Since then, the Commission  takes 
costs of social and environmental obligations into account when calculating an injury margin. 
Now  the  cost  of  compliance  with  multilateral  environmental  agreements  and  International 
Labour Organisation Conventions during the lifetime of any measures may be included in the 
EU industry’s costs of production. They can include the additional future costs associated with 
complying with the EU Emissions Trading System, a cornerstone of the EU’s policy to comply 
with multilateral environmental agreements. These costs featured in two anti-dumping cases 
completed in 2024: Electrolytic manganese dioxides and Alkyl Phosphate Esters, both cases 
concerning China. The addition of these costs increased the non-injurious prices1 and hence the 
injury  margins.  However,  this  impacts  on  the  final  level  of  measures  only  where  the  duties 
imposed are based on injury margins and in 2024 only in the Electrolytic manganese dioxides 
case  were  the  duties  based  on  the  injury  margin.  In  the  Alkyl  Phosphate  Esters  case,  the 
measures imposed were based on dumping margins2.  

Social and environmental standards can also be considered when examining undertaking offers. 
However, in 2024 the Commission received no undertaking offers in anti-dumping cases and 
in  the  BEV  case  the  undertaking  offers  were  rejected  for  other  reasons,  so  consideration  of 
social and environmental issues did not arise in that context.  

4. 

ACTIVITIES OF THE HEARING OFFICER 

The  Hearing  Officer  plays  a  crucial  role  in  ensuring  that  interested  parties  affected  by 
procedures and measures under EU legislation concerning international trade can exercise their 
procedural  rights,  including  the  right  to  be  heard.  In  2024,  the  Hearing  Officer  received  12 
requests for intervention, all of which pertained to trade defence proceedings. 

The requests came from various parties, including users (2), exporting producers (4),  Union 
industry representatives (2), a third-country government (1), and importers (3). Notably, one 
case generated three requests for intervention from two importers and an exporting producer, 
resulting in three hearings. Two other proceedings prompted two requests each. 

The  primary  concerns  raised  by  the  requesting  parties  involved  additional  disclosure  or 
objections  to  facts  and  findings  (5  requests)  and  objections  to  the  application  of  best  facts 
available  (5  requests).  In  some  cases,  the  Hearing  Officer  received  requests  that  were  more 
appropriately addressed to the investigation departments, which were then promptly forwarded 
to the relevant teams. In 2024 the Hearing Officer did not extend any deadlines. 

1  The  price  which  the  industry  is  expected  to  have  charged  under  normal  circumstances  i.e.  in  the  absence  of 
dumped or subsidised imports 
2 The rate of duty is based on the dumping margin, unless a lower rate would remove the injury 

8 

 
 
 
 
In  2024,  the  Hearing  Officer  held  three  hearings,  all  related  to  the  same  proceeding.  The 
Hearing Officer continued to follow the established practice of encouraging parties to raise their 
concerns with the Commission services responsible for the investigation before requesting a 
hearing.  This  approach  allowed  most  parties  to  resolve  their  concerns  directly  with  the 
investigation  teams,  with  the  Hearing  Officer  closely  monitoring  the  process  and  remaining 
available to address any further issues. 

Ultimately, the Hearing Officer found that the procedural rights of all parties had been respected 
in every case.  

5. 

DEALING WITH TRADE DEFENCE ACTIVITY AGAINST THE EU 

In 2024, the significant increase in the number of new investigations initiated by the EU was 
mirrored by an increase in investigations conducted by third country authorities. Monitoring 
these cases is crucial to ensure that unjustified trade defence measures are not an obstacle to 
exports by EU industry.  

The importance of monitoring third country cases against the EU was brought sharply into focus 
during 2024 when EU exporters were faced with a number of investigations initiated on dubious 
legal grounds. Moreover, three cases initiated by China were clearly initiated as a retaliation 
against the EU’s anti-subsidy investigation on battery electric vehicles.   

