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On September 18, 2026, the European Commission (EC) issued Implementing Regulation (EU) 2026/2133 imposing provisional safeguard measures on certain grain-oriented electrical steel (GOES) products and certain steel sheets and cores used in transformers and inductors. The measures will take effect on September 25, 2026, and will apply for 155 days, until February 26, 2027. Notably, Vietnam is included among the developing countries excluded from the provisional measures on GOES because imports from Vietnam into the EU are at negligible levels.
EU Imposes Provisional Safeguard Measures on GOES and Related Products
The EC imposed the provisional safeguard measures after initiating a safeguard investigation on March 27, 2026, concerning certain grain-oriented electrical steel products and steel sheets and cores used in transformers and inductors.
GOES is a type of electrical steel with an oriented grain structure and magnetic properties suitable for use in transformer cores. According to the EC, the product plays an important role in electrical equipment and the EU’s electricity transmission infrastructure. The EC considers that the EU GOES industry is under significant pressure from high import volumes, against a backdrop of global excess production capacity and the contraction of certain traditional export markets.
The scope of the provisional measures is not limited to GOES. Regulation (EU) 2026/2133 also applies to certain steel sheets and cores processed from GOES for use in transformers and inductors, including cores already incorporated into transformers. This expansion is intended to cover certain downstream processing stages in the transformer industry value chain.
GOES products covered by the measures are currently classified primarily under CN codes 7225 11 00 and 7226 11 00, while steel sheets and cores used for transformers and inductors are classified under CN code 8504 90 13.
Mechanism Combining Tariff Rate Quotas and Price Thresholds
Under Regulation (EU) 2026/2133, the EU has opened separate tariff rate quotas for GOES and steel sheets and cores for the 155-day period during which the measures apply.
For GOES, quotas are allocated among different groups of sources, including China, Japan, Korea, and other countries. The total quota allocated to the group of other countries is 5,360.39 tons for the period of application. The quota allocation operates on a “first come, first served” basis.
In addition to the quotas, the EU applies a price-threshold mechanism. Under this mechanism, the provisional safeguard duty is determined based on the difference between the established price threshold and the net import price at the EU border before duty, where the import price is below the applicable threshold. Where the import price is equal to or higher than the price threshold, no safeguard duty is payable under this mechanism.
For GOES, the in-quota price thresholds range from EUR 2,800 to EUR 3,400 per ton, depending on the type of product, while the out-of-quota price threshold is EUR 3,500 per ton. For steel sheets and cores, higher price thresholds have been established depending on the specific product.
For steel cores incorporated into transformers, the Regulation provides for a separate provisional safeguard duty of EUR 1,140 per ton of the relevant product contained in the transformer, with no quota applicable to this category of products.
Vietnam Excluded from the Provisional Safeguard Measures
An important point for Vietnamese companies is that Vietnam is listed among developing countries that are WTO members. However, in the list of products from developing countries subject to the provisional measures, the EC identifies GOES originating in China and Brazil, while steel sheets and cores are identified as originating in Türkiye, China, and the United Arab Emirates. Vietnam is not included among the sources subject to the measures.
Vietnam’s exclusion is based on the negligible volume of imports of the relevant products from Vietnam into the EU under the mechanism applicable to developing countries. Therefore, during the current provisional measure, Vietnamese companies exporting products covered by the case are not subject to the safeguard measures on the basis of Vietnamese origin.
However, exclusion from the current measures does not mean that companies can disregard developments in the case. If exports from Vietnam to the EU increase significantly in the future, companies should continue monitoring how the EC assesses import volumes and applies the rules concerning developing countries during the investigation and any subsequent review of the measures.
Electrical Steel Market and Vietnamese Business Activities
Electrical steel, including GOES, is an important material in the manufacture of transformers and electrical equipment because of its ability to reduce energy losses during the transmission and transformation of electricity. In Vietnam, the material is used, imported, and traded by companies operating in the electrical equipment, transformer manufacturing, and electrical steel processing sectors.
Several Vietnamese companies are reported to have activities related to electrical steel products. For example, Dong Anh Licogi Electrical Equipment Manufacturing Joint Stock Company (EEMC) is described as a manufacturer of electrical equipment and a supplier of electrical steel used in transformers. In addition, Saigon Steel Processing and Services Co., Ltd. trades silicon steel, including grain-oriented electrical steel used for transformer cores.
Trade data also indicate that certain companies involved in the electrical equipment and steel sectors import GOES into Vietnam. For example, JFE Shoji Steel Vietnam and JFE Shoji Steel Haiphong are recorded as having import transactions involving grain-oriented electrical silicon steel under HS code 722511, while NST Saigon Coil Center has transaction data relating to grain-oriented electrical steel in coil form under HS code 722611.
These activities indicate that trade measures affecting GOES may concern not only companies directly manufacturing or exporting steel but also companies using GOES as an input for transformers, steel cores, and electrical equipment. If the EU measures are expanded or made definitive in the future, developments in the supply and pricing of GOES in international markets may become a factor for Vietnamese companies using the product.
Vietnamese Companies Should Continue Monitoring the Case
According to the EC, the safeguard investigation should normally be completed within nine months of initiation and may, in exceptional circumstances, be extended to a maximum of 11 months. The imposition of provisional measures does not constitute a final determination in the investigation. Following completion of the investigation, if the EC determines that the conditions for applying safeguard measures are met, it may propose definitive measures for consideration by the Safeguard Measures Committee. Any definitive measure must receive the requisite qualified majority support from EU Member States.
For Vietnamese companies producing, exporting, importing, or using GOES and related products, Vietnam’s current exclusion from the provisional measures reduces the direct impact during the current period. Nevertheless, companies should proactively review their HS/CN codes, product origin, and supply chains to accurately determine whether their products fall within the scope of the investigation or any subsequent EU measures.
In particular, Vietnamese companies importing GOES from other sources for use in manufacturing transformers, steel cores, or electrical equipment should note that the EU safeguard measures are determined based on the origin of the goods, rather than solely on where a company purchases the goods or where the goods are processed or used. Companies should therefore assess the impact separately for each source of supply and avoid confusing Vietnam’s exclusion with the treatment of products originating in countries currently subject to the measures.
As the EU continues to strengthen trade remedies affecting the steel industry and related products, Vietnamese companies operating within the electrical equipment, transformer, and electrical steel supply chains should continue monitoring the investigation and its outcome so that they can proactively adjust their export, import, and raw material sourcing plans when necessary.
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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