In brief
On 3 June 2025, SECEX (the Brazilian Secretariat of International Trade) initiated an antidumping investigation on the Brazilian imports of hot-rolled flat steel from China, commonly classified under the NCM codes 7208.10.00, 7208.25.00, 7208.26.10, 7208.26.90, 7208.27.10, 7208.27.90, 7208.36.10, 7208.36.90, 7208.37.00, 7208.38.10, 7208.38.90, 7208.39.10, 7208.39.90, 7208.40.00, 7208.53.00, 7208.54.00, 7208.90.00, 7211.13.00, 7211.14.00, 7211.19.00, 7211.90.10, 7211.90.90, 7225.30.00, 7225.40.90, and 7226.91.00.
This is an input used for structural applications, pressure vessels, pipelines for gas and oil, and oil exploration products, as well as in the automotive industry, civil construction, machinery, equipment, and household utilities.
The investigation may result in the imposition of antidumping measures and the consequent increase in the cost of Brazilian imports of flat-rolled hot-rolled flat laminates for a period of five years.
The original text of the Official Notice of Initiation of the antidumping investigation (in Portuguese) is available in the following link.
In depth
Relevance of stakeholder participation
Active participation of importers, exporters, and any other interested parties in the investigation may be decisive in securing a more favorable outcome. Interested parties can request to be admitted as parties in the investigation until 23 June 20251, provided that they demonstrate the extent to which they could be affected by the imposition of the antidumping duty.
- Deadline for replying to the Importer's Questionnaire: 30 days as of acknowledgement of receipt (presumed three days after the date of electronic transmission by the authority).
- Deadline for replying to the Exporter's Questionnaire: 30 days as of acknowledgement of receipt (presumed seven days after the date of electronic transmission by the authority).
Usually, a public interest assessment may be requested only after the conclusion of the trade remedies investigation, as established by SECEX Ordinance No. 282/2023 (additional information is available in our Legal Alert on the subject).
More details
- Petitioners: ArcelorMittal Brasil S.A., Gerdau Açominas S.A., and Usinas Siderúrgicas de Minas Gerais S.A.
- Investigated product: Hot-rolled flat steel products.
- Uses: The product is typically used in structural applications, pressure vessels, pipelines for gas and oil, oil exploration products, automotive industry, civil construction, machinery, equipment, and household utilities.
- Dumping margins:
- China: USD 530.37/t | 87.76%
- Background: This product has already been subject to previous antidumping and subsidies investigations that resulted in the application of trade defense measures simultaneously suspended for public interest reasons:
- On 19 January 2018, Brazilian imports of hot-rolled flat products originating from China and Russia were levied with antidumping duties for a period of up to five years, with rates ranging from USD 77.72/ton to USD 207.43/ton. On the same date, the measure was suspended for up to one year on public interest grounds, and later the suspension was extended for another year. Following a new public interest assessment, CAMEX (the Brazilian Foreign Trade Chamber) decided to terminate the measures on 17 January 2020.
- On 21 May 2018, Brazilian imports of hot-rolled flat products originating from China were levied with countervailing measures for a period of up to five years, with rates ranging from USD 196.49/ton (45.10%) to USD 425.22/ton (104.30%). However, on the same date, the measure was suspended for the remaining period of the countervailing duty, on public interest grounds. On 21 May 2023, following a request by the petitioners for reapplication of the measure, CAMEX decided to terminate the trade defense measure.
1 20-day deadline, pursuant to Article 45, paragraph third, of the Decree No. 8,058/2013.
* * * * *
Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
