European Commission
Directorate-General for Trade
Rue de la Loi 200, 1049 Brussels, Belgium
Attention: Executive Vice-President and Commissioner

for Trade and Economic Security
Maroš Šefčovič

Dear Mr. Šefčovič,

PJSC Zaporizhzhia Abrasive Plant, a leading Ukrainian manufacturer of abrasive materials and tools based on fused alumina (HS code 2818 10 10), addresses you, recognizing you as a steadfast friend of Ukraine and a dedicated advocate for European values and economic justice. It is a pleasure to recall our meeting ten years ago, in 2015, at the office of Ukraine’s Gas Transmission System Operator, where I had the honor of serving as Chief Engineer.

We express our full support for the anti-dumping investigation AD 720, initiated by the European Commission in November 2024, concerning imports of this raw material from the People’s Republic of China. As a strategic partner of the European Union under the Association Agreement and the Deep and Comprehensive Free Trade Area (DCFTA), our company, views these measures as a critical tool for strengthening European industrial resilience and protecting Ukraine’s national interests.

We gratefully acknowledge your initiative and leadership in safeguarding the European market from unfair competition caused by the dumping of Chinese goods at artificially low prices (with a dumping margin of up to 40-50%, as established by prior investigations, such as Implementing Regulation (EU) 2025/1456). The proposed anti-dumping duties of up to 136% are a proportionate and justified response to the systematic violation of WTO rules by Chinese exporters, which has led to a 15-20% reduction in production in the EU and Ukraine over the past year. We are convinced that these anti-dumping measures are not aimed at “excluding competitors,” as some critics claim, but at restoring fair conditions for all market players—from small and medium-sized enterprises (SMEs) to large conglomerates.

In contrast to narratives propagated by some players, which warn of “monopolization by a single conglomerate” and “plant closures in the refractory sector,” we emphasize the tangible benefits of these tariffs for the entire European economic ecosystem:

• Increased tax revenues, not their reduction: A healthy industry generates stable taxes and GDP. Dumping undermines this, leading to losses in budgets amounting to hundreds of millions of euros annually. The AD 720 tariffs, conversely, will stimulate local production, boosting employment and investment, which will ultimately increase tax revenues for the EU by 5-7% in the abrasives and refractory materials sector, according to analysts (including reports by the European Federation of Abrasives Producers, FEPA).
• Protection of competition, not its elimination: Anti-dumping measures do not create monopolies but rather encourage the development of alternative suppliers, such as Ukrainian manufacturers. Over the past year, Zaporizhzhia Abrasive Plant JSC has increased its exports of fused alumina and abrasive products to the EU by 25%, ensuring stable supply chains independent of Asian monopolies. We are ready to supply over 45,000 tonnes of high-quality Brown Fused Alumina (BFA) annually to European consumers at competitive prices. Additionally, we are prepared to restore idled production capacities, which would provide an additional 30,000 tonnes per year. Thus, within one year, Ukrainian manufacturers can ensure the supply of 75,000 tonnes of high-quality BFA, meeting the highest EU standards (ISO 9001 and CE certifications). At the same time, we do not seek to compete in the abrasive tools market, recognizing the importance of supporting European manufacturers in this segment, and focus on supplying raw materials for their operations.

Ukraine is committed to support the European Union in replacing Chinese supplies of fused alumina with the same resilience that the EU demonstrates in supporting our defense capabilities amid ongoing aggression. This is not a “punitive tariff” but a fair barrier against unfair trade practices, strengthening the unified European market.

To ensure comprehensive protection of all industrial supply chains, we propose extending anti-dumping measures to abrasive tools (e.g., HS codes 6804-6805) and steel (including products similar to those already subject to duties, such as tinplate and organic coated steel from China, with tariffs ranging from 13% to 62% under 2025 regulations). Implementing anti-dumping duties on these categories is critical to protecting end-producers of steel, as the very foundation of the European Union was built on the unification of countries around coal mining and steel production under the European Coal and Steel Community (ECSC) of 1951. The democratic unity of the European continent must be reinforced despite encroachments by Chinese producers, whose dumping practices threaten the economic stability and strategic independence of the EU.

PJSC Zaporizhzhia Abrasive Plant urges the European Commission to:

1. Confirm and implement the proposed anti-dumping duties in full for a duration of at least five years.
2. Engage representatives of Ukrainian manufacturers in consultations within the framework of the AD 720 investigation to consider alternative supply sources.
3. Consider extending measures to related products, including abrasive tools and steel products from China, to ensure comprehensive protection of industrial supply chains.

We are ready to provide detailed statistical data, expert assessments, and product samples to support this position. Please contact us at [email protected] for further discussion.

Yours sincerely,

Ihor Burak

Chief Executive Officer