Commission Implementing Regulation (EU) 2025/1189of 13 June 2025imposing provisional anti dumping duties on imports of screws without heads originating in the People’s Republic of China

(163) Having established that Thailand is at this stage considered an appropriate representative country within the meaning of Article 2(6a)(a), these claims were dismissed.

3.2.7.3.

Labour

(164) The Commission used the last available statistics published by the Bank of Thailand

https://app.bot.or.th/BTWS_STAT/statistics/BOTWEBSTAT.aspx?reportID=636&language=ENG (last consulted 3 April 2025).

to establish the benchmark for labour. The Bank of Thailand provided information on a quarterly basis on the average monthly wages in Thailand in the manufacturing sector for the investigation period. These were adjusted to include social charges charges payed by the employer

https://www.papayaglobal.com/countrypedia/country/thailand/ (last consulted 3 April 2025).

.

(165) Information on worked hours was not available in the statistics published by the Bank of Thailand, therefore the Commission used information on hours per week worked in Thailand as provided by the Labor Force Statistics database of the International Labor Organization

ILO, Labor Force Statistics database, Mean weekly hours actually worked per employed person by sex and economic activity – Annual, Thailand. https://rshiny.ilo.org/dataexplorer35/?lang=en&segment=indicator&id=HOW_TEMP_SEX_ECO_NB_A&ref_area=THA (last consulted 3 April 2025).

.

(166) Consequently, the Commission calculated the labour cost per hour in Thailand by dividing the annual labour cost by the annual hours worked.

(167) Following the Second Note, both Junyue and Chinafar Group contended that the Commission should use the actual worked hours of the Chinese exporting producers to calculate the benchmark for labour, instead of ILO data.

(168) In their view, this was justified since Article 2(6a) of the basic Regulation only prevented the use of data related to prices and costs in the exporting countries and, by contrast, non-price- related information should not be automatically discarded.

(169) The Commission noted that it had used the actual worked hours by the Chinese exporting producers and, as part of the calculation of the normal value, had multiplied them with the corresponding cost in Thailand. The purpose of the methodology was to recalculated how much these worked hours would cost in the representative country. The labour cost in Thailand would necessarily be the ratio between the total cost of labour and the total hours of labour in Thailand. The claim was therefore rejected.

3.2.7.4.

Electricity

(170) In the Second Note, the Commission announced that it intended to use the quotation of the electricity price for business, industrial and state enterprises published by the Thailand Board of Investment

○ BOI : The Board of Investment of Thailand (last consulted 3 April 2025).

, using the Time of use tariff (TOU tariff) – Large General Service, Voltage level below 22 Kv in order to calculate the benchmark for electricity.

(171) This energy is unchanged since 2018 and is updated on a monthly basis using the instrument called Ft surcharge. Electricity charges billed for each month are therefore calculated as:

(a) an electricity base charge, according to the tariffs described above and which remained constant over the years;

(b) an energy adjustment charge (Ft), which is periodically updated by the Thai Energy Regulatory Commission (ERC) and published by the Metropolitan Electricity Authority

https://www.mea.or.th/en/our-services/tariff-calculation/latestft (last consulted 3 April 2025).

.

(172) After the Second Note, the Commission established a benchmark for electricity for each sampled exporting producer based on the respective peak and off-peak consumption. The resulting usage was allocated to the peak and off-peak rates.

(173) In addition, the Commission decided to include both the demand charge and the service charge in the electricity rate benchmark, to fully reflect the cost of electricity in the representative country. The service charge was expressed as a fixed amount per month, while the demand charge was established, in kW, based on the conservative calculation of the electricity demand. This was established by dividing the total peak consumed energy by the number of production hours. The weighted average rate for both peak and off-peak was established as a respective benchmark for each sampled exporting producer.

(174) In the Second Note, the Commission stated that it would deduct the value added tax (VAT) from the electricy rates. However, after further investigation, the Commission established that electricity prices in Thailand were quoted exclusive of VAT.

3.2.7.5.

Natural gas

(175) To establish the benchmark for natural gas, the Commission used the prices published by the Energy Policy and Planning Office of the Ministry of Energy

Ministry of Energy – Energy policy and planning office (Table 7.2.4) https://www.eppo.go.th/index.php/en/en-energystatistics/energy-economy-static (last consulted 3 April 2025).

, namely Table 7.2-4, which illustrates the Final Energy Consumption Per Capita. The Commission used as benchmark the average of 2023 and 2024 data indicated in that Table.

3.2.7.6.

By-products

(176) To establish the benchmark for by-products, the Commission used the ratio between the value of the by-products and the value of the original raw material, as recorded in the exporting producers’ accounting system and applied this ratio to the benchmark obtaing from GTA.

3.2.7.7.

Manufacturing overhead costs, SG & A and profits

(177) According to Article 2(6a)(a) of the basic Regulation, the constructed normal value shall include an undistorted and reasonable amount for administrative, selling and general costs and for profits. In addition, a value for manufacturing overhead costs needs to be established to cover costs not included in the factors of production referred to above.

(178) The manufacturing overheads incurred by the cooperating exporting producers were expressed as a share of the costs of manufacturing actually incurred by the exporting producers. The percentage was applied to the undistorted costs of manufacturing.

(179) For establishing an undistorted and reasonable amount for SG & A and profit at the ex-works level of trade, the Commission relied on the financial data for 2023 for the companies Sanwa Iron (Thailand) Company Ltd. and Thai Meira Co. Ltd., as extracted from Orbis.

3.2.8.

Calculation

(180) On the basis of the above, the Commission constructed the normal value per product type on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation.

(181) First, the Commission established the undistorted manufacturing costs. The Commission applied the undistorted unit costs to the actual consumption of the individual factors of production of the cooperating exporting producer. These consumption rates were verified during the verification. The Commission multiplied the usage factors by the undistorted costs per unit observed in the representative country.

(182) Once the undistorted manufacturing cost established, the Commission applied the manufacturing overheads, SG & A and profit as noted in recitals (178) and (179).

(183) SG & A expressed as a percentage of the Costs of Goods Sold (COGS) and applied to the undistorted costs of production, amounted to 8 %. The profit expressed as a percentage of the COGS and applied to the undistorted costs of production, amounted to 21,2 %.

(184) On that basis, the Commission constructed the normal value per product type on an ex-works basis in accordance with Article 2(6a)(a) of the basic Regulation.

3.3.

Export price

(185) The sampled exporting producers exported to the Union directly to independent customers.

(186) The export price was the price actually paid or payable for the product concerned when sold for export to the Union, in accordance with Article 2(8) of the basic Regulation.

3.4.

Comparison

(187) Article 2(10) of the basic Regulation requires the Commission to make a fair comparison between the normal value and the export price and to make allowances for differences in factors which affect prices and price comparability. The Commission compared the normal value and the export price of the sampled exporting producers at ex-works level. As further explained below, where appropriate, the normal value and the export price were adjusted in order to: (i) net them back to ex-works level; and (ii) make allowances for differences in factors which were claimed, and demonstrated, to affect prices and price comparability.

3.4.1.

