Commission Implementing Regulation (EU) 2025/1919 of 25 September 2025 imposing a definitive anti-dumping duty and definitively collecting the provisional duty imposed on imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Egypt, Japan and Vietnam, and terminating the investigation on imports thereof originating in India

(201) After final disclosure FHS reiterated its claim that the similar decline level of both the Union industry sales volume in the Union free market and the Union industry captive transfers in the Union market resulted first and foremost from a contracted demand on the Union free market and not from imports from the countries concerned.

(202) Whilst invoking this argument in favour of using the total Union consumption which thus included both captive and free-market transactions as the denominator for the calculation of the market shares, FHS however disregarded the existence of a displacement of the sales of the Union producers in the free market by the exporting producers from the countries concerned which saw their market share increase at a time when the overall demand was shrinking as showed in table 2. On this basis, this claim was rejected.

(203) In a context where the Union Industry controlled about 70,8 % of the free market and more than 85 % of total consumption, the Commission confirmed its findings that a 3,4 % decrease in market share could not be considered as an ordinary competitive variation. The updated figures confirmed that the Union industry had no other choice but to follow the price level set by the dumped imports to avoid losing further market share. This resulted in a deterioration of the situation of the Union industry as showed by various macro and micro indicators such as profitability, sales volume, market share, employment and cash flow. On this basis, these claims were rejected.

(204) Nippon Steel and JFE noted that according to Table 12 of the provisional Regulation, employment levels in the Union industry have increased from 2023 to the IP, by 3,4 %, however, the Commission only highlighted the reduction of 7,0 % over the period considered.

(205) Nippon Steel and JFE pointed to the information provided by the Union industry, that showed that average labour costs started to stabilise, falling significantly from their peak in 2023.

(206) The Commission first considered that certain injury indicators should not be interpreted in isolation to determine whether the Union industry suffered material injury. On the contrary, injury should be determined by assessing all injury indicators. Furthermore, not all injury indicators should show a deterioration of the Union industry’s performance to conclude that it suffered material injury.

(207) As far as employment is concerned, the Commission considered that the increase from 2023 to the IP, by 3,4 % was mostly due to the adjustments made by some of the Union producers after the COVID-19 crisis, which deeply affected the market demand and prices.

(208) The Commission referred to the recitals (45) and (224) to (226) of the provisional Regulation, where it explained that all the indicators of the Union industry were affected, as those of many other industries, by the pandemic situation in 2020. The temporary more favourable situation observed in 2021 and 2022 was due to an unusual supply-demand imbalance in the aftermath of the COVID-19 pandemic. Once the supply-demand situation became more balanced, the Union producers found themselves under renewed pressure from imports from the countries concerned, which affected their market share and economic performances.

(209) On this basis, the claims were rejected.

(210) Since the revised tables as modified after final disclosure showed the same trends, the findings regarding injury were definitively confirmed.

(211) The above revised figures to include non-captive sales on the free market to related parties confirmed that the Union Industry as a whole could not maintain its production and sales volumes and improve its capacity utilisation rate. The production and sales volumes actually decreased more than the consumption on the Union market. In view of the decreasing production, the Union industry took concrete actions to improve efficiency by keeping a tight grip on cost of production (mainly raw materials and labour costs) and by increasing the production per employee when the situation of the Union industry started to deteriorate. Nonetheless, the cost of production increased by 18 % when the unit sales price remained stable, with the exception of the year 2022, during the period considered. Consequently, the profitability of the Union industry deteriorated significantly going from 12 % in 2021 and 2022, when the Union industry benefitted from the recovery of the economy after the COVID-19 crisis, to a loss-making situation in 2023 and the IP. The sampled Union producers could still make investments throughout the period considered showing its dynamism despite a deteriorating financial situation.

(212) In the light of the foregoing, it is definitively concluded that the above data show that the Union industry has suffered material injury during the period considered within the meaning of Article 3(5) of the basic Regulation.

(213) In recital (265) of the provisional Regulation, the Commission concluded that the material injury of the Union industry was caused by the dumped imports of the product concerned originating in the countries concerned.

(214) Following provisional and final disclosure, the GOJ and FHS disagreed with the conclusions in Section 5.1 of the provisional Regulation.

(215) The GOJ submitted that, as a result of the ‘Tariff Rate Quotas’ (‘TRQ’s’) of the safeguard measures, the overall volume of hot-rolled steel imports did not increase and argued therefore that there have only been substitutions of the origins of the imported products within the volume of TRQ’s allowed. On this basis, GOJ considered that imports originating in Japan could not have caused material injury to the EU’s domestic industry. The GOJ further claimed that the market share of the imports from Japan has consistently remained below 4 %, and even the market share of the subject imports as a whole had been low at around [8,0-8,5 %].

(216) The GOJ finally argued that the volume of imports of products from Japan in the second half of 2024 had fallen by 51,2 % compared to the previous year, due to the maximum cap of 15 % per single country, which was introduced in June 2024 (30). Therefore, the GOJ questioned the injury analysis which was not properly considering the above-mentioned circumstances and could not be considered as an objective examination in the sense of Article 3.1 of the AD Agreement.

