CELEX: 51997PC0569
Language: en
Date: 1997-11-07
Title: Proposal for a Council Regulation (EC) imposing a definitive anti-dumping duty on certain imports of flat pallets of wood originating in the Republic of Poland and collecting definitively the provisional duty imposed

COMMISSION OF THE EUROPEAN COMMUNITIES
                                               Brussels, 07.11.1997
                                               COM(97) 569 final
                                Proposal for a
                      COUNCIL REGULATION (EO
  imposing a definitive anti-dumping duty on certain imports of flat pallets of
wood originating in the Republic of Poland and collecting definitively the
                         provisional duty imposed
                       (presented by the Commission)
 ---pagebreak---  ---pagebreak---                                   EXPLANATORY MEMORANDUM
By Regulation (EC) 1023/971, the Commission imposed provisional anti-dumping duties
on certain imports of flat pallets of wood originating in Poland falling within CN code
4415 20 20. Simultaneously, the Commission accepted undertakings offered by certain
exporters for the most important type of pallet, namely the EUR-pallet.
In August 1997, the provisional regulation was amended2 to grant a number of genuine
new Polish exporters the same treatment, in terms of provisional measures, as the one
given to co-operating companies not selected in the sample, namely a duty of 6.3%
instead of 10.6% and acceptance of undertakings offered with regard to the EURjpallet
type-
Subsequently, interested parties were also given the opportunity to make their point of
view known in writing and to request a hearing. Their comments were taken into account
where appropriate. The Commission continued to seek all information it deemed
necessary for.its definitive findings.
Apart from minor changes concerning the dumping margin of two investigated Polish
exporters which decreased from 6.3% to 5.9%, the provisional conclusions on dumping
are confirmed.
Given the fact that as far as injury, causality and community interest are concerned, no
new arguments leading to a change of the provisional conclusions were submitted, it is
confirmed that the Community industry suffered from material injury caused by dumped
imports and that it is in the Community interest to adopt definitive measures.
In view of the above findings, it is proposed to adopt the following definitive anti-
dumping measures :
 1
     OJ No L 150, 6/06/1997, p.4
2
     OJ No L 225, 15/08/1997, p. 11 and p. 13.
 ---pagebreak--- undertakings to be accepted with regard to the EUR-pallet when offered by a number
of further genuine new exporters by a Commission decision.
Duties : - no duties for two investigated companies for which no dumping was found
         - duties varying from 4% to 10.6% for the other companies investigated
         - a weighted average duty of 6.3% for co-operating companies
         - a residual duty of 10.6% for the other companies
                                                                                   au
 ---pagebreak---                                 Council Regulation (EC) No    191
                                               of....
        imposing a definitive anti-dumping duty on certain imports of flat pallets of
      wood originating in the Republic of Poland and collecting definitively the
                                 provisional duty imposed
       The Council of the European Union
       Having regard to the Treaty establishing the European Community
       Having regard to Council Regulation (EC) No 384/96 of 22 December 1995 on
       protection against dumped imports from countries not members of the European
       Community1, as amended by Regulation (EC) No 2331/962, and in particular
       Articles 9(4) and 10(2) thereof,
       Having regard to the proposal presented by the Commission after consulting the
       Advisory Committee,
       Whereas:
                               A.  PROVISIONAL MEASURES
(1)   The Commission, by Regulation (EC) No 1023/973 (hereinafter referred to as the
      provisional Regulation) imposed provisional duties on certain imports into the
1
    OJNoL56, 6.3.1996, p. 1.
2
     OJNoL317,6.12.1996,p.l.
3
    OJNoL150, 7. 6.1997, p. 4.
                                                                                      lé>
 ---pagebreak---      Community of Hat pallets of wood falling within CN code ex 4415 20 20 and
     originating in Poland. In addition, undertakings offered by certain exporters in
     connection with those imports were accepted by the same Regulation. The product
     scope of these undertakings was limited to a certain type of flat pallets of wood, i.e.
     EUR-pallets.
(2)   By Regulation (EC) No 1632/974, the Commission amended the above provisional
      Regulation by adding a provision whereby genuine new Polish exporters can be
      attributed the weighted average duty applicable to co-operating companies not
      included in the sample of exporters investigated and can have undertakings
      accepted with regard to exports of EUR-pallets.
 (3) By Regulation (EC) No 1633/975, in application of the above-mentioned new
      provision, the Commission further amended the provisional Regulation by
      including a number of genuine new exporters in the list of companies receiving the
      weighted average duty and by accepting undertakings from some of these new
      exporters.