Adjustments made to the normal value

(188) As explained in recital (180) the normal value was established at ex-works level and therefore, no adjustments were necessary.

(189) In their comments to the Second Note, Junyue argued that the methodology used by the Commission to establish the SG & A ratio might result in an unfair comparison between the normal value and the export price, since the SG & A used to construct the normal value likely contained expenses, which are similar to those incurred by Junyue that would be deducted by the Commission to determine the ex-works export price.

(190) Junyue contended that it was for the Commission to provide a detailed breakdown of SG & A expenses to ensure no overlap with expenses already removed from the export price. If such detail was unavailable, the Commission should not perform any adjustment to the export price.

(191) Junyue made reference to the judgement of the General Court in the Case T-762/20

Sinopec Chongqing SVW Chemical and Others v Commission.

Sinopec which is under appeal

Case C-319/24 P, Commission v Sinopec Chongqing SVW Chemical and others, pending.

, and which considered this point of adjustment of the export price under Article 2(10) of the basic Regulation where the normal value had been constructed under Article 2(6a) of the basic Regulation.

(192) As explained in recital (187) the Commission chose to compare the export price and the normal value at the ex-works level of trade. As explained in recital (180) the normal value was established at the ex-works level of trade by using costs of production together with amounts for SG & A and for profit, which were considered to be reasonable for that level of trade. Therefore, no adjustments were necessary to net the normal value back to the ex-works level.

(193) In its judgement in CCCME, which was subsequent to the Judgement in Sinopec, the General Court first recalled that in accordance with the case-law, if a party claims adjustments under Article 2(10) of the basic Regulation in order to make the normal value and the export price comparable for the purpose of determining the dumping margin, that party must prove that its claim is justified. The burden of proving that the specific adjustments listed in Article 2(10)(a) to (k) of the basic regulation must be made lies with those who wish to rely on them

Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 183.

. It follows that, in that case, as in this investigation, it was for the interested parties, in accordance with that case-law, to demonstrate the need for the adjustment requested in support of evidence which they adduced during the investigation

Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 185.

.

(194) The General Court then held that it should be noted that although the practice of making adjustments may prove to be necessary, under Article 2(10) of the basic Regulation, to take account of differences between the export price and the normal value which affect their comparability, such deductions cannot be made with respect to a value which has been constructed and which is not, therefore, genuine. That value is not generally affected by factors which might damage its comparability, because it has been artificially established

Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para 188.

. Moreover, as in the case of CCCME, in the case at hand the construction of the normal value per product type on an ex-works basis included a reasonable amount for SG & A costs and there was no information available showing that the SG & A costs of the two Thai companies concerned included transport expenses for the delivery to customers. Consequently, in view of the Commission’s discretion in the application of Article 2(10) of the basic Regulation

Judgement of 2 October 2024, CCCME and Others v Commission, T-263/22, ECLI:EU:T:2024:663, para. 184.

, the Commission’s approach adhered to the most recent case-law concerning unsubstantiated claims that amounts for SG & A costs used in the construction of the normal value under Article 2(6a)(a), which are considered by the Commission to be reasonable for the ex-works level of trade, contain transport costs. The claim was therefore rejected.

3.4.2.

Adjustments made to the export price

(195) In order to net the export price back to ex-works, adjustments were made on the account of: freight, insurance, handling loading, as well as packing and discounts.

(196) Allowances were made for the following factors affecting prices and price comparability: credit cost and bank charges.

(197) Regarding the adjustment of the export price for commissions, the Commission found that the related company involved in the transactions was performing functions similar to those of an agent working on a commission basis, while using the staff of the exporting producer. Thus, the adjustment for a commission was constructed based on the related company’s SGA, the portion of SG & A costs of the exporting producer related to the related company’s functions and a nominal profit.

3.5.

Dumping margins

(198) For the sampled cooperating exporting producers, the Commission compared the weighted average normal value of each type of the like product with the weighted average export price of the corresponding type of the product concerned, in accordance with Article 2(11) and (12) of the basic Regulation.

(199) On this basis, the provisional weighted average dumping margins expressed as a percentage of the CIF Union frontier price, duty unpaid, are as follows:

CompanyProvisional dumping margin (%)

Zhejiang Junyue Standard Part Co., Ltd.

62,3

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,9

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,7

(200) For the cooperating exporting producers outside the sample, the Commission calculated the weighted average dumping margin, in accordance with Article 9(6) of the basic Regulation. Therefore, that margin was established on the basis of the margins of the sampled exporting producers.

(201) On this basis, the provisional dumping margin of the cooperating exporting producers outside the sample is 67,4 %.

(202) For all other exporting producers in China, the Commission established the dumping margin on the basis of the facts available, in accordance with Article 18 of the basic Regulation. To this end, the Commission determined the level of cooperation of the exporting producers. The level of cooperation is the volume of exports of the cooperating exporting producers to the Union expressed as proportion of the total imports from the country concerned to the Union in the IP, that were established on the basis of Eurostat.

(203) The level of cooperation in this case is high because the exports of the cooperating exporting producers constituted 100 % of the total imports during the IP. On this basis, the Commission found it appropriate to establish the dumping margin for non-cooperating exporting producers at the level of the cooperating sampled individually examined company with the highest dumping margin.

(204) The provisional dumping margins, expressed as a percentage of the CIF Union frontier price, duty unpaid, are as follows:

CompanyProvisional dumping margin (%)Zhejiang Junyue Standard Part Co., Ltd.62,3

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,9

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,7Other cooperating companies67,4All other imports originating in country concerned80,7

1. INJURY

4.1.

Definition of the Union industry and Union production

(205) The like product was manufactured by 42 known producers in the Union during the investigation period. They constitute the Union industry within the meaning of Article 4(1) of the basic Regulation.

(206) The total Union production during the investigation period was established at around 50466 tonnes. The Commission established this figure on the basis of data provided by the complainant and the sampled Union producers. As indicated in recital (8), the three sampled Union producers represented around 14 % of the estimated total Union production and sales of the like product in the Union.

4.2.

Union consumption

(207) The Commission established the Union consumption by adding the Union industry’s sales volume in the Union market and the imports of the product concerned, as reported in Eurostat. The source of information was the reply to the macro questionnaire by the complainant and the official data by Eurostat.

(208) Union consumption developed as follows:

Table 2

Union consumption (unit)

Source:

macro questionnaire reply by the complainant and Eurostat.

202120222023Investigation periodTotal Union consumption (tonnes)210909217980182676183338Index1001038787

(209) The Union consumption slightly increased in 2022 (+3 % from 2021), then decreased by 13 % in 2023, with the level during the investigation period remaining 13 % below that of 2021.

4.3.

Imports from the country concerned

4.3.1.

Volume and market share of the imports from the country concerned

(210) The Commission established the volume of imports on the basis of Eurostat. The market share of the imports was established on the basis of the import volume and total Union consumption.

(211) Imports into the Union from the country concerned developed as follows:

Table 3

Import quantity and market share

Source:

Eurostat.

