EU Confirms Retroactive PVC Anti-Dumping Duty, 23 Oct 2026

The European Commission confirmed any future anti-dumping duty on S-PVC from China, Korea, Mexico and Taiwan will apply to goods entered from 23 October 2026.

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The European Commission has confirmed that any anti-dumping duty it may impose on suspension PVC from China, the Republic of Korea, Mexico and Taiwan will reach goods that entered the EU from 23 October 2026. Registration under Regulation (EU) 2026/2345 began that same day. The confirmation turns a registration exercise into a live financial exposure for importers who landed Asian resin after late October. The move is the next procedural stage of a case that began with the September investigation.

The four origins are the same ones named in the investigation the Commission opened on 24 September 2026. The product is suspension PVC and bulk PVC in pure form, not mixed with other substances. Emulsion PVC, the paste resin used in coatings and flooring, stays outside the measure. The customs codes are CN ex 3904 10 00, with four TARIC lines: 3904 10 00 15, 21, 80 and 81. The United Kingdom opened its own case on 4 August 2026 and runs on a separate clock; the EU registration does not cover British imports. The case, AD762, was opened after a complaint from PVC producers established in the Union. Its scope and customs codes were published in Official Journal notice C/2026/4912.

What the Commission confirmed

Registration is not a tax. It is a record. The basic Anti-Dumping Regulation lets a definitive duty be charged on goods entered for consumption up to 90 days before provisional measures apply, but not before the investigation opened, and only where those entries were registered. The Commission has now fixed 23 October 2026 as the retrospective cut-off: entries cleared on or after that date sit in the window that a future duty can reach.

The 90-day look-back is standard in EU trade defence. The new element is the Commission fixing the entry date from which the record counts. The nine-month registration window opened on 23 October and runs for the life of the investigation, so entries made between then and any definitive duty sit in the recorded pool.

A container that cleared in November can therefore carry a liability quantified in 2027, at a rate no one can state today. The exposure exists even though no duty has been imposed. No duty is due today; the liability is conditional on a positive finding later in the case. The importer who keeps the entry date and the producing company on the certificate of analysis is the one who can later show which rate applies to that cargo.

The look-back in numbers

Eurostat data cited by Argus Media put PVC imports from the four origins under investigation at 593,715 tonnes during the investigation period, which the Commission set at 1 April 2025 to 31 March 2026. Argus assessed the PVC import price on a CIF Europe basis at 850 to 890 euros per tonne in the week the announcement appeared. Any duty would be ad valorem, calculated on the CIF value, so that assessed price sets the euro amount at stake per tonne. The resin feeds construction, packaging and automotive supply chains in the Union, so a settled duty would flow into the cost of pipe, profile and window stock.

The duty the Commission may set follows the lesser-duty rule. Under EU law the rate is the lower of the dumping margin and the injury elimination level. The disclosure, reported by the trade press when the registration opened, put the Chinese dumping margin at 84% to 273% and the injury level at 68%, which points to a duty near 68% for China. The other origins sit lower.

These numbers signal direction, not a set rate. An exporter the Commission examined individually may receive a company-specific figure while every other supplier falls to the residual country-wide rate.

The schedule now on the table

The Commission has placed the next steps on a calendar. Argus Media reports pre-disclosure of provisional measures is likely on 23 April 2027, with definitive measures expected on 20 November 2027. Those are the Commission's stated windows, not committed dates. The 90-day look-back runs from the provisional disclosure backwards, so entries dating back to late January 2027 could fall inside it if the cut-off of 23 October 2026 is read as the outer registration boundary. The deferred dates give importers roughly eighteen months of recorded entries that a final duty could reach, which is why the registration step drew attention across the four origins.

Nothing here predicts the outcome. The lesser-duty rule can still pull the final figure below the injury level, and the country-wide rate is only a ceiling until the Commission publishes company-specific figures. A buyer choosing a supplier today cannot know which column the cargo will meet in 2027. The Commission has not yet imposed a provisional or definitive duty; both dates are windows placed by its own procedure.

What an importer controls today

The work is administrative and front loaded. The customs broker should confirm each entry is registered under the correct TARIC line, and the entry summary with its date belongs in the file. The producing company named on the certificate of analysis matters, because a company-specific rate depends on that name. A contract clause should state who bears any duty collected after the goods are used, and how far ahead the buyer must be told. The scope needs checking case by case, since paste resin remains outside this measure today and may not stay outside the next one.

Sectors most exposed are construction, packaging and automotive, where PVC enters as pipe, profile and window stock. An importer with large volumes from the four origins should model the exposure at the indicated duty rates, because the lesser-duty rule still leaves the China figure near 68%. Some buyers are reviewing supply from origins outside the four, though substitution depends on grade match and lead time.

The rate that lands on those October entries will not be known before the spring of 2027, and the lesser-duty rule can still pull it below the injury level.

Sources: Cambios Legales, Hong Kong TID circular 829/2026, Regulation (EU) 2026/2345, EUR-Lex.