Key data
| Regulation | Commission Implementing Regulation (EU) 2026/2390 of 28 October 2026 |
|---|---|
| Publication | 29 October 2026 |
| Entry into force | 28 October 2026 |
| Affected product | Acetylsalicylic acid (ASA) originating from the People's Republic of China |
| Measure | Mandatory registration of imports as a precursor to anti-dumping tariffs |
| Potential effect | Retroactive settlement of anti-dumping tariffs on already registered shipments |
| Affected parties | European importers of ASA, pharmaceutical industry and distributors |
| Category | European Regulation — Foreign Trade / Anti-dumping |
If your company imports acetylsalicylic acid (ASA) — the active ingredient in aspirin — from China, you have a problem that could materialize in unexpected costs in the coming months. The Commission Implementing Regulation (EU) 2026/2390, published on 29 October 2026, activates mandatory registration of all such imports as a precautionary measure prior to the imposition of anti-dumping duties.
The mechanism is straightforward but potentially serious in its consequences: the European Commission now registers each shipment to maintain a complete "trail". If the anti-dumping investigation currently underway concludes that China is selling ASA at artificially low prices, tariffs will be applied retroactively to all shipments already registered. In other words: what you buy today at market price may end up costing you more in a few months.
What does this regulation establish?
Regulation 2026/2390 does not yet impose any tariff. What it does is activate a registration precautionary measure, an instrument provided for in EU anti-dumping regulations that allows the Commission to act in two phases:
- Phase 1 — Registration: All European importers of ASA of Chinese origin must declare each shipment to the customs authorities of the Member State of entry. The registration is noted and linked to the importer.
- Phase 2 — Retroactive settlement (conditional): If the anti-dumping investigation concludes with a positive result, the Commission may impose anti-dumping duties and require payment on shipments already registered from the date of entry into force (28 October 2026).
The underlying reason is to protect European ASA producers against what the Commission suspects are artificially low prices by Chinese exporters, a practice known as dumping. Registration ensures that no importer can "advance" large volumes before definitive tariffs are set to avoid paying them.
| Element | Detail |
|---|---|
| Product | Acetylsalicylic acid (ASA) — active ingredient in aspirin |
| Country of origin | People's Republic of China |
| Immediate obligation | Declaration of each shipment to European customs |
| Effect if investigation positive | Anti-dumping tariffs applied retroactively to registered shipments |
| Objective of the measure | Protect European ASA producers against artificially low prices |
Economic and operational impact
The impact has two dimensions that procurement managers and CFOs must evaluate separately:
Immediate operational impact: Mandatory registration of each shipment increases the administrative burden on customs and logistics departments. Each import of Chinese ASA now requires a specific declaration, which may slow customs clearance times and require more internal or external resources (customs agents).
Deferred economic risk: This is the most relevant impact for the income statement. Shipments registered from 28 October 2026 are "marked". If the anti-dumping investigation concludes positively — which may occur in the coming months — the company will have to pay retroactively the tariffs on all volume imported from that date. The greater the volume accumulated during the investigation period, the larger the potential bill.
European pharmaceutical manufacturers and distributors dependent on Chinese ASA as raw material or semi-finished product are the most exposed: their procurement costs could increase significantly and with retroactive effect, with no margin to renegotiate already closed contracts.
Who does it affect?
- Direct importers of Chinese ASA in any EU Member State: immediate registration obligation and exposure to retroactive settlement.
- European pharmaceutical laboratories that use ASA as an active ingredient in the manufacture of medicines (analgesics, antiplatelet agents, etc.).
- Pharmaceutical wholesale distributors that market ASA in bulk or semi-finished forms from China.
- Procurement and supply chain departments of pharmaceutical companies with Chinese ASA suppliers: must review contracts and provision for tariff risk.
- Customs agents and operators managing customs clearance of these goods: must know the registration procedure and apply it in each operation.
Practical example
Imagine a Spanish pharmaceutical laboratory that imports 50 tonnes of Chinese ASA per month to manufacture aspirin tablets. From 28 October 2026, each of those monthly shipments must be declared and registered with the Tax Agency (Customs).
