EU anti-dumping investigation concerning imports of Fused Alumina from China

THE EUROPEAN REFRACTORY INDUSTRY’S PERSPECTIVE

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AGENDA

1. Introduction
2. Brief comments on the complaint and the scope of the investigation
3. Union interest : the impact of antidumping duties on EU industries
4. Conclusions : what are we advocating for ?

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1. INTRODUCTION

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The European Refractories Producers Federation – founded in 1953

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PRE and its Members

PRE represents national associations from 15 EU Member States and four EU-based multinational companies

• Austria
• Czech Republic – Slovakia
• France
• Germany
• Italy
• Poland
• Slovenia – Croatia
• Spain – Portugal
• Sweden – Denmark – Finland – Norway

• Calderys
• Refratechnik
• RHI Magnesita
• Vesuvius

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The EU refractory industry

• Over 20,000 direct jobs and 60,000 indirect jobs in the EU
• EUR 4 billion revenue in 2023

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Refractories are crucial inputs in several industrial sectors and particularly for the iron and steel sector

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EU refractory industry is both trade-exposed and export-oriented

• € 2,5 billion of exports in 2023
• Trade balance already showing a decline as imports increased presence in the EU

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Trade balance in the EU refractory industry (in million tons)

What are refractory products ?

• Refractories are technologically advanced heat resistant, ceramic materials that can withstand thermal and mechanical abuse and chemical corrosion at extremely high temperatures. They play a critical role in the daily operations of almost every primary sector of finished goods manufacturing.

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• Supplied to customers in powders (monolithics), bricks, custom-shaped or functional products, refractories protect furnaces and other equipment from the inside by safely containing countless different materials, as they are melted, burned, shaped, or bonded.

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What is Fused Alumina ?

Source : unioncement.com

Other applications

Foundry, technical ceramics or electrical components

60%

30%

10%

End users of Fused Alumina

Fused Alumina’s production process & cost structure

60-65% of costs

20-25% of costs

85-90% of costs

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EU antidumping investigation on Fused Alumina imports from China

• Complaint filed by Imerys, on behalf of the Union industry of fused alumina, on 9 October 2024.
• Notice of initiation published by the European Commission on 21 November 2024.
• Product investigated : Fused Alumina (all sub-types)

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• Provisional measures adopted on 18 July 2025 (full Regulation here)
• Provisional duties ranging between 111,9% and 136,3% were imposed;
• Duties will be collected starting from 18 July (publication in the official journal);
• They cover all sub-types of fused alumina imported from China.

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• Definitive measures : Q4 2025
• Disclosure expected end of October 2025
• Regulation : January 2026

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2. BRIEF COMMENTS ON THE COMPLAINT AND ON THE SCOPE OF THE INVESTIGATION

EU investigation on Fused Alumina imports from China

Antidumping duties can only be applied by the EU when the complainant proves :

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• Dumping from Chinese exporters :​
• Comparison between (constructed) normal value of the product and export price to the EU. The difference is called the dumping margin. ​Complainant claims an average dumping margin of 150%.
• BUT the complainant’s demonstration is based on faulty comparison and erroneous data.

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• Injury caused by dumped imports :​
• Complainant must demonstrate that the Union industry suffers injury due to the dumped imports (loss of market share, surge in imports, low profitability, employment impact)
• BUT the injury suffered by Imerys is due to a combination of its own business decisions (production process, purchasing strategy) and of high raw material and energy prices in the EU.

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• Imposition of duties is in the Union’s interest :
• Complainant must demonstrate that the imposition of duties in the Union’s interest
• BUT F.A. is a key raw material for refractories, and potential cost increase will harm not only EU refractory producers but also other strategic downstream industries, including steel producers.

