Before a provisional anti-dumping duty applies, the Commission may disclose its proposed rates in advance. For buyers, the useful question in that window is who actually makes the goods.
Under the EU’s basic anti-dumping regulation, interested parties that request information within the prescribed deadline receive details of proposed provisional duties four weeks before they are imposed. The Commission’s 14 October 2026 pre-disclosure on refined copper tubes in level-wound coils shows what those proposed rates can look like. For goods originating in China, it proposes 33.5% for one named producer and 51.5% for all other imports. The case also covers Mexico, Uzbekistan and Vietnam, with company-specific differences in Uzbekistan and Vietnam.
So two buyers of the same product from the same country can face very different costs. The difference can come down to the factory and the paperwork.
In a separate case, the Commission’s provisional regulation on alkyl phosphonic acids from China, Regulation (EU) 2026/1045, illustrates how an individual rate can be tied to a valid commercial invoice. The invoice must carry a signed declaration identifying the manufacturer, its address and its TARIC additional code. If that declaration is missing or incomplete, the rate for all other imports applies. Customs also secures the provisional duty when the goods are released.
This is where buying through a trading company needs care. The invoice can come from a trader, but its declaration needs to identify the actual producer. If the producer is not on the Commission’s list, or the invoice does not identify it correctly, the importer may face the residual rate. When a quote carries only a trader’s name, we would ask which factory makes the goods before placing the order.
Timing matters as well. Where imports have been registered, a definitive duty may, under specific conditions, apply to goods entered up to 90 days before provisional measures take effect. One condition is a further substantial rise in imports. Shipping extra volume early can therefore add to the risk it was meant to avoid.
For anyone buying a product under investigation, we would confirm the producing factory in writing, check it against the Commission’s list, agree the required invoice declaration with the supplier before shipment, and include the residual rate in the landed-cost calculation as a fallback. The Hong Kong Trade and Industry Department’s list of open EU cases against China at 30 September 2026 includes steel shelving, alkaline batteries and PVC, so this reaches well beyond copper and industrial chemicals.
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