China Extends Anti-Subsidy Investigation into EU Dairy Imports: What Founders & Exporters Need to Know (August 2025 Update)
China’s Ministry of Commerce (MOFCOM) has extended its investigation into EU dairy imports until February 21, 2026.
Originally launched in August 2024, the probe targets subsidies granted to EU milk, cream, and cheese producers under the Common Agricultural Policy (CAP) and other national support schemes. The extension reflects the case’s complexity and MOFCOM’s need for further analysis.
For European suppliers, investors, and China importers, this means heightened trade risks will persist into early 2026 — with potential countervailing duties still on the table.
What Is the Case About?
On August 21, 2024, MOFCOM launched a countervailing duty investigation into dairy imports originating from the European Union. The case was filed following a joint petition by the Dairy Association of China and the China Dairy Industry Association, alleging that subsidized EU dairy products were harming domestic producers.
The investigation is looking into:
- EU-level subsidies under the CAP
- Member State-specific programs from Austria, Belgium, Croatia, Czech Republic, Finland, Italy, and Romania
A total of 20 subsidy schemes are under review.
Products Under Investigation
The case targets the following dairy products:
- Fresh cheeses (including whey cheese and curd)
- Processed cheeses (grated or powdered)
- Blue cheese and other mold-ripened cheeses
- Milk and cream (fat content >10%, not concentrated or sweetened)
HS Codes involved:
04015000, 04061000, 04062000, 04063000, 04064000, 04069000
These products are widely used in food manufacturing, hospitality, and direct retail — including e-commerce platforms and dairy-based ingredient supply chains.
Timeline Update: Investigation Extended to February 2026
Originally due to conclude by August 21, 2025, MOFCOM officially extended the probe by six months on August 18, 2025, citing the complexity of subsidy verification and injury analysis.
This extension prolongs uncertainty for EU suppliers and their Chinese partners potentially affecting pricing, contract terms, and delivery risk.
China’s Dairy Import Landscape (2023–2024)
According to China’s General Administration of Customs (GACC):
- Milk and cream imports (HS 04015000) and cheese imports (HS 040610–040690) from the EU reached record highs in 2023
- EU dairy imports from January–July 2024 continued strong, especially in the premium cheese and high-fat cream segments
If MOFCOM ultimately imposes duties, EU exporters may face reduced competitiveness, particularly in sectors where price sensitivity is high (e.g. food service and processed foods).
What Should Decision Makers Do Now?
Exporters & Importers
- Review contracts for tariff clauses or cost pass-through mechanisms
- Prepare documentation: companies may be asked to respond to detailed subsidy questionnaires
- Monitor MOFCOM notices for preliminary findings or public hearings
Founders & Investors
- Reassess sourcing strategy if relying heavily on EU dairy imports
- Diversify supplier base or explore local partnerships where possible
- Engage legal or trade advisory if involved in the categories under review
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