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On August 31, 2026, the Department for Internal Market Defence of the Eurasian Economic Commission (EEC) issued Notice No. 2026/509/SG13 publishing the Preliminary Investigation Report in the safeguard investigation concerning tinplate imported into the territory of the Eurasian Economic Union (EAEU).
According to the Report, the EEC preliminarily determined that there had been an increase in imports of the investigated product, that unforeseen developments had contributed to this increase, and that the EAEU industry was suffering serious injury. On this basis, the EEC proposed the imposition of a special safeguard measure in the form of a 25.2% safeguard duty for a period of three years.
Tinplate Products Subject to the Investigation
The investigated product consists of flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more and a thickness of less than 0.5 mm, plated or coated with a metal layer containing at least 97% tin by weight. The product is referred to in the investigation documents as “tinplate,” “white tinplate” or “white tin,” corresponding to tinplate or tin-coated flat-rolled steel.
The product is classified under EAEU HS code 7210 12 200 0.
The investigation was initiated by the EEC on March 4, 2026, based on an application for a special safeguard investigation submitted by Metaloprokatnaya Kompaniya LLC and supported by Magnitogorsk Iron and Steel Works (MMK) JSC. The Ministry of Industry and Trade of Vietnam was included among the authorities of exporting countries notified by the EEC of the initiation of the investigation.
The EEC used 2025, from January 1, 2025 to December 31, 2025, as the principal period for assessing the increase in imports and serious injury. Meanwhile, the period from January 1, 2023 to December 31, 2025 was used to analyze trends in the domestic industry and market.
China Accounts for a Large Share of Tinplate Supply
A notable point in the Preliminary Report is the high concentration of the investigated product’s supply from China. According to the data analyzed by the EEC, China accounted for approximately 88–100% of total imports of the investigated product into the EAEU in 2023, 92–100% in 2024 and 93–100% in 2025. In the fourth quarter of 2025 alone, this share reached approximately 95–100%.
During the investigation, several Governments argued that there was no causal relationship between imports from the countries concerned and injury to the EAEU industry. The parties also requested that the EEC fully assess other factors that could affect the condition of the domestic industry apart from the impact of imported goods.
However, in the Preliminary Report, the EEC maintained its view that the conditions for imposing a special safeguard measure had been satisfied.
Excess Capacity and Trade Measures Identified as Key Factors
To determine the existence of unforeseen developments leading to the increase in imports, the EEC focused on two main groups of factors: global excess steel production capacity and the increase in trade restrictions on steel and tinplate in third-country markets.
According to OECD data cited by the EEC, global excess steel production capacity reached approximately 640.3 million tonnes in 2025, an increase of more than 105 million tonnes compared with 2023. Excess capacity is projected to continue increasing to approximately 744.7 million tonnes by 2028.
The EEC considered that the significant increase in excess capacity compared with the time when EAEU countries negotiated and made tariff commitments within the framework of the WTO was a development that could not have been reasonably foreseen at that time.
In addition, the EEC analyzed the increase in trade remedy measures and trade restrictions on steel in third-country markets, particularly measures imposed by the United States and the European Union. According to the EEC’s preliminary assessment, these measures could alter global trade flows and create additional pressure to redirect supplies toward the EAEU market.
EEC Determines that the EAEU Industry Is Suffering Serious Injury
The Preliminary Report assesses multiple indicators of the EAEU industry, including production, sales, market share, inventories, capacity, capacity utilization, selling prices, costs, profits, profitability, investment, cash flow, employment and productivity.
According to the EEC, many indicators of the industry showed a downward trend in 2025, with adverse developments becoming more pronounced in the third and fourth quarters of 2025. The investigating authority considered the increase in imports to be one of the factors causally related to declines in production, sales, selling prices, profits and profitability of the EAEU industry.
Based on its assessment of the above factors, the EEC preliminarily concluded that the EAEU industry was suffering serious injury due to the increase in imports of the investigated product.
Proposed 25.2% Safeguard Duty for Three Years
If implemented as proposed in the Preliminary Report, the special safeguard measure would take the form of a 25.2% safeguard duty for a period of three years. The proposed duty rate is expected to decrease by one percentage point after each year of application.
The proposed duty is significantly higher than the current 5% ordinary import duty applicable to the product. Therefore, if the measure is adopted, the cost of importing tinplate into the EAEU market could increase significantly, directly affecting relevant producers, exporters and importers.
For Vietnam, a key issue is that the EEC does not apply an exclusion mechanism to Vietnam under the criteria applicable to developing countries in this case. According to the EEC’s determination, the exclusion mechanism is available only to countries that are both included in the list of countries using the EAEU’s Unified System of Tariff Preferences and meet the condition of having an insignificant share of imports, consisting of an individual share of no more than 3% and a combined share of no more than 9% for all countries in this group.
As Vietnam is not included in the list identified by the EEC for application of the exclusion mechanism, goods exported from Vietnam may fall within the scope of the measure if the safeguard measure is formally imposed.
Vietnamese Businesses Should Note the Deadline for Submitting Comments
According to Notice No. 2026/509/SG13, parties participating in the investigation may submit comments on the Preliminary Investigation Report no later than September 14, 2026.
This is an important opportunity for Vietnamese businesses producing and exporting tinplate to the EAEU to review the Report and assess the potential impact of the proposed safeguard measure. Businesses may consider submitting comments on the findings concerning the increase in imports, unforeseen developments, serious injury, causal relationship, as well as the proposed level and duration of the measure.
Businesses should also continue monitoring the EEC’s subsequent proceedings, particularly the final investigation findings and the official decision on whether to impose the safeguard measure. If the measure is imposed, accurately determining the product scope, origin and applicable duty obligations will be matters to which Vietnamese exporters should pay particular attention.
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].
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