202120222023Investigation periodQuantity of imports from China (tonnes)106520120061102057112315Index10011396105Market share (%)51555661Index100109111121

(212) The import volume from China increased overall by 5795 tonnes in absolute terms, equivalent to a 5 % rise during the period considered. In 2022 imports grew significantly by 13 % compared to the previous year. In 2023 the imports dropped by 4 % in relation to 2021; as overall European demand decreased. This decline was only temporary as in the IP the imports increased by over 10000 tonnes in relation to 2023 despite demand in the Union remaining low during the IP.

(213) Considering the decreasing Union consumption by 13 % during the period considered, the Chinese imports market share in the Union rose steadily between 2021 and the IP. From 51 % in 2021 they rose to 61 % in the IP, thus taking over 10 percentage points of market share from the Union industry and other third countries.

4.4.

Prices of the imports from the country concerned: price undercutting and price suppression

(214) The Commission established the prices of imports on the basis of Eurostat data. Price undercutting of the imports was established on the basis of questionnaire replies provided by the sampled exporting producers and sampled Union producers.

(215) The weighted average price of imports into the Union from the country concerned developed as follows:

Table 4

Import prices (EUR/tonnes)

Source:

Eurostat.

202120222023Investigation periodChina1307167613031213Index10012810093

(216) The Chinese import prices first increased by 28 % in 2022 and then decreased by the same amount in 2023 to further decrease by 7 % in the IP. Overall, during the period considered the Chinese import prices were overall reduced by 7 % falling from 1307 EUR per tonne in 2021 to 1213 EUR per tonne in the IP.

(217) The Commission determined the price undercutting during the investigation period by comparing:

(a) the weighted average sales prices per product type of the sampled Union producers charged to unrelated customers on the Union market, adjusted to an ex-works level; and

(b) the corresponding weighted average prices per product type of the imports from the sampled cooperating country name producers to the first independent customer on the Union market, established on a Cost, insurance, freight (CIF) basis, with appropriate adjustments for customs duties and post-importation costs.

(218) The price comparison was made on a type-by-type basis for transactions at the same level of trade, duly adjusted where necessary, and after deduction of rebates and discounts. The result of the comparison was expressed as a percentage of the sampled Union producers’ theoretical turnover during the investigation period. It showed a weighted average undercutting margin of between 59 % and 64 % by the imports from the country concerned in the Union market for a large majority of the imported product (between 75 % and 90 %).

(219) In addition to price undercutting, there was also significant price suppression within the meaning of Article 3(3) of the basic Regulation. Due to the significant price pressure caused by the low-priced dumped imports from Chinese exporting producers, the Union industry was unable to raise the prices throughout the IP in line with the development of costs of production and in order to achieve a reasonable level of profit, as set out in Table 8 below. The significant price suppression is confirmed by the price underselling found on the basis of the data provided by the sampled exporting producers.

4.5.

Economic situation of the Union industry

4.5.1.

General remarks

(220) In accordance with Article 3(5) of the basic Regulation, the examination of the impact of the dumped imports on the Union industry included an evaluation of all economic indicators having a bearing on the state of the Union industry during the period considered.

(221) As mentioned in recital (8), sampling was used for the determination of possible injury suffered by the Union industry.

(222) For the injury determination, the Commission distinguished between macroeconomic and microeconomic injury indicators. The Commission evaluated the macroeconomic indicators on the basis of the verified data contained in the reply to the macro-questionnaire submitted by the complainant. The Commission evaluated the microeconomic indicators on the basis of the verified data contained in the questionnaire replies from the sampled Union producers. Both sets of data were found to be representative of the economic situation of the Union industry.

(223) The macroeconomic indicators are: production, production capacity, capacity utilisation, sales volume, market share, growth, employment, productivity, magnitude of the dumping margin, and recovery from past dumping.

(224) The microeconomic indicators are: average unit prices, unit cost, labour costs, inventories, profitability, cash flow, investments, return on investments, and ability to raise capital.

4.5.2.

Macroeconomic indicators

4.5.2.1.

Production, production capacity and capacity utilisation

(225) The total Union production, production capacity and capacity utilisation developed over the period considered as follows:

Table 5

Production, production capacity and capacity utilisation

Source:

verified macro questionnaire reply.

202120222023Investigation periodProduction quantity (tonnes)69289663335673650446Index100968273

Production capacity (tonnes)343386343846344003340837Index10010010099Capacity utilisation (%)20191615Index100968273

(226) During the period considered, the production volume decreased steadily and overall by 27 %.

(227) The production capacity remained overall generally stable and only slightly decreased by 1 % during the investigation period.

(228) Capacity utilisation, being already very low at the start of the period considered, decreased further over the period, namely from 20 % in 2021 to 15 % in the IP. This was due to the reduction of the production volumes at equivalent levels of production capacity.

4.5.2.2.

Sales quantity and market share

(229) The Union industry’s sales quantity and market share developed over the period considered as follows:

Table 6

Sales quantity and market share

Source:

verified macro questionnaire reply.

202120222023Investigation periodTotal sales quantity on the Union market (tonnes)65038597225358146614Index100928272Market share (%)31272925Index100899582

(230) The Union industry sales volume decreased by 28 % over the period considered, significantly faster than the decrease of consumption that decreased by 13 % during the same period (i.e. more than a double score). At the same time, the Union industry market share fell from 31 % in 2021 to 25 % during the IP, i.e. a decrease of 6 percentage points.

4.5.2.3.

Growth

(231) In a context of decreasing consumption, the Union industry not only lost sales volumes in the Union but also market share, contrary to Chinese imports which gained absolute sales volume and market share in the Union.

4.5.2.4.

Employment and productivity

(232) Employment and productivity developed over the period considered as follows:

Table 7

Employment and productivity

Source:

verified macro questionnaire reply.

202120222023Investigation periodNumber of employees526535523494Index1001029994Productivity (tonnes/employee)132124109102Index100948277

(233) The Union industry employment has been recovering to the levels before COVID-19 pandemic from 2021 to 2022, however, overall it decreased over the period considered, due to the reduction in production and sales. During the IP the reduction reached 6 % compared to the beginning of the period considered, without taking into consideration any indirect employment.

(234) The productivity per employee also dropped significantly following a similar trend with the drop of the production. It took an adverse turn in 2022. The situation significantly worsened in 2023 and during the investigation period. The overall reduction was 23 % in relation to 2021.

4.5.2.5.

Magnitude of the dumping margin and recovery from past dumping

(235) All dumping margins were significantly above the de minimis level. The impact of the magnitude of the actual margins of dumping on the Union industry was substantial, given the volume and prices of imports from the country concerned.

(236) This is the first anti-dumping investigation regarding the product concerned. Therefore, no data were available to assess the effects of possible past dumping.

4.5.3.

Microeconomic indicators

4.5.3.1.

Prices and factors affecting prices

(237) The weighted average unit sales prices of the sampled Union producers to unrelated customers in the Union developed over the period considered as follows:

Table 8

Sales prices in the Union

Source:

verified questionnaire reply of the sampled Union producers.

