Antidumping and countervailing duty measures continue to be widely used to address the dumping of unfairly priced and subsidised steel onto world markets. A growing number of countries have also established, or are introducing, broader measures to protect their steel industries more effectively from surges in imports, particularly from countries with excess capacity. Despite these actions, Chinese and other sources of excess capacity continue to flood markets with surplus steel, often by shifting shipments through or to less-protected markets and by finding new ways of circumventing the trade measures. At the same time, export restrictions on some key steelmaking raw materials are increasing, adding further pressure on steel producers globally.
5. Trade actions increase as the steel crisis worsens
Copy link to 5. Trade actions increase as the steel crisis worsensAbstract
Recent trade remedy investigations on steel products
Copy link to Recent trade remedy investigations on steel productsAntidumping and countervailing duty (AD/CVD) measures continued to be widely used to address the dumping of unfairly priced and subsidised steel into world markets in 2025. In addition to these measures, a growing number of countries have established, or are introducing, more sweeping trade measures to address rising concerns about surges in steel imports, particularly from countries with excess capacity.
While the growth in the number of new AD/CVD investigations moderated slightly in 2025, the number was nevertheless relatively high, at a combined level of 75, down from 90 in 2024. China remained the primary target of these investigations, accounting for 27 of the total number, far more than any other country. Eighteen countries initiated the cases, led by Canada with 20 investigations, followed by Brazil with 9. Japan also joined the group of petitioners, launching investigations against China, Chinese Taipei and Korea. A total of 27 countries were targeted in the unfair trade cases.
All but one of the investigations in 2025 resulted in positive preliminary determinations. Countries became more efficient in processing the cases, with the number of days for preliminary determinations falling from 200 days in recent years to 144 days in 2025. Countervailing duty investigations were often launched in tandem with dumping actions. The United States also launched AD and CVD investigations in tandem on reinforcing bars from Algeria, Egypt, and Viet Nam during the year.
The full impact of unfair trade cases on markets, however, needs to be considered in a multi-year context, as actions taken in earlier years continue to affect trade until the tariff actions are terminated. What is remarkable in recent years is that new cases continue to be filed by a growing number of countries on a growing number of countries, on a growing number of products. The number of AD/CVD measures in place, counting cases started since 2016, reached a record high of 395 in 2025, up from 321 in 2024. Currently, there are 113 trade actions targeting China, 41 on Korea, and 33 on Viet Nam (Figure 5.1). The United States leads with 77 measures in place, followed by Canada (64), Australia (46), and the European Union (32). Collectively, these four jurisdictions account for about one-half of all global AD/CVD trade measures.
Other measures affecting the steel trade
Copy link to Other measures affecting the steel tradeThe AD/CVD actions described above are particularly well-suited to addressing issues involving specific products from specific countries, but they have proven inadequate to address the larger-scale problems associated with global overcapacity across all steel products. A growing number of countries have therefore introduced across-the-board measures that aim to deal more effectively and efficiently with the scope and impact of growing global overcapacity on steel markets (see Table 5.1 for some examples), though in many instances they also affect imports from countries that are not sources of excess capacity, thereby affecting regional value chains. The actions have been taken in light of the importance of the industry to economies and to national security, including economic security. Features in some of the more recent measures include:
recognition of the threat global excess capacity in the steel industry is having on the viability of their national steel industries, and, at the same time, the importance of the steel industry to national economic and defence security
remedial global tariffs of up to 50% on many steel products
indefinite duration periods for the measures
implementation or consideration of measures to discourage or prevent diversion by requiring imported steel to include information on the origin of the hot metal used to produce imported products, no matter where final transformation took place
inclusion of downstream products in tariff measures, to discourage efforts by foreign steel producers and traders to evade the measures by refocussing on more advanced products.
Figure 5.1. Number of active antidumping and countervailing duty measures, by imposing and defendant countries, 2025
Copy link to Figure 5.1. Number of active antidumping and countervailing duty measures, by imposing and defendant countries, 2025Count of initiated measures under investigation or in place, December 2025
Note: Investigations targeting multiple countries are counted as separate investigations in the figure above. Ongoing investigations are defined as those initiated but with no provisional date established as of March 2026 and no negative investigation outcome. The measures in force are those with a provisional, definitive, or extension date established. Only investigations and measures that started in 2016 or after are considered. Only countries with at least five investigations are displayed in the figure. The data from Australia has been additionally complemented with cases from the Australian Anti-Dumping Commission.