(217) The Commission noted that safeguard and anti-dumping measures address different situations. In this case, safeguard measures have indeed been imposed under the form of a TRQ, on the basis of traditional trade flows and with a view to avoid trade diversion. However, the safeguard measure does not prevent the imposition of measures to remove the effects of unfair trade practices, in particular within the limits of the TRQ, i.e. before any safeguard duty would apply. Thus, the reference to volume caps unaffected by an additional safeguard duty cannot put into question the causation between the subject imports and the injury to the Union industry. The Commission also recalled that its analysis covered the investigation period ending on 30 June 2024. Hence, the inclusion of post-IP elements in its causation analysis, such as a decrease in imports in the second half of 2024, would not ensure an objective examination of the facts. On this basis, this claim was rejected.

(218) As mentioned in recital (194), FHS argued that the negative effects on macro and micro economic indicators such as capacity utilisation, production capacity, production, sales volumes and market share could not result from the imports from Vietnam as the quantities were too small.

(219) The Commission rejected this argument on the grounds that the conditions for assessing the imports from the countries concerned cumulatively were fulfilled so that dumped imports from Vietnam were assessed together with imports from the other countries concerned.

(220) FHS stated that while acknowledging that the recent profitability and cash-flow results of the Union industry were weak, it was not established whether the losses arising from lower demand, higher energy and input costs, an ambitious investment timetable, or other structural factors had negatively influenced these micro economic indicators.

(221) The Commission disagreed with this view. The list of factors raised by FHS were already considered by the Commission as mentioned in recitals (240) and Section 5.7 of the provisional Regulation. Whilst FHS did not present any new elements contradicting the analysis made by the Commission on how these factors influenced the micro economic indicators. These claims were therefore rejected.

(222) FHS stated that the Commission failed to carry out an objective examination of each of several elements, which contributed to the Union industry’s difficulties such as weakened global demand.

(223) In the absence of more precise and substantiated claims regarding the alleged lack of objectivity in the Commission’s assessment, the Commission referred to Section 5 of the provisional Regulation and more specifically Section 5.8 which addresses this factor in particular.

(224) Ezz Steel argued after final disclosure that Egypt could not have caused injury to the Union industry as it had low production capacity compared to other third countries such as Japan, India or Vietnam. In addition, it stated it could not increase its exports to the EU due to the implementation of safeguard measures and that it only supplied HRF according to specific purchase orders ‘under fair and transparent conditions’.

(225) The Commission considered these elements as irrelevant when assessing the effect of the dumped imports from the countries concerned. While the production capacity of Egypt may be lower than that of the other countries concerned, it remained that individual production capacity is not an element to assess the injury caused. Equally, the statement that Egypt cannot allegedly increase its exports to the Union because of the safeguard measures is factually incorrect since the measures do not prohibit imports from entering the Union market, even after Egypt’s quota has been exhausted. In order to assess the effect of the dumped imports, the Commission analysed inter alia the increase in market share and the price level of the dumped imports originating in Egypt and the other countries concerned after the conditions for a cumulative assessment of their effects had been fulfilled, as provided in Section 4.3.1 of the provisional Regulation.

(226) In the absence of any other comments with respect to this section, the Commission confirmed its conclusions set out in recitals (241) and (242) of the provisional Regulation.

(227) After final disclosure, FHS argued that reduction in capacity utilisation resulted from the weakening of both captive and free market demand which could not be automatically caused by the imports from the countries concerned. FHS further noted that its imports did not compete with the Union industry on the captive market.

(228) The Commission disagreed with this view, as in fact, the Union primary and secondary industry were in direct competition with non-related steel trader and processing companies in the Union which are sourcing HRF in the countries concerned. It was therefore only logic that the reduced capacity utilisation showed a decline, which could only be attributed to the countries concerned, since the Union industry’s output, whether used for captive or free market consumption was similarly affected by the dumped imports from the countries concerned as confirmed by the loss of market share.

(229) In the absence of any other comments with respect to this section, the Commission confirmed its conclusions set out in recitals (243) and (244) of the provisional Regulation.

(231) The sampled Union producers export volumes decreased by 20 % over the period considered to remain below 600 000 tonnes in the IP. Overall, the volumes exported by the Union industry accounted for only about 2,3 % of their total sales in the free market during the investigation period and an even smaller proportion of total production in the same period.

(232) The GOJ claimed that while export sales have decreased by 20 % over the investigation period compared to 2021 as shown in Table 17 of the provisional Regulation and Table 5 above, Union producers have significantly increased their investments in 2023 as shown in Table 16 of the provisional Regulation. The GOJ considered that it was this business strategy of the producers has led to reduced profit margins.

(233) FHS claimed that Union producers’ deteriorating export performance has itself contributed to the alleged material injury, particularly through reduced volumes, lower international prices, and lost economies of scale.