202120222023Investigation periodAverage unit sales price in the Union on the total market (EUR/tonne)1372193419331833

Index100141141134Unit cost of production (EUR/ tonne)1431188821382083Index100132149146

(238) The unit cost of production in the Union has increased significantly since 2021. It rose by 32 % from 2021 to 2022, it further rose in 2023 and slightly declined during the IP. The overall increase was by 46 % in relation to 2021. This followed the sharp increase in labour

Labour representing on average 16 % of the cost of production over the period considered.

and raw material pricing

Raw materials representing on average 48 % of the cost of production over the period considered.

and was due to the outbreak of the Russian war against Ukraine, which caused a large increase in inflation in the Union, supply chain disruptions, significantly increased raw material costs in the Union.

(239) The average unit sales price showed a similar trend. By 2022-2023, the rise in sales price had reached 41 %. However, during the IP the unit price dropped in comparison with the year 2023 even though it overall remained 34 % higher than 2021.

(240) The fact that the average unit sales price had an overall increase by 34 % while the unit cost of production increased by 46 % during the same period indicates that the Union industry was not able to fully absorb the rising production costs. In other words, the increasing volumes of dumped Chinese imports into the Union market prevented the Union producers to raise their prices to sustainable levels to cover the increased cost of production. This situation severely impacted the Union industry’s financial performance.

4.5.3.2.

Labour costs

(241) The average labour costs of the sampled Union producers developed over the period considered as follows:

Table 9

Average labour costs per employee

Source:

verified questionnaire reply of the sampled Union producers.

202120222023Investigation periodAverage labour costs per employee (EUR)45881482564758150119Index100105104109

(242) Average labour cost per employee increased by + 9 % over the period considered.

4.5.3.3.

Inventories

(243) Stock levels of the sampled Union producers developed over the period considered as follows:

Table 10

Stocks

Source:

verified questionnaire reply of the sampled Union producers.

202120222023Investigation periodClosing stock (tonnes)2136248621421591Index10011610075Closing stock as a percentage of production (%)17273122

(244) The level of closing stocks increased by 16 % in 2022 in relation to the year before, following the decrease in sales. By 2023 and throughout the investigation period, Union producers visibly undertook efforts to adjust stock levels in response to declining sales and production. In 2023, stock levels reverted to baseline figures, and further reductions were observed during the investigation period. Overall closing stock was reduced by 25 % during the period concerned.

4.5.3.4.

Profitability, cash flow, investments, return on investments and ability to raise capital

(245) Profitability, cash flow, investments and return on investments of the sampled Union producers developed over the period considered as follows:

Table 11

Profitability, cash flow, investments and return on investments

Source:

verified questionnaire reply of the sampled Union producers.

202120222023Investigation periodProfitability of sales in the Union to unrelated customers (% of sales turnover)11–5–10Index10096–380–734Cash flow (EUR)–660656–43844238874–2023839Index–100–666–306Investments (EUR)408232611544685591281829Index10015016869

Return on investments (%)65–17–27Index10084–291–460

(246) The Commission established the profitability of the sampled Union producers by expressing the pre-tax net profit of the sales of the like product to unrelated customers in the Union as a percentage of the turnover of those sales. The profitability was positive at the start of the priod considered in 2021

As long as the selling price per tonne was higher than the variable cost per tonne, while fixed cost covered, each additional sale brought in some profit (a positive contribution margin). Since Union producers sold a high volume that year, it helped them to gain some profit even though the average production cost per tonne was higher.

and 2022. Over the period considered, the Union industry’s profitability decreased significantly, from around 1 % in 2021-2022 to – 5 % in 2023 and further to – 10 % in the IP. The fact that the Union industry had to perform with – 10 % losses in the IP can be explained by the increased competition of Chinese exports at dumped prices, which forced the Union industry to decrease its prices to lossmaking levels in a period of increasing cost of production, as explained in Section 4.5.3.1

(247) The net cash flow is the ability of the Union producers to self-finance their activities. The unsustainable profit levels of the Union industry, as explained above, were also reflected in a negative cash flow for nearly the entire period, which deteriorated further in the IP, surpassing – 2 million EUR, equivalent to approximately 15 % of the sales value during the IP.

(248) While investments in maintenance and replacement increased in the period 2021-2023, they fell dramatically during the IP, similar to other main injury indicators. Overall investments declined by one-third from the beginning to the end of the period considered.

(249) The return on investments is the profit in percentage of the net book value of investments. The Union industry's return on investment fell from 6 % in 2021 to – 27 % in the IP.

(250) Given the dramatic drop in profitability, net cash flow and return on investment, the sampled Union producers’ ability to raise capital was severely affected.

4.5.3.5.

Conclusion on injury

(251) All main injury indicators showed a negative trend during the period considered. The production volume of the Union industry decreased by 27 % and its sales volume decreased by 28 %. The Union industry also lost market share, which fell from 31 % in 2021 to 25 % in the IP. On the contrary, the market share of Chinese imports to the Union during the same period increased by 10 percentage points; it was 51 % in 2021 and in the IP it rose to 61 %. This was achieved despite the drop in Union consumption by 13 % during the period considered.

(252) The profitability of the Union industry declined over the period considered, decreasing from around 1 % in 2021-2022 to – 5 % in 2023 and further to – 10 % in the IP, which is clearly not sustainable. A similar decreasing trend was observed for the productivity of the Union industry (decreased by 23 %), its employment (decreased by 6 %), investments (decreased by 31 %), return on investment and cash flow, which all decreased over the period considered.

(253) The Union industry was unable to compensate for the lost sales volumes in the Union market through increased exports, as exports accounted for only approximately 8 % of the industry’s total production and were gradually declining, as set out in Section 5.4 below.

(254) On the basis of the above, the Commission concluded at this stage that the Union industry suffered material injury within the meaning of Article 3(5) of the basic Regulation.

1. CAUSATION

(255) In accordance with Article 3(6) of the basic Regulation, the Commission examined whether the dumped imports from the country concerned caused material injury to the Union industry. In accordance with Article 3(7) of the basic Regulation, the Commission also examined whether other known factors could at the same time have injured the Union industry. The Commission ensured that any possible injury caused by factors other than the dumped imports from the country concerned was not attributed to the dumped imports. These factors are: the imports from countries other than China, the export performance of the Union industry, consumption decline and increase in cost.

5.1.

Effects of the dumped imports

(256) The Commission examined whether there was a casual link between the dumped imports and the injury suffered by the Union industry. During the period considered the imports of the dumped like product from China increased by 5 % despite the declining Union consumption.

(257) The reduced prices of the Chinese imports by 7 % in the period considered in combination with the significantly increased cost of production by the Union industry by 46 % in the same period, helped Chinese imports to the Union increase their market share by 21 %. This was at the expense of the Union industry, which had significant losses in sales volume by 28 % and a decrease in its market share by 18 %. At the same time the profitability of the Union industry was significantly reduced to non-sustainable levels (it operated with – 10 % losses in the IP).

(258) The fact that there was such a significant gap between the average price of the dumped imported product from China and the average price of the Union industry like product (1213 EUR/tonne v 1833 EUR/tonne) prevented the Union industry to increase its prices to reflect the increased cost of production and, thus, sustain its profitability.