                                B.  SUBSEQUENT PROCEDURE
 (4) Following the imposition of provisional anti-dumping duties, several interested
      parties submitted comments in writing. The parties who so requested were granted
      an opportunity to be heard by the Commission. The Commission continued to seek
      and verify all the information it deemed necessary for the purpose of its definitive
      findings.
(5)   Parties were informed of the essential facts and considerations on the basis of
      which it was intended to recommend the imposition of definitive anti-dumping
4
    OJ No L 225, 15.08.1997, p. 11.
5
    OJ No L 225, 15.08.1997, p. 13.
 ---pagebreak---      duties and the definitive collection of amounts secured by way of provisional
     subsequent to this disclosure.
(6)  The comments submitted by the interested parties were duly examined and. where
     deemed appropriate, taken into account in making the definitive findings.
                     C.   PRODUCT CONCERNED AND LIKE PRODUCT
(7)  According to Recitals (8) and (9) of the provisional Regulation, the product under
     consideration is flat wooden pallets, falling under CN code ex 4415 20 20 and
     originating in Poland.
     It appeared that the provisional anti-dumping duty on wooden pallets was not
     applied consistently by Customs authorities. For example, while some customs
     offices applied the provisional anti-dumping duty on used and repaired pallets,
     others did not. It was also reported that the anti-dumping duty had in some cases
     been applied to pallets when they were loaded with other goods for the purpose of
     importing these goods into the Community.
 (8) Despite the fact that used and repaired pallets have a similar use and physical
     characteristics closely resembling the product concerned, i.e. newly produced
     pallets, the investigation has shown that newly produced pallets on the one hand
     and used and repaired pallets on the other hand differ substantially in terms of the
     perception by potential pallet users and channels through which they are usually
     sold.
(9)  On the basis of the foregoing, it is concluded that used and repaired pallets cannot
     be considered to be like products in accordance with the provisions of 1 (4) of the
     Basic Regulation and therefore these pallets are not covered by the scope of the
     present investigation. It follows that anti-dumping measures should not apply to
      used and repaired pallets but only to imports of newly produced flat wooden pallets
      originating in Poland.
 ---pagebreak---      In addition, as regards flat pallets of wood originating in Poland which are loaded
     with other goods for the purpose of importing these goods into the Community, the
     Commission is of the opinion that these should be treated as used pallets provided
     that the pallets represent only a minor proportion of the total value of the loaded
     goods imported.
                                       D.    DUMPING
                                       1. Normal value
(10) As set out in recital (16) of the provisional Regulation, in constructing normal
     values for pallets other than the EUR-pallet, the weighted average profit margin
     relating to domestic sales found for two investigated companies which had
     representative and profitable domestic sales was used for other Polish exporters not
     having made representative and/or profitable domestic sales, in accordance with
     Article 2(6)(a) of the Basic Regulation.
(11) Two of these other Polish exporters claimed that the domestic sales used as a basis
     for determining this weighted average profit margin may not be representative due
     to circumstances which are particular to the two companies having made these sales
     and which may thus have generated exceptionally high profit levels. However, the
     investigation has shown that the sales used to calculate the weighted average profit
     margin have been made in sufficient quantities and in the ordinary course of trade,
     and that the resulting profit margin can be considered to reasonably reflect the
     actual amounts of profit realised on the Polish market.
(12) With regard to the remaining aspects of normal value, in the absence of any new
     argument raised by the interested parties, the methodology and the findings as
     described in recitals (16) to (18) of the provisional Regulation are confirmed.
 ---pagebreak---                                        2. Export price
(13) Following disclosure of the provisional findings, two Polish exporters, for whom
     export prices have been constructed in accordance with Article 2(9) of the Basic
     Regulation, and their related importer in the Community have claimed that the
     adjustments made for SG&A-expenses and profit were excessive in respect of the
     amounts actually attributed to the product under investigation.
(14) As regards profits, the Commission has re-examined the issue and has sought
     additional information and evidence from independent importers of wooden pallets
     on profits realised in the investigation period, i.e. the calendar year 1994
     (hereinafter referred to as the "IP"). As a result of this re-examination the findings
     made for the purpose of the provisional measures are confirmed and, therefore,
     retained as definitive findings.
(15) In the provisional Regulation, the amount of SG&A expenses was determined by
     allocating these expenses to the product concerned on the basis of turnover. This
     allocation key was used in the absence of a specific, historically utilised allocation
     or any other more appropriate method. The company also agreed to this approach
     during the on-the-spot verification. Afterwards the importer proposed a different
     allocation of SG&A expenses based on an estimated apportionment of all cost
     items to the product concerned and other activities of the company. However, given
     that it has not been shown that the new allocation method has been historically
     used, the claim had to be rejected and preference given to the allocation of costs on
     the basis of turnover, in accordance with Article 2(5) of the Basic Regulation.