The specific cases concerned were anti-dumping investigations on brandy and pork and an anti-
subsidy investigation into dairy products by China. The Commission considers that all three 
investigations  lacked  sufficient  evidence  for  initiation  and  imposition  of  any  measures  and 
intervened  extensively  in  all  three  investigations  in  close  cooperation  with  the  industry 
concerned.  Misuse  of  the  instruments  for  retaliatory  purposes  is  unacceptable  and  the 
Commission robustly defends the interests of the EU producers concerned through all available 
channels, including in the WTO. In this context, the Commission challenged the initiation of 
the  investigation  on  dairy  products  and  challenged  the  initiation  of  the  investigation  and 
imposition of provisional measures in the brandy case at the WTO.  

In other cases where the Commission intervened there were some results more favourable for 
EU exporters than may otherwise have been the case. The Commission’s accomplishments in 
2024  are  described  in  the  accompanying  Staff  Working  Document,  with  some  examples 
herewith. 

• 

• 

In January 2024, the US terminated an anti-dumping investigation into imports of tin 
mill  from  the  Netherlands  after  a  finding  of  no  dumping  by  the  Department  of 
Commerce. In February 2024, the investigation concerning imports of the same product 
from Germany was terminated because of a finding of no injury by the US International 
Trade  Commission.  The  Commission  was  very  active  in  supporting  the  exporters 
concerned from the outset of the investigations in February 2023. Economically, these 
cases  were  very  important  as  they  represent  around  EUR  1  billion  value  in  exports, 
higher than any other US trade defence case against the EU or its Member States. 
In  November  2024,  the  US  International  Trade  Commission  determined  that  the 
domestic  industry  was  not  injured  because  of  imports  of  aluminium  extrusions  from 
Italy and the investigation was terminated without any measures. The investigation was 
opened  in  October  2023  and  the  Commission  actively  supported  the  exporters 
concerned throughout the investigation. The economic interest in this  case was EUR 
104 million.  

9 

 
 
 
• 

In July 2024, the US imposed AD measures of 6,14% on imports of paper shopping 
bags  from  Portugal.  The  Commission  was  very  active  supporting  the  exporters 
concerned and the duties imposed were much lower than the dumping margins of up to 
189% originally alleged by the petitioners. The economic interest in this case was EUR 
17 million.  

By the end of 2024, there were 168 trade defence measures in force affecting EU exports, 8 less 
than at the end of 2023. The bulk of the measures were 124 AD, 37 SFG and the balance being 
7 AS measures. This compares to 125 AD, 44 SFG, and 7 AS measures in 2023. 

In 2024, the United States remained the most frequent user of TDIs against EU exports, with 
41  measures  in  place.  Türkiye  and  China  followed  with  23  measures  and  18  measures 
respectively. Brazil and Indonesia each have 10 measures in place. Canada and Madagascar are 
also notable users, with 9 definitive measures each. South Africa together with the Southern 
African Customs Union (SACU), with 7 measures. Other frequent users are Argentina, Mexico, 
and Morocco each with 5 measures, while Australia and India have 4 measures each. Thailand 
has 3 measures in force, while the Republic of Korea, New Zealand, and Pakistan each have 2 
measures. Additionally, Colombia, Egypt, Ghana, the GCC countries, Lebanon, the Philippines, 
Tunisia, the United Kingdom,  and Vietnam  each maintained 1 measure  in  force against EU 
exports. 

In 2024, 34 new investigations were initiated against the EU and its Member States, marking a 
significant increase compared to the 20 investigations initiated in 2023. The 34 investigations 
comprised of 17 AD, 14 SFG and 3 AS investigations.  

Among the AD investigations, India, the United States, and China initiated the most with 5, 4 
and 3 respectively. Türkiye followed with 2 investigations, while Australia, Canada, and the 
United Kingdom initiated 1 each. 

Türkiye  opened  the  most  SFG  investigations  with  3  new  cases,  followed  by  Indonesia  and 
Madagascar  with  2  initiations  each.  Other  countries  initiating  SFG  investigations  included 
China, India, Jordan, Morocco, the Philippines, South Africa, and the United States, with 1 new 
investigation each. 

An increase was also observed in the adoption of new measures. In 2024, a total of 17 new 
measures  against  EU  exports  were  introduced,  consisting  of  9  AD  measures  and  8  SFG 
measures. This represents an increase compared to 2023, when 4 AD and 7 SFG measures were 
imposed.  The  US  and  Türkiye  each  imposed  three  new  AD  measures  followed  by  Canada, 
China, and India, which imposed one AD measure each. Madagascar imposed three new SFG 
measures while Türkiye imposed two such measures. Additionally, Ghana, South Africa and 
the US each imposed one SFG measure during the year. 