5.2.

Effects of other factors

(259) The Commission examined whether other factors of injury other than the dumped imports from China had an impact on the state of the Union industry, but did not find any other factors that could have had a substantial impact on the injurious situation of the Union industry.

5.3.

Imports from third countries

(260) The quantity of imports from other third countries developed over the period considered as follows:

Table 12

Imports from third countries

Source:

Eurostat.

Country202120222023Investigation periodUnited KingdomQuantity (tonnes)11051942977976739Index100857161Market share (%)5444Average price (EUR/tonne)3108359343044505

Index100116138145TaiwanQuantity (tonnes)4023493540553376Index10012310184Market share (%)2222Average price (EUR/tonne)3761452650575006Index100120134133TürkiyeQuantity (tonnes)9046974149775052Index1001085556Market share (%)4433Average price (EUR/tonne)1541201822692326Index100131147151Other third countriesQuantity (tonnes)1525314122102439242Index100936761Market share (%)7665Average price (EUR/tonne)2953372045545152Index100126154174Total of all third countries except ChinaQuantity (tonnes)39374382282707224410Index100976962Market share (%)19181513Average price (EUR/tonne)2755335941374368Index100122150159

(261) Imports from other third countries originated mainly from the United Kingdom, Taiwan and Turkey. Total imports volume from all third countries except China decreased by 38 %, between 2021 and the IP, going from 39374 tonnes to around 24410 tonnes.

(262) The market share of all third countries apart from China was reduced from 19 % in 2021 to 13 % in the IP.

(263) Overall, the average import prices of other third countries increased by 59 % during the period considered and were on average considerably higher than the prices of imports from China, which decreased by 7 % during the period considered. In the IP, the average import price of other third countries excluding China was 4368 EUR/tonne, while the average import price from China was 1213 EUR/tonne.

(264) On the basis of the above, the Commission concluded that imports from other third countries were not the source of the material injury suffered by the Union industry.

5.4.

Export performance of the Union industry

(265) The volume of exports of the sampled Union producers developed over the period considered as follows:

Table 13

Export performance of the sampled Union producers

Source:

verified questionnaire replies of the sampled Union producers.

202120222023Investigation periodExport volume (tonnes)5466530943154392Index100977980Average price (EUR/tonnes)1504167015141415Index10011110194

(266) During the period considered, the Union industry’s exports decreased by overall 20 %. This trend is similar to the negative trend of the Union producers’ sales within the Union, which dropped even more than their exports, i.e. by 28 %, during the period considered. It is also similar to the negative trend of the reduced market share of the Union producers within the Union, which dropped by 18 % during the period considered.

(267) The average export price of the Union producers also dropped by 6 % during the period considered. It should be noted that the export sales represent 9 % of the Union industry’s overall sales. Therefore the effect of reduced sales to the injury of the Union industry is found to be limited and, while it might have contributed to the injury suffered by the Union industry to a small extend considering the volumes involved, it was not capable of attenuating the causal link between the dumped imports from China and the injury suffered by the Union industry.

5.5.

Consumption decline

(268) The Union market contracted by 13 % during the period considered. The decrease was due to several interconnected factors: the European economy experienced a slower growth in 2023 in comparison to the year before (the Union GDP grew by 0,4 % in 2023 v 3,5 % in 2022), with apparent steel consumption shrinking by 6,3 %

https://www.eurofer.eu/press-releases/persisting-downside-factors-deepen-downturn-in-2023-and-curb-steel-demand-rebound-in-2024.

. This downturn affected various sectors, including construction and manufacturing, which are major consumers of industrial products like screws. High energy prices and uncertainty in the energy market also contributed to reduced industrial output and weakened demand across sectors

https://orgalim.eu/wp-content/uploads/orgalim-economics-and-statistics-report-autumn-2024-2.pdf.

. Under normal conditions of competition, in such a shrinking market, sales volumes of all the market participants would have gone down more or less equally. However, in the present case, China gained an additional 10 percentage point market share of the Union market during the period considered to the detriment of the Union industry and the other importing countries (which equally lost 5,4 percentage points of market share). Therefore, the economic contraction of the Union market was not found to cause material injury to the Union industry in this case.

5.6.

Increase in cost of production

(269) As outlined in recital (238) above, the unit cost of production within the Union increased substantially (by 46 %) over the period considered. Nevertheless, in 2022, Union producers were able to raise their sales prices in response to the rising production costs, enabling them to partially offset these increases and achieve a degree of profitability. However, during the investigation period, despite a slight decrease in the cost of production, the profitability of Union producers declined sharply, reaching significantly negative levels. This deterioration clearly demonstrates the material injury sustained by the Union industry. The presence of dumped imports should not prevent the Union producers from adjusting their prices to reflect increased production costs. In circumstances where Union producers' prices were severely suppressed by the growing volume of dumped imports, while production costs remained elevated, the resulting collapse in profitability cannot be attributed to internal inefficiencies or market mismanagement. Rather, it is a direct consequence of the injurious effects of dumped imports.

5.7.

Conclusion on causation

(270) The injury analysis showed that the Chinese imports suppressed the Union market price during the period considered. The significant increase of the dumped imports from China and the price suppression, as explained in recital (219), they exerted during the second half of the IP affected the Union industry’s ability to pass on the higher cost of production to the users. This coincided in time with the deterioration of the Union industry’s financial performance indicators, like a decrease in profitability, resulting in losses in 2023-IP. The gain of 10 percentage points in market share of the Chinese imports was at the expense of the Union industry, which lost sales volume and market share (by 6 percentage points), especially notable in the second half of the period considered. Therefore, we concluded that the material injury was caused by the dumped imports from China.

(271) The Commission distinguished and separated the effects of all known factors on the situation of the Union industry from the injurious effects of the dumped imports. While the export performarce of the Union industry might have contributed to the material injury suffered by the Union industry to a small extend, it did not attenuate the causal link between the dumped imports and the material injury found.

(272) Regarding the effects of imports from other third countries, the Commission concluded that those imports did not cause injury to the Union industry. Similar to the Union industry the imports from third countries other than China also lost market share during the period considered and their cumulative import volumes significantly decreased (by 38 %). Moreover, the average import prices from other third countries increased by 59 % during the period considered. Hence, imports from other third countries did not attenuate the causal link between the imports from China and the injury suffered by the Union industry.

(273) Regarding the effects of export performance of the Union industry, even though the trend was negative with reduced sales, it should be noted that the export sales represent a small part of the Union overall sales. This means that the effect to the injury of the Union industry was found to be limited.

(274) With respect to the consumption decline and the increase in cost of production, it is undisputable that the Union industry was faced with challenges over the period considered. In the absence of price pressure from dumped imports, the industry would have been able to adjust prices to reflect higher costs and better respond to shifting market conditions. As previously noted, dumped imports should not hinder Union producers from passing on cost increases. Therefore, despite the impact of the increase in cost and reduced demand, consumption decline and increase in cost of production were found not to have caused material injury to the Union industry.