Source: OECD, based on trade remedy data from the Japan Iron and Steel Federation and the Australian Anti-Dumping Commission.
Table 5.1. Trade measures, including those taken to address global overcapacity on steel markets, in 2025 and early 2026: Developments in selected economies
Copy link to Table 5.1. Trade measures, including those taken to address global overcapacity on steel markets, in 2025 and early 2026: Developments in selected economies|
Brief description of measures |
|
|---|---|
|
Brazil |
The tariff rate quota (TRQ) introduced in June 2024 was extended for another year in May 2025, and certain products were subsequently added to the coverage. In February 2026, tariffs were increased to 25% (no TRQs) on certain additional sheet, wire, and wire products. |
|
Canada |
In June 2025, Canada implemented TRQs on steel imports to help stabilise the Canadian market and prevent the harmful diversion of foreign steel from third countries into Canada, while minimising impacts on Canadian importers and downstream users. The measure covers a wide range of semi-finished, flat, long and tubular steel products, but does not include rail products and a number of other specialised products. Imports above the quota levels, originally set at 100% of 2024 levels for countries without free trade agreements with the country, are subject to a 50% surtax. In the months that followed, the quota level was reduced to 50% of 2024 levels, and then, in December, to 20%. In August, TRQs were expanded to include Free Trade Agreement (FTA) countries (except Mexico and the United States), based on 100% of their 2024 import levels. In December, the TRQ for the FTA countries was reduced to 75%. At the same time, the steel measures were expanded to include prefabricated buildings, wire, cables, chains and fasteners; these derivative (downstream) products are, with some exceptions, now subject to a tariff of 25%. Also in 2025, Canada imposed a 25% surtax on steel imports that contained steel melted and poured in China. The surtax was applied in light of the broad range of pervasive Chinese non-market policies and practices, and the resulting spread of trade distortions into global supply chains, pursuant to the country’s Customs Tariff regulation. When an imported article is subject to this surtax and the TRQ mentioned above, only the latter is currently applied. |
|
China (People’s Republic of) |
In December 2025, the Chinese Ministry of Commerce, together with the General Administration of Customs of the People’s Republic of China, announced the addition of steel products to the list of products subject to export licensing, effective on 1 January 2026. The mandatory export permits cover all steel mill products. |
|
European Union |
The safeguard measure that was introduced in 2018, in the form of a TRQ, was strengthened in 2025, including by 1) the provision under which the quota was liberalised by 1% per year, was reduced to 0.1%; 2) countries were no longer permitted to use the entire volumes of unused quotas by other countries; and 3) a carry-over mechanism that allowed countries to roll over unused quotas to the next quarter was eliminated for product categories with high import pressure and low consumption. In March 2026, the European Union initiated a safeguard involving certain grain-oriented flat-rolled products of silicon-electrical steel. The Steel and Metals Action Plan announced in March 2025 included steps to promote and protect the industry beyond 2026, in light of the expected ongoing pressures from global excess capacity on steel markets. In April 2026, a political agreement was reached on a new measure to replace the EU safeguard, which will expire by 30 June 2026. The new measure will be based on a revised TRQ system with a biannual review and imports in excess of the quota will be subject to a 50% ad valorem tariff. The measure also includes a provision requiring imported steel products to include an identification of the country where the steel was originally melted and poured to increase supply chain transparency. On 1 January 2026, the European Union’s Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase, following a transitional period from 2023 to 2025. The CBAM is designed both to place a fair price on the carbon emitted during the production of carbon-intensive goods imported into the European Union and to encourage cleaner industrial production in non-EU countries. |
|
India |
In 2025, the Steel Import Monitoring System was tightened, requiring importers to demonstrate compliance with the applicable Indian Standards and Bureau of Indian Standards (BIS) specifications as a condition of entry, unless otherwise exempted. These requirements apply to all steel products in Harmonized System (HS) Chapters 72 and 73 for which BIS Quality Control Orders exist. Also in 2025, the government strengthened its policy providing preferential treatment to domestically manufactured iron and steel products linked to government procurement, and a safeguard action on certain flat-rolled products was implemented; under the safeguard measure, an initial additional tariff of 12% is being applied to imports whose cost, insurance and freight value falls below a prescribed level. |
|
Mexico |
