European Aluminium s position on the anti-dumping. proceeding concerning imports of silicon originating in Bosnia and Herzegovina and in Brazil.

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1 Save nb: t Save Date: 14/02/ Page 1 of 6 - TDI.Limited and for parties 2 February 2018 For Inspection 1. INTRODUCTION & EXECUTIVE SUMMARY European Aluminium takes note of the initiation by the European Commission ( Commission ) of an anti-dumping. European Aluminium represents the entire aluminium value chain in Europe. 1 European Aluminium and its membership support free and fair trade. Our members believe that the present anti-dumping investigation should be concluded without the imposition of measures in view of the following: European Aluminium fails to see evidence of dumping causing material injury; European Aluminium fails to see a clear link between imports originating in Bosnia and Herzegovina and in Brazil and the alleged dumping causing material injury, and In any event, the adoption of measures would be against the Union interest, since they would significantly distort the entire aluminium supply chain within the EU which is heavily import dependent. European Aluminium respectfully requests the Commission to consider the below elements in its investigation. 1 European Aluminium is the voice of the entire aluminium value chain in Europe. Our 80+ members include primary aluminium producers; downstream manufacturers of extruded, rolled and cast aluminium; producers of recycled aluminium and national aluminium associations are representing more than 600 plants in 30 European countries. We represent 80% of all production in wider Europe from smelting to rolling and extrusion to recycling. European Aluminium promotes the use of aluminium as a material with permanent properties that is part of the solution to achieving sustainable goals.

2 Save nb: t Save Date: 14/02/ Page 2 of 6 - TDI.Limited and for parties 2. EUROPEAN ALUMINIUM FAILS TO SEE EVIDENCE OF THE EXISTENCE OF DUMPING CAUSING MATERIAL INJURY According to Article 3(2) of the basic Regulation 2 a determination of injury should be based on positive evidence and involves an objective examination of the volume of alleged dumped imports, their effects on prices on the Union market and the consequent impact of those on the Union industry. In view of the price rally and the relative stable market shares of the countries under investigation, our members fail to see evidence of dumping causing material injury The Price Level Of Imports Originating in Bosnia And Herzegovina And in Brazil Largely Follow The Average EU Price Evolution During The Investigation Period The price level of silicon on the metal market increased from around 1,600 per tonne in September 2016 to 2,030 per tonne in September 2017, and further rose to around 2,200 per tonne by the end of This price rally represents a price increase of approximately 27% during the investigation period ( IP ), and an increase of 38% when including Q4 17. The average annual prices for imports originating in Bosnia followed in the period 2013 to 2016 the average EU price evolution, as published by CRU. During certain periods, the price levels of imports originating in Bosnia were even higher than the market average. This was especially the case during During 2017, the average Brazilian import price level corresponded to the average market price level in the EU with the exception of the last quarter of A price hike took place during Q4 2017, from around 1,900 in Q to 2,200 per tonne in Q Import prices for December 2017 are not yet available to our members. The Bosnian import price level in 2016 was well above the EU market average price level, as published by CRU. During 2017, the Bosnian import price was below the average EU market price, however, it was on an increasing trend from Q1 to Q4 2017, following the market price evolution. 2 Regulation (EU) 2016/1036 of the European Parliament and of the Council of 8 June 2016 on protection against dumped imports from countries not members of the European Union, OJ L 176, , p.21. / 2

3 Save nb: t Save Date: 14/02/ Page 3 of 6 - TDI.Limited and for parties 2.2. The Volumes Of Imports Originating in Bosnia And Herzegovina And in Brazil Stayed Relatively Stable During The IP The import share of Bosnia and Herzegovina has remained stable over time. During the IP, we even see a decreasing trend in imports originating in Brazil and only a very slight increase in imports originating in Bosnia and Herzegovina. Table 1: Silicon imports in the EU (tonnes) 3 Country IP (Q4'16-Q3'17) 2017 est. 2017/ /2016 Norway % -12% China % 17% Brazil % -24% Bosnia &Herz % 35% Russia % -34% Australia % -11% Rest % -22% Total % -9% Brazil had a market share of 26% in 2017 versus 23% in 2016; and Bosnia and Herzegovina a share of 7% in 2017 versus 6% in In other words, the import shares of both investigated countries remained relatively stable during the IP. There has not been a significant increase in imports from the countries under investigation, neither in absolute terms or relative to production or consumption in the Union. Table 2: Silicon import share in EU (tonnes) Country IP (Q4 16 Q3 17) 2017 est. Average Import Share China 27,2% 29,1% 17,7% 20,9% 22,7% 24% Brazil 12,9% 11,6% 18,7% 16,3% 15,6% 15% Bosnia &Herz. 4,1% 4,3% 5,3% 7,0% 7,8% 5% Russia 4,4% 5,3% 5,6% 4,5% 4,1% 5% Australia 4,4% 4,9% 3,6% 3,6% 3,5% 4% Rest 8,3% 7,2% 8,4% 8,0% 7,2% 8% 100,0% 100,0% 100,0% 100,0% 100,0% 100% 3 Estimated on the basis of October and November 2017 data (Eurostat). / 3

