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India Issues Preliminary Findings on Safeguard Investigation of Alloy and Non-Alloy Flat-Rolled Steel

On March 18, 2025, the Directorate General of Trade Remedies (DGTR) of India issued its preliminary findings in the safeguard investigation concerning the import of alloy and non-alloy flat-rolled steel into India.

Case Details

The investigation was initiated following a petition by the Indian Steel Association, representing major steel producers such as Arcelor Mittal Nippon Steel, AMNS Khopoli, Jindal Steel and Power, and the Steel Authority of India.

  • Investigated Products: Alloy and non-alloy flat-rolled steel under HS codes 7208, 7209, 7210, 7211, 7212, 7225, and 7226. The scope of the investigation includes hot-rolled steel, cold-rolled steel, corrosion-resistant coated steel (galvanized steel, cold-coated steel, zinc-magnesium alloy-coated steel), and color-coated steel.
  • Excluded Products: Cold-rolled grain-oriented electrical steel, cold-rolled non-grain-oriented steel coils/sheets, electro-galvanized steel, tin-plated steel, and stainless steel.
  • Investigation Period: October 1, 2023 – September 30, 2024. DGTR also considered data from April 1, 2021, to March 31, 2024.

Petitioner’s Allegations

The petitioner argued that the investigated products were being imported into India in significantly increased quantities, causing serious injury to the domestic industry. The unforeseen factors leading to this surge in imports included:

  • The U.S. imposing a 25% tariff on steel imports under Section 232 of the Trade Expansion Act.
  • Excess steel production capacity in China, Japan, and South Korea.
  • China’s policy shift from long steel production to flat-rolled steel for export.
  • Chinese investments in steel production within ASEAN countries.
  • India’s obligations under GATT 1994 and related agreements.

The petitioner requested the imposition of provisional safeguard measures due to an emergency situation and sought a four-year safeguard measure.

Preliminary Findings

DGTR preliminarily concluded that:

  1. There has been a sharp increase in the import volume of the investigated products, causing serious injury to the domestic industry.
  2. An emergency situation exists, and failing to impose provisional safeguard measures could result in irreparable harm.
  3. Immediate implementation of provisional safeguard measures is necessary.

DGTR proposed a 12% provisional safeguard duty for 200 days on the investigated products. However, this duty will not apply to products with an import price at or above the minimum CIF price specified by DGTR.

Vietnam is not exempt from the safeguard measure, as its market share in India’s steel imports exceeds 3%. DGTR has allowed stakeholders to submit comments on the scope of the investigation within 30 days (by April 16, 2025). Before issuing the final determination, DGTR will hold a hearing and may conduct verification if necessary.

Recommendations for Vietnamese Enterprises

  1. Carefully review the preliminary findings and product scope, and submit comments within the stipulated deadline.
  2. Monitor updates from DGTR or Vietnam’s Trade Remedies Authority and register for the hearing.
  3. Fully cooperate with the investigating authority during the final stage.
  4. Work closely with Trade Remedies Authority for timely support.

To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnamese law firms specializing in anti-dumping and trade remedy for timely assistance.

View the official document here.

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