EU registers Chinese polyether polyols, opening door to retroactive duties

The European Commission has told EU customs authorities to register imports of certain polyether polyols originating in China, an input used to make polyurethane foams. Implementing Regulation (EU) 2026/2409, adopted on November 5 and published in the Official Journal on November 6, entered into force on November 7. Registration lasts nine months, that is, until early August 2027.

Registration is not a duty, and nothing extra is charged at the border today. It means that an anti-dumping duty, if the investigation ends in definitive measures and the legal conditions are met, can also be collected on shipments already registered. The Commission ordered registration on its own initiative and says it will assess the conditions for retroactive collection only in the regulation imposing definitive duties, if any.

Calculations in the complaint estimate a dumping margin of 101% and an injury elimination level of 60%. Under the EU’s general rule, any liability would normally be set at the lower of those two levels. The Commission, however, says it cannot yet estimate the amount and that the complaint’s figures are for information only. If it finds raw material price distortions and concludes that a lower level would not remove the injury, the liability could be set at the level of the dumping margin.

The registered product is polyether polyols with a hydroxyl number between 10 and 520, obtained by polymerising a starter with ethylene oxide and/or propylene oxide, currently classified under CN code ex 3907 29 20 (TARIC 3907 29 20 35 and 3907 29 20 90). It covers pure polyols, blends, and formulations with additives such as flame retardants, surfactants and stabilisers, or with catalysts, provided at least 50% of the weight is pure polyol. Polyethylene glycols (PEGs), under CN code 3907 29 11, are excluded.

The investigation opened on June 30, 2026, after a complaint lodged on June 8 by BASF, Covestro, PCC Rokita, Shell and Chimcomplex on behalf of producers representing more than 25% of EU production. The investigation period runs from April 1, 2025 to March 31, 2026, and the complainants named Mexico as the representative country for constructing normal value. Under the schedule in the initiation notice, provisional measures can be imposed no later than seven months after the opening, and in any event no later than eight, which puts the deadline at the end of January 2027, or the end of February 2027 at the latest. The Commission informs parties four weeks before imposing provisional duties.

Polyols are not the only Chinese chemical under registration in the EU. According to a November 10 circular from Hong Kong’s Trade and Industry Department, Implementing Regulation (EU) 2026/2391, published on October 30, also made imports of certain cellulose ethers originating in China, among other countries, subject to registration from October 31.

Trade defence on chemical inputs runs both ways. The US has just imposed a preliminary anti-dumping deposit on Chinese PTMEG, another polyurethane input, and China is investigating para-aramid filament from the European Union.

CSP take: for European importers of Chinese polyols, exposure no longer starts on the date of a provisional duty; it can reach shipments registered since November 7. It is worth checking whether each product falls within the scope, including formulated systems, and agreeing in the contract who pays if duties are collected retroactively. On our reading of the scope, foams and finished goods such as mattresses and seats are not covered, because registration applies to the polyol classified under CN code ex 3907 29 20. Outside the EU, the measure changes no tariff. This reading is ours, not the European Commission’s.