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In response to the Commission’s General Disclosure Document, ETRA has lodged a strong protest against the measures that will be proposed against bicycle imports from Vietnam.
In ETRA’s view it was unjust for the Commission to assess Chinese and Vietnamese bicycle imports cumulatively. It is precisely that assessment that has allowed the Commission to conclude that the bicycle import from Vietnam is being dumped.
According to the Basic Regulation, cumulative assessment must be appropriate in light of the conditions of competition between imported products and the conditions of competition between the imported and the Community product. ETRA has pointed out to the Commission that this is not the case for Chinese and Vietnamese imports which, in the European Union, are hardly in competition with each other.
The Commission itself has found that Chinese bicycles are mainly sold in high volume sales channels. Moreover, the Commission confirmed in the General Disclosure Document that the sampled Community producers mainly compete in the same sales channels. The bicycles imported from Vietnam into the European Union however are to a very large degree sold by specialist dealers. It mainly concerns bicycles which are either branded by the Vietnamese producers themselves or branded bicycles which the Vietnamese companies produce as subcontractors for Community companies.
ETRA also pointed out that a separate assessment of the Vietnamese import would have allowed the Commission to find that the strong increase of bicycles imported from Vietnam was to a large extent the result of Community producer Raleigh closing down their UK production facilities. In 2003, over 43% of the Vietnamese import into the EU was sold to the UK. Compared to 2002, the EU import rose with 645,296 bicycles. The UK accounted for more than 75% of that increase, since the British import of Vietnamese bicycles grew from 103,431 to 591,588 units.
In the General Disclosure Document, the Commission concludes that importers and retailers will not be substantially affected by anti-dumping duties against Vietnamese bicycles since “fairly priced bicycles will still be available in the market”. ETRA refuted this claim by indicating that the interest of retailers in this matter does not only involve “fairly priced bicycles” but also the brand and the quality as supplied by the Vietnamese companies.
If the application of anti-dumping duties should result in a sudden decline of Vietnamese imports into the EU, that may well result in a restriction of competition. In those countries, which import branded and private label bikes, such a decline cannot be compensated at short notice. Importers cannot move from one subcontractor to another just like that. Dealers cannot switch from one brand to another that easily. As a result, a number of jobs in the IBD-sector will be in the balance whereas consumers will be confronted with a restricted offer, higher prices and less choice with regard to price range.
As for the envisaged measures against Chinese bicycle imports, ETRA applauds the Commission intention to propose 48.5% duty for a new period of 5 years. With that however, ETRA stresses that the measures in place have failed to offset dumping because of the lack of surveillance. The association therefore believes that the new measures can only have the desired effect provided that they are properly policed.