Revision of the calculation methodology of dumping

28-02-2017

The IA appears to provide a well-researched explanation of the evidence base for the legislative proposal; it clearly explains the scale of the problem, illustrated by facts and figures giving a clear view of the international situation. However, a better, more coherent organisation of the data related to the problem definition, and a broader range of options, would have strengthened the IA. Option 3 is the only viable one to address all the objectives, although – as also indicated by stakeholders – its elements are only vaguely presented. The IA would have been more persuasive had it been clearer about the modification of the standard methodology. In particular, it would have benefited from a better explanation as to how it would work in practice, in order to allow the EU to continue to disregard domestic costs and prices of China and other NME countries, as this appears to be the most crucial element of the preferred option. The IA does not look at the impact on the economic performance of the EU sectors concerned, and remains unclear as to how EU SMEs would be affected. The stakeholder consultation covered a broad range of stakeholders and the collected views are presented systematically throughout the IA. However, it seems that stakeholders were not given the opportunity to comment in detail on the preferred option 3. The consultation seems to have happened at an early stage in the drafting process of the IA, which could explain the vague questions asked and the shortened period of consultation of 10 weeks instead of 12.

The IA appears to provide a well-researched explanation of the evidence base for the legislative proposal; it clearly explains the scale of the problem, illustrated by facts and figures giving a clear view of the international situation. However, a better, more coherent organisation of the data related to the problem definition, and a broader range of options, would have strengthened the IA. Option 3 is the only viable one to address all the objectives, although – as also indicated by stakeholders – its elements are only vaguely presented. The IA would have been more persuasive had it been clearer about the modification of the standard methodology. In particular, it would have benefited from a better explanation as to how it would work in practice, in order to allow the EU to continue to disregard domestic costs and prices of China and other NME countries, as this appears to be the most crucial element of the preferred option. The IA does not look at the impact on the economic performance of the EU sectors concerned, and remains unclear as to how EU SMEs would be affected. The stakeholder consultation covered a broad range of stakeholders and the collected views are presented systematically throughout the IA. However, it seems that stakeholders were not given the opportunity to comment in detail on the preferred option 3. The consultation seems to have happened at an early stage in the drafting process of the IA, which could explain the vague questions asked and the shortened period of consultation of 10 weeks instead of 12.