WTO Panel Upholds Indonesia's Key Challenge Against EU Anti-Dumping Duties on Fatty Acid Imports

Key Findings

·         The WTO Panel found that the European Union violated Article 2.4.1 of the Anti-Dumping Agreement by failing to use the exchange rate on the date of sale when calculating the dumping margin.

·         As a consequence of this incorrect exchange-rate methodology, the EU imposed anti-dumping duties exceeding the margin of dumping, thereby acting inconsistently with:

o    Article 9.3 of the Anti-Dumping Agreement, and

o    Article VI:2 of the GATT 1994.

·         The Panel also found the EU inconsistent with Article 1 of the Anti-Dumping Agreement because this violation flowed directly from the substantive breaches.

Claims Rejected by the Panel

The Panel rejected Indonesia's allegations that the EU had violated:

·         Article 5.6 by continuing the anti-dumping investigation after withdrawal of the written application.

·         Article X:3(a) of GATT 1994 concerning the administration of EU anti-dumping and anti-subsidy regulations.

·         Articles 2.2 and 2.2.2 relating to the construction of normal value.

·         Articles 3.1 and 3.4 concerning the EU's injury analysis and assessment of positive injury indicators.

·         The broader consequential claim under Article VI of GATT 1994, except for the specific violation of Article VI:2 linked to the excessive anti-dumping duty.

Panel's Conclusions

·         The Panel concluded that the EU's WTO-inconsistent measures nullified or impaired benefits accruing to Indonesia under the Anti-Dumping Agreement and the GATT 1994.

·         Pursuant to Article 19.1 of the Dispute Settlement Understanding (DSU), it recommended that the European Union bring its measures into conformity with its WTO obligations.

Outcome at a Glance

Claims Upheld

·         Failure to use the date-of-sale exchange rate (Article 2.4.1 ADA).

·         Anti-dumping duty exceeded the lawful dumping margin (Article 9.3 ADA and Article VI:2 GATT 1994).

·         Consequential violation of Article 1 of the Anti-Dumping Agreement.

Claims Rejected

·         Withdrawal of application.

·         Administration of EU regulations.

·         Construction of normal value.

·         Injury determination.

·         General consequential claim under Article VI of GATT 1994.

Recommendation

·         The WTO Panel recommended that the European Union amend its anti-dumping measures to comply with the Anti-Dumping Agreement and the GATT 1994.

 

[ABS News Service/09.07.2026]

WTO Panel Issues Report regarding EU Duties on Imports of Fatty Acid from Indonesia

On 8 July, the WTO circulated the panel report in the case brought by Indonesia in European Union - Anti-Dumping Measures on Imports of Fatty Acid from Indonesia (DS622).

Summary of key findings

DS622: European Union - Anti-Dumping Measures on Imports of Fatty Acid from Indonesia

·         Just the findings and conclusions

·         Panel report

·         Addendum

Summary of the dispute to date

The summary below was up-to-date at 8 July 2026

Consultations

Complaint by Indonesia

On 7 February 2024, Indonesia requested consultations with the European Union with respect to (i) the definitive anti-dumping measures on imports of fatty acid from Indonesia; (ii) the investigation leading to the imposition of these measures; and (iii) the methodology applied by the European Union in anti-dumping investigations (including in the investigation on imports of fatty acid from Indonesia) for constructing normal value based on product control numbers (PCN)-specific costs and profit data.

Indonesia claimed that definitive anti-dumping measures on imports of fatty acid from Indonesia, and the investigation leading to their imposition appear to be inconsistent with:

·         Articles 1, 2.2, 2.2.2, 2.4.1, 3.1, 3.4, 5.3, 5.4, 5.6, 5.8, 9.2, and 9.3 of the Anti-Dumping Agreement; and

·         Articles X:3(a) and VI of the GATT 1994.

Indonesia also claimed that the methodology applied by the European Union in anti-dumping investigations for constructing normal value based on PCN-specific costs and profit data appears to be inconsistent with:

·         Articles 2.2 and 2.2.2 of the Anti-Dumping Agreement; and

·         Article X:3(a) of the GATT 1994.