(16) With regard to the remaining aspects concerning the determination of the export
     price, in the absence of any new argument raised by the interested parties, the
     methodology and the findings as described in recitals (19) to (21) of the provisional
     Regulation are confirmed.
 ---pagebreak---                                         3. Comparison
(17) In the absence of any new argument raised by the interested parties, the
     methodology and the findings made with regard to the comparison between the
     export price and the normal value as described in recitals (22) to (25) of the
     provisional Regulation are confirmed.
                                     4. Dumping margins
(18) As set out in recital (27) of the provisional Regulation, one single dumping margin
     was allocated to the two Polish exporters which are both related to the same
     importer in the Community, in order to preclude the possibility that future exports
     to the Community might be channelled through the company having the lower
     margin. The single dumping margin applicable to both Polish exporters concerned
     was calculated on the basis of the weighted average of the individual dumping
     margins found for each company.
(19) As a result of the revision of the methodology provisionally used to weigh the two
     margins, the definitive single dumping margin to be applied to both companies
     amounts to 5.9% instead of 6.3%.
(20) As regards the dumping margins found for the Polish exporters in the sample, the
     margin applicable to co-operating exporters not investigated and the margin
     applicable to non-co-operating exporters not investigated, in the absence of any-
     new argument, the methodology and findings as set out in recitals (26) and (28) to
     (31) of the provisional Regulation are confirmed.
(21) In view of the above, the definitive dumping margins are as follows:
 ---pagebreak---        Investigated companies included in the sample:
       • P.P.H.i.U. Eldagran, Slawoborze                                4.9%
       • Intur-Kfs, Spolka z o.o., Inowroclaw                           9.7%
       • Z.P.H. Palettenwerk Kazimierz Kozik, Bystra Podhalanska        4.0%
       • RSP Rzecko, Choszczno                                          0.0%
       • Sabelmar Import-Export, Konczyce Male                          9.8%
       • Paletex , Roman Panasiuk, Warszawa                             9.8%
       • Tor-Pal, Spolka z o.o., Kwidzyn                                0.0%
       • Z.P.P.D., Zielona Gora                                        10.6%
   2. Individually treated companies (PPHU Alpa, Spolka zo o,
      Dobrzyca and PPHU Palimex, Spolka z o o , Wloszakowice)           5,9%
   3. Co-operating companies not investigated:                          6.3%
   4. Non-co-operating companies                                       10.6%
                   E.   DETERMINATION OF THE COMMUNITY INDUSTRY
(22) As no new arguments were received in connection with the definition of the
      Community industry as set out in recital (32) of the provisional Regulation, the
      qualification of the complaining industry as the Community industry for the
      purposes of the present investigation is confirmed.
 ---pagebreak---                                          F.   INJURY
(23) A main submission with regard to injury was received from two related Polish
     exporters. They claimed that the Commission only analysed the changes in
     consumption .between the beginning and the end of the period covered by the
     examination of injury, thus not taking into account the variations which had
     occurred between 1992 and the IP. According to these exporters, the trends
     concerning consumption and other injury indicators such as sales, market share and
     production, observed between 1992 and the IP, corroborated the fact that the
     Community industry did not suffer any injury.
(24) As a matter of principle it should be recalled that in anti-dumping investigations the
     time period on which the analysis and the determination of injury is based, covers a
     period of several years. As mentioned in recital (6) of the provisional Regulation,
     in the investigation at issue this period covered the time from 1 January 1991 to the
     end of the IP, namely 31 December 1994.
     As set out in recitals (51) to (53) of the provisional Regulation, injury has been
     assessed and determined in the light of the evidence available for the period
     covering the analysis of injury by considering the development and trends of the
     various injury indicators throughout this entire period.
(25) The analysis of injury has shown that dumped imports have continuously increased
     both in absolute terms (+ 87%) as well as in terms of Community market share
     (+83%) from 1991 to the IP (1994).
(26) As regards prices, it has been found that Polish pallet prices decreased significantly
     over the above period, i.e. by 26%. Furthermore, during the IP an average price
     undercutting level of 14% was found to exist.
(27) As far as the situation of the Community industry is concerned, the investigation
     has shown that all the injury indicators investigated and analysed in detail, namely
     sales, production, capacity utilisation, market share, profitability, price evolution
     and employment have continuously deteriorated since 1991.
 ---pagebreak---       The imports under investigation therefore had a considerable impact on both the
      Community market and the Community industry. As mentioned in recital (51) of
      the provisional Regulation this conclusion was reached despite the fact that the
      Community industry's production, capacity utilisation and sales improved from
       1993 up to the IP due to the fact that this improvement was only the result of a
      recovery of Community consumption back to the level prevailing in 1991. Other
      factors, notably the development of the Community industry's market shares,
      prices and profitability, clearly showed a negative trend which can only be
      explained by the existence of the dumped imports. The argument raised by the
      Polish exporters could therefore not be accepted.
