China has moved to impose provisional countervailing duties on a basket of European Union dairy products, a step that marks a new escalation in an already tense trade relationship between Beijing and Brussels. The Ministry of Commerce (MOFCOM) announced a preliminary determination on 22 December 2025 and said temporary duty deposits would be collected from 23 December 2025.
The announcement affects a range of cheeses and certain higher‑fat milk and cream products and comes after an anti‑subsidy probe that began in August 2024. With company‑specific rates set and an investigation running through early 2026, exporters, producers and governments on both sides are preparing for a prolonged dispute over China tariffs on EU dairy imports.
MOFCOM’s announcement and immediate measures
MOFCOM published a preliminary (provisional) countervailing determination on 22 December 2025, concluding that imports of the relevant dairy products from the EU were subsidized and caused substantial injury to China’s domestic dairy industry. The ministry said that, as a result, temporary duty deposits will be collected while the investigation proceeds to its final determination.
The collection of provisional deposits began on 23 December 2025; these are not final tariffs but are levied to offset the alleged subsidy margins while China completes its probe. MOFCOM described the move as a legal application of China’s trade‑remedy rules and set company‑specific rates based on its preliminary findings (full MOFCOM text: MOFCOM announcement).
MOFCOM framed the provisional duties as a necessary short‑term measure to protect domestic producers while the country assesses evidence and gathers further information a of the final ruling. The ministry also published supporting Q&A and procedural notices as part of the public record for the investigation.
Products covered and notable exclusions
The provisional measures target a basket of dairy goods that includes fresh and processed cheeses, explicitly naming blue cheeses or Roquefort/Gorgonzola‑type products and curd, along with certain higher‑fat milk and cream items. The scope is specific rather than universal across all dairy categories exported from the EU.
Several widely reported dairy products were notably excluded from the provisional duties: milk powder and infant formula were broadly reported as not covered by this preliminary determination. That carve‑out reduces the immediate disruptive impact on some of the most sensitive dairy trade flows to China.
Nonetheless, the products included in the provisional list are important for regional and seasonal producers across Europe, including many Protected Designation of Origin (PDO) and Protected Geographical Indication (PGI) cheeses that rely on export markets for higher‑value sales.
Tariff rates and company‑specific allocations
MOFCOM announced a graduated range of provisional countervailing rates, described as ‘from‑value’ subsidy rates, spanning roughly from 21.9% up to a maximum of 42.7%. The highest provisional rate was applied to non‑cooperating entities or where MOFCOM judged subsidies and injury to be greatest.
Company‑specific assignments reported by media and present in MOFCOM’s preliminary materials show variation: Italy’s Sterilgarda Alimenti SpA was reported to have received the lowest provisional rate at 21.9%. A cluster of about 60 sampled companies , including major names such as Arla Foods (brands like Lurpak and Castello) , were assigned rates in the high‑20s (around 28.6% and 29.7%). FrieslandCampina entities were reported as facing the maximum provisional rate of 42.7%.
MOFCOM’s approach follows typical trade‑remedy practice: cooperation with investigators can yield lower company‑specific deposits, while lack of cooperation commonly triggers the highest margin. These provisional rates can be revised in the final determination, as occurred in past cases.
Origin of the probe and procedural timeline
The investigation was opened on 21 August 2024 following a request from Chinese domestic industry groups , specifically the Dairy Association of China and the China Dairy Industry Association. Those associations argued that subsidized EU dairy imports were harming China’s domestic dairy sector.
MOFCOM’s preliminary ruling on 22 December 2025 followed more than a year of evidence gathering, sampling and company interviews. The ministry has extended the case timetable and set the final determination window to run through February 2026, giving both sides time for submissions and possible mitigation proposals.
Under China’s trade‑remedy law, provisional duty deposits serve as an interim tool; companies that engage constructively in the probe may obtain lower company‑specific rates in the final ruling, while firms that do not cooperate risk the maximum duty. EU authorities have indicated they will scrutinize whether MOFCOM followed WTO procedures.
EU reaction and industry response
The European Commission swiftly criticized the move. EU trade spokesperson Olof Gill said ‘the commission’s assessment is that the investigation is based on questionable allegations and insufficient evidence, and that the measures are therefore unjustified and unwarranted.’ Brussels said it would examine options to defend EU exporters, including recourse through WTO channels (Reuters).
Industry groups across Europe described the decision as a shock and a hard blow. French dairy bodies such as FNIL warned of the impact on producers, and Germany’s dairy association urged rapid political action. Producer and exporter groups cautioned that seasonal and regional specialty cheeses , many relying on EU certification schemes , could suffer disproportionate harm from sudden tariffs.
EU officials and trade bodies are assessing the legal basis of MOFCOM’s findings and preparing to engage diplomatically and through trade remedies if needed. Businesses affected will also examine contractual, pricing and routing options to mitigate immediate damage while the investigation continues.
Wider trade context and possible outcomes
The provisional measures come amid a broader Sino‑EU trade spat. In 2024 the EU imposed anti‑subsidy tariffs on Chinese electric vehicles, with duties reported up to around 45.3% including base tariffs, and Beijing has since launched counter‑investigations and measures on several European food and drink products (for example provisional measures on pork and brandy earlier in this dispute).
Past Chinese provisional measures have sometimes been moderated in final rulings , for example, Beijing narrowed or reduced duties after negotiations or price‑commitment remedies in prior cases. That historical pattern suggests the final outcome for dairy could result in adjusted rates or negotiated remedies, though nothing is guaranteed.
The trade value directly affected by the probe was reported at about USD 589 million for 2024. Given the commercial scale and political sensitivity on both sides, the dispute may be fought on multiple fronts: MOFCOM’s final determination in early 2026, bilateral negotiations, and potential WTO complaints or consultations initiated by the EU.
For now, exporters and importers face immediate practical challenges: provisional deposits are being collected and firms must decide whether to engage fully with China’s investigators to seek lower rates. Observers will watch the final MOFCOM ruling, scheduled for the February 2026 window, for signs of de‑escalation or entrenchment.
As the process unfolds, stakeholders on both sides will weigh legal avenues, commercial mitigation and political negotiation. The situation illustrates how disputes over industrial policy and subsidies can spill into sectors , like dairy , that touch livelihoods, regional specialties and consumer markets beyond line industries such as autos.
