EU Anti-Dumping Proceedings for Citric Acid: R851 and R870

Short Abstract

The European Commission is currently conducting two parallel anti-dumping reviews concerning imports of citric acid originating in the People’s Republic of China. R851, initiated on 14 April 2026, is an expiry review examining whether the existing anti-dumping measures should remain in force or be allowed to expire.

R870, initiated on 14 September 2026, is an interim review examining whether changed market circumstances justify a reassessment of dumping and injury margins and potentially a change in the level of the existing duties. The R870 investigation also addresses the methodology used to determine Chinese production costs and normal value, including the possible use of representative countries such as Colombia or Brazil.

The Commission may also decide, during the R870 investigation, to require the registration of imports from China, which could become relevant for the possible retroactive collection of additional anti-dumping duties if the applicable legal conditions are met. Registration itself does not constitute an import quota.

The ongoing regulatory uncertainty is already influencing purchasing behaviour in the European market. Many distributors are securing additional volumes and increasing inventories, which is contributing to tighter availability and increasing international citric acid prices.

1. R851 – Expiry Review

Start date: 14 April 2026

R851 is an expiry review of the existing anti-dumping measures applicable to imports of citric acid originating in China.

The central question is: Would the expiry of the current anti-dumping measures be likely to result in a continuation or recurrence of dumping and injury to the EU citric acid industry?

The existing measures remain in force while the expiry review is ongoing. The investigation covers the review investigation period from 1 April 2025 to 31 March 2026.

The European producers supporting the review argue that Chinese production overcapacity, export pricing and market conditions mean that injurious dumping would likely continue or recur if the current measures were allowed to expire.

The Commission must also examine the Union interest, which includes the interests of Union producers, importers, users and consumers.

Possible outcomes of R851

The Commission can essentially reach one of two outcomes:

1. The existing anti-dumping measures remain in force
   This would be the result if the Commission concludes that the expiry of the measures would be likely to lead to a continuation or recurrence of dumping and injury.
2. The existing anti-dumping measures are allowed to expire
   This would occur if the Commission determines that continuation or recurrence of dumping and injury is not sufficiently likely. The investigation may be concluded earlier, but should normally be completed within 12 months, i.e. by 14 April 2027, and in any event no later than 14 July 2027.

2. R870 – Interim Review

Start date: 14 September 2026

R870 is an interim review of the existing anti-dumping measures. Unlike R851, the purpose is not simply to decide whether the duties should remain in place. The purpose of R870 is to determine whether circumstances have changed sufficiently to justify a reassessment of the dumping and injury margins and potentially the level of the existing anti-dumping duties. The Commission states that the purpose of the review is to establish the rates of dumping and injury.

The applicants argue that circumstances have changed due to factors including:

• increased Chinese production capacity for citric acid
• structural overcapacity in China
• lower Chinese export prices
• increased pressure on the EU citric acid industry

The applicants further argue that Chinese domestic prices and production costs should not be used directly because of alleged significant distortions affecting the Chinese economy and chemical sector. According to the Notice, the applicants proposed Colombia as a possible representative country for constructing normal value and also submitted a constructed normal value using Brazil. The Commission has indicated that Colombia may be considered as a representative third country but will examine whether other suitable countries exist with:

• a comparable level of economic development
• production and sales of citric acid
• sufficiently available and reliable data

The review investigation period is 1 April 2025 to 31 March 2026, while the analysis of injury trends covers the period from 1 January 2023 to 31 March 2026.

Possible Outcomes of R870

The Commission could reach several different conclusions.

Existing duty levels remain unchanged

If the Commission concludes that the current measures remain appropriate, the existing duty levels may stay substantially unchanged.

Duties are increased

If the Commission finds that the current measures are no longer sufficient to counteract dumping and injury, the anti-dumping duties may be increased.

Duties are reduced

If the investigation results in lower dumping or injury margins, the applicable duties may be reduced.