(234) These claims have been examined by the Commission and the findings reached in the provisional Regulation that the export sales accounted for a minor share of total sales were confirmed. Their decrease could not have a significant impact on the performance of the Union industry as a whole.

(235) In the absence of any other comments with respect to this section, the Commission confirmed its conclusions set out in recitals (245) to (247) of the provisional Regulation.

(237) The investigation revealed that the market share of imports from India, South Korea, Taiwan and Vietnam (Hoa Phat Group) increased over the period considered and except for India, both in absolute and relative terms. On the contrary, the Commission observed that the imports from other third countries did not increase over the same period, but in fact decreased by 11 %. In contrast, imports from the countries concerned increased significantly. However, the share of imports from the countries concerned in all third countries imports increase by 53 percent over the period considered, which therefore indicated that the imports from the countries concerned increased comparably more than the imports from all countries which only increased by 14 %.

(238) After final disclosure, FHS argued that the Commission had failed to assess the fact that, during the investigation period, exporting producers in India, South-Korea, and Taiwan together supplied approximately 3,2 million tonnes of HRF to the Union market; more than three times the combined volumes from Egypt or FHS. FHS also stressed that the Commission did not provide any undercutting analysis nor CIF price trends and no market-behaviour differentiation was made between the countries concerned and other third countries.

(239) The Commission noted that while a thorough analysis of the level and prices of imports from other third countries has been done, there was no legal obligation to proceed to any price undercutting analysis or CIF prices from countries not covered by the investigation at hand. Although the Commission assessed imports from these countries, producers in these countries not being interested parties to this investigation, the Commission was not in a position to request such information from them, nor was it the purpose of this investigation.

(240) The Commission also analysed the evolution of import prices from third countries. Except for the year 2021, the average import prices from each of the four countries, as well as all third countries taken globally, were on average higher than the import prices from the countries concerned. On this basis, the Commission considered that the evolution of imports from third countries did not attenuate the causal link.

(241) Following the imposition of provisional measures, FHS considered that by omitting any structured attribution analysis of these formally non-dumped yet clearly injurious volumes originating in other third countries, the provisional Regulation overstated the causal role of the imports from Egypt, Japan and Vietnam, while understating broader market dynamics that are demonstrably more influential in shaping price trends and competitive pressures. The Commission recalled that these aspects had been examined in detail in recitals (248) to (252) of the provisional regulation. The claim was rejected.

(242) As noted in recital (183), Ezz Steel considered that the average prices of imports from Egypt were relatively high and did not undercut EU sales prices. Therefore, these imports could have not caused injury to Union producers.

(243) After final disclosure, Ezz Steel further argued that the Commission failed to consider the approach taken in Council Regulation (EC) No 1420/2007 (31) imposing a definitive anti-dumping duty on imports of silico-manganese originating in the People’s Republic of China and Kazakhstan and terminating the proceeding on imports of silico-manganese originating in Ukraine, in which it found that the effect of imports from Ukraine should be assessed separately in view of the absence of undercutting. The Commission first noted that the said regulation was adopted in 2007, whereby the concept of price suppression which refers to prices that are kept artificially low had not been considered at that time, and second, as mentioned in recital (197) of the provisional regulation, the investigation also revealed that the Union industry’s prices were suppressed by the low priced imports originating in Egypt, which followed similar trends and trade patterns. On this basis, this claim was rejected.

(244) As noted in recital (197) of the provisional Regulation, the Commission concluded that, although imports of HRF were not undercutting Union industry prices, there was price suppression whereby they were impacting negatively the performance of the Union industry.

(245) Nippon Steel and JFE considered that the production figures could not be taken as evidence that the Union industry was suffering material injury, given the refusal to increase production even in the particularly favourable environment created by the investigation and that imports were evidently an important source of supply for the EU market – including for the Union producers themselves.

(246) With regard to the import volume, the Commission considered that Nippon Steel and JFE overstated the volume of imports from the countries concerned by including imports from India in their analysis although the Commission’s causation analysis was limited to Egypt, Japan and dumped imports from Vietnam. The verified information received from the sampled EU producers, confirmed that the 220 000 tonnes of HRF were in fact mostly imported in limited quantities by Union steel secondary producers related to Union primary producers. The vast majority of imports from the countries concerned were made by Union non-related trader and processors. Referring to recital (253) of the provisional Regulation, the Commission reiterated that, Union producers’ related entities are not required to buy from their related companies and purchase on an arm’s length basis. As mentioned in recital (313) of the provisional Regulation, the objective of anti-dumping duties is not to close the Union market from any imports, but to restore fair trade by removing the effect of injurious dumping. Imports from the countries concerned are therefore not expected to come to an end, but to continue, albeit at fair prices.

