In-depth analysis of the end-of-term review of ethanolamine anti-dumping: domestic industrial protection and industry pattern iteration under the trade remedy mechanism

In-depth analysis of the final review of ethanolamine anti-dumping: In-depth analysis of the final review of trade ethanolamine anti-dumping: Domestic industrial protection and industry pattern under the trade Iteration of domestic industrial protection and industry pattern under the relief mechanism

1. The industrial macro background and underlying motivation of this final review 1. The industrial macro background and underlying motivation of this final review

Ethanolamine (MEA/DEA/TEA) is the basic rigid demand raw material in the modern fine chemical system. It spans the entire industrial chain of surfactants, gas purification, pesticides and medicine, textile building materials, metal processing, and daily chemical cleaning. It belongs to the typical "small product category, large rigid demand, and strong correlation" basic chemical products. Its supply chain stability, stable price, and independent production capacity are directly related to the cost and supply security of thousands of downstream fine chemical products. Our country is the largest consumer market for ethanolamine in the world, but for a long time, the domestic production capacity concentration, technical process stability, and large-scale cost advantages are not as good as overseas mature giants. The impact of foreign import dependence and external low-price dumping has existed for a long time. Ethanolamine (MEA/DEA/TEA) is the basic rigid demand raw material in the modern fine chemical system. It spans the entire industrial chain of surfactants, gas purification, pesticides and medicine, textile building materials, metal processing, daily chemical cleaning, etc. It belongs to the typical "small product category, large rigid demand, strong correlation" basic chemical products. Its supply chain stability, stable price, and independent production capacity are directly related to the cost and supply security of thousands of downstream fine chemical products. Our country is the largest consumer market for ethanolamine in the world, but for a long time, the domestic production capacity concentration, technical process stability, and large-scale cost advantages are not as good as overseas mature giants. The impact of foreign import dependence and external low-price dumping has existed for a long time.

In 2018, our country implemented five-year anti-dumping measures against imports of ethanolamine from the United States, Saudi Arabia, Malaysia and Thailand for the first time, which is essentially a trade correction for low-cost dumping of overseas low-cost production capacity into China and squeezing the survival space of domestic industries. After the expiration of 2023, domestic leading ethanolamine producers jointly submitted a final review application. The core appeal is not simple trade barrier protection, but based on the first time in 2018 that our country implemented five-year anti-dumping measures against imports of ethanolamine from the United States, Saudi Arabia, Malaysia and Thailand. The essence is a trade correction for low-cost dumping of overseas production capacity into China and squeezing the survival space of domestic industries. After the expiration of 2023, domestic leading ethanolamine producers jointly submitted a final review application. The core appeal is not simply trade barrier protection, but based on the multiple realities of global production capacity restructuring, overseas low-cost production capacity continued to overflow, domestic industrial upgrading has not been completed, downstream rigid demand continues to expand global production capacity restructuring, overseas low-cost production capacity continues to overflow, domestic industrial upgrading has not been completed, and downstream rigid demand continues to expand , to prevent after the end of the five-year protection period, overseas low-priced products once again impact the domestic market, resulting in idle local production capacity, stagnant industrial investment, and continuous compression of industry profits.

From the perspective of the industry structure, companies such as Dow, Ineos, Huntsman, Saudi SABIC, Petronas Petrochemical of Malaysia, and TOC of Thailand rely on the advantages of low-cost oil and gas raw materials, large-scale equipment, and integrated industrial chain, and have strong cost-crushing capabilities. In the absence of trade remedy constraints, overseas enterprises can quickly seize the domestic market through low-price dumping, suppress domestic enterprises' R & D investment and production capacity expansion, and form a vicious circle of "low-end dumping, high-end monopoly, and long-term domestic industry restraint". This is also the core underlying logic of maintaining the original taxation policy during this review and investigation. From the perspective of the industry structure, companies such as Dow, Ineos, Huntsman, Saudi SABIC, Petronas Petrochemicals of Malaysia, and TOC of Thailand rely on the advantages of low-cost oil and gas raw materials, large-scale equipment, and integrated industrial chain, and have strong cost crushing capabilities. In the absence of trade remedy constraints, overseas enterprises can quickly seize the domestic market through low-price dumping, suppress domestic enterprises' R & D investment and capacity expansion, and form a vicious circle of "low-end dumping, high-end monopoly, and long-term domestic industry restraint". This is also the core and underlying logic of maintaining the original taxation policy during this review and investigation.