 (28) As there is no concrete or positive evidence which would allow the modification of
      the provisional conclusion made by the Commission whereby the Community
      industry had suffered material injury within the meaning of Article 3 of the Basic
      Regulation, this conclusion is confirmed.
                                G.    CAUSATION OF INJURY
(29) As far as the analysis of the causal link between dumping and injury is concerned
      the above-mentioned Polish exporters claimed that this analysis was not
      consistently based on data relating to the whole Community.
      In this respect reference is made to recitals (54) to (69) of the provisional
      Regulation where it has been established that a causal link between dumping and
      injury existed on a Community-wide level. The provisional Regulation also pointed
      out that the aforementioned conclusion has been reinforced and confirmed by a
      more detailed and thorough analysis carried out in specific Member States referred
      to as "selected markets1' in the provisional Regulation. This analysis clearly showed
      that the claim made by these two exporters could not, therefore, be accepted.
 ---pagebreak--- (30) In the absence of any further argument, the findings set out in the provisional
     Regulation are confirmed indicating that in accordance with Article 3 (6) of the
     Basic Regulation dumped imports have caused material injury to the Community
     industry.
                                H.   COMMUNITY INTEREST
(31) As no new arguments were received in connection with the Community interest
     analysis made in the provisional Regulation, the provisional findings are
     confirmed.
                             I.    ANTI-DUMPING MEASURES
(32) Based on the above conclusions on dumping, injury, causal link and Community
     interest, it was considered what form and level of anti-dumping measures would
     have to be taken in order to remove the trade-distorting effects of injurious
     dumping and to restore effective competitive conditions on the Community market.
(33) Since the level of prices at which the injurious effects of the imports would be
     removed was higher than the dumping margins found in the investigation, the level
     of the measures should be based on the dumping margins.
(34) As already mentioned in recital (2), the Commission has, at the provisional'stage of
     the investigation, accepted undertakings pursuant to Article 8 of the Basic
     Regulation in respect of the EUR pallet. Pursuant to these undertakings, the Polish
     exporters have, inter alia, offered not to sell EUR pallets below a certain minimum
     price. The undertakings also contain strict monitoring provisions. Furthermore, it
     will be recalled that exports of other pallet types than the EUR pallet made by
     exporters from which an undertaking was accepted as well as all other exports of
     the product concerned to the Community made by other exporters were subject to a
     provisional anti-dumping duty.
                                                                                        10
 ---pagebreak--- (35) It is now definitively confirmed that the combined effect of the undertakings and
      the anti-dumping duty is considered sufficient to remove the injurious effects of
      dumping. Since the investigation has now been concluded, definitive anti-dumping
      duties will be imposed in case of violation or withdrawal of an undertaking given
      by any exporter. The level of the duty for the EUR-pallet type in case of such
      breach or violation would be the same as the duty applicable to imports of other
      types of pallet.
(36) On the above basis, and, where applicable, in parallel with undertakings accepted,
      definitive duties, in the form of ad valorem duties, should be imposed.
                                      J. NEW EXPORTERS
(37) As already mentioned in recital (3) above, the Commission, by Regulation (EC)
      1633/97 amending the provisional Regulation, attributed the weighted average duty
      imposed on co-operating exporters not investigated to a number of genuine new
      exporters. By the same amending regulation the Commission accepted
      undertakings with regard to EUR-pallets from some of these new exporters, thus
     exempting them from any provisional duty with regard to that type of pallet.
     This treatment of genuine new exporters is confirmed definitively.
(38) In the meantime, the Commission has received further applications from allegedly
      new exporters. Those applicants which provided sufficient evidence showing that
      they are genuine new exporters should be made subject to the weighted average
      definitive duty. Furthermore, the new exporters from which the Commission has
      accepted an undertaking by Commission decision 97/X/EC6 should be exempted
      from any anti-dumping duty with regard to that type of pallet.
6
  See page X of this Official Journal
                                                                                      11
 ---pagebreak---    (39) A provision should be included in the Regulation imposing definitive duties
        whereby, through an amendment of that Regulation, any genuine new exporters who
        may come forward in the future shall be made subject to the weighted average duty
        and shall be exempted from any duty in case the Commission accepts undertakings
        from those exporters.