This  increase  in  the  use  of  SFG  investigations  is  particularly  worrying  given  that  under  the 
WTO rules, safeguard measures apply to imports from all origins, as opposed to targeting only 
origins where unfair trading conditions are present. This makes SFG the most restrictive of all 
trade  remedies,  and  they  should  be  used  only  in  response  to  an  import  surge  caused  by  an 
unforeseen development  and when strict criteria  are met. The Commission  intervened in  all 
cases where systemic problems and deficiencies have been identified. 

10 

 
 
 
 
 
 
 
 
 
 
6. 

WTO-RELATED ACTIVITIES 

The WTO hosts meetings of the Subsidies and Countervailing, Anti-dumping and Safeguards 
Committees  each  year  in  spring  and  autumn.  Under  the  auspices  of  the  Anti-dumping 
Committee, the WTO also hosts two groups: a Working Group on Implementation (WGI) and 
an Informal Group on Anti-circumvention practices where members exchange information on 
the practicalities of investigations. There are also informal sessions for ‘Friends of Safeguards 
Investigations’.  

In  the  various  Committees,  WTO  members  monitor  the  implementation  of  the  relevant 
agreements by investigating authorities and raise concerns and exchange views on trade defence 
cases. The EU is very active in all the committees, drawing attention to concerns of a general 
and systemic nature as well as specific trade defence cases which impact our exporters. The EU 
also strongly defends its own trade defence activities. 

The EU participated in both meetings of the Anti-dumping Working Group on Implementation. 
Members  discussed  the  following  topics:  Adjustments  to  the  scope  of  the  product  under 
investigation, the impact  of COVID-19 on investigations  and lessons learned for the future; 
conditions  of  competition  in  the  context  of  injury  analysis  as  well  as  dealing  with  threat  of 
material injury and material retardation in investigations. 

The  Informal  Group  on  Anti-circumvention  met  in  October  2024,  its  first  meeting  in  a  few 
years,  where  participants  shared  information  and  experiences  on  the  ways  and  means  they 
address circumvention.  

In the Special Committee on Subsidies and Countervailing Measures, the members continued 
the review of subsidy notifications made in  2023.  The EU’s notification  was reviewed with 
questions from Australia about the EU’s fisheries subsidies. The WTO Secretariat’s update on 
notifications  showed  that  compliance  with  notification  obligations  under  the  Agreement  on 
Subsidies  and  Countervailing  Measures  (ASCM)  remains  low.  Less  than  half  of  the  WTO 
membership  made  a  notification  of  subsidies  in  2023.  The  EU  continued  to  stress  the 
importance of complying with the obligations and pushed for greater transparency on subsidies, 
with next notifications due in June 2025.    

In the regular Committee on Subsidies and Countervailing Measures, the EU defended its anti-
subsidy  investigations  into  battery  electric  vehicles  from  China  and  aluminium  road  wheels 
from Morocco. In turn, the EU raised concerns and highlighted shortcomings in anti-subsidy 
investigations by Australia into canned tomatoes from Italy, by China into dairy products from 
the EU and by the US into melamine from Germany.  

In the Anti-dumping Committee, the EU responded to criticisms raised about its anti-dumping 
investigations  on hot  rolled flat  products  from  Japan, optical  fibre  cables  from  India and  an 
expiry review into tube and pipe fittings by Russia. The EU raised its concerns about the anti-
dumping investigations by Australia into canned tomatoes from Italy as well as investigations 
by China concerning brandy and pork products from the EU. Regarding the investigations by 
China,  the  EU  highlighted  the  fact  that  these  were  based  on  questionable  allegations  and 
insufficient evidence and represented an unfair use of trade defence instruments given the clear 
overlap  in  timing  between  China’s  actions  and  different  milestones  of  the  European 
Commission’s anti-subsidy investigation on battery electric vehicles.    