Professional logic of differentiated tax rates in the second and fourth countries: not one-size-fits-all, accurately matching dumping margins Professional logic of differentiated tax rates in the second and fourth countries: not one-size-fits-all, accurately matching dumping margins

The anti-dumping tax rate extended this time presents significant country-by-country and enterprise differentiation characteristics, and is not a unified tax rate control. It fully reflects the core principles of "seeking truth from facts, matching the amplitude, and precise regulation" in our country's anti-dumping investigation. The tax rate completely corresponds to the differences in the true dumping margin and cost advantage of different countries and enterprises, and has strong professionalism and rationality. The anti-dumping tax rate extended this time presents significant country-by-country and enterprise differentiation characteristics, and is not a unified tax rate control. It fully reflects the core principles of "seeking truth from facts, matching the amplitude, and precise regulation" in our country's anti-dumping investigation. The tax rate completely corresponds to the differences in the true dumping margin and cost advantage of different countries and enterprises, and has strong professionalism and rationality.

The US has the highest corporate tax rate (76.0% -97.1%), which is the core object of this trade regulation. The US ethanolamine industry relies on the world's leading ethylene oxide-ammonia process integration process, with a large scale of equipment, high degree of automation, and extremely low cost of raw materials. It has the largest dumping margin against China and the strongest market impact. Some small and medium-sized enterprises have nearly doubled the dumping margin. Therefore, it corresponds to the highest punitive tax rate to effectively curb the influx of US products into the domestic market at low prices. The US has the highest corporate tax rate (76.0% -97.1%), which is the core object of this trade regulation. The US ethanolamine industry relies on the world's leading ethylene oxide-ammonia process integration process, with large-scale equipment, high degree of automation, and extremely low raw material costs. It has the largest dumping margin against China and the strongest market impact. Some small and medium-sized enterprises have nearly doubled their dumping margins. Therefore, corresponding to the highest punitive tax rate, it effectively curbs the influx of US products into the domestic market at low prices.

Saudi Arabia has the lowest tax rate range (10.1% -27.9%), the core reason is that Saudi petrochemical enterprises rely on local cheap oil and gas resources, production costs are naturally low, and their export pricing relies more on cost advantages. The malicious dumping margin is relatively limited, and the top compliance corporate tax rate is only 10.1%. This reflects the accurate distinction between "cost advantage exports" and "malicious low-price dumping" by the investigation agency, and avoids excessive trade protection from causing market supply shortages. Saudi Arabia has the lowest tax rate range (10.1% -27.9%), the core reason is that Saudi petrochemical enterprises rely on local cheap oil and gas resources, production costs are naturally low, and their export pricing relies more on cost advantages. The malicious dumping margin is relatively limited, and the top compliance corporate tax rate is only 10.1%. This reflects the accurate distinction between "cost advantage exports" and "malicious low-price dumping" by the investigation authorities, and avoids the shortage of market supply caused by excessive trade protection.

The tax rates of Malaysia (18.3% -20.3%) and Thailand (unified 37.6%) are in the middle. Relying on the advantages of location logistics, South East Asia enterprises export to China with low transportation costs and convenient customs clearance. They are the main force in the incremental export of ethanolamine to China in recent years. The dumping margin is stable and concentrated. Therefore, the tax rate is set in a balanced and unified manner, accurately matching its market output scale and dumping hazard. At the same time, Malaysia has set an exclusive enterprise differentiated tax rate, which is moderately relaxed for formal compliance trade enterprises, and strictly controlled for disorderly export enterprises, taking into account trade fairness and market supply stability. The tax rates of Malaysia (18.3% -20.3%) and Thailand (unified 37.6%) are in the middle. Relying on the advantages of location logistics, South East Asia enterprises export to China with low transportation costs and convenient customs clearance. They are the main force in the increase of ethanolamine exports to China in recent years. The dumping margin is stable and concentrated. Therefore, the tax rate is set in a balanced and unified manner, accurately matching the scale of its market output and the degree of dumping harm. At the same time, Malaysia has set an exclusive enterprise differentiated tax rate, which is moderately relaxed for formal compliance trade enterprises, and strictly controlled for disorderly export enterprises, taking into account trade fairness and market supply stability.