(247) After final disclosure, FHS considered that the Commission could not conclude that the imposition of duties could still allow users to imports HRF from diversified sources and at the same time, improve the market shares and profitability of the Union industry. The Commission disagreed with this analysis and recalled that it had explained in detail in recitals (313) to (325) of the provisional Regulation why the impact of the imposition of the duties would not be significant and not outweigh the positive effects of measures on the Union industry. On this basis, this claim was rejected.

(248) In the absence of any other comments than those already addressed in recitals (177) to (179) with respect to this section, the Commission confirmed its conclusions set out in recital (253) of the provisional Regulation.

(249) In the absence of any comments with respect to this section, the Commission confirmed its conclusions set out in recitals (254) to (256) of the provisional Regulation.

(250) After final disclosure, FHS claimed that the Commission failed to make a quantitative assessment of the cost of energy prices by using publicly available energy price information as this cost shock should have been measured and netted out before imports from the countries concerned were made responsible for the injury. In view of FHS, this cost-price squeeze led directly to the erosion of profitability and was wrongly attributed by the Commission to the imports from the countries concerned.

(251) The Commission recalled that it conducted an analysis of the increase of costs of electricty, which results were outlined in recital (259) of the provisional Regulation. Rather than using publicly available information, which would have been disconnected from the actual situation of the sampled Union producers, the Commission used the information requested and verified from the Union producers. On this basis, this claim was rejected.

(252) In the absence of any other comments with respect to this section, the Commission confirmed its conclusions set out in recitals (257) to (262) of the provisional Regulation.

(253) In the absence of any comments other than those addressed in recitals (158) and (160) with respect to this section, the Commission confirmed its conclusions set out in recitals (263) to (264) of the provisional Regulation.

(254) The Commission assessed the impact of all other known factors, taking into account the comments of interested parties, and concluded that those factors did not attenuate the causal link. Therefore, the Commission confirmed the conclusions in recitals (265) to (267) of the provisional Regulation that there was a causal link between the injury suffered by the Union industry and the dumped imports from the countries concerned which was not attenuated by the factors mentioned above.

(255) In the provisional Regulation (recitals (272) to (287)), the Commission detailed the methodology used to establish margins adequate to remove injury to the Union industry.

(256) Following provisional disclosure, Nippon Steel claimed that an amount for the out-of-quota duties paid under the safeguard measures should be added when establishing the landed export price for the purpose of the injury margin calculations, as any other normal customs duties.

(257) The Commission disagreed with Nippon Steel. The Commission recalled that the anti-dumping measures and the safeguard duties are not cumulative contrary to conventional customs duties. Rather, the anti-dumping measures will apply to imports made under the available tariff free quota, i.e. on imports that are not subject to the safeguard tariff measure. As to imports made once the relevant tariff quota is exhausted, they would be subject to a total duty level (excluding the conventional customs duty) equivalent to the higher of the safeguard tariff measure or the anti-dumping measure, as the case may be. In other words, when the anti-dumping duty exceeds the level of the safeguard measure, the safeguard measure is effectively deducted from the applicable anti-dumping duty to be collected. As a result of the mechanism put in place to avoid any cumulation of safeguard or anti-dumping measure beyond the higher of the two measures, increasing the landed import price of Nippon Steel with the paid safeguard tariff measures during the investigation period to determine the level of anti-dumping duty would result in reducing the anti-dumping duty to a level insufficient to address the injury caused by the said dumped imports, either because the safeguard measure is not applied or because it is effectively deducted from the applicable anti-dumping duty. For these reasons, the Commission concluded that the allegation made by Nippon Steel was factually incorrect and conceptually wrong. In any case, it was found that, during the investigation period, safeguard duties were paid on less than 6 % of the imported volume of HRF originating in Japan and therefore the impact of not considering the safeguard duties in this particular case was marginal, that is around 0,1 percentage point. On this basis, this claim was rejected.

(258) After final disclosure, Nippon Steel reiterated that in order to comply with the basic Regulation, the landed prices should be based on the situation in the investigation period (i.e. NSC’s sales prices including safeguard duties are competing with the prices of the Union industry). This claim was already addressed in the GDD and we therefore rejected.

(259) Furthermore, Nippon Steel submitted that the injury margin calculations did not take delivery time into account. It alleged that, although not quantifiable, buyers in the EU were willing to pay a price premium for short delivery times. According to Nippon Steel, it takes on average approximately 43 days for shipments to arrive to the Union border from Japan. Furthermore, because of the EU Steel Safeguard Measure, there might be an additional waiting time until the start of the following quarter of the EU Steel Safeguard Measure to be able to customs clear imports. The exporting producer further stated that this explained the gradually increasing undercutting and underselling margins the farther the country of export was located from the EU – the higher the injury margins were found for Japanese exporters.

(260) The Commission concurred with the view that such ‘price premium for short delivery times’, even if demonstrated, was not quantifiable. Furthermore, if short delivery times were a factor increasing the selling price, the Commission failed to see how this could gradually increase the undercutting and underselling margins the farther the country of export was located from the EU. Nippon Steel’s reasoning was also contradicted by the low underselling margin found for JFE, another Japanese exporting producer in the country concerned.