In the Safeguards Committee, the EU and many delegations expressed concerns at the misuse 
of safeguards worldwide, their duration, the fact that they are used as a retaliatory weapon and 
often do not respect WTO rules. Some developing countries, who are relatively new users of 

11 

 
 
 
the instrument, had an exponential increase in the number of safeguard cases as they consider 
the instrument an easier alternative to anti-dumping or anti-subsidy. Discussions also focused 
on individual cases of concern with the EU’s steel safeguard attracting much attention at the 
meetings. The EU robustly defended its steel safeguard against criticism from Brazil, China, 
India,  Japan,  Korea,  Türkiye  ,  Switzerland,  and  Russia.  Most  of  them  reiterated  previous 
arguments that the measures should have been terminated and not extended. No consensus was 
reached on a US proposal to transfer the informal ‘Friends of Safeguard Investigations’ group 
to the Committee due to opposition by India. 

In  2024,  including  during  the  WTO’s  13th  Ministerial  Conference,  the  WTO  negotiations 
continued  on  the  outstanding  issues  to  achieve  a  comprehensive  agreement  on  fisheries 
subsidies. The EU conducted outreach to encourage other WTO members to accept the WTO 
Agreement on Fisheries Subsidies which had been concluded at the 12th Ministerial Conference 
in 2022. The Agreement will enter into force once two thirds of WTO members have accepted 
it. 

Furthermore, the EU and other like-minded WTO members continued subsidies-related work 
strands  under  the  WTO  Fossil  Fuel  Subsidy  Reform  initiative  and  under  the  Trade  and 
Environmental Sustainability Structured Discussions. 

Trilateral  cooperation  with  the  US  and  Japan  focused  on  a  sectoral  assessment  of  market-
distortive policies and practices, including subsidies that are not sufficiently addressed by WTO 
rules. The partners shared specific examples and exchanged information on potential tools to 
address the identified practices. 

7. 

SMALL AND MEDIUM-SIZED ENTERPRISES (SMES) 

To  help  small  and  medium-sized  enterprises  (SMEs)  overcome  their  limited  resources  in 
understanding  and  utilizing  the  trade  defence  instruments  the  European  Commission  offers 
comprehensive support and guidance. This is directed to SMEs whether they are EU producers, 
exporters or importers.  

In  2024,  the  Commission  continued  its  outreach  program  to  raise  awareness  about  the 
instruments. To reach the maximum audience possible, by building on existing networks, the 
Commission presented information on trade defence in four Access2Market events during 2024 
and  in  one  Market  Access  Day  event  organised  in  Belgium.  In  addition,  the  trade  defence 
services  presented  information  at  an  Export  Management  Masterclass  hosted  by  Trade 
Promotion Europe in Brussels in May 2024.  

In 2024, small and medium-sized enterprises (SMEs) continued to be involved in trade defence 
proceedings. Some new investigations launched in the year involved SMEs as EU producers, 
including  anti-dumping  investigations  into  imports  from  China  of  products  such  as  candles, 
hardwood  plywood,  multilayered  wood  flooring,  screws  without  heads  and  sweetcorn. 
Additionally, in January 2024, the Commission imposed definitive anti-dumping duties on steel 
bulb  flats  from  China  and  Türkiye,  providing  protection  to  the  only  EU  producers,  both  of 
which  are  SMEs  that  employ  between  130  and  160  people,  thus  supporting  these  small 
businesses. 

12 

 
 
 
 
 
 
 
8. 

INFORMATION AND COMMUNICATION ACTIVITIES/ BILATERAL CONTACTS 

The  Commission  is  fully  committed  to  improving  transparency  and  collaboration  on  trade 
defence issues and, in this context, the Trade Defence services organised, as well as participated 
in, various information sharing activities in 2024.    

In  January  2024,  there  was  a  meeting  of  the  EU-Korea  Working  Group  on  Trade  Remedy 
Cooperation held online which brought together experts to discuss trade remedy cooperation. 
The Commission also held a TDI dialogue with the Turkish trade defence service in June 2024, 
providing a platform for the exchange of information and ideas. 