Panel and Appellate Body proceedings

On 14 November 2024, Indonesia requested the establishment of a panel. At its meeting on 25 November 2024, the DSB deferred the establishment of a panel.

At its meeting on 18 December 2024, the DSB established a panel. Australia, Brazil, Canada, China, Japan, the Russian Federation, Singapore, Türkiye, Ukraine, the United Kingdom and the United States, reserved their third-party rights.

Following the agreement of the parties, the panel was composed on 11 April 2025.

On 1 October 2025, the Chair of the panel informed the DSB that, in light of the amount and complexity of the work involved, the panel did not expect to issue its final report to the parties before the first quarter of 2026. The Chair also apprised the DSB that the report would be available to the public once it was circulated to the Members in all three official languages, and that the date of circulation depends on completion of translation.

On 8 July 2026, the panel report was circulated to Members.

Summary of key findings

This dispute concerns Indonesia's complaint against the anti-dumping measures applied by the European Union on imports of fatty acid from Indonesia following an anti-dumping investigation conducted by the European Commission and an allegedly unwritten measure that the European Commission is claimed to have used in calculating dumping margins.

Claims related to withdrawal of the written application

With respect to Indonesia's claim challenging the European Commission's continuation of the anti-dumping investigation despite the withdrawal of the written application without first making a separate determination that the conditions in Article 5.6 of the Anti-Dumping Agreement were met, the Panel found that the European Commission did not act inconsistently with Article 5.6 because this Article applies only to the initiation of an investigation and does not set out rules of application in the course of the investigation.

Regarding Indonesia's claims of non-uniform and unreasonable administration of Article 9(1) of the EU Basic Anti-Dumping Regulation and Article 14(1) of the EU Basic Anti-Subsidy Regulation following the European Commission's continuation of the anti-dumping investigation while terminating an allegedly parallel countervailing duty investigation, the Panel found that the European Commission did not act inconsistently with Article X:3(a) of the GATT 1994.

Claims related to dumping margin calculations

Concerning Indonesia's claims challenging the European Commission's decision to rely on profits, and selling, administrative and general (SG&A) expenses for certain models of the product under investigation which were derived from domestic sales of those models that were made in low volumes, the Panel found that the European Commission did not act inconsistently with Articles 2.2, 2.2.2, 9.2 and 9.3 of the Anti-Dumping Agreement or Articles X:3(a) and VI:2 of the GATT 1994.

With respect to Indonesia's claims challenging an error made by the European Commission resulting from a failure to correctly convert the currency of certain transactions, the Panel found that the European Commission's error was inconsistent with Article 2.4.1 of the Anti-Dumping Agreement. Based on this finding, the Panel also found that the European Commission acted inconsistently with Article 9.3 of the Anti-Dumping Agreement and Article VI:2 of the GATT 1994.

Claims related to the unwritten measure

Regarding Indonesia's claims challenging an allegedly unwritten measure that the European Commission is asserted to have used in calculating dumping margins, the Panel found that the European Commission did not act inconsistently with Articles 2.2.2 and 2.2 of the Anti-Dumping Agreement and Article X:3(a) of the GATT 1994 because Indonesia had not established that any such unwritten measure existed.

Claims related to injury determination

With respect to Indonesia's claims challenging the European Commission's evaluation of the state of the domestic industry based on various factors set out in the Anti-Dumping Agreement, the Panel found that the European Commission did not act inconsistently with Articles 3.1 and 3.4 of the Anti-Dumping Agreement.

Other claims

Regarding Indonesia's claims under Article 1 of the Anti-Dumping Agreement and Article VI of the GATT 1994 as a consequence of the alleged substantive violations under these Agreements, having found the substantive inconsistencies with Articles 2.4.1 and 9.3 of the Anti-Dumping Agreement, the Panel upheld Indonesia's claim under Article 1 of the Anti-Dumping Agreement. However, the Panel rejected the consequential claim under Article VI of the GATT 1994.