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Issues regarding the existence of material injury

• Import volume: imports from China decreased in absolute terms during the period; import levels also remained within historical volumes
• Price/cost evolution: Union industry was generally able to increase prices and keep them above costs
• Market share: Union industry’s share remained largely stable, decreasing by only 6% in the IP
• Investment: Complainant maintained high levels of investment throughout the period; between 2021 and 2022 alone, investment jumped by 180%
• Stock: Complainant’s stock remained stable during the period, with only a small increase in the IP

Several economic indicators are not consistent with a finding of ‘material injury’

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Issues regarding causality

Several “other known factors” have contributed to any injury suffered by the Union industry in such a way that effectively breaks the causal link in the case

• Contraction in EU demand: consumption in the IP decreased by almost 30% below 2021 levels
• Increase in production costs and productivity issues: Union industry faced crippling cost increases in the period, particularly for energy; cost increases exacerbated long-standing productivity issues
• Self-imports: Imerys imports FA from its own subsidiaries in China and Bahrein, in a clear attempt to sidestep its EU productivity issues
• Export performance: Complainant’s exports decreased by 46% during the period

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EU refractory industry cannot substitute imports from China through available Union supply

BFA

Refractory-grade FA

• Limited production of BFA: only Imerys is producing BFA in one plant located in La Beyrède. BFA is predominantly sourced abroad.

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• Limited sustainability: WFA and BFA are produced in different plants and are viewed as not substitutable by downstream users in terms of technical characteristics and price.

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• Majority of the Union production is of abrasive-grade : only between 20% and 30% of the Union production of FA is dedicated to refractory-grade FA.

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• Limited interchangeability: abrasive and refractory-grade FA may be used interchangeably only for certain applications. This interchangeability is however mostly from the abrasive side.

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• No data or analysis on EU production of refractory-grade FA & BFA (Brown fused alumina) in the Provisional Regulation
• Supply security would be compromised due to the limited production in the Union.

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4. UNION INTEREST : THE IMPACT OF ANTIDUMPING DUTIES ON EU INDUSTRIES

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AD measures will have a substantial impact on the EU refractory industry

FA is an essential input for the EU refractory industry

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• FA can represent up to 90% of the raw material cost for refractory products that require this input

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• Cost of raw materials can represent 60% or more of the total cost of certain products

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• AD measures would have a substantial impact on the cost structure of FA-using refractory products produced in the EU

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AD measures will have a substantial impact on the EU refractory industry

The EU refractory industry will be unable to pass on cost increases

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• It will be extremely difficult for EU producers to increase their prices 🡪 main consumer industry is the EU iron and steel industry, which has been experiencing a prolonged recession and will strongly resist any attempt at price increase

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• EU refractory market is extremely open and competitive – non-EU competitors that are not exposed to this cost impact will have an immediate and significant price advantage over EU producers

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AD measures will have a substantial impact on the EU refractory industry

Measures will severely compromise the EU industry’s competitiveness

• EU industry will be unable to compete with 3rd country refractory products in the EU: Industry is highly trade-exposed 🡪 included in the Commission’s “carbon leakage risk list” under ETS 1

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• EU industry will be unable to compete with 3rd country products in export markets: Export sales are essential for EU refractory producers

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Expected cost increase will fundamentally change the economic reality of the EU refractory industry for large and smaller producers alike – harm to EU industrial base will far outweigh any benefits to the Union FA industry

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There will be no increased production of refractory-grade FA in the EU

The imposition of AD measures will not lead to a significant increase in production of refractory-grade FA in the EU that can replace imports from China

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• No business case for Union FA industry to “reactivate idled capacities” and resume focus on refractory-grade FA 🡪 product is too expensive to produce in the EU in view of the small margins relative to abrasive-grade

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• Union industry has made clear that it intends to supply the EU market from offshore production sites

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Protection from AD measures would reinforce Imerys’ dominant position

• EU FA market is already highly concentrated (4 EU producers only : Imerys, Motim, Niche, Saint Gobain), with Imerys holding a clear dominant position (70% of EU FA production capacity, monopoly on refractory-grade BFA).
• Commission already identified the problematic level of concentration (Imerys/Alteo transaction in 2016), focusing on bubble alumina. Similar concerns exist today for several FA products
• The presence of Chinese imports is essential to ensure the competitiveness of the EU market. Imports from third countries are not significant and cannot exert competitive pressure

Any import increase will only benefit Imerys’ subsidiaries in places like Brazil and Bahrein, reinforcing its dominant position and ability to dictate prices in the EU

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Overall impact of potential duties on the FA trade

• If duties are imposed, EU F.A. price will increase (higher demand, lower offer) while global F.A. prices will decrease due to the redirection of Chinese exports to third countries.
• Consequently, competitiveness of EU refractories will decrease due to higher production and raw materials costs, while refractories production in third countries will become cheaper.
• At the same time, the EU F.A. industry will not benefit from this market evolution since F.A. users will be incentivized to buy from third countries instead of from EU producers.