(275) On the basis of the above, the Commission concluded at this stage that the dumped imports from the country concerned caused material injury to the Union industry and that the other factor (the export performance of the Union industry) did not attenuate the causal link between the dumped imports and the material injury. The injury consists of reduced market share, production, production capacity utilisation, productivity, profitability, closing stocks, cash flow and return on investments. Furthermore, as explained above in recital (219), the Union industry suffered price supression caused by imports from China.

1. LEVEL OF MEASURES

(276) To determine the level of the measures, the Commission examined whether a duty lower than the margin of dumping would be sufficient to remove the injury caused by dumped imports to the Union industry.

6.1.

Injury margin

(277) The injury would be removed if the Union Industry were able to obtain a target profit by selling at a target price in the sense of Articles 7(2c) and 7(2d) of the basic regulation.

(278) In accordance with Article 7(2c) of the basic Regulation, for establishing the target profit, the Commission took into account the following factors: the level of profitability before the increase of imports from the country under investigation, the level of profitability needed to cover full costs and investments, research and development (R&D) and innovation, and the level of profitability to be expected under normal conditions of competition. Such profit margin should not be lower than 6 %.

(279) The Commission could not established a basic profit covering full costs under normal conditions of competition before increase of imports from China, since Chinese imports accounted for over 50 % of market share during the whole period considered, while market shares before the start of the period considered could not be calculated due to insufficient data. The Commission, thus, established the target profit to determine the non-injurious price at 6 %, in accordance with Article 7(2c) of the basic Regulation

(280) No claims were made that the Union industry’s level of investments, R&D and innovation during the period considered would have been higher under normal conditions of competition.

(281) Likewise, no claims were made concerning the future costs resulting from Multilateral Environmental Agreements, and protocols thereunder, to which the Union is a party and that the Union industry will incur during the period of the application of the measure pursuant to Article 11(2), in accordance with Article 7(2d) of the basic Regulation.

(282) On this basis, the Commission calculated a non-injurious price for the like product of the Union industry by applying the above-mentioned 6 % target profit margin to the cost of production of the sampled Union producers during the investigation period and then adding the adjustments under Article 7(2d) on a type-by-type basis.

(283) The Commission then determined the injury margin level on the basis of a comparison of the weighted average import price of the sampled cooperating exporting producers in country concerned, as established for the price undercutting calculations, with the weighted average non-injurious price of the like product sold by the sampled Union producers on the Union market during the investigation period. Any difference resulting from this comparison was expressed as a percentage of the weighted average import CIF value.

(284) The injury elimination level for other cooperating companies and for all other imports originating in country concerned is defined in the same manner as the dumping margin for these companies and imports.

CompanyDumping margin (%)Injury margin (%)Zhejiang Junyue Standard Part Co., Ltd.62,3196

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,9211

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,7237Other cooperating companies67,4212All other imports originating in country concerned80,7237

6.2.

Conclusion on the level of measures

(285) Following the above assessment, provisional anti-dumping duties should be set as below in accordance with Article 7(2) of the basic Regulation:

CompanyProvisional anti-dumping duty (%)Zhejiang Junyue Standard Part Co., Ltd.62,3

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,9

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,7Other cooperating companies67,4All other imports originating in country concerned80,7

1. UNION INTEREST

(286) Having decided to apply Article 7(2) of the basic Regulation, the Commission examined whether it could clearly conclude that it was not in the Union interest to adopt measures in this case, despite the determination of injurious dumping, in accordance with Article 21 of the basic Regulation. The determination of the Union interest was based on an appreciation of all the various interests involved, including those of the Union industry, importers, wholesalers, retailers, users, consumers.

7.1.

Interest of the Union industry

(287) According to information available to the Commission, there were fourty-two known producers of screws without heads in the Union during the period considered. The complaint was submitted by the European Industrial Fasteners Institute (EIFI), on behalf of eight Union producers, all of which were SMEs, and supported by another seven Union producers.

(288) The imposition of measures will improve the market conditions for Union producers, thereby allowing them to enhance their competitive position in the market, regain lost sales volume and market share, increase capacity utilisation, and raise their prices to sustainable levels. This, in turn, would assist them in improving their profitability to the levels that are anticipated under normal competition conditions.

(289) The absence of measures would have significant negative effects for the Union industry, as the latter would continue to endure economic injury due to sustained price pressure from dumped Chinese imports. Market share losses would accelerate, leading to further declines in sales and production. As a result, capacity utilisation, already at an unsustainable 15 % during the investigation period, will continue to drop, making operations increasingly unviable. The already loss-making situation would be further exacerbated, with severe consequences for investments and employment in the Union. The Commission therefore concluded that the imposition of provisional measures is in the interest of the Union industry.

7.2.

Interest of unrelated importers

(290) Twenty-six importers came forward following the initiation of the investigation. Three were selected for sampling, and of those two submitted questionnaire responses. The cooperating importers that responded to the sampling exercise imported over 90 % of their total imports of screws without heads from China. Among the sampled cooperating importers, Chinese imports accounted for more than 80 % of their total imports of the product concerned. The sampled importers were found to be profitable, and the turnover generated from the product concerned represented only 0,5 % to 2,5 % of their total business turnover.

(291) Given the limited share of the product in their overall business activities, the imposition of anti-dumping measures is unlikely to have a material impact on the financial stability of importers. Furthermore, importers can mitigate potential cost increases by diversifying their sourcing strategies, including exploring alternative suppliers within the Union or other third countries. The data suggested that any potential impact on importers would be minimal.

7.3.

Interest of users

(292) In the absence of cooperation of users the Commission was not able to assess the actual impact of the anti-dumping duties for users. However, taking into account the existence of alternative suppliers in other third countries, together with the large production capacities of the Union industry, the Commission considered that the users could continue to source screws from multiple sources of adequate quality and quantity. The Commission thus considered that in case the anti-dumping measures are imposed, the impact on the users was limited.

7.4.

Conclusion on Union interest

(293) On the basis of the above, the Commission concluded that there were no compelling reasons that it was not in the Union interest to impose measures on imports of screws originating in China at this stage of the investigation.

1. PROVISIONAL ANTI-DUMPING MEASURES

(294) On the basis of the conclusions reached by the Commission on dumping, injury, causation, level of measures and Union interest, provisional measures should be imposed to prevent further injury being caused to the Union industry by the dumped imports.

(295) Provisional anti-dumping measures should be imposed on imports of product originating in countryies concerned, in accordance with the lesser duty rule in Article 7(2) of the basic Regulation. The Commission compared the injury margins and the dumping margins in recital (284) above. The amount of the duties was set at the level of dumping margins for all the exporting producers, which was found to be the lower of the dumping and the injury margins.

(296) On the basis of the above, the provisional anti-dumping duty rates, expressed on the CIF Union border price, customs duty unpaid, should be as follows:

CompanyProvisional anti-dumping duty (%)Zhejiang Junyue Standard Part Co., Ltd.62,3

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,9

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,7Other cooperating companies67,4All other imports originating in country concerned80,7

(297) The individual company anti-dumping duty rates specified in this Regulation were established on the basis of the findings of this investigation. Therefore, they reflect the situation found during this investigation with respect to these companies. These duty rates are exclusively applicable to imports of the product concerned originating in China and produced by the named legal entities. Imports of the product concerned produced by any other company not specifically mentioned in the operative part of this Regulation, including entities related to that those specifically mentioned, should be subject to the duty rate applicable to all other imports originating in country concerned. They should not be subject to any of the individual anti-dumping duty rates.

