ETRA has provided the European Commission with position papers on the proceedings against China and Vietnam.
ETRA is in favour of the interim review of the anti-dumping measures on the import of Chinese bicycles but the organisation's position paper officially opposes the initiation of anti-dumping proceedings against bicycles originating in Vietnam, and asks the Commission to dismiss the EBMA complaint.
Both positions are based on an analysis of the non-confidential EBMA complaints, an evaluation of the European bicycle market and of the share of the concerned imports in that market and on an assessment of the interests of bike shops - and customers - in both matters.
ETRA said that since 2002 imports from China are increasing and that this is a "cause for concern."
The organisation wants measures against Chinese dumping to be beefed up. As most Chinese bikes are of very low cost, ETRA doesn't believe they are safe and in is position paper argues that consumers could be put at risk of injury should they buy these ultra cheap bicycles from supermarkets and other non-bicycle related outlets.
Cheap Chinese bicycles "may well deter consumers from cycling and in the worst case even cause physical injury," said ETRA.
However, EBMA's case against dumping from Vietnam is far from proven, claims ETRA. Many bike brands - especially British bike brands - outsource the manufacture of their bicycles to companies in Vietnam. These companies are often owned or co-owned by Taiwanese companies not noted for their export of cheap, shoddy bicycles.
Vietnam-produced bicycles can be high-end and produced for brands noted for quality bicycles available from quality retail outlets.
ETRA clams that if the EU were to introduce anti-dumping measures, these could well result in a sudden decline of Vietnamese imports into the EU as well as in a restriction of competition. ETRA warns that in those countries, which import branded and private label bikes from Vietnam such a decline cannot be compensated at short notice.
"Importers cannot move from one subcontractor to another just like that," said ETRA.
"Dealers cannot switch from one brand to another very easily. A number of jobs in the independent bike shop sector would be in the balance. The consumer will be confronted with a restricted offer, higher prices and less choice."
EBMA's dumping complaint against Vietnam is factually wrong, claims ETRA.
"The majority of the accused manufacturers in Vietnam produce for export only and not for the domestic market. Therefore, it is improbable for them to generally dump sales in the EU, which cannot be compensated by domestic sales.
"Normal value and price undercutting as calculated by EBMA are not realistic."
ETRA also questions EBMA's arithmetic, claiming the Paris-based organisation - run by Brian Montgomery of Cycleurope - is "inconsistent in quoting figures on EU bicycle consumption, production, market shares."
Worse, ETRA believes EBMA is pulling wool over the eyes of EU anti-dumping officials to protect the interests of only a "minority" of European bicycle producers.
This is the fifth dumping complaint lodged by the EBMA against bicycle imports originating in a Southeast Asian country in approximately the last 15 years," said ETRA.
"Apart from the complaint against Chinese bicycle imports, none of them have resulted in an improvement of the Community producers situation. Could this be because the alleged dumping is not the cause of their situation? With every dumping complaint inspired by protectionist motives, the Community producers harm the interests of IBDs, some of whom are their own customers, and of consumers.
"EBMA is misusing the European anti-dumping legislation for protectionist reasons and is aiming at capitalising on that legislation at the expense of consumers and bike shops who are, by far, the biggest employers in the European bicycle business."
ETRA has a stark message for those bicycle producers who continue to fund the European Bicycle Manufacturers' Association: stop moaning.
"Time and money should be spent on growing the bicycle market in Europe by means of constructive initiatives."