In  October  2024,  the  Commission's  Directorate-General  for  Trade  (DG  Trade)  organised  a 
training seminar for officials from third countries, focusing on trade defence investigations. The 
seminar,  which  was  well-received,  attracted  participants  from  five  countries:  Madagascar, 
Malaysia,  Türkiye,  the  Philippines,  and  the  Dominican  Republic.  The  event  enabled  the 
exchange of trade defence procedures and practices among third-country authorities, promoting 
cooperation and knowledge-sharing. 

The  Commission  also  participated  in  an  International  Webinar  on  Trade  Remedy 
Investigations, hosted by the Japanese Ministry of Economy,  Trade and  Industry (METI) in 
November 2024. The webinar provided a platform for the exchange of views and information 
on  investigative  practices,  with  officials  from  the  World  Trade  Organization  (WTO)  also 
attending. 

In  addition  to  these  events,  the  Commission  engaged  throughout  the  year  with  various 
stakeholder associations, including Business Europe and AEGIS Europe, to hear the views of 
interested parties. In September 2024, the Commission made a presentation to the Civil Society 
Dialogue, providing an update on developments in trade defence.  

II 

ANTI-SUBSIDY INVESTIGATION ON BATTERY ELECTRIC VEHICLES FROM CHINA 

The EU’s anti-subsidy investigation into battery electric vehicles (BEVs) from China, launched 
in October 2023, was a highly publicised and complex case that garnered significant attention 
from within and outside the EU.  

The investigation was  initiated by the Commission on its own initiative, as it had sufficient 
evidence of subsidised imports threatening to cause economic injury to EU producers of BEVs. 
The case was announced by President von der Leyen in her State of the European Union address 
in 2023. 

The  investigation  revealed  that  China’s  entire  BEV  value  chain  is  heavily  subsidised,  with 
subsidies  provided  to  upstream  sectors  such  as  mining  and  battery  production,  as  well  as 
downstream sectors like consumer rebates for BEV purchases. The Commission found various 
countervailable subsidies, including traditional schemes like grants and tax exemptions, as well 
as case-specific schemes such as the national subsidy (producers of BEVs get a certain amount 
per electric car sold), the provision  of batteries and their components  for less than adequate 
remuneration, and the use of green bonds (specific to the green industry and BEVs whereby the 
producers can raise funds at preferential rates as banks are encouraged to purchase such bonds). 
The  investigation  found  that  these  subsidised  BEVs  from  China  were  threatening  to  cause 

13 

 
 
 
 
 
 
 
 
 
economic injury to the competing EU producers of electric vehicles. Before imposing measures, 
the Commission evaluated the interests of various stakeholders, including importers, users, and 
consumers, as part of the Union interest test. Provisional measures were imposed in July 2024, 
with imports of BEVs having been registered from March 2024. 

In  the  meantime,  the  EU  and  China  engaged  in  negotiations  to  find  a  mutually  agreeable 
solution,  exploring  the  possibility  of  price  undertakings.  However,  despite  political 
commitment  to  finding  a  solution,  no  agreement  was  reached  before  the  legal  deadline  to 
conclude the investigation. 

As a result, the Commission imposed definitive duties effective from 30 October 2024, ranging 
from 7,8% to 35,3%. These measures were designed to re-establish a level playing field while 
keeping the EU market open to imports from China.  

Discussions on price undertakings continued after the conclusion of the investigation, but no 
mutually agreeable solution has been found to date. 

Throughout the investigation, the Commission maintained extensive communication to ensure 
transparency and avoid misunderstandings, given the complexity and high stakes involved. The 
investigation and its outcome demonstrate the EU’s commitment to enforcing its trade rules 
and protecting its industries from unfair subsidies, while also ensuring that its market remains 
open to imports from China. 

In August 2024, China requested WTO dispute consultations on the imposition of provisional 
measures  in  the  case  which  was  superseded  by  a  request  in  November  2024  for  WTO 
consultations on the imposition of definitive measures. The panel was established on 25 April 
2025  (DS630).  At  the  start  of  2025,  several  electric  vehicle  manufacturers  (SAIC  Motor 
Corporation, BYD Auto, Zhejiang Geely Automobile, BMW, and Tesla (Shanghai)) and the 
China Chamber of Commerce for  Import  and Export of Machinery and  Electronic Products 
(CCCME) filed court cases challenging the anti-subsidy measures.  

14