In this scenario, all EU industries will lose competitiveness (F.A. producers, refractories producers, downstream industries)

Downstream industries oppose imposition of anti-dumping measures

Commission’s Provisional Regulation, recital 300:

“The Commission estimated that, if duties are imposed at the proposed level […], the cost of production for users could increase by between 10 % and 30 %, depending on the specific company.

European Industries’ Joint Statement:

“Overall, given the risk of supply shortage and the high impact that any increase of production costs would have on the entire downstream value chain, including on steel producers, PRE, FEPA, VDS and other co-signatories strongly oppose the imposition of duties on fused alumina imports from China. Signatories urgently call on the Commission to reconsider its provisional findings in view of the the critical importance of fused alumina for refractories and abrasives producers, as well as other strategic European industries, and to base any future decisions on a value-chain approach.”

Downstream industries outweighs the Union FA Industry

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• 4 companies
• Approximately 1,000 direct jobs
• < 0.2 billion euros in sales*

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*Estimation based on the sales in volumes and the average unit sales price in the Union.

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• Around 50 companies and associations
• > 39,000 direct jobs*
• > 6 billion euros in revenue**

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*20.000 jobs in the refractories industry, and estimation based on 19.000 in the abrasives industry.

**Turnover for the abrasive industries was provided for Italy and Germany alone (EUR 2,3 billion in annual revenue).

Union FA industry

Downstream users

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5. CONCLUSIONS

What are refractories producers advocating for ?

• The European Commission should terminate the investigation and not impose antidumping duties on Fused Alumina imports.

Criteria set out in the Basic Antidumping Regulation (Reg. EU 2016/1036) are not met :

• Dumping calculation is based on faulty values.
• There is no causal link between Chinese imports and the alleged injury suffered by Imerys.
• Imposition of duties is certainly not in the Union’s interest, as recalled by many industries.

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• EU Members States should oppose the imposition of duties to protect EU jobs and the competitiveness of strategic EU industries like refractories, steel, cements, glass.

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What are refractories producers advocating for ?

• At the very least, mitigation measures should be implemented to avoid further harming a strategic EU industry, by :
• Excluding products subject to a risk of supply shortage from the scope of the duties (such as Brown Fused Alumina and refractories raw materials).

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• Extending any duty to indirect imports in the form of finished goods.

This presentation and the position expressed are co-signed by :

For further information regarding PRE’s position and actions in this investigation, please contact :

• Mr. Omid MAJIDI, Trade Policy Manager, PRE (majidi@pre.eu / +32.491.87.78.73)

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Appendix

Appendix – Bauxite prices

• Complainant falsely claims that “China’s prices for bauxite are also significantly lower as compared to prices in representative international markets”.

China

Europe

Appendix – Fused Alumina trade

• No link between the decrease of EU F.A. exports and Chinese exports

EU exports of Fused Alumina decrease between 2021 and the investigation period (IP)…

…BUT none of these markets experienced an increase of imports from China (except UK)

EU exports of fused alumina (CN code 281810), 2021-IP, by main export market, in volume (tons)

Chinese exports of fused alumina (28181010 & 28181090), 2021-IP, by main EU export market, in value (USD)

Appendix – Causality between dumped imports and injury

• The lack of competitiveness of the EU F.A. industry is mostly due to high production costs in the EU

Inflation rate in the EU (2020-present)

Electricity prices as of Q1 2023 (€/MWh)

Source : complaint by Imerys

Appendix – Causality between dumped imports and injury

• The injury suffered by the EU F.A. industry is due to a diminution of EU consumption of F.A.

Evolution of EU consumption and imports from China of Fused Alumina, and of Complainant’s profitability

Appendix – Causality between dumped imports and injury

• The injury suffered by the EU F.A. industry is due to a diminution of EU consumption of F.A.

Production in EU refractory industry

Source : Eurostat

Lower refractory production = lower F.A. consumption

Appendix - Comparison physical differences (PSD) between refractory-grade and abrasive-grade Fused Alumina

Technical data sheet WFA Refractory (Traxys)

Technical data sheet WFA Abrasive (Traxys)

Appendix – The refractory industry

• Cost increase of refractories raw materials will impact many strategic EU industries

Top 3 end-users of refractories (> 70% of sales)

THANK YOU FOR YOUR ATTENTION