Legal analysis of Thailand's essential facts report in cold-rolled steel sunset review

Thailand Publishes Essential Facts Report in Sunset Review of Anti-Dumping Duties on Cold Reduced Carbon Steel from Vietnam, China, and Taiwan

The Department of Foreign Trade (DFT) of Thailand has issued the essential facts report in the sunset review of anti-dumping (AD) duties imposed on cold reduced carbon steel (in coils and not in coils) originating in or imported from Vietnam, China, and Taiwan.

1. Products under Review

The steel products subject to review are classified under several HS codes, including: 7209.1500, 7209.1600, 7209.1700, 7209.1820, 7209.1890, 7209.2500, 7209.2600, 7209.2700, 7209.2810, 7209.2890, 7209.9010, 7209.9090, 7211.2310, 7211.2320, 7211.2330, 7211.2390, 7211.2910, 7211.2920, 7211.2930, 7211.2990, and 7225.5000.

2. DFT’s Preliminary Conclusion

According to the report, the termination of the AD duty order would likely result in the recurrence of dumping practices, which could lead to renewed injury to the Thai domestic industry. Consequently, DFT has proposed extending the AD measures for an additional five (05) years, maintaining the current duty rates ranging from 4.22% to 20.11% of CIF value, effective from January 25, 2025.

3. Risk of Anti-Circumvention Investigation

During the review period (2024), the Thai domestic industry alleged possible circumvention of AD duties through the importation of ZAM steel (zinc–aluminum–magnesium alloy coated steel) from China, with volumes reportedly reaching up to 1 million tons.
DFT indicated that if clear evidence of circumvention via ZAM steel emerges, interested parties may submit petitions for the initiation of an anti-circumvention investigation.

4. Rights of Interested Parties

  • Enterprises and interested parties may submit written comments on the report no later than 16:30, October 6, 2025 (Bangkok time).
  • Stakeholders may also register to participate in a hearing (up to 2 representatives per party), accompanied by written statements. The hearing is scheduled for 10:00, October 9, 2025, at Meeting Room 1601, 16th Floor, Department of Foreign Trade, Thailand.

5. Recommendations from Vietnam’s Trade Remedies Authority (TRAV)

  • For the Vietnam Steel Association: promptly inform relevant producers and exporters; closely monitor the possibility of Thailand launching an anti-circumvention investigation on ZAM steel.
  • For enterprises:
    • Review ZAM steel export activities and prepare response strategies in case Thailand initiates an anti-circumvention investigation;
    • Consider submitting timely feedback to DFT;
    • Actively coordinate and communicate with TRAV for timely support.

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.

The essential facts report can be downloaded here.

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