O'Connor and Company European Lawyers
Law firm specialising in EU law.
ID: 187290847654-32
Lobbying Activity
Response to Trade measure addressing the negative trade-related effects of global excess capacity on the EU steel sector
16 Dec 2025
FOREWORD The proposal for a Regulation of the European Parliament and of the Council addressing the negative trade-related effects of global overcapacity on the Union steel market must include Fasteners (CN 7318), made of 99% of steel, in the list of products subject to the Regulation. STATEMENT Fasteners (31 CN codes under 7318), as a downstream product, consist of up to 99% of the steel already included in the proposed Regulation. Point 1 of the Annex to this submission demonstrates the correspondence between the 31 CN codes of 7318 with the steel types listed in Annex I of the proposed Regulation. EU27 import volumes of Fasteners from extra-EU27 (see Annex, point 2) have increased in 2024 by 36% since 2013 and the figures for the first 9 months of 2025, compared with the equivalent period in 2013, show an even bigger increase of 56%. In the same period (see Annex, point 3), import market share rose from 38% to 48% balanced by a decrease in EU27 producers market share from 80% to 68%. More dramatic is the situation related to the first 9 months of 2025 vs the same period in 2013 where import market share rose from 38% to 52% while EU27 producers market share decreased from 80% to 63%. This continuous negative trend is jeopardizing the EU27 manufacturing Industry and putting its existence at risk: it has already generated several Company closures, downsizing, bankruptcy, with loss of 3,645 jobs (Fasteners Production) and 10,935 jobs (Fasteners Production Supply Chain, ratio of 3). The European Commission itself has recognized the problem in relation to China (see Reg 191/2022 recital 190): In addition to the Report, the complaint listed a few additional factors pointing to the presence of distortions in the fasteners sector. It listed firstly the problem of overcapacity on the wire rod market. Secondly, the complaint pointed to the state intervention into energy and electricity. Furthermore, the complaint mentioned distortions in the automotive and construction sectors in China (two important users of fasteners), as evidenced by the two publications by the European Union Chamber of Commerce in China: the 2018/2019 and 2019/2020 Business in China Position Papers. The complaint also mentions the two reports prepared by the Think!Desk China Research & Consulting: Final Report Assessment of the normative and policy framework governing the Chinese economy and its impact on international competition, and Draft Final Report The China Iron and Steel Association Government Partner and Information Hub, which show distortions due to the government control over the iron and steel sector, including fasteners. Finally, the complaint pointed to the fact that in the past investigation the Commission already found distortions on the steel market in China. The FOURTH AEGIS EUROPE REPORT ON THE EUS TRADE DEFENCE INSTRUMENTS, while addressing the issue of Excess capacities in many industries, recognizes that Fasteners are currently suffering a global overcapacity of 3.4, which is expected to further develop to 3.5 in the next 5 years (see Annex, point 4 - Table 1, page 7), and this prior to the introduction of duties in the US, which are expected to redirect additional excess capacity towards the EU27. CONCLUSION The Union fasteners sector is suffering injury. The global fasteners industry is in overcapacity. Imports into the Union are increasing. It is in the general interest of the Union to include fasteners in the Annex I of the proposed Regulation. They are made of 99% of steel already covered in Annex I.
Read full responseMeeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and
6 May 2025 · EU’s steel industry