                         K.    COLLECTION OF THE PROVISIONAL DUTIES
   (40) In view of the magnitude of the dumping margins found for the exporting producers
         and in the light of the seriousness of injury caused to the Community industry, it is
         considered necessary that the amounts secured by way of provisional anti-dumping
         duties should be definitively collected at the level of the definitive duties for newly
         produced flat pallets of wood originating in Poland. Amounts secured in excess of
         the level of the definitive duties and amounts secured for repaired, used and loaded
         pallets shall be released.
HAS ADOPTED THIS REGULATION:
                                            Article 1
1. A definitive anti-dumping duty is imposed on imports of new flat pallets of wood falling
   within CN code ex 4415 20 20 (TARIC code: 4415 2020 10), originating in Poland. This
   duty shall not apply to imports of used and of repaired flat pallets of wood.
   Fiat pallets of wood'which are loaded with other gooes for the purpose of importing theie
   goods into the Community showki be treated as \m4 pfJiets provided that the goods in
   question are thf mmn purpose of the import ai*d thai tto# pallets represent only a minor
   proportion of the total value of the goods imported.
                                                                                               12
 ---pagebreak--- 2. The rate of definitive anti-dumping duties applicable to the net free-at-Community
   frontier prices, before duty, shall be as follows:
                                  Manufacturer                     Rate of   I Taric
                                                                   Duty        Additional
                                                                               Code
   Zielonogorskie Przedsiebiorstwo Przemyslu Drzewnego,              10,6%          8013
   PL-65-950 Zielona Gora
   Firma "Sabelmar" - Leszek Sabela, PL-43-525 Konczyce Male         9,8%            8014
   P.P.H.U. "Alpa" Sp. z o.o., PL-76-038 Dobrzyca                    5^9%            8011
   P.P.H.U. "Palimex" Sp. zo.o, PL-64-140 Wloszakowice               5,9%            8ÏÏÏ5
   P.W. "Intur-KFS" Sp. z o.o., PL-88-100 Inowroclaw                 9J%            8ÔÏ6
   "Paletex" Produkcja Palet, Roman Panasiuk, PL-01-601 Warszawa     9,8%           8014
   Przedsiebiorstwo Produkcyji Handlu I Uslug S.C. "Eldagran",       4,9%           8ÔÏ7
   Mr. M. Zeminski, PL-78-314 Slawoborze
   Z.P.H. "Palettenwerk" - K. Kozik, PL-34-789 Bystra Podhalanska    4,0%           8ÔÏ8
   Przedsiebiorstwo Produkcyjno Handlowe                              0%             8020
   "Tor-Pal" Sp.z.o.o.
   PL-82-500 Kwidzyn
   Rolnicza Spoldzielnia Produkcyjna Rzecko                           0%             8020
   PL-73-200 Choszczno
   Companies listed in Annex I to this regulation                    6,3%            8019
   Others                                                            10,6%          89ÔÔ
3. Unless otherwise specified, the provisions in force concerning customs duties shall apply.
                                                  Article 2
   Notwithstanding Article 1, the duties shall not apply to imports of one specific pallet
   type, namely the EUR-pallet, being a flat pallet of wood, marked by the registered mark
   "EUR" and the initials of the approving railway, manufactured, exported to the
   Community and invoiced to buyers established in the Community by the companies
   listed in Annex II to this regulation in respect of which undertakings have been accepted
   by Commission Regulation (EC) No 1023/97, as amended by Commission Regulations
   No 1632/97 and No 1633/97, and Commission Decision xx/xx/
                                                                                            13
 ---pagebreak---                                            » Article 3
The amounts secured by way of provisional anti-dumping duty under Regulation (EC)
No 1023/97 as last amended by Regulation (EC) No 1633/97 shall be definitively
collected at the duty rates definitively imposed. Amounts secured in excess of the
definitive rate of anti-dumping duty and amounts secured for repaired, used and loaded
pallets shall be released.
                                            Article 4
 1. Where any party provides sufficient evidence to the Commission that:
          - it did not export to the Community or produce the goods described in Article
            1(1) of this Regulation during the investigation period
         - it is not related to any of the exporters or producers in the exporting country
           which are subject to the anti-dumping duties imposed by this Regulation,
         - it has actually exported to the Community the goods concerned after the
           investigation period , or it has entered into an irrevocable contractual
         obligation to export a significant quantity to the Community,
then the Council, acting by simple majority on a proposal submitted by the Commission
after consulting the Advisory Committee, may amend this Regulation by adding that
party to the list of companies in Annex I.
2. Where the Commission accepts undertakings with regard to the EUR-pallet from any
    party mentioned in Paragraph 1 of this Article with regard to the EUR-pallet, the
    Council, acting by simple majority on a proposal submitted by the Commission after
    consulting the Advisory Committee, may amend this Regulation by adding
    that party to the list of companies in Annex II.
