In brief
SECEX (the Brazilian Secretariat of Foreign Trade) opened on 8 March 2024 a new antidumping investigation against Brazilian imports of pre-painted steel sheets, from China, commonly classified under the NCM codes 7210.70.10, 7210.70.20, 7212.40.10, 7212.40.21 and 7212.40.29.
Pre-painted steel sheets are widely used in white goods appliances, construction, the automobile industry, and steel packaging.
The full text of the SECEX Circular (in Portuguese) that opened the investigation can be accessed in this link.
Importance of stakeholder participation
Active participation of importers, exporters, and any other interested parties in the investigation could be decisive in securing a more favorable outcome. Interested parties may request to be admitted to the process until 29 March 20241, provided 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 acknowledgment of receipt (presumed 3 days after the date of electronic transmission by the authority);
- Deadline for replying to the Exporter's Questionnaire: 30 days as of acknowledgment of receipt (presumed seven days after the date of electronic transmission by the authority).
Considering the recently issued regulation, a proceeding for the assessment of public interest would generally only occur after the trade defense investigation is closed (kindly find details on our Legal Alert on the subject).
More details
The new investigation was initiated upon the request of Companhia Siderúrgica Nacional (CSN), which, together with Tekno S.A. Indústria e Comércio, would account for the totality of the Brazilian production of pre-painted steel sheets, according to the information available in the case records up until now.
- Investigated product: Pre-painted steel sheets, as they are commonly referred to in the market, are flat-rolled carbon steel products, coated on one or both sides with a layer of paint, the same or differentiated per side, with a substrate of coated or uncoated low carbon steel, or coated with plastic. They are supplied in coils or sheets, with or without a protective or decorative film.
- Uses: Information kept confidential in the Circular that opened the investigation. However, based on information publicly available, it is known that pre-painted steel sheets are widely used in the production of white goods appliances (such as in refrigerators, stoves, microwaves, washing machines and electronics); in the construction industry (for example, in roof tiles and siding, thermo-acoustic panels, façades, gutters and conductors, window frames, doors and gates, light metal structures, shutters and electrical panels); in the automotive industry (internal painting of chassis, floors, auto parts, trailer bodies, oil filters, fuel tanks, bus sides, etc.); in the production of steel packaging for foods (such as tomato products, fish and powdered milk), paints and varnishes, lubricants, among others.
- Calculated dumping margin for China: Information kept confidential in the investigation initiation Circular.
1 20-day deadline, pursuant to Article 45, paragraph third, of the Decree No. 8,058/2013, accounted for in a conservative manner.
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