China Unveils Preliminary Anti-Subsidy Ruling On EU Dairy Imports
- rsatax
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On 22 December 2025, China’s Ministry of Commerce issued Announcement No. 83 of 2025, setting out the preliminary determination of its countervailing (anti-subsidy) investigation into certain dairy products imported from the European Union. Provisional countervailing duties will be imposed with a deposit with effect from 23 December 2025 to 21 February 2026. Following this provisional period, the authorities will decide whether to confirm and impose definitive countervailing duties. Follows the translation of the announcement.
Announcement of the Preliminary Determination of the Countervailing Investigation into Certain Dairy Products Imported from the European Union.
Issuing Authority: Trade Remedy Bureau
Document No.: MOFCOM Announcement No. 83 of 2025
Date of Issue: December 22, 2025
In accordance with the Regulations of the People’s Republic of China on Countervailing Measures (hereinafter referred to as the “Countervailing Regulations”), on August 21, 2024, the Ministry of Commerce (hereinafter referred to as the “investigating authority”) issued Announcement No. 34 of 2024, deciding to initiate a countervailing investigation into certain dairy products imported from the European Union (hereinafter referred to as the “products under investigation”).
The investigating authority conducted an investigation into whether the products under investigation were subsidized and the amount of such subsidies, whether the domestic industry producing like dairy products suffered injury and the degree of such injury, and whether there was a causal relationship between the subsidies and the injury. Based on the findings of the investigation and in accordance with Article 25 of the Countervailing Regulations, the investigating authority has made a preliminary determination (see Appendix 1). The relevant matters are hereby announced as follows:
I. Preliminary Determination
The investigating authority preliminarily determines that certain dairy products imported from the European Union are subsidized, that the relevant domestic dairy industry in China has suffered material injury, and that there is a causal relationship between the subsidies and the material injury.
II. Provisional Countervailing Measures
Pursuant to Articles 29 and 30 of the Countervailing Regulations, the Ministry of Commerce has proposed to the Customs Tariff Commission of the State Council that provisional countervailing measures be imposed on certain dairy products imported from the European Union. Based on the proposal of the Ministry of Commerce, the Customs Tariff Commission of the State Council has decided that, as of December 23, 2025, provisional countervailing measures shall be implemented in the form of cash deposits for provisional countervailing duties on certain dairy products imported from the European Union.
When importing the products under investigation, import operators shall provide to the Customs of the People’s Republic of China the corresponding provisional countervailing duty cash deposits based on the ad valorem subsidy rates for each company as determined in this preliminary determination.
The specific description of the products under investigation is as follows:
Scope of Investigation: Certain dairy products imported from the European Union.
Product Name: Certain dairy products.
English Name: Certain dairy products.
Product Description: The products include fresh cheese (including whey cheese) and curd; processed cheese (whether or not grated or powdered); blue-veined cheese and other cheese with veins produced by Penicillium roqueforti; other cheeses not elsewhere specified; and milk and cream, not concentrated and not containing added sugar or other sweetening matter, with a fat content by weight exceeding 10%.
Main Uses: Mainly for direct human consumption as food, or for consumption after processing.
Customs Tariff Codes (PRC Import and Export Tariff Schedule): 04015000, 04061000, 04062000, 04063000, 04064000, 04069000.
The ad valorem subsidy rates applicable to companies in the European Union are set out in Appendix 2 to this Announcement.
III. Method for the Collection of Provisional Countervailing Duty Cash Deposits
As of December 23, 2025, when importing certain dairy products originating in the European Union, import operators shall provide the corresponding provisional countervailing duty cash deposits to the Customs of the People’s Republic of China based on the ad valorem subsidy rates determined for each company in this preliminary determination. The provisional countervailing duty cash deposits shall be levied on an ad valorem basis using the dutiable value of the imported goods as determined by Customs, calculated according to the following formula:
Provisional countervailing duty cash deposit amount =
Customs-determined dutiable value of the imported goods × provisional countervailing duty cash deposit rate
The cash deposit for import-stage value-added tax shall be levied on an ad valorem basis using as the tax base the customs-determined dutiable value of the imported goods plus customs duties and the provisional countervailing duty cash deposits.
IV. Comments
Interested parties may submit written comments to the investigating authority within 10 days from the date of publication of this Announcement.
Appendices:
Ministry of Commerce
December 22, 2025
List of EU Companies and subsidy rates:
Elvir (29.7%)
Fromarsac (29.7%)
B.G. (29.7%)
Bressor Sa (29.7%)
Compagnie Des Fromages Et Richesmonts (29.7%)
Compagnie Fromagere De La Vallee De L’ance (29.7%)
Grand’ouche Sa (29.7%)
Lescure (29.7%)
Fromageries Papillon (29.7%)
Fromageries Perreault (29.7%)
Fromagerie De Vihiers (29.7%)
Fromageries Des Chaumes (29.7%)
Frieslandcampina Belgium N.V. (42.7%)
Frieslandcampina Nederland B.V. (42.7%)
Sterilgarda Alimenti Spa (21.9%)
Basso Sebastiano S.R.L (28.6%)
Beppino Occelli Agrinatura S.R.L. (28.6%)
Brazzale S.P.A. (28.6%)
Campo De San Juan; S.L.U. (28.6%)
Candia (28.6%)
Coopérative Agricole Laitière Les Maîtres Laitiers Du Cotentin (28.6%)
Delizia S.P.A. (28.6%)
Molkerei Ammerland Eg (28.6%)
Laïta (28.6%)
Isigny Sainte-Mere (28.6%)
Dmk Deutsches Milchkontor Gmbh (28.6%)
Lactosan A/S (28.6%)
Privatmolkerei Naarmann Gmbh (28.6%)
Arla Foods Amba (28.6%)
Arla Foods Deutschland Gmbh (28.6%)
Corporación Alimentaria Peñasanta, S.A. (28.6%)
Innolact, Sl (28.6%)
Lacteos Industriales Agrupados S.A. (28.6%)
Latte Montagna Alto Adige Soc. Agr. Coop. (28.6%)
Egidio Galbani S.R.L. (28.6%)
Fromagerie De Livarot (28.6%)
Industrias Lacteas De Mollerusa, S.L.U (28.6%)
Molkerei-Laitiere Walhorn (28.6%)
Societe Fromagere De Charchigne (28.6%)
Societe Fromagere De Lons Le Saunier (28.6%)
Societe Fromagere De Rodez (28.6%)
Societe Laitiere De L’hermitage (28.6%)
Sill Sas (28.6%)
Zanetti S.P.A (28.6%)
Granarolo S.P.A. (28.6%)
Cilento S.P.A. (28.6%)
Centro Trasformazione Latte L.L.C. (28.6%)
Prika Dairy Industry B.V. (28.6%)
Schipper Cheese B.V. (28.6%)
A-Ware Mozzarella & Cream Bv (28.6%)
A-Ware Cheese Production B.V. (28.6%)
Olympia N.V. (28.6%)
Lactalis International (28.6%)
Consortium Latterie Virgilio Agricultural Cooperative Company (28.6%)
Fallini Formaggi Srl (28.6%)
Formalactis S.R.L. Limited Liability Company (28.6%)
Igor S.R.L (28.6%)
Kerry Ingredients & Flavours Limited (28.6%)
Latteria Soresina Dairy Agricultural Cooperative Company (28.6%)
Produttori Latte Associati Cremona Sca (28.6%)
Rupp Austria Gmbh (28.6%)
Royal A-Ware Food Group B.V. (28.6%)
Fromageries Bel Production (28.6%)
Eurial Holding (28.6%)
Other EU Companies (42.7%)