If the anti-dumping investigation lasts, for example, six months, the laboratory will have imported 300 tonnes of registered ASA during that period. If the Commission concludes that there is dumping and sets an anti-dumping duty of 20% on the value of the goods, the laboratory will receive a retroactive settlement on those 300 tonnes. Depending on the purchase price of Chinese ASA, that bill could represent tens or hundreds of thousands of euros not budgeted.
The key is that risk accumulates day by day from the date of entry into force. The sooner measures are taken — supplier diversification, accounting provisions, contract renegotiation — the lower the final exposure.
What should companies do now?
- Verify if you import ASA of Chinese origin: Review your supplier portfolio and confirm if any supply acetylsalicylic acid manufactured or exported from China. If so, you are directly affected from 28 October 2026.
- Activate the customs registration procedure: Coordinate with your customs agent or internal department to ensure that each shipment of Chinese ASA is correctly declared under the new registration regime. An unregistered shipment may generate additional problems in the settlement.
- Quantify retroactive economic exposure: Calculate the volume of Chinese ASA you expect to import during the investigation period and estimate the potential impact based on different tariff scenarios. Communicate this risk to the CFO and board if the amount is material.
- Account for the risk with provisions: Consider creating a provision for tariff contingency in the financial statements to reflect the potential liability arising from a retroactive settlement.
- Explore alternative sourcing options: Evaluate ASA suppliers in countries not affected by the investigation (India, Europe) to reduce dependence on Chinese supply and limit the accumulation of retroactive risk.
- Review contracts with customers and suppliers: If you have fixed-price supply contracts that include Chinese ASA as raw material, analyze whether they include clauses for adjustment due to tariff variation. If not, consider renegotiating them.
- Monitor the progress of the anti-dumping investigation: Follow publications in the Official Journal of the EU to learn when the investigation concludes and what the result is. The final resolution will determine whether retroactive tariffs materialize and in what amount.
Frequently asked questions
What is import registration and why does it require declaring each shipment?
Import registration is a precautionary measure provided for in EU anti-dumping regulations. It requires importers to declare each shipment of Chinese ASA to customs authorities so that it is documented. Its purpose is to allow the Commission to apply anti-dumping tariffs retroactively to those shipments if the investigation concludes positively. Without prior registration, retroactivity would not be possible.
When can retroactive tariffs arrive and on which shipments will they be applied?
Retroactive tariffs will only materialize if the anti-dumping investigation concludes with a positive result. In that case, they will be applied to all Chinese ASA shipments registered from 28 October 2026, the date of entry into force of Regulation 2026/2390. Shipments prior to that date are not affected by retroactivity.
What happens if an importer does not declare their Chinese ASA shipments during the registration period?
Regulation 2026/2390 establishes registration as an obligation for importers of ASA of Chinese origin. Failure to declare shipments constitutes non-compliance with European customs regulations, which may result in consequences in the subsequent settlement process and potential customs penalties according to the legislation of the corresponding Member State. Furthermore, failure to register does not exempt from payment of retroactive tariffs if the investigation concludes positively.
Does this regulation affect only direct importers or also manufacturers who buy ASA from intermediaries?
The registration obligation falls directly on the importer, that is, whoever carries out customs clearance of Chinese ASA in the EU. However, the economic impact extends throughout the chain: pharmaceutical laboratories and distributors that buy ASA from importers will see their procurement costs increase if retroactive tariffs are passed on to the price of the intermediary supplier's sale.
Can I continue importing Chinese ASA normally or should I look for alternative suppliers?
There is no prohibition on importing Chinese ASA. Regulation 2026/2390 does not impose tariffs yet, only mandatory registration. However, given the risk of retroactive settlement, it is advisable to evaluate diversification towards ASA suppliers in countries not affected by the investigation (such as India or other European producers) to reduce economic exposure accumulated during the investigation period.
Official source
Consult full regulation at official source — Commission Implementing Regulation (EU) 2026/2390
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602390