                                                                                           14
 ---pagebreak---                                              Article 5
  This Regulation shall enter into force on the day following its publication in the Official
  Journal of the European Communities.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels,      1997
                                                                For the Council
                                                                                              15
 ---pagebreak---                                                                                     ANNEX 1
Manufacturer
 "Baum-Holz" S.C., PL-10-547 Olsztyn
 "DAST" GmbH, PL-60-682 Poznan
 Drew-Pol Export-Import, Mr. Wodarz Norbert, PL-46-030 Murow
 Eugeniusz Dziurny - Czeslaw Nowak, PL-38-313 Snietnica
 F.P.H. "Tina" - E.J. Grabias, PL-40-733 Katowice
 Firma Produkcyjno-Handlowa, Mr. Tadeusz Fisher, PL-87-313 Maly Gleboczek
 Firma Produkcyjno-Uslugowo-Handlowa "Rol-Mar", Mr. Adam Piatek, PL-57-300 Klodzko
 Import-Export, Miroslaw Przybyiek, PL-98-363 Klonowa
 Internationale Paletten Company, PL-84-300 Lebork
 "Kross-Pol" Sp. z.o.o., PL-78-100 Kolobrzeg
 P.P.H/'Drewnex" S.A., PL-31-159 Krakow
 P.P.H. "GKT" S.C., PL-23-414 Majdan Nowy
 P.P.H. "Pamadex" J. Szczypka, PL-43-518 Ligota
 P.P.H. "Unikat", PL-23-408 Aleksandrow IV
 P.P.H.U. "Adapol" S.C., PL-05-200 Wolomin
 P.P.H.U. "Aiwa" Sp. z.o.o., PL-76-123 Tychowo
 P.P.H.U. "SMS" - St. Mrozowicz, PL-83-320 Suleczyno
 P.T.H. "Mirex", PL-78-100 Kolobrzeg
 P.W. "Peteco" Sp. z.o.o., PL-04-330 Warszawa
 Parafia Rzymsko-Katolicka, Mr. B. Niepokalaneg Dzialalnose Gospodaroza, PL-33-300 Nowy Sacz
 Produkcja Palet "Andrzej Adamus", Mr. Marek Gajzler, PL-63-523 Kuznia Grabowska
 Produkcja, Skup Palet Drewnanych, Stanislaw Lachowicz, PL-37-536 Majdan Sieniawski 170
 Przedsiebiorstwo "Amesko", Mr. Andrzej Skora, Director, PL-55-100Trzebnica
 Przedsiebiorstwo Handlowe Uslugowe "Justyna", PL-66-620 Gubin
 Przedsiebiorstwo Handlowe-Uslugowe "Akropol", PL-30-140 Krakow
 Przedsiebiorstwo Handlowe Uslugowe Produkcyjne "Lech", Mr. Lech Szwec, PL-68-200 Zary
 Przedsiebiorstwo Obrobki Drewna "Palet-Pol" Sp. o.o., Mr. Andrzej Niemiec, PL-66-311 Dabrowka
 WLKP
 Przedsiebiorstwo Produkcyjno Handlowe, Zygmunt Skibinski, PL-87-820 Kowal
 Przedsiebiorstwo Produkcyjno Handlowe-Uslugowe, "AWA" Sp.z.o.o., PL-33-300 Nowy Sacz
 Przedsiebiorstwo Wielobranzowe, Mr. Zdziolaw Milocki, PL-14-100 Ostroda
 "Scan-Product-System Wood" S.A., Podczerwone, PL-34-470 Czarny Dunajec
 S.C. "Bed", Mr. DariuszZuk, PL-21-004 Krasienin
 S.U.T.R. "Rol Trak", PL-59-230 Prochowice
  Stolarstwo Export-Import, Mr. Tadeusz Swirski, PL-57-520 Dlugopole Zdroj
                                                                                               16
 ---pagebreak--- • Torunskie Przedsiebiorstwo Przemyslu Drzewnego w Toruniu, Mr. Adam Wisniewski, PL-87-100
  To run
• "Transdrewneks" Sp. z.o.o., PL-86-317 Grudziadz-Owczarki
• W.Z.P.U.M. "Euro-Tech", Import-Export Spedycja, PL-87-111 Rakszawa
» Wytwazanie Skrzyn i Opakowan Drewnianych, Malgorzata i Ryszard Nowak, PL-77-207 Piaszyna
• Zaklad Produkcyjno Bohuszko, Mr. Ryszard Bohuszko, PL-69-220 Osno
  Zaklad Produkcyjno Handlowy "Maw" S.C., Mr. Andrzej Kulej, PL-58-536 Lubomierz
  Zaklad Uslugowo-Handlowy "Rolmex", Mr. E. Cackowski, Direktor, PL-87-600 Lipno
  Zaklad Wielobranzowy Produkcyjno Uslugowy, Ryszard Potoniec, PL-33-370 Muszyna
  Zakzad Przerobu Drewna, J.Z.S. Kawinscy, PL-78-500 Drawsko Pomorskie
  Zphu "Drewex", Spolka Cywilna, Ms. Agnieszka Pawlaczyk, PL-66-440 Skwierzyna