(298) To minimise the risks of circumvention due to the difference in duty rates, special measures are needed to ensure the application of the individual anti-dumping duties. The application of individual anti-dumping duties is only applicable upon presentation of a valid commercial invoice to the customs authorities of the Member States. The invoice must conform to the requirements set out in Article 1(3) of this Regulation. Until such invoice is presented, imports should be subject to the anti-dumping duty applicable to all other imports originating in country concerned.

(299) While presentation of this invoice is necessary for the customs authorities of the Member States to apply the individual rates of anti-dumping duty to imports, it is not the only element to be taken into account by the customs authorities. Indeed, even if presented with an invoice meeting all the requirements set out in Article 1(3) of this Regulation, the customs authorities of Member States must carry out their usual checks and may, like in all other cases, require additional documents (shipping documents, etc.) for the purpose of verifying the accuracy of the particulars contained in the declaration and ensure that the subsequent application of the lower rate of duty is justified, in compliance with customs law.

(300) Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume after the imposition of the measures concerned, such an increase in volume could be considered as constituting in itself a change in the pattern of trade due to the imposition of measures within the meaning of Article 13(1) of the basic Regulation. In such circumstances and provided the conditions are met an anti-circumvention investigation may be initiated. This investigation may, inter alia, examine the need for the removal of individual duty rate(s) and the consequent imposition of a country-wide duty.

1. REGISTRATION

(301) As mentioned in recital (3), the Commission made imports of the product concerned subject to registration. Registration took place with a view to possibly collecting duties retroactively under Article 10(4) of the basic Regulation.

(302) In view of the findings at provisional stage, the registration of imports should be discontinued.

(303) No decision on a possible retroactive application of anti-dumping measures has been taken at this stage of the proceeding.

1. INFORMATION AT PROVISIONAL STAGE

(304) In accordance with Article 19a of the basic Regulation, the Commission informed interested parties about the planned imposition of provisional duties. This information was also made available to the general public via DG TRADE’s website. Interested parties were given three working days to provide comments on the accuracy of the calculations specifically disclosed to them.

(305) No comments on the accuracy of the calculations were received.

1. FINAL PROVISIONS

(306) In the interests of sound administration, the Commission will invite the interested parties to submit written comments and/or to request a hearing with the Commission and/or the Hearing Officer in trade proceedings within a fixed deadline.

(307) The findings concerning the imposition of provisional duties are provisional and may be amended at the definitive stage of the investigation,

HAS ADOPTED THIS REGULATION:

Article 1

1. A provisional anti-dumping duty is imposed on imports of screws and bolts, whether or not with their nuts and washers, without heads, of iron or steel other than stainless steel, regardless of tensile strength, excluding coach screws and other wood screws, screw hooks and screw rings, self-tapping screws, and screws and bolts for fixing railway track construction material, currently falling under CN codes 73181542 and 73181548 and originating in the People’s Republic of China.

1. The rates of the provisional anti-dumping duty applicable to the net, free-at-Union-frontier price, before duty, of the product described in paragraph 1 and produced by the companies listed below shall be as follows:

CompanyProvisional anti-dumping duty (%)TARIC additional codeZhejiang Junyue Standard Part Co., Ltd.62,389ML

Brother Group:

Jiaxing High-enter Fasteners Co., Ltd.

Zhejiang Morgan Brother Technology Co., Ltd.

Jiaxing Brother Standard Part Co., Ltd.

63,989MM

Chinafar Group:

Jiaxing Chinafar Standard Parts Co., Ltd.

Jiangsu Zhe Fasteners Co., Ltd.

80,789MNOther cooperating companies listed in Annex67,4See AnnexAll other imports originating in country concerned80,78999

1. The application of the individual duty rates specified for the companies mentioned in paragraph 2 shall be conditional upon presentation to the Member States’ customs authorities of a valid commercial invoice, on which shall appear a declaration dated and signed by an official of the entity issuing such invoice, identified by his/her name and function, drafted as follows: I, the undersigned, certify that the (volume in unit we are using) of (product concerned) sold for export to the European Union covered by this invoice was manufactured by (company name and address) (TARIC additional code) in country concerned. I declare that the information provided in this invoice is complete and correct. Until such invoice is presented, the duty applicable to all other imports originating in country concerned shall apply.

1. The release for free circulation in the Union of the product referred to in paragraph 1 shall be subject to the provision of a security deposit equivalent to the amount of the provisional duty.

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

Article 2

1. Interested parties shall submit their written comments on this regulation to the Commission within 15 calendar days of the date of entry into force of this Regulation.

1. Interested parties wishing to request a hearing with the Commission shall do so within 5 calendar days of the date of entry into force of this Regulation.

1. Interested parties wishing to request a hearing with the Hearing Officer in trade proceedings are invited to do so within 5 calendar days of the date of entry into force of this Regulation. The Hearing Officer may examine requests submitted outside this time limit and may decide whether to accept to such requests if appropriate.

Article 3

1. Customs authorities are hereby directed to discontinue the registration of imports established in accordance with Article 1(1) of Implementing Regulation (EU) 2025/141.

1. Data collected regarding products which entered the EU for consumption not more than 90 days prior to the date of the entry into force of this Regulation shall be kept until the entry into force of possible definitive measures, or the termination of this proceeding.

Article 4

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

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

Done at Brussels, 13 June 2025.

For the Commission

The President

Ursula von der Leyen

Annex

ANNEX

Chinese cooperating exporting producers not sampled

NameTARIC additional codeANHUI GOODLINK FASTENER CO., Ltd.89MOCELO Suzhou Precision Fasteners Co., Ltd.89MPCHANGZHOU MIKI HARDWARE TECHNOLOGY CO., Ltd.89MQCixi Jinmao Fastener Co., Ltd.89MRCIXI NONGER HARDWARE CO., Ltd.89MSEagle Metalware Co., Ltd.89MTEC International (Nantong) Co., Ltd.89MUEverbest Hardware Products Co., Ltd.89MVEVERGREEN (ZHEJIANG) INTELLIGENT MANUFACTURING CO., Ltd.89MWFASTWELL METAL PRODUCTS CO., Ltd.89MXFinework (Hunan) New Energy Technology Co., Ltd.89MYHAI YAN MACHINERY CO., Ltd.89MZHAINING XINLIAN HARDWARE MACHINERY CO., Ltd.89NAHaining Xinxing Fasteners Co., Ltd.89NBHaining Zhongheng Metal Products Co., Ltd.89NCHAIYAN LONGCHENG STANDARD PARTS CO., Ltd.89NDHAIYAN BOLT CO., Ltd.89NEHaiyan C&F Fittings Co., Ltd.89NFHaiyan Jiamei Hardware Manufacturing and Tech. Co., Ltd.89NGHAIYAN JINNIU FASTENERS CO., Ltd.89NHHAIYAN LONGSHENG HARDWARE CO., Ltd.89NIHaiyan Wancheng Fasteners Co., Ltd.89NJHaiyan Wandefu Precision Hardware Co., Ltd.89NKHaiyan Xingang Standard Parts Co., Ltd.89NLHAIYAN XINYUAN FASTENER CO., Ltd.89NMHaiyan Xinyuan Technology Co., Ltd.89NNHaiyan Xinyue Electrical Appliances Co., Ltd.89NOHAIYAN YINGJIE FASTENER CO., Ltd.89NPHAIYAN YONGJIE TECHNOLOGY CO., Ltd.89NQHaiyan Yuanzhong Hardware Co., Ltd.89NRHandan Changfa Fastener Manufacturing Co., Ltd.89NSHandan City Daoning Fastener Manufacturing Co., Ltd.89NTHANDAN CITY JINGGONG CONSTRUCTION ANCHORING MANUFACTURE CO., Ltd.89NU