(261) As mentioned in recital (100), Nippon Steel contested the method used to assess the CIF value for certain transactions. As explained in recitals (101) to (104), this claim was partially accepted whereby the CIF values used as a denominator was revised for certain transactions. Consequently, the injury margin calculated for Nippon Steel was adjusted accordingly.

(262) After final disclosure Nipon Steel claimed that the Commission failed to add the post-importation costs to this CIF price for sales through two related companies and thereby, the price taken for the underselling margin calculations were not ‘fully landed in the EU’ given that these post-importation costs were excluded from the CIF price. The Commission accepted this claim and revised its calculations to include post-importation costs for two companies. Consequently, the injury margin calculated for Nippon Steel in the General Disclosure Document was further adjusted accordingly.

(264) In the absence of any other comments with respect to this section, the Commission confirmed its conclusions set out in recitals (272) to (289) of the provisional Regulation.

(266) After publication of the provisional measures, the exporting producers FHS and Ezz Steel, the GOE and the GOJ, submitted comments on the Union interest.

(267) In the absence of any related claim or comment regarding the interest of the Union industry, the conclusions reached in recitals (291) to (295) of the provisional Regulation were confirmed.

(268) Following provisional disclosure, the GOJ claimed that it would not be in the Union interest to impose anti-dumping measures against the countries concerned. They alleged that anti-dumping measures would be against the interests of importers and Steel Service Centres because they will have an anti-competitive effect (Union producers will increase their prices) and because Union producers do not produce certain types of cold-rolled flat steel products.

(269) These allegations were already dealt with in recitals (296) to (305) regarding the anti-competitive effects and recital (306) to (325) of the provisional Regulation regarding the claim that the Union industry did not produce certain specific categories of HRF. As no substantive additional information for such allegations was provided after the provisional disclosure, the claims were rejected.

(270) In view of the above the Commission maintained that the overall benefits of the measures outweighed the potential negative impact for importers and users and therefore, the conclusions in recitals (296) to (325) of the provisional Regulation were confirmed.

(271) Ezz Steel and the GOE argued that the Commission had largely ignored a number of important considerations in the provisional Regulation when assessing whether it is in the Union interest to impose measures on Egypt.

(272) They argued in particular that:

(273) First, the Union enjoys a mutually beneficial trade relationship with Egypt. The trade balance between Egypt and the Union resulted in a surplus of USD 10,4 billion in favour of the Union in 2023. With respect to HRF, in particular, the volume of imports of HRF from Egypt to the Union represents only 1,25 % of the total Union captive and non-captive HRF consumption during the IP. In contrast, Egypt has opened its borders to Union imports of HRF, which represented between [9-14] % of Egyptian consumption between 2021 and 2023. Moreover, the imposition of measures would contradict the assistance provided by the Union to Egypt through short-term macro financial loans. The imposition of anti-dumping measures on Union imports of HRF, not only harm the national Egyptian steel industry and its international competitiveness, but also negatively impact the national economy as a whole in blatant contradictions with the objectives pursued by the macro-financial loans granted to Egypt by the Union.

(274) Second, Ezz Steel also argued that Egyptian export prices are the highest among all countries covered by the investigation; and that the Commission has found no evidence of price undercutting by Egypt.

(275) Third, Union suppliers rely extensively on the purchase of raw materials by Egyptian steel manufacturers. Furthermore, since its inception in 1994, Ezz Steel has invested a substantive amount in equipment from Union suppliers. Moreover, Ezz Steel argued that between 2019 and mid-2024, it imported a substantial amount worth of raw materials and spare parts from the Union.

(276) Fourth, the imposition of measures would not be in the interest of the Union industrial users, Ezz Steel producing a number of high-grade HRF which are in high demand by Union customers.

(277) Fifth, the imposition of measures would not allow Union users to benefit from the ‘clean’ steel produced by Egyptian steel manufacturers, to the detriment of the objectives of the Carbon Border Adjustment Mechanism (‘CBAM’) (32). The Commission should therefore consider the positive environmental impact of the steel produced by Ezz Steel when determining whether the imposition of anti-dumping measures on Egypt is in the Union interest.

(278) Concerning the first point regarding the allegations made by Ezz Steel on the negative impact on the national economy as a whole and the contradictions with the objectives pursued by the macro-financial loans granted to Egypt by the Union, the Commission considered that the adoption of anti-dumping measures could not affect the cooperation on trade and investment which are fundamental aspect of the EU-Egypt Strategic Partnership. The European Union will continue to support Egypt’s economic reform efforts, including improving the trade and business environment to facilitate Egypt’s sustainable economic growth, undistorted trade, and investment flows and green energy transition. Therefore, these claims were rejected.

(279) Concerning the second point, this allegation was found to be correct, however the average export prices were still significantly below the Union Industry average prices, and both were largely inferior to the average cost of production per tonne of the Union industry. This claim was therefore rejected.