III. The core value of the end-of-term review investigation mechanism: steady-state guarantee during the transition period III. The core value of the end-of-term review investigation mechanism: steady-state guarantee during the transition period

According to our country's "Anti-Dumping Regulations", anti-dumping measures must be subject to a final review after five years expire, and the core criterion is "whether the termination measure will cause the continuation or recurrence of dumping and industrial injury". During the review cycle of the case filed in October 2023 and closed in October 2024, the Tariff Commission of the State Council made it clear that according to our country's "Anti-Dumping Regulations", anti-dumping measures must be subject to a final review after five years expire. The core criterion is "whether the termination measure will cause the continuation or recurrence of dumping and industrial injury". During the review cycle of the case filed in October 2023 and closed in October 2024, the Tariff Commission of the State Council made it clear that maintaining the original taxation policy unchanged and maintaining the original taxation policy unchanged is the standard steady-state operation of chemical trade remedies, with strong industrial protection rationality., is the standard steady-state operation of chemical trade remedies, with strong industrial protection rationality.

The setting of the review investigation period is highly scientific: the dumping investigation period focuses on the trade data of the past year (2022.7-2023) to accurately capture the latest dumping behavior; the industrial damage investigation period is extended to nearly five years (2019-2023), and core indicators such as domestic production capacity, operating rate, profit, market share, and investment willingness are tracked for a long time to avoid short-term market fluctuations from interfering with the judgment results. This investigation mode combining long and short cycles can accurately identify the continuous harm of overseas dumping and prevent policy misjudgments caused by short-term market fluctuations. The setting of the review investigation period is highly scientific: the dumping investigation period focuses on the trade data of the past year (2022.7-2023) to accurately capture the latest dumping behavior; the industrial damage investigation period is extended to nearly five years (2019-2023), and core indicators such as domestic production capacity, operating rate, profit, market share, and investment willingness are tracked for a long time to avoid short-term market fluctuations from interfering with the judgment results. This investigation model combining long and short cycles can accurately identify the continuous harm of overseas dumping and prevent policy misjudgments caused by short-term market fluctuations.

Maintain the original tax rate for the entire review cycle, completely avoiding the risk of "policy gap period". If the tax is terminated immediately after the review is filed, overseas low-priced products will be flooded in a short period of time, rapidly impacting the domestic market, disrupting the industry price system, and causing domestic enterprises to suffer periodic losses. Even if the subsequent ruling continues the anti-dumping measures, the industry has suffered irreversible damage. Continued taxation during the transition period provides a stable policy buffer and development window period for the domestic industry. Maintain the original tax rate for the entire review cycle, completely avoiding the risk of "policy gap period". If the tax is terminated immediately after the review is filed, overseas low-priced products will be flooded in a short period of time, rapidly impacting the domestic market, disrupting the industry price system, and causing local enterprises to lose money in stages. Even if the subsequent ruling extends the anti-dumping measures, the industry has suffered irreversible damage. Continued taxation during the transition period provides a stable policy buffer and development window for the domestic industry.

IV. The logic of domestic industrial upgrading behind trade remedies (core exclusive view) IV. The logic of domestic industrial upgrading behind trade remedies (core exclusive view)

The core value of anti-dumping measures is by no means simply raising import costs and restricting the entry of overseas products, but the core value of anti-dumping measures. It is by no means simply raising import costs and restricting the entry of overseas products. It is for the upgrading of domestic high-end, refined and green industries to gain time and profit space for the upgrading of domestic high-end, refined and green industries. This is also the deep strategic appeal of this industry joint application for review. Since the implementation of the first round of anti-dumping in 2018, the domestic ethanolamine industry has completely bid farewell to disorderly competition at low prices, repaired industry profits, and the leading enterprises have continued to increase investment in process technology transformation, environmental protection upgrading, and high-end category research and development., which is also the deep strategic appeal of this industry joint application for review. Since the implementation of the first round of anti-dumping in 2018, the domestic ethanolamine industry has completely bid farewell to disorderly competition at low prices, repaired industry profits, and continued to increase investment in technological innovation, environmental protection upgrades, and high-end category research and development.