In late 2025, Mexico boosted tariffs on non-FTA countries on a broader range of products, including more steel products. Regarding steel, HS 7207 (semi-finished slabs and billets) was the only four-digit steel code excluded from the tariff measures. The tariffs were effective as of 1 January 2026, with no set duration. Covered steel products are now generally subject to a 35% tariff. |
|
United Kingdom |
In July 2025, the safeguard provisions were strengthened. In March 2026, the UK government published a paper articulating its strategy for the sector in the months and years to come. On the trade front, the strategy is designed to defend against global overcapacity in steel once the current safeguard measure expires on 30 June 2026. Under the plan, a new set of TRQs will be introduced, containing quota levels that are 60% lower than those under the current safeguard, with an increased out-of-quota tariff rate of 50%. The country intends to initiate a process under Article XXVIII of the General Agreement on Tariffs and Trade 1994, to lift its bound rates to 50%, from the current duty-free level. Moreover, the scope of the new measure will be expanded to include additional steel products made in the United Kingdom but not currently covered by the steel safeguard. The new measure will cover all countries, including those which have entered into FTAs with the country. Also, the possibility of introducing requirements to identify where the steel used in imports is melted and poured will be explored. |
|
United States |
Measures under Section 232 of the Trade Expansion Act of 1962 were modified in 2025. Principal actions taken in in early 2025 included: 1) termination of exemptions and special treatment for a number of countries so that all trading partners were brought under the Section 232 steel regime; 2) termination of general approved exclusions (GAEs), a set of preapproved, product specific exclusions, and the discontinuation of new product exclusion requests; 3) exemption of derivative products from the tariffs when produced abroad exclusively from steel melted and poured in the United States; and 4) expansion of the list of derivative steel products subject to Section 232 tariffs. In June 2025, the tariff was increased to 50% ad valorem, except for the United Kingdom, which remained subject to the 25% tariff under the terms of the US-UK Economic Prosperity Deal. In April 2026, the tariff regime was further modified. The principal changes contained in the Presidential Proclamation included: 1) articles made entirely or almost entirely of steel will pay a 50% tariff on their full value; 2) derivative articles made substantially of steel will pay a 25% tariff on their full value; 3) certain metal-intensive industrial equipment and electrical grid equipment will pay a 15% tariff through 2027, to accelerate the industrial base buildout currently underway in the United States; 4) products made abroad entirely with American steel will pay a tariff of 10%; and 5) products made of 15% or less of steel will no longer be subject to the Section 232 tariffs. The proclamation also reinforces the enforcement powers of the Customs and Border Protection agency, with particular attention to illegal transhipment, under valuation and other tariff evasion issues. |
Source: OECD Steel Secretariat.
Trade diversion and the circumvention of trade measures
Copy link to Trade diversion and the circumvention of trade measuresWhile the AD/CVD measures introduced limit inflows of targeted steel, they can also lead to steel being diverted to alternative markets (OECD, forthcoming[1]), which then experience the effects of the dumped and/or subsidised products. Countries with lower levels of trade enforcement or less developed trade remedy systems are often affected.
In many cases, steel producers and traders are trying to circumvent trade measures to which they are subject. Their use reflects the ease with which the producers can tweak their products and/or manage their trade by, for example, altering the chemistry, form, gauge, finish and other characteristics of a steel product in ways that would place that product outside the scope of a trade action, or by simply shifting shipments to upstream or downstream products. This is particularly significant in AD and CVD actions, as the cases focus on narrowly defined products, where width, thickness, chemistry and finish are key parameters for classifying products. Moreover, AD and CVD cases are country-specific; shipping products subject to an AD or CVD order to intermediate countries not subject to an order for limited processing of the product could change the country-of-origin designation of the product. As a result, the processed product would fall outside the scope of the AD or CVD duties in the final country of importation.
Many countries, however, have or are setting up tools to address circumvention. The tools include: 1) extension of AD/CVD measures to products that have been slightly modified or used as components in the manufacture of other goods; 2) products that have been processed in a third country; and 3) the possibility to extend orders to all producers in a country. In the case of the United States, the European Union, Australia and Canada (and others), formal investigations are required to determine whether the scope of orders can be expanded.