(280) Concerning the third point and the allegations that Union suppliers rely extensively on the purchase of raw materials by Egyptian steel manufactures, the Commission noted that the scope of anti-dumping investigation does not specifically cover the economic situation of other Union related industries, whether supplying raw material and other consumables or production machines. Furthermore, none of these suppliers came forward during the investigation, therefore, these allegations could not be verified.

(281) The question raised in the fourth point was extensively addressed in Recital (307) of the provisional Regulation.

(282) Regarding the fifth point and the claim of Ezz Steel that the imposition of measures would not allow Union users to benefit from the ‘clean’ steel produced by Egyptian steel manufacturers. This would be detrimental for the objectives set by the CBAM. Firstly, the Commission recalled that CBAM entered into force on 1 October 2023, and it is currently in a transitional period until 2026 when the definitive regime will apply. Moreover, the scope of the present investigation was not to verify whether an exporting producer provides ‘clean’ steel, therefore, these allegations were not considered relevant for this proceeding and could not be verified. The claim was therefore dismissed.

(283) FHS claimed that while, users had raised specific, documented concerns about the real-world impact of duties, the Commission offered only qualitative assurances that alternative supply sources exist as mentioned in recital (315) of the provisional Regulation, without any rigorous modelling of market behaviour, supply-chain capacity, or price elasticity.

(284) The Commission rejected this argument on the ground that, first, these users had not put forward any concrete modelling of market behaviour, supply-chain capacity, or price elasticity by alternative supply sources, whilst the Union industry market behaviours was well known to these users, and second, as mentioned in recital (316) of the provisional Regulation, referring to industry specialised sources, the imposition of measures would not lead to a shortage of supply of the product concerned/like product.

(285) The international competitiveness of users was also well documented in recitals (317) to (320) of the provisional Regulation, showing that with a competitive market and the availability of spare capacity among Union producers, contrary to what was argued by the users, the activities of the companies processing flat metal products or involved in the resale of the product under investigation should remain competitive, despite the competitive market conditions on the EU market.

(286) Finally, FHS argued that the companies processing flat metal products, the Steel Service Centres (‘SSC’) which also included SSC related to primary steel makers would be more affected by the measures than the Union primary steel makers, with knock-on risks across multiple strategic sectors of the EU economy, such as the automotive, construction or ‘white’ goods sectors.

(287) In addition to the findings set out in recitals (312) to (325) of the provisional Regulation, it was noted that in a joint statement issued in April 2025 (33), both the complainant and the European steel distributors and processors association (Eurometal) claimed that the weakening of downstream steel ‘supply chain puts at risk 13,6 million direct jobs across steel processing, intermediate suppliers, and manufacturing sectors in the EU, and threatens a wider European deindustrialisation’. According to the complainant (34), the steel sector employs 306 000 people directly and is responsible for up to 2,5 million indirect jobs.

(288) Further to the point raised in recital (247), FHS argued after final disclosure that the existence of spare capacity could not be used simultaneously to demonstrate injury for the purposes of Article 3 of the basic Regulation and be used as an argument in the Union interest test under Article 21 of that Regulation. FHS referred to a WTO Appellate Body decision in US – Hot-Rolled Steel (35) whereby the Appellate Body required authorities to maintain a consistent framework of analysis across injury and causation. According to FHS, the Commission’s reliance on spare capacity as both a harm and a benefit was a clear breach of this principle and rendered its Union-interest conclusion legally unsound.

(289) The Commission disagreed with this claim. First, the WTO Appellate Body decision did not specifically address the issue at hand but rather recalled that ‘the investigating authorities must determine, objectively, and on the basis of positive evidence, the importance to be attached to each potentially relevant factor and the weight to be attached to it. In every investigation, this determination turns on the “bearing” that the relevant factors have “on the state of the [domestic] industry”’ (36). Second, there was no contradiction in considering the negative impact of dumped imports on the Union industry capacity utilisation on the one hand and the low level of capacity utilisation (63 % in the IP) on the other hand. The latter could certainly be seen as a positive element in the assessment of the Union Interest in case of imposition of duties, while not undermining the injury found. The claim was therefore rejected.

(290) After final disclosure, FHS argued that the above joint Eurometal-EUROFER statement could also be understood not only as a plea from the industry not simply to protect primary steel mills, but also to draw attention to the need to maintain cost-effective access to inputs for downstream manufacturers. FHS alleged that in ‘citing the quote out of context’, the Commission was obscuring ‘the real economic interdependence between upstream and downstream sectors’. The Commission recalled that as explained in recitals (178) and (312) of the provisional Regulation, several Union producers have related companies either trading or processing the like product. Hence, primary steelmakers and steel processors are in competition, not only between them, but also with third country imports of upstream and downstream steel products and therefore, they shared the same challenges and concerns caused by global overcapacity. The Commission considered that the quote explained exactly the situation, in which, all segments of the Union steel value chain, starting from the primary steel mills to the steel processors and traders until end users, all have an interest to benefit from fair conditions of competition. The argument was therefore rejected.

