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The Trade Remedies Authority of Vietnam (TRAV) has announced that the competent authority of Egypt has officially issued a decision to impose safeguard measures on imports of flat steel products, including cold-rolled steel, galvanized steel, and pre-painted steel. The decision follows an investigation which found a significant surge in imports causing serious injury to the domestic industry.
1. General information on the case
According to the Egyptian authority, the products subject to safeguard measures include:
• Cold-rolled coils (CRC)
• Galvanized steel (HDG/GI)
• Pre-painted steel (PPGI)
These products are classified under the following HS codes:
• CRC group: 720915, 720916, 720917, 720918, 720925, 720926, 720927, 720928, 720990, 721123, 721129, 721190, 722692
• HDG/GI group: 721041, 721049, 721230, 721250, 722592, 722699
• PPGI group: 721070, 721090, 721240, 721260, and 722599
The investigation period covers 2022 to 2024, with the initiation decision issued on September 10, 2025.
2. Findings of the Egyptian investigating authority
The investigation concluded that steel imports into Egypt increased sharply during the period under review, causing serious injury to the domestic industry.
Specifically, the import index rose from a base level of 100% in 2022 to 186% in 2024, reflecting a rapid surge in imports.
For the domestic industry, market share declined significantly by 44% compared to 2022. Notably, business performance deteriorated severely, with profitability shifting from positive to substantial losses, as the profit index dropped to negative 179% in 2024.
Regarding causation, the Egyptian authority determined that the increase in imports resulted from “unforeseen developments,” including the implementation of the Carbon Border Adjustment Mechanism (CBAM) by the European Union and the impact of international trade sanctions, which diverted excess global steel supply toward Egypt.
3. Safeguard measures applied
Egypt has imposed safeguard duties in the form of ad valorem tariffs on CIF value combined with minimum duty levels, with a progressive reduction over a three-year period. The specific duty rates are as follows:
Cold-rolled steel (CRC)
• April 2, 2026 – September 13, 2026: 13.7% (minimum USD 83/ton)
• September 14, 2026 – September 13, 2027: 13% (minimum USD 79/ton)
• September 14, 2027 – September 13, 2028: 12.5% (minimum USD 76/ton)
Galvanized steel (HDG/GI)
• April 2, 2026 – September 13, 2026: 14% (minimum USD 93/ton)
• September 14, 2026 – September 13, 2027: 13.5% (minimum USD 90/ton)
• September 14, 2027 – September 13, 2028: 13% (minimum USD 86/ton)
Pre-painted steel (PPGI)
• April 2, 2026 – September 13, 2026: 14.5% (minimum USD 122/ton)
• September 14, 2026 – September 13, 2027: 14% (minimum USD 118/ton)
• September 14, 2027 – September 13, 2028: 13.5% (minimum USD 114/ton)
The simultaneous application of ad valorem duties and minimum duty thresholds indicates Egypt’s intention to ensure the effectiveness of the measure under all price scenarios.
4. Notes and recommendations for enterprises
In light of these measures, TRAV recommends that relevant industry associations and exporting enterprises proactively adopt appropriate response strategies:
Review of exclusion scope
Egypt has excluded certain specific product lines from the scope, including:
• antibacterial coated steel;
• PET/VCM coated steel;
• Plastisol-coated steel with coating thickness of 200 microns or more;
• Al-Si or Zn-Al-Mg alloy coated steel;
• Full Hard cold-rolled steel (unannealed) with high strength.
Enterprises should carefully examine Mill Test Certificates and technical specifications to determine eligibility for duty exemptions.
Monitoring tariff reduction schedule
As safeguard duties are gradually reduced over time, companies should develop export strategies to take advantage of lower duty rates in future periods.
Diversification of export markets
The relatively high minimum duties, particularly for pre-painted steel, may significantly reduce competitiveness in the Egyptian market. Therefore, enterprises should proactively adjust pricing strategies, explore alternative markets, or focus on higher value-added product segments outside the scope of the measures.
To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnam Antidumping Law Firm specializing in anti-dumping and trade remedy for timely assistance.
ASL Law is a leading full-service and independent Vietnamese law firm made up of experienced and talented lawyers. ASL Law is ranked as the top tier Law Firm in Vietnam by Legal500, Asia Law, WTR, and Asia Business Law Journal. Based in both Hanoi and Ho Chi Minh City in Vietnam, the firm’s main purpose is to provide the most practical, efficient and lawful advice to its domestic and international clients. If we can be of assistance, please email to [email protected].
ASL LAW is the top-tier Vietnam law firm for Anti-dumping & countervailing. If you need any advice, please contact us for further information or collaboration.