The efforts described earlier by countries to mandate “melt and pour” reporting requirements in order to enhance supply chain transparency may also have implications for addressing circumvention, as this required information would follow steel shipment from the ladle to its final destination, thereby undermining efforts by producers and traders to blur origin using third-country transhipment.
Circumvention opportunities, it should be noted, can also arise when countries that are FTA members or benefit from developing country exemptions process the steel subject to safeguard measures into products that are exempt from FTA and/or developing country exemptions.
In 2025, the OECD initiated a workstream to assess the magnitude and scope of efforts by steelmakers and traders to circumvent AD and CVD steel remedies (OECD, forthcoming[2]). Particular attention is being paid to developments in Southeast Asia, which is a major steel-producing, steel-importing and steel-exporting area. There is evidence that producers and traders in China, which is named in more AD and CVD actions than any other country, have responded to the imposition of punitive AD and CVD tariffs by adapting their commercial strategies. They seek to avoid AD/CVD remedies by increasing their steel exports to Association of Southeast Asian Nations (ASEAN) countries that are not subject to similar trade remedies, where the steel is then processed or otherwise modified. In many instances, the processed product is then treated as a product of the ASEAN country, enabling it to be exported freely to the country where the trade remedy is in effect, without a punitive tariff being imposed, thereby, in effect, circumventing the remedy.
At the same time, the surge in Chinese exports to the ASEAN region over the past five years, often at low prices, has led to a growing number of trade actions by Southeast Asian countries, some of which have developed tools to address circumvention. During 2020-2024, ASEAN countries as a group initiated 35 AD investigations, 10 of which were against China.
Preliminary work examines how circumvention is being addressed in Southeast Asia (OECD, forthcoming[2]). The examination focussed on the situation in the Thai and Vietnamese steel industries, and the actions that the two countries had taken to address circumvention. Thailand has thus far initiated six anti-circumvention cases, all of which involved steel products; Viet Nam has one such case underway on steel. China was the party named in all seven cases.
The OECD analysis also examines how trade flows have shifted following the initiation of steel AD and CVD investigations in OECD Member countries, with a view towards identifying patterns that could eventually be linked to circumvention. This initial work examines how ASEAN steel trade flows have shifted following the initiation of an AD/CVD case by an OECD Member country against China. The analysis finds that products subject to OECD trade remedies may have continued to reach OECD markets indirectly via non-OECD intermediaries, such as ASEAN countries.
The report also finds that, following the implementation of trade measures against China, Chinese exports of semi-finished steel increased to ASEAN countries; at the same time, exports of ASEAN exports of finished steel to OECD areas increased, suggesting that AD/CVD actions may have been circumvented through the processing of semi-finished steel into products that otherwise would have been subject to AD/CVD duties, had they been exported directly from China.
Export restrictions on steelmaking materials
Copy link to Export restrictions on steelmaking materialsTrade in some of the critical raw materials used in steelmaking has been subject to an increasing number of actions to restrict exports in recent years. Ores and minerals, including nickel and chromium, have seen the most rapid increase in restrictions, often aimed at promoting domestic processing and, by increasing supply and lowering domestic prices of those materials, supporting steel producers in the countries that apply them (OECD, 2025[3]). Such trade restrictions not only have the potential to disrupt global value chains for steel but also have ripple effects on downstream industries that manufacture steel-based products, with potentially significant implications for broader economic activity. Given the extensive use of steel across key industries, disruptions in raw material availability can lead to production bottlenecks, increased costs and economic security risks for both industrialised and developing economies.
Scrap faces growing export restrictions
Steel scrap is an essential raw material for the steel industry, enabling cost-effective and energy-efficient production while supporting the circular use of resources (OECD, 2024[4]). Scrap is an essential input for making steel in the EAF production mode and is also used, albeit to a much lesser extent, in BOFs. While it is a cost-effective and practical material that ensures the circularity of production, it is also an important material for low-emission steel production. As such, it is increasingly being considered a strategic material by countries.
Areas with high steel consumption, such as North America, Europe, East Asia and China, have relatively abundant scrap supplies, while emerging markets may face chronic shortages. This geographic heterogeneity can spur trade tensions, especially if major suppliers impose export restrictions to safeguard domestic supplies.