  ZPHU "Sek-Pol" - "Hadpol*- - Krzysztof Hadrys, PL-39-400 Tarnobrzeg
  "Euro-Mega-Plus" Sp. z o.o., PL-25-632 Kielce
  "C.M.C", Sp. z.o.o., PL-31-213 Krakôw
  Wyrôb, Sprzedaz, Skup Palet, Josef Kolodziejczyk, PL-23-408 Aleksandrôw IV 704
  Firma Produkcyjno Transportowa, Marian Gierka, PL-87-300 Brodnica
  ZPHU "Drewnex", S.C. Export-Import, PL-62-818 Zelazkôw 45 b
  Import-Export "Elko", Sp. z o.o., PL-62-800 Kalisz
  PPHU "Probox", Import-Export, PL-62-800 Kalisz
  Drewpal, S.C, PL-62-820 Stawiszyn
  Zaman, S.C, PL-26-600 Radom
  "Marimpex", PL-24-100 Pulawy
  "Aven", Sp. z.o.o., PL-66-470 Kostrzyn
  P.P.H.U. "Eurex" S.C, PL-98-276 Godynice
  P.H. "Drewex SC, PL-84-300 Lebork
  MACED Sklad Palet, Jadu iga Macionga, PL-77-200 Miastko
  ENKEL Spôlka Cywilna. PL-24-100 Pulawy
  PAL-PACK s.p.z.o.o., PL-78-530 Wierzchowo
  Produkcja Stolarska Posrednictwo Export-Import, W.i.T. HENSOLDT, PL-84-300 Lebork
  Biuro Uslugowo-Handloue. Wieslaw Rzezniczek, PL-84-300 Lebork
  Przedsiebiorstwo Produkovjno Uslugowo Handlowe "DREWPOL", PL-98-277 Braszewiçe
  PTN Kruklanki Sp. Z. o.o.. PL-11-612 Kruklanki
  WEDAM Spôlka Cywilna. PL-83-322 Stezyca
  Import-Export Jan Sibinski. PL-63-524 Czajkow
  Zaklad Produkcyjny "Tarta", PL-68-300 Lubsko
  Firma "Krausdrew", PL-84-312 Cewice
  "Lidal" Spolka Cywilna, PL-77-200 Miastko
  Zaklad Przerobu Drewna Import-Export, Stanislaw Kociolek, PL-57-540 Ladek Zdroj
  P.P.H.U. "Alk", PL-73-240 Bierzwnik
                                                                                           17
 ---pagebreak--- "Empol" s.c, PL-62-812 Jastrzebniki 37
Zaklad Produkcji Drzewnej Nr. 1, Export-1 m port, Julian Bartkowski, PL-38-500 Sanok
Przedsiebiorstwo Produkcyjno Handlowe "Drewex", PL-64-700 Czarnkow
"ZAP" Przedsiebiorstwo Handlowe-Uslugowe Sp.C, PL-67-400 Wschowa
P.P.H.U. "OPAL", Zygmunt Podgorski, PL-38-505 Bukowsko41
"Algepa-Pol", Spolka z.o.o., PL-68-300 Lubsko
                                                                                     18
 ---pagebreak---                                                                                        ANNEX II
Manufacturer                                                    I Tarie Additional Code
"Baum-Holz" S.C.,- PL-10-547 Olsztyn               \              857Ô
Eugeniusz Dziurny - Czeslaw Nowak, PL-38-313 Snietnica            8571
F.P.H. "Tina" - E.J. Grabias, PL-40-733 Katowice                  8572                    ~~
Firma "Sabelmar" - Leszek Sabela, PL-43-525 Konczyce Male         8573                     ~
Import-Export, Miroslaw Przybyiek, PL-98-363 Klonowa              8574                     ~
Internationale Paletten Company, PL-84-300 Lebork                 8575                    ~~
"Kross-Pol" Sp. z.o.o., PL-78-100 Kolobrzeg                       857(5                    ~
P.P.H."Drewnex" S.A., PL-3 1-159 Krakôw                           8577
P.P.H. "GKT" S.C, PL-23-414 Majdan Nowy                           8584
P.P.H. "Pamadex" J. Szczypka, PL-43-518 Ligota                    8581
P.P.H. "Unikat", PL-23-408 Aleksandrow IV                        8586
P.P.H.U. "Adapol" S.C, PL-05-200 Wolomin                          8587
P.P.H.U. "Alpa" Sp. zo.o., PL-76-038 Dobrzyca                     8581
P.P.H.U. "Aiwa" Sp. z.o.o., PL-76-123 Tychowo                     8581
P.P.H.U. "Palimex" Sp. zo.o., PL-64-140 Wloszakowice             8590
P.P.H.U. "SMS" - St. Mrozowicz, PL-83-320 Suleczyno              8591
P.T.H. "Mirex", PL-78-100 Kolobrzeg                              8597