(291) Considering the above, the Commission confirmed the conclusions in recital (326) of the provisional Regulation that there were no compelling reasons to come to the conclusion that it was not in the Union interest to impose measures on imports of hot-rolled flat products originating in the countries concerned.

(292) In view of the conclusions reached with regard to dumping, injury, causation, level of measures and Union interest, and in accordance with Article 9(4) of the basic Regulation, definitive anti-dumping measures should be imposed in order to prevent further injury being caused to the Union industry by the dumped imports of the product concerned.

(294) The individual company anti-dumping duty rates specified in this Regulation were established on the basis of the findings of this investigation. Therefore, they reflect the situation found during this investigation in respect to these companies. These duty rates are thus exclusively applicable to imports of the product under investigation originating in the countries concerned and produced by the named legal entities.

(295) Imports of the product concerned manufactured by any other company not specifically mentioned in the operative part of this Regulation, including entities related to those specifically mentioned, cannot benefit from these rates and should be subject to the duty rate applicable to ‘all other imports originating in Egypt, Japan or Vietnam’.

(296) A company may request the application of these individual anti-dumping duty rates if it changes subsequently the name of its entity. The request must be addressed to the Commission (37). The request must contain all the relevant information enabling to demonstrate that the change does not affect the right of the company to benefit from the duty rate which applies to it. If the change of name of the company does not affect its right to benefit from the duty rate which applies to it, a Regulation about the change of name will be published in the Official Journal of the European Union.

(297) To minimise the risks of circumvention due to the difference in duty rates, special measures are needed to ensure the proper application of the individual anti-dumping duties. The application of individual anti-dumping duties is only applicable upon presentation of a valid commercial invoice to the customs authorities of the Member States. The invoice must conform to the requirements set out in Article 1(4) of this Regulation. Until such invoice is presented, imports should be subject to the anti-dumping duty applicable to ‘all other imports originating in Egypt, Japan or Vietnam’.

(298) While presentation of this invoice is necessary for the customs authorities of the Member States to apply the individual rates of anti-dumping duty to imports, it is not the only element to be taken into account by the customs authorities. Indeed, even if presented with an invoice meeting all the requirements set out in Article 1(4) of this Regulation, the customs authorities of Member States should carry out their usual checks and may, like in all other cases, require additional documents (shipping documents etc.) for the purpose of verifying the accuracy of the particulars contained in the declaration and ensure that the subsequent application of the rate of duty is justified, in compliance with customs law.

(299) Should the exports by one of the companies benefiting from lower individual duty rates increase significantly in volume, in particular after the imposition of the measures concerned, such an increase in volume could be considered as constituting in itself a change in the pattern of trade due to the imposition of measures within the meaning of Article 13(1) of the basic Regulation. In such circumstances, an anti-circumvention investigation may be initiated, provided that the conditions for doing so are met. This investigation may, inter alia, examine the need for the removal of individual duty rate(s) and the consequent imposition of a country-wide duty.

(300) To ensure a proper enforcement of the anti-dumping duties, the anti-dumping duty for all other imports originating in Egypt, Japan or Vietnam should apply not only to the non-cooperating exporting producers in this investigation, but also to the producers which did not have exports to the Union during the investigation period.

(301) Exporting producers that did not export the product concerned to the Union during the investigation period should be able to request the Commission to be made subject to the anti-dumping duty rate for cooperating companies not included in the sample. The Commission should grant such request provided that three conditions are met. The new exporting producer would have to demonstrate that: (i) it did not export the product concerned to the Union during the IP; (ii) it is not related to an exporting producer that did so; and (iii) has exported the product concerned thereafter or has entered into an irrevocable contractual obligation to do so in substantial quantities.

(302) In view of the dumping margins found and given the level of the injury caused to the Union industry, the amounts secured by way of provisional anti-dumping duties imposed by the provisional Regulation, should be definitively collected up to the levels established under the present Regulation.

(303) As mentioned in Section 1.2, the Commission made imports of the product under investigation subject to registration.

(304) As set out in recital (336) of the provisional Regulation, the Commission could not take a decision on a possible retroactive application of anti-dumping measures at that stage of the investigation. Therefore, the Commission has to decide, in line with Article 10(4) of the basic Regulation, whether definitive anti-dumping measures shall be retroactively collected on imports during the period of registration.

(305) During the definitive stage of the investigation, the data collected in the context of the registration was assessed. The Commission analysed whether the criteria under Article 10(4) of the basic Regulation were met for the retroactive collection of definitive duties.

(307) Therefore, it was considered that the conditions for collecting retroactively the duties were not met.

(308) In view of Article 109 of Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council (38), when an amount is to be reimbursed following a judgment of the Court of Justice of the European Union, the interest to be paid should be the rate applied by the European Central Bank to its principal refinancing operations, as published in the C series of the Official Journal of the European Union on the first calendar day of each month.