Over the past few years, there has been an increase in the application of export restrictions on ferrous scrap, indicating the growing importance of ferrous scrap to certain economies as an input for their steelmaking operations. According to the OECD Inventory on Export Restrictions on Industrial Raw Materials, in 2023, 42 economies applied some form of restriction on ferrous scrap (OECD, 2025[3]). These include several large steelmaking economies, such as China, Egypt, Indonesia and India, as well as a wide range of smaller markets. However, when comparing these measures against export volumes at the Harmonized System (HS) 6-digit level, only about 15.2% of global scrap trade was actually subject to restrictions. Among the world’s major exporters, only India currently maintains an active measure (India Code, 2023[5]), indicating that while restrictions are widespread in number, they still cover a rather limited part of global scrap trade flows (see Table 5.2).
Table 5.2. Active export restrictions on ferrous scrap (major exporters) in selected economies, 2025
Copy link to Table 5.2. Active export restrictions on ferrous scrap (major exporters) in selected economies, 2025|
Scrap exports (Mt) |
Share of global exports (%) |
Number of export restrictions currently in force |
|
|---|---|---|---|
|
European Union |
22.9 |
17.2 |
0 |
|
United States |
21.4 |
16.0 |
0 |
|
Türkiye |
19.0 |
14.3 |
0 |
|
India |
11.8 |
8.8 |
1 |
|
United Kingdom |
7.5 |
5.7 |
0 |
|
Japan |
7.0 |
5.2 |
0 |
|
Canada |
5.6 |
4.2 |
0 |
|
Viet Nam |
5.2 |
3.9 |
1 |
|
Korea |
4.2 |
3.1 |
0 |
|
Mexico |
3.7 |
2.8 |
0 |
|
Chinese Taipei |
3.5 |
2.6 |
0 |
|
Pakistan |
2.5 |
1.9 |
0 |
|
Australia |
2.2 |
1.6 |
0 |
|
Thailand |
1.9 |
1.4 |
0 |
|
Switzerland |
1.1 |
0.9 |
0 |
|
Indonesia |
1.1 |
0.9 |
2 |
|
Brazil |
1.1 |
0.8 |
0 |
|
Hong Kong (China) |
1.1 |
0.8 |
0 |
|
Russia |
1.1 |
0.8 |
1 |
|
Morocco |
1.0 |
0.8 |
1 |
|
China (People’s Republic of) |
0 |
0 |
1 |
Note: Data on ferrous scrap trade are obtained from the Iron and Steel Statistics Bureau (ISSB) and include the following Harmonized System (HS) codes (6 digit): 720410, 720421, 720429, 720430, 720441, 720449, 720450. Data on export restrictions are obtained from the OECD Export Restrictions on Critical Raw Materials Database and complemented by desk research carried out by the Steel Secretariat. EU data do not include EU intra-trade.
Source: OECD (2025[3]).
While scrap export restrictions affect only a small share of global trade, their growing number is a cause for concern. The spread of such measures, particularly among developing economies, signals rising competition for scrap, which could tighten availability in the medium term for steelmaking countries that depend on imports.
Chromium restrictions raise concerns for stainless-steel supply chains
Chromium is an essential raw material for the steel industry, particularly in the production of stainless and alloy steels, where its use is required. It improves resistance to corrosion, increases hardness and allows steel to withstand high temperatures.
The chromium value chain begins with chrome ore, which undergoes beneficiation to increase its grade. The ore is then smelted into ferrochrome, the main form through which chromium enters steelmaking. Around 90% to 95% of mined chrome ore is converted into ferrochrome, and the stainless-steel sector accounts for 80% to 90% of global ferrochrome use (du Preez et al., 2023[6]). World chromite resources are geographically concentrated in Zimbabwe, Kazakhstan, and South Africa, which together account for around 90% of the world’s resources. China overtook South Africa as the world’s largest ferrochrome producer in 2012, and by 2014, it was firmly established as the global leader (ICDA, 2025[7]). This development was driven not only by the rapid expansion of domestic smelting capacity but also by sustained overseas investment, as Chinese enterprises, frequently state-backed and operating within the framework of the Belt and Road Initiative, acquired chromite and ferroalloy assets in Zimbabwe and South Africa to secure long-term access to raw materials.
