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The Trade Remedies Authority of Vietnam (TRAV) has received information that the competent authority of Egypt has issued a decision to impose definitive safeguard measures on imports of hot-rolled steel products, including Hot Rolled Flat Steel (HRC/HRFS). This development follows a lengthy investigation process and is expected to have a significant impact on steel exporters, including those from Vietnam.
1. General information on the case
According to the Egyptian authority, the product subject to the safeguard measure is hot-rolled steel sheets (HRC/HRFS), classified under the following HS codes:
7208.10, 7208.25, 7208.26, 7208.27, 7208.36, 7208.37, 7208.38, 7208.39, 7208.40, 7208.51, 7208.52, 7208.53, 7208.54, 7208.90, 7211.14, 7211.19, 7225.30, 7225.40, 7226.91, and 7226.990010.
The investigation period was determined from January 2021 to December 2024. The case was officially initiated on April 22, 2025.
2. Key findings of the Egyptian investigating authority
Following its examination of submitted data and market conditions, the Egyptian authority concluded that imports of hot-rolled steel increased significantly and caused serious injury to the domestic industry.
Specifically, import volumes increased by 50% in 2022 and continued to rise sharply by an additional 31% in 2024, indicating a clear upward trend during the investigation period.
For the domestic industry, despite growing domestic demand, the market share of Egyptian producers declined substantially. According to the findings, the domestic industry’s market share decreased by 21% over two consecutive years (2023–2024). Notably, industry profits dropped by as much as 70% in 2024, reflecting the severity of the impact from imported products.
In terms of causation, the Egyptian authority determined that the surge in imports resulted from “unforeseen developments,” including global steel overcapacity and the increasing use of trade protection measures in major markets such as the United States under Section 232 tariffs, as well as similar measures in the United Kingdom and the European Union, which diverted trade flows toward Egypt.
3. Safeguard measures applied
Based on the investigation findings, Egypt decided to impose safeguard duties in the form of ad valorem tariffs combined with minimum duty levels (USD/ton).
The duty rates follow a progressive reduction schedule over a three-year period as follows:
• April 2, 2026 – September 13, 2026: 13.6% (minimum USD 76/ton)
• September 14, 2026 – September 13, 2027: 13.5% (minimum USD 75/ton)
• September 14, 2027 – September 13, 2028: 13.4% (minimum USD 74/ton)
The simultaneous application of ad valorem rates and minimum duties demonstrates the authority’s intention to ensure the effectiveness of the safeguard measure even in cases of declining export prices.
4. Notes and recommendations for enterprises
To proactively respond and mitigate adverse impacts on export activities, TRAV recommends that relevant industry associations and manufacturing/exporting enterprises pay attention to the following:
Review of exclusion scope
The safeguard measure does not apply to certain specific product categories, including:
• hot-rolled steel plates with thickness exceeding 20 mm and width over 1,600 mm;
• steel with carbon content not exceeding 0.02% used for enameling technology (ED/IF steel).
Enterprises should carefully review technical specifications, product standards, and supporting documentation to assess eligibility for exemption during export procedures.
Monitoring tariff reduction schedule
As the duty rates are gradually reduced over time, companies should develop export plans aligned with this schedule to optimize costs and profit margins.
Diversification of export markets
With a minimum duty of up to USD 76/ton, export costs to Egypt are expected to increase significantly in the short term. Therefore, enterprises should reassess pricing strategies, explore alternative markets, or focus on higher-quality product lines with technical specifications outside the scope of the measure.
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.