For a long time, domestic ethanolamine products are mostly concentrated in low-end application fields such as industrial cleaning, ordinary surfactants, and basic gas purification, with serious product homogeneity and low added value; while high-end pharmaceutical intermediates, high-purity electronic grade ethanolamine, and fine daily chemical products still have import dependence. The five-year trade protection cycle has allowed domestic leading enterprises such as Sierbang, Zhongke Refining, and Jinyan Chemical to complete large-scale capacity expansion and process iteration, and gradually realize domestic substitution of high-end categories. For a long time, domestic ethanolamine products are mostly concentrated in low-end application fields such as industrial cleaning, ordinary surfactants, and basic gas purification. The product homogeneity is serious and the added value is low; while high-end pharmaceutical intermediates, high-purity electronic grade ethanolamine, and fine daily chemical products still have import dependence. The five-year trade protection cycle has allowed domestic leading enterprises such as Sierbang, Zhongke Refining, and Jinyan Chemical to complete large-scale capacity expansion and process iteration, and gradually realize domestic substitution of high-end categories.

If the anti-dumping measures are cancelled rashly, overseas high-end and low-priced products will squeeze the domestic market in both directions, which will not only lead to the loss of low-end products, but also directly interrupt the process of high-end domestic substitution, so that the domestic industry will be locked in the low-value-added track for a long time and lose the impetus for technological upgrading. The essence of the continuation measures of this review is to exchange reasonable trade protection for the independent controllable and high-quality development of domestic fine chemical basic raw materials. If the anti-dumping measures are cancelled rashly, overseas high-end and low-priced products will squeeze the domestic market in both directions, which will not only lead to the loss of low-end products, but also directly interrupt the process of high-end domestic substitution, so that the domestic industry will be locked in The continuation measures of this review are essentially to use reasonable trade protection in exchange for the independent, controllable and high-quality development of domestic fine chemical basic raw materials.

5. Analysis of the chain influence on the upstream and downstream industrial chains 5. Analysis of the chain influence on the upstream and downstream industrial chains

For the upstream raw material end, the continuous anti-dumping policy has stabilized the operating rate and capacity utilization rate of the domestic ethanolamine industry, ensured the stable domestic demand of basic raw materials such as ethylene oxide and liquid ammonia, and promoted the healthy development of the upstream petrochemical supporting industry, avoiding the imbalance between raw material supply and demand caused by the large-scale shutdown and production reduction of the industry. For the upstream raw material end, the continuous anti-dumping policy has stabilized the operating rate and capacity utilization rate of the domestic ethanolamine industry, ensured the stable domestic demand of basic raw materials such as ethylene oxide and liquid ammonia, and promoted the healthy development of the upstream petrochemical supporting industry, avoiding the imbalance of raw material supply and demand caused by the large-scale shutdown of the industry. For downstream applications, in the short term, the supply of imported low-priced raw materials is limited, and the domestic price of ethanolamine maintains a reasonable stable range, which prevents the vicious collapse of prices and the chaos of industry losses and closures caused by overseas dumping. In the long run, the stable industry environment promotes the continuous improvement of domestic product quality. High-purity, low-impurity, and stable batches of domestic ethanolamine gradually replace imported products, but reduce the procurement costs and supply chain risks of downstream high-end daily chemical, pharmaceutical, and precision manufacturing enterprises, and achieve a two-way balance of "benign profits in the industry + stable supply in the downstream". For downstream applications, in the short term, the supply of imported low-priced raw materials is limited, and domestic ethanolamine prices maintain a reasonable stable range, which prevents the vicious collapse of prices and the chaos of industry losses and closures caused by overseas dumping. In the long run, the stable industry environment promotes the continuous improvement of domestic product quality. High-purity, low-impurity, and stable batches of domestic ethanolamine gradually replace imported products, but reduce the procurement costs and supply chain risks of downstream high-end daily chemical, pharmaceutical, and precision manufacturing enterprises, and achieve a two-way balance of "benign profits in the industry + stable supply in the downstream".