The high concentration of chromite resources in a few countries, together with China’s dominant role in ferrochrome production based on imported ore, raises concerns about supply dependencies. Recurrent electricity and infrastructure constraints in South Africa, as well as policy measures in Zimbabwe, such as export restrictions and beneficiation requirements, further increase the exposure of global stainless-steel supply chains to market and regulatory risks.
Recent trade and policy developments in chromium raise strategic concerns for stainless-steel supply chains. According to OECD data (OECD, 2025[3]), chromium ore exports from both South Africa and Zimbabwe are affected by some form of export restrictions. These two countries together account for about 88% of global chromium ore exports. These measures have been introduced with the stated objective of promoting domestic beneficiation by scaling up the value chain and processing chrome ore locally rather than exporting it in raw form. There are no restrictions on ferrochromium.
Beyond the restrictions themselves, the deeper vulnerability lies in the high geographic concentration of production of this material in southern Africa, coupled with extensive Chinese investment and the dominance of China-linked trading relationships with both South Africa and Zimbabwe.
Major nickel ore suppliers maintain some form of export restriction
Nickel is a base metal with a broad range of industrial applications. Overall, however, more than 70% of nickel demand is tied to steel-related applications. At the same time, batteries already represent a smaller but rising share of use, even though stainless steel is expected to continue dominating overall consumption.
In recent years, a slowdown in the stainless-steel market, combined with weaker-than-expected demand from the battery sector, the second-largest nickel market, has led to oversupply and falling prices. Many nickel producers, particularly in OECD Member countries, have struggled to operate, and some have been forced to exit the market. Between 2020 and 2024, Indonesia added an estimated 1.5 Mt of new nickel supply, while production outside Indonesia contracted by around 500 000 tonnes. As a result, Indonesia’s share of global refined nickel output rose from 6% in 2015 to 61% in 2024 and is projected to reach about 74% by 2028, raising concerns among consuming economies about growing supply dependencies and the associated risks for market stability (Financial Times, 2025[8])
Regarding supply, since 2020, Indonesia has imposed a full ban on nickel ore exports to promote domestic smelting and battery-related investments. Other producers have also sought to limit the outflow of unprocessed ore: the Philippines, while not imposing an outright ban, has introduced fiscal and administrative measures, such as value-added tax (VAT) rules and strict export-permitting requirements, that raise the cost of shipping raw ore abroad. Currently, four of the world’s major nickel ore suppliers, Indonesia, the Philippines, New Caledonia and the Russian Federation, maintain some form of restriction on nickel ore exports. By contrast, ferronickel and nickel oxide sinter, two key processed intermediates used in stainless-steel production, remain unaffected by export restrictions.
The core concern is therefore the tightening control over the raw ore segment, which is critical for feeding stainless-steel production. By limiting the tradability of nickel ore, these measures heighten the vulnerability of global supply chains to policy shifts in a handful of jurisdictions.
References
[6] du Preez, S. et al. (2023), “An overview of currently applied ferrochrome production processes and their waste management practices”, Minerals, Vol. 13/6, p. 809, https://doi.org/10.3390/MIN13060809.
[8] Financial Times (2025), ‘The Opec of nickel’: Indonesia’s control of a critical metal, https://www.ft.com/content/0bbbe7c7-12a1-43ba-8bef-c5c546367a0e (accessed on 13 September 2025).
[7] ICDA (2025), Market Insights: chromium market overview and analysis, International Chromium Development Association, https://www.icdacr.com/market-insights (accessed on 15 September 2025).
[5] India Code (2023), The Second Schedule - Export Tariff, https://upload.indiacode.nic.in/schedulefile?aid=AC_CEN_2_2_00039_197551_1554713855359&rid=791 (accessed on 29 September 2025).
[3] OECD (2025), OECD Inventory of Export Restrictions on Industrial Raw Materials 2025: Monitoring the Use of Export Restrictions Amid Growing Market and Policy Tensions, OECD Publishing, Paris, https://doi.org/10.1787/facc714b-en.
[4] OECD (2024), The Global Scrap Steel Market: Opportunities and Challenges, OECD Publishing, Paris.
[1] OECD (forthcoming), “Steel trade and trade policy developments”, OECD Publishing, Paris.
[2] OECD (forthcoming), “Steel trade circumvention”, OECD Publishing, Paris.