Handan Haosheng Fastener Co., Ltd.89NVHANDAN HUAMING FASTENER CO., Ltd.89NWHANDAN MINGXIN METAL PRODUCTS CO., Ltd.89NXHANDAN TONGHE FASTENER MANUFACTURE CO., Ltd.89NYHandan Xiaojun Fastener Manufacturing Co., Ltd.89NZHandan Xingbang Fastener Co., Ltd.89OAHandan Yaofeng Fastener Manufacturing Co., Ltd.89OBHandan Yongnian Hongji Machinery Parts Co., Ltd.89OCHandan Zhonglong Fastener Manufacturing Co., Ltd.89ODHebei Chengyi Engineering Materials Co., Ltd.89OEHEBEI FUAO FASTENER MANUFACTURING CO., Ltd.89OFHebei Goodfix Industrial Co., Ltd.89OGHebei Gude Fastener Manufacturing Co., Ltd.89OHHEBEI YUETONG FASTENERS MANUFACTURING CO., Ltd.89OIJiangsu Hengyue Hardware Co., Ltd.89OJJIANGSU LIRUNYOU MACHINERY TECHNOLOGY CO., Ltd.89OKJiashan Donghe Fastener Co., Ltd.89OLJIASHAN SANXIN FASTENER Co., Ltd.89OMJiashan Tianyang Fastener Co., Ltd89ONJIASHAN WEIJIE HARDWARE CO., Ltd.89OOJiaxing Aerotec Precision Co., Ltd.89OPJIAXING BROTHER UNITED FASTENER CO., Ltd.89OQJIAXING CHUANGLI HARDWARE CO., Ltd.89ORJIAXING EXCELLENT FASTENER CO., Ltd.89OSJIAXING GOOD METAL TECHNOLOGY CO., Ltd.89OTJIAXING HONGJIAN TECHNOLOGY CO., Ltd.89OUJIAXING JIAWEI MACHINERY TECHNOLOGY COMPANY, Ltd.89OVJIAXING JINYU FASTENER FACTORY, Ltd.89OWJiaxing Jiuli Precision Manufacturing Co., Ltd.89OXJiaxing Julong Hardware Technology Co., Ltd.89OYJIAXING KINFAST HARDWARE CO., Ltd.89OZJIAXING LONGFIX FASTENERS CO., Ltd.89PAJIAXING PAIYOU METAL PRODUCT CO., Ltd.89PBJIAXING RISEN HARDWARE CO., Ltd.89PCJIAXING SUNFAST METAL CO., Ltd.89PDJIAXING YIDA NEW MATERIAL TECHNOLOGY CO., Ltd.89PE

Jinan Star Fastener Co., Ltd.89PFJOYSTART AUTOMOTIVE PARTS CO., Ltd.89PGLangxi Longwei Metal Technology Co., Ltd.89PHLianyungang Jinyu Hardware Co., Ltd.89PILIANYUNGANG PINGXIN FASTENER COMPANY LIMITED89PJLianyungang Xincheng hardware Co., Ltd.89PKLYG Dragonscrew Co., Ltd.89PLMIANXUAN FASTENERS CO., Ltd.89PMNEDSCHROEF FASTENERS (KUNSHAN) CO., Ltd.89PNNingbo Da Zhi Machine Technology CO., Ltd.89PONingbo Dongxin High-Strength Nut Co., Ltd.89PPNINGBO EXACT FASTENERS CO., Ltd.89PQNingbo Jinding Fastening Piece CO., Ltd.89PRNINGBO LEMNA PRODUCT TECHNOLOGY CO., Ltd.89PSNingbo Sardis Hardware Products Co., Ltd.89PTNINGBO XINGSHENG OIL PIPE FITTINGS MANUFACTURE CO, Ltd.89PUNINGBO YINZHOU HAIYUN METAL PRODUCTS CO., Ltd.89PVNingbo Zhenghai Yongding Fastener Co., Ltd.89PWNINGBO ZHENHAI DINGLI FASTENER SCREW CO., Ltd.89PXNingbo Zhongjiang High Strength Bolts Co., Ltd.89PYOK TECH CO., Ltd.89PZPINGHU DRAGON FASTENER CO., Ltd.89QAPINGHU ZHAPU NUT FACTORY, Ltd.89QBQIFENG PRECISION INDUSTRY SCI-TECH CORP.89QCQingdao Super Star Tools Co., Ltd.89QDQINGDAO VANKU INDUSTRY GROUP89QEQINGDAO XINHUA HARDWARE PRODUCTS CO., Ltd.89QFSHANGHAI FIRM METAL CO., Ltd.89QGShanghai Kingpluse Industry Co., Ltd.89QHSHANGHAI MOREGOOD HARDWARE CO., Ltd.89QIShanghai Moutain Industries Co., Ltd.89QJSHANGHAI ROMAX HARDWARE CO., Ltd.89QKSHANGRAO CITY YIWEN FASTENER CO., LIMITED89QLSuzhou YNK Fastener Co., Ltd.89QMT&Y Hardware Industry Co., Ltd.89QNTAISHAN DONYI HARDWARE CO., Ltd.89QOTANDL INDUSTRY CO., Ltd.89QP

Xingtai Mindu Industrial Co. Ltd.89QQYongnian Country Tianbang Fasteners Co., Ltd.89QRYuyao Alfirste Hardware Co., Ltd.89QSZhejiang Cooper Turner Beck Green Energy Co., Ltd.89QTZHEJIANG DONGHE FASTENER CO., Ltd.89QUZhejiang Donghe Machinery Technology Corporation Limited89QVZHEJIANG EXCELLENT INDUSTRIES CO., Ltd.89QWZhejiang Haixun Precision Technology Co., Ltd.89QXZHEJIANG HYSTRON AUTO PARTS CO., Ltd.89QYZHEJIANG NEW SHENGDA FASTENER CO., Ltd.89QZZHESHANG DEVELOPMENT HUASENER(ZHEJIANG) HARDWARE TECHNOLOGY CO., Ltd.89RA