                                                                                     :
P.W. "Intur-KFS" Sp. z o.o., PL-88-100 Inowroclaw                8661
P.W. "Peteco" Sp. z.o.o., PL-04-330 Warszawa                     8690
"Paletex" Produkcja Palet, Roman Panasiuk, PL-01-601 Warszawa    8691
Produkcja Palet "Andrzej Adamus", Mr. Marek Gajzler, PL-63-523   8692
Kuznia Grabowska
Przedsiebiorstwo Produkcyjno Handlowe, Zygmunt Skibinski, PL-    8693
87-820 Kowal
Przedsiebiorstwo Handlowe-Uszugowe "Akropol", PL-30-140          8713
Krakow                           •
S.U.T.R. "Roi Trak", PL-59-230 Prochowice                        8714
"Scan-Product-System Wood" S.A., Podczerwone, PL-34-470          8715
Czarny Dunajec            _^__
"Transdrewneks" Sp. z.o.o., PL-86-317 Grudziadz-Owczarki         8716
W.Z.P.U.M. "Euro-Tech", Import-Export Spedycja, PL-87-111        8725
Rakszawa
Z.P.H. "Palettenwerk" - K. Kozik, PL-34-789 Bystra Podhalanska   8726
Zakzad Przerobu Drewna, J.Z.S. Kawinscy, PL-78-500 Drawsko       8745
Pomorskie                                                      j
                                                                                             19
 ---pagebreak--- Manufacturer                                                 Tarie Additional Code
ZPHU "Sek-Pol" - "Hadpol" - Krzysztof Hadrys, PL-39-400      8526
Tarnobrzeg
"Euro-Mega-Plus" Sp. z o.o., PL-25-632 Kielce                8527
 "C.M.C", PL-31-213 Krakôw                                   8528
Wyrôb, Sprzedaz, Skup Palet, Josef Kolodziejczyk, PL-23-408  8529"
Aleksandrôw IV 704
Firma Produkcyjno Transportowa, Marian Gierka, PL-87-300     8530
Brodnica                           '
ZPHU "Drewnex", S.C Export-1 m port, PL-62-818 Zelazkôw 45 b  8531
Import-Export "Elko", Sp. z o.o., PL-62-800 Kalisz           8531
PPHU "Probox", Import-Export, PL-62-800 Kalisz               8533
Drewpal, S.C, PL-62-820 Stawiszyn                            8531
Zaman, S.C, PL-26-600 Radom                                  8531
"Marimpex", PL-24-100 Pulawy                                 8537
P.P.H.U. "Eurex" S.C, PL-98-276-Godynice                     8538
MACED Sklad Palet, Jadwiga Macionga, PL-77-200 Miastko       8539
ENKEL Spôlka Cywilna, PL-24-100 Pulawy                       854Ô
Produkcja Stolarska Posrednictwo Export-Import, W.i.T.       8541
HENSOLDT, PL-84-300 Lebork
Przedsiebiorstwo Produkoyjno Uslugowo Handlowe "DREWPOL",    8834
PL-98277 Braszewice
PTN Kruklanki Sp. Z.o.o., PL-11612 Kruklanki                 8556
                                                   :
WEDAM Spôlka Cywilna, PL-83-322 Stezyca                      8557
"AVEN" Sp. Z o.o., PL-66-470 Kostrzyn                        8558
Import-Export Jan Sibinski, PL-63-524 Czajkow                8559
"Empol" s.c, PL-62-812 Jastrzebniki 37                       8560"                 ~~
P.P.H.U. "Alk", PL-73-240 Bierzwnik                          8561
                                                                                      20
 ---pagebreak---  ---pagebreak---                                                                   ISSN 0254-1475
                                                           COM(97) 569 final
                                             DOCUMENTS
EN                                                                    02   11
                                    Catalogue number : CB-CO-97-584-EN-C
                                                             ISBN 92-78-26780-5
Office for Official Publications of the European Communities
L-2985 Luxembourg
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