Ferroglobe isn’t content just to charge Brazil and Bosnia with silicon metal dumping but now has warned producers in Norway and Russia they are in its sights.
In its petition, Ferroglobe pointed out that Elkem and Wacker have silicon smelters in Norway. Elkem, wholly-owned subsidiary of China National has three silicon plants in Norway, while Wacker has one plant.
Imports from Norway, although at high levels, have decreased over the period under consideration and the EU market share of Norwegian producers decreased from 30% to 27%. According to Eurostat, imports from Norway are made almost exclusively into Germany and the Netherlands. With regard to imports into Germany, these are most likely
intra-company transfers by Wacker. Imports into the Netherlands, over 90,000 mt, significantly exceed demand in the Netherlands, which is only a couple hundred mt. It is therefore reasonable to conclude that Elkem must have a distribution hub in the Netherlands from where it supplies customers in other EU Member States, and that the import prices reported by Eurostat are transfer prices.
Ferroglobe will continue to monitor silicon imports from Norway closely, especially in light of the recent imposition of provisional AD measures in the US.
However, based on the above observations, it is reasonable to conclude that imports from Norway have not been a cause of injury.
Ferroglobe said imports from Russia have decreased and lost market share over the period under consideration.
There is one (large) silicon producer in Russia, Rusal. Rusal has two plants, ZAO Kremniy and Sual-Kremniy-Ural, with a total annual production capacity of approximately 59,000 mt.
Import volumes from Russia were at a low and stable level throughout the period under consideration. The market share of imports from Russia decreased to 3% in the IP.
As is the case for imports from Norway, imports from Russia were made mainly into the Netherlands and to Germany and again the import volumes into the Netherlands significantly exceeded domestic demand. It is therefore reasonable to conclude that the Russian imports were also made at transfer prices to a warehouse for later distribution to other EU Member States.
This is supported, for example, by comparing Rusal’s average prices in the IP to the Netherlands (€1,490/MT) with those to Germany (€2,023/MT), where sales quantities are indicative of actual arm’s length, third party sales, rather than importation to the warehouse of a related importer. The sales into Germany were clearly made at non-injurious price levels. In addition, average prices of imports from Russia undercut the EU industry’s prices in 2016 Q3- 2017 Q1, but increased and showed no undercutting in 2017 Q2.
In sum, considering the low and decreasing volumes and increasing price trends, it is reasonable to conclude that silicon imports from Russia have not been a cause of injury to the EU industry. In any event, any impact they may have had clearly did not break the causal link between the dumped imports from the subject countries and the material injury of the EU producers. Ferroglobe will however continue to monitor Russian imports closely as well.