At the same time, the policy effectively avoids the domestic production capacity clearance caused by the disorderly import of overseas production capacity, guarantees the stability of domestic employment, petrochemical industry investment and regional chemical industry chain, and has significant industrial economy and real economy protection value. At the same time, the policy effectively avoids the domestic production capacity clearance caused by the disorderly import of overseas production capacity, guarantees domestic employment, petrochemical industry investment and regional chemical industry chain stability, and has significant industrial economy and real economy protection value.

6. Follow-up landing results and long-term trends in the industry 6. Follow-up landing results and long-term trends in the industry

Combined with the Ministry of Commerce's Final Ruling Announcement No. 44 of 2024, the final ruling of this final review: dumping and industrial damage have the possibility of continuation, combined with the Ministry of Commerce's Final Ruling Announcement No. 44 of 2024, the final ruling of this final review: dumping and industrial damage have the possibility of continuation, From October 30, 2024, continue to impose anti-dumping duties on imports of ethanolamine from the four countries for a period of five years, and the tax rate will remain unchanged in 2018. From October 30, 2024, continue to impose anti-dumping duties on imports of ethanolamine from the four countries for a period of five years. The tax rate will remain unchanged in 2018 , marking that our country's ethanolamine industry will once again obtain a five-year stable policy protection window., marking that our country's ethanolamine industry will once again obtain a five-year stable policy protection window Period.

In the future, the industry will present three core trends: First, the domestic substitution will be fully accelerated, and the production capacity of high-end electronic and pharmaceutical grade ethanolamines will continue to be released, gradually getting rid of the monopoly of overseas technologies and products; second, the industry concentration will continue to increase, the advantages of leading large-scale and integrated enterprises will be further enlarged, and the small and medium-sized backward production capacity will be accelerated. Third, the export market will gradually expand. Under the protection of the steady state of the domestic market, domestic enterprises will gradually participate in the global market competition, realizing the transformation from "passive defense" to "active going overseas". In the future, the industry will present three core trends: first, the domestic substitution will be fully accelerated, and the production capacity of high-end electronic grade and pharmaceutical grade ethanolamine will continue to be released, gradually getting rid of overseas technology and product monopoly; second, the industry concentration will continue to increase, the advantages of leading large-scale and integrated enterprises will be further enlarged, and the small and medium-sized backward production capacity will be accelerated. Third, the export market will gradually expand. Under the protection of the steady state of the domestic market, domestic enterprises will gradually participate in the global market competition, realizing the transformation from "passive defense" to "active going to sea".

7. Summary 7. Summary

The end-of-term review of ethanolamine anti-dumping and the continuous taxation policy during the transition period are typical cases of "accurate, appropriate and effective" chemical trade remedies in our country. The policy is not a trade protection barrier, but a market-oriented corrective means for overseas malicious dumping. It not only precisely regulates the unfair trade practices of different countries and enterprises through differentiated tax rates, but also provides a key window period for the upgrading of the domestic basic fine chemical industry, the domestic substitution of high-end categories, and the independent controllability of the industrial chain. In the context of global petrochemical overcapacity and intensifying international trade frictions, a sustained and stable trade remedy policy is an important institutional support to ensure the safety of the supply chain of basic chemical raw materials in our country, promote the high-quality development of the fine chemical industry, and improve the modern petrochemical industry system. The final review of the anti-dumping period of ethanolamine and the continuous taxation policy during the transition period are typical cases of "accurate, appropriate and effective" chemical trade remedies in our country. The policy is not a trade protection barrier, but a market-oriented means of correcting overseas malicious dumping. It not only precisely regulates the unfair trade practices of different countries and enterprises through differentiated tax rates, but also provides a key window period for the upgrading of the domestic basic fine chemical industry, the domestic substitution of high-end categories, and the independent controllability of the industrial chain. In the context of global petrochemical overcapacity and intensifying international trade frictions, a sustainable and stable trade remedy policy is an important institutional support to ensure the security of the supply chain of basic chemical raw materials in our country, promote the high-quality development of the fine chemical industry, and improve the modern petrochemical industry system.

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