How EU trade defence measures affect your business more than ever

The European Commission published recently its 44th Annual Report on Trade Defence Instruments (TDI), which covers the EU's anti-dumping, anti-subsidy, and safeguard activities throughout 2025. This report contains several critical developments that impact exporters. The 2025 report reveals a significant escalation in EU trade defence scrutiny, with particular focus on Chinese imports. The EU is sharpening its response to import pressure linked to global overcapacity. The game is changing, scrutiny will not start as soon as an investigation starts, import patterns, pricing and supply-chain routes may attract scrutiny well before an investigation starts and measures are imposed.

Three developments to watch

1. Sustained import pressure is in focus

The European Commission’s 44th annual trade-defence report says EU industry’s concerns have shifted from short-term trade diversion to longer-term import pressure associated with global overcapacity, particularly originating in China. Separately, in June 2026 the Commission established an import barometer focused on sustained increases in imports at decreasing prices. The earlier trade-diversion monitoring results are no longer updated. Exports that have been growing steadily but below the radar of traditional surge-detection tools may now trigger investigations. This is particularly relevant for sectors with chronic overcapacity. Economic operators can assess the risks of investigations through the import barometer. A monitoring signal is obviously not, by itself, an investigation or a finding of unfair trade.

2. Registration increases exposure during investigations

The Commission automatically registered imports in new anti-dumping and anti-subsidy investigations initiated in 2025. Registration can enable retroactive duty collection where the legal conditions are met; it does not mean duties automatically apply retroactively. According to the annual report, retroactive measures were applied in three of the 26 definitive measures imposed in 2025. All three cases involved products originating in China.

Companies should be able to substantiate shipment dates, import volumes, prices and applicable measures throughout an investigation, rather than waiting for the final decision. Moreover, importers should regularly check whether relevant investigations are initiated for their products, in order to foresee eventual duty debt for the products imported.

3. Increased level of enforcement and circumvention monitoring

The Commission developed an exporter-reporting and consignment-tracking tool for products subject to company-specific measures. The new tool was introduced early in 2026 in relation to the implementation of the undertaking covering battery electric vehicles.

Moreover, the Commission is paying close attention to transshipment and low-value processing through third countries, improving its ability to identify sophisticated circumvention practices. In July 2025, it extended anti-dumping measures on monosodium glutamate from China to imports from Malaysia after finding transshipment and processing with limited added value.

Exporters using third-country assembly or distribution routes should ensure that commercial records accurately reflect where meaningful production occurs and how goods are routed. A change in shipping route or product presentation should not be treated as a substitute for a defensible origin and trade-defence assessment.