4 Save nb: t Save Date: 14/02/ Page 4 of 6 - TDI.Limited and for parties 2.3. All Major Union Producers of Silicon Should Be Investigated The number of silicon producers with EU production facilities is very limited. The three main producers in the EU are FerroAtlántica and Ferropem (both owned by Ferroglobe) and RW Silicium GmbH. The domestic EU production of silicon, both for metallic and chemical use, is estimated to be around 0.2 million tonne per year. RW Silicium GmbH accounts for a significant part of the production in the EU. In order to establish whether the Union industry is in fact suffering material injury, we urge the Commission to investigate the performance of all EU producers of silicon, including RW Silicium GmbH who is not one of the complainants. 3. EUROPEAN ALUMINIUM FAILS TO SEE A CAUSAL LINK BETWEEN THE IMPORTS UNDER INVESTIGATION AND THE ALLEGED DUMPING CAUSING MATERIAL INJURY In accordance with Article 3(6) and (7) of the basic Regulation, the Commission should examine whether the alleged dumped imports originating in the countries under investigation have caused injury to the Union Industry to a degree that enables it to be classified as material. Known factors other than the alleged dumped imports, should also be examined There Is No Clear Impact Of Imports Originating in Bosnia And Herzegovina And in Brazil As mentioned above, our members fail to see an impact of imports of the product concerned originating in Bosnia on the Union industry, in view of their price levels and volumes. In any event, any possible impact does not reach a degree that could be classified as material Effects Of Imports From Other Third Countries Should Be Considered In terms of volumes and market shares, there are six main countries exporting silicon to the EU with significant volumes, and an additional 10 to 15 with only very small volumes. At present, the main countries exporting silicon to the EU are Norway with an estimated average import share of 39% in the period ; China with 24% import share, Brazil - with 15% import share, Russia with 5% - import share, Bosnia and Herzegovina - with 5% and Australia with 4%. (see Table 2). The remaining exporting countries constitute together 12% of total EU imports. The Chinese import share is the only one that very substantially varied with a maximum of 29%, and a minimum of 19% during the period 2014 and / 4

5 Save nb: t Save Date: 14/02/ Page 5 of 6 - TDI.Limited and for parties When calculating the market shares ex China, it appears that Norway had the largest increase in import share recently (with 58 % in 2017 versus 49% in 2016). 4. ADOPTION OF ANTI-DUMPING MEASURES IN THE PRESENT CASE WOULD -- IN ANY EVENT -- BE AGAINST THE UNION INTEREST In accordance with Article 21 of the basic Regulation, the Commission should examine whether, despite any conclusion on alleged injurious dumping, compelling reasons existed for concluding that it is not in the Union interest to adopt measures. The EU, including the aluminium industry as one of the main users of silicon, is heavily import dependent for silicon, relying for 2/3 of its demand on importations. Imposition of anti-dumping measures on imports originating in Bosnia would significantly disrupt the supply chain in the EU and be detrimental to the entire European aluminium industry The Aluminium Industry Is One Of The Main Users Of Silicon In The EU We estimate the total demand for silicon in the EU was approximately 0.6 million metric tonnes in The two main end-use sectors for silicon in the EU are the aluminium industry and the chemical industry. The aluminium industry represents approximately 45 % of total consumption. Most of the silicon volumes in the aluminium industry are used in the production of casting ingots. We estimate that over 80% of all supply of silicon to the aluminium industry in the EU is used for casting. Approximately 8 to 11% of the total input for casting consists of silicon. In other words, aluminium refiners rely to a large extend on silicon for their activities. In addition, silicon is also used in other segments of the aluminium industry (e.g. for semi fabrication). The supply of silicon for aluminium production processes is vital to the entire aluminium industry in the EU The EU Is Heavily Import Dependent For Silicon The domestic EU production of silicon, both for metallic and chemical use, is estimated to be around 0.2 million tonnes per year. As mentioned, the demand in the EU for silicon was approximately 0.6 million metric tonnes in In other words, the total domestic supply to the EU industry accounts only for 1/3 of total demand in the EU. The EU, including the aluminium industry, is heavily import dependent for its silicon needs. Approximately 2/3 of total EU silicon demand needs to be imported. / 5

6 Save nb: t Save Date: 14/02/ Page 6 of 6 - TDI.Limited and for parties 4.3. The Demand For Silicon In The EU Is Increasing Making Imports Even More Important The demand for silicon in the EU is increasing. Demand in 2015 was 537 ktonnes in the EU. Driven by the large increase in production volumes in the aluminium refining industry, we believe that the domestic demand increased last year to around 600 ktonnes. With a growing demand, more silicon is supplied by EU domestic production volumes. EU domestic production increased approximately with 70 to 80 ktonnes in 2017 compared to However, domestic production remains unable to meet the (growing) domestic demand. In addition, after 4 years of rising imports during the period of 2011 to 2014, a decline in the total imports of silicon into the EU took place as of Total imports declined by approximately 11% from 2014 till 2017 (with 48 ktonnes) With domestic production still far from sufficient to address overall demand in the EU; further increase in demand and a decline in imports it is critical that the Commission does not impose anti-dumping measures since this would significantly disrupt the entire aluminium supply chain in the EU. * * * / 6