Calculation methodology is changed

The Commission may also change the methodology or benchmark basis used for determining normal value. This may include determining:

• which representative third country should be used
• which raw-material and energy costs should be considered
• which benchmark prices should be applied
• how alleged Chinese market distortions should be reflected in the calculation

The R870 investigation may be concluded earlier, but should normally be completed within 12 months, i.e. by 14 September 2027, and in any event no later than 14 December 2027.

Import Registration and Possible Retroactive Duties

An important distinction is that R870 is an anti-dumping review, not an import quota proceeding. The normal instrument in an anti-dumping proceeding is an additional customs duty, not a fixed maximum quantity that may be imported into the EU. However, the R870 Notice expressly states that the European Commission may, at a later stage of the investigation, instruct customs authorities to register imports of citric acid originating in China. Registration means that customs authorities formally record the relevant imports so that, if the necessary legal conditions are later satisfied, additional anti-dumping duties may potentially be collected on certain imports.

Registration does not mean that imports are stopped once a particular quantity has been reached. It also does not mean that higher duties will automatically be applied retroactively. Retroactive collection requires the applicable legal conditions to be fulfilled and depends on subsequent Commission decisions. Where the legal conditions are met, EU anti-dumping law allows definitive duties in certain circumstances to be imposed retroactively for a limited period. For importers and buyers, this creates an additional element of uncertainty when planning purchases and deliveries during the investigation period.

Could the EU Introduce an Import Quota?

A genuine quota or quantitative ceiling is different from an anti-dumping duty. The current R870 proceeding does not propose a fixed maximum quantity of Chinese citric acid that may be imported into the European Union. A quantitative restriction would normally require a different legal instrument, such as a safeguard proceeding, subject to separate legal requirements.

It is therefore important to distinguish between:

Higher anti-dumping duties
A possible outcome of R870

Registration of imports
A possible procedural measure during R870 that may become relevant to retroactive duty collection.

Import quota or quantitative restriction
A different trade-defence mechanism and not currently proposed under R870.

Current Market Impact

The uncertainty surrounding the ongoing anti-dumping reviews is already influencing purchasing behaviour in the European citric acid market. Many European distributors are currently attempting to increase warehouse inventories and secure additional volumes in advance. The reasons include uncertainty regarding:

• possible increases in anti-dumping duties
• possible future registration of imports
• the timing of the Commission’s decisions
• potential exposure to additional duty costs on future imports

This increased purchasing activity is contributing to stronger demand for available citric acid volumes, particularly from China.

As a consequence, the market is currently experiencing:

• tighter availability
• stronger forward purchasing
• increased pressure on production allocations
• rising international citric acid prices

These developments should not be interpreted as evidence that the Commission has already decided to increase duties or introduce additional restrictions. They are primarily a commercial response to regulatory uncertainty and anticipated future risk.

How R851 and R870 Work Together

The two investigations are running in parallel but address different legal questions.

R851 asks:

Should the existing anti-dumping measures continue after their normal expiry?

R870 asks:

Are the existing measures still appropriate, and should the level or calculation of the duties be changed?

It is therefore possible that the two cases result in complementary decisions. For example, R851 could conclude that anti-dumping measures should continue, while R870 could conclude that the level of the measures should be increased, reduced or recalculated.

Key Dates

Both investigations may be concluded earlier than these dates.

Conclusion

The two EU proceedings could have a significant impact on the European citric acid market during 2027. R851 will determine whether the existing anti-dumping protection should continue, while R870 may determine whether the current level and calculation of that protection should change. Until the investigations are completed, importers, distributors and users of citric acid should closely monitor developments concerning duty levels, import registration and Commission decisions.

The current uncertainty is already affecting purchasing strategies, availability and international pricing, and further market reactions can be expected as the investigations progress. This information is provided for general market information purposes only and should not be regarded as legal or customs advice.