(309) The measures provided for in this Regulation are in accordance with the opinion of the Committee established by Article 15(1) of Regulation (EU) 2016/1036,

HAS ADOPTED THIS REGULATION:

Article 1

The following products are excluded:

(i) products of stainless steel and grain-oriented silicon electrical steel;

(ii) products of tool steel and high-speed steel;

(iii) products, not in coils, without patterns in relief, of a thickness exceeding 10 mm and of a width of 600 mm or more; and

(iv) products, not in coils, without patterns in relief, of a thickness of 4,75 mm or more but not exceeding 10 mm and of a width of 2 050 mm or more.

Article 2

The amounts secured by way of the provisional anti-dumping duty under Implementing Regulation (EU) 2025/670 imposing a provisional anti-dumping duty on imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Egypt, Japan and Vietnam shall be definitively collected. The amounts secured in excess of the definitive rates of the anti-dumping duty shall be released.

Article 3

Article 1 (2) may be amended to add new exporting producers from Egypt, Japan and Vietnam and make them subject to the appropriate weighted average anti-dumping duty rate for cooperating companies not included in the sample. A new exporting producer shall provide evidence that:

(a) it did not export the goods described in Article 1(1) during the period of investigation (1 April 2023 to 31 March 2024);

(b) it is not related to an exporter or producer subject to the measures imposed by this Regulation, and which could have cooperated in the original investigation; and

(c) it has either actually exported the product concerned or has entered into an irrevocable contractual obligation to export a significant quantity to the Union after the end of the period of investigation.

Article 4

Article 5

The anti-dumping proceeding concerning imports of the product mentioned in Article 1(1) originating in India is hereby terminated.

Article 6

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 25 September 2025.

For the Commission The President Ursula VON DER LEYEN

(1) OJ L 176, 30.6.2016, p. 21, ELI: http://data.europa.eu/eli/reg/2016/1036/oj.

(2) Notice of initiation of an anti-dumping proceeding concerning imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel, originating in Egypt, India, Japan and Vietnam (OJ C, C/2024/4995, 8.8.2024, ELI: http://data.europa.eu/eli/C/2024/4995/oj).

(3) Commission Implementing Regulation (EU) 2024/2719 of 24 October 2024 making imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel, originating in Egypt, India, Japan and Vietnam subject to registration (OJ L, 2024/2719, 25.10.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/2719/oj).

(4) Commission Implementing Regulation (EU) 2025/670 of 4 April 2025 imposing a provisional anti-dumping duty on imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Egypt, Japan and Vietnam (OJ L, 2025/670, 7.4.2025, ELI: http://data.europa.eu/eli/reg_impl/2025/670/oj).

(5) Relevant CN codes for tool steel: 7224 10 10 , 7224 90 02 , 7225 30 10 , 7225 40 12 , 7226 91 20 , 7228 30 20 , 7228 40 10 , 7228 50 20 and 7228 60 20 .

(6) Exhibit 1: Summary, page 1, ‘Review of EC dumping calculation’, Implement Consulting Group, 27 July 2025.

(7) Commission Implementing Regulation (EU) 2023/1444 of 11 July 2023 imposing a provisional anti-dumping duty on imports of steel bulb flats originating in the People’s Republic of China and Türkiye (OJ L 177, 12.7.2023, p. 63, ELI: http://data.europa.eu/eli/reg_impl/2023/1444/oj), recital 138.

(8) Commission Implementing Regulation (EU) 2023/265 of 9 February 2023 imposing a definitive anti-dumping duty on imports of ceramic tiles originating in India and Türkiye (OJ L 41, 10.2.2023, p. 1, ELI: http://data.europa.eu/eli/reg_impl/2023/265/oj), recitals 251-252.

(9) For instance Annex F-1-2-6 EFS Financial Statements IFRS 2023 (EN) page 14 where it is stated that ‘the period in which the functional currencies lacked exchangeability has been determined from March 1, 2023 until the end of the financial year and continued to the date of the Egyptian pound’s float in March 2024’.

(10) See Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs Code (OJ L 343, 29.12.2015, p. 558, ELI: http://data.europa.eu/eli/reg_impl/2015/2447/oj).

(11) This entity was declared by Nippon Steel as the reason for declaring MISI as a related entity by email on 16 September 2024.

(12) One of these entities was reported by Nippon Steel as the reason for determining Nippon Steel and SCGM as related entities by email on 16 September 2024. The other entity was mentioned in Nippon Steel’s submission after initiation.

(13) Case C-76/19, Direktor na Teritorialna direktsiya Yugozapadna Agentsiya ‘Mitnitsi’, formerly Nachalnik na Mitnitsa Aerogara Sofia v ‘Curtis Balkan’ EOOD, ECLI:EU:C:2020:543.

(14) This entity seems to have had the name NSM Coil Centre Co., Ltd. until 1 January 2025, but is currently called NST Coil Centre Co., Ltd. See for example page 20 of Nippon Steel Trading’s 2024 report, available at https://www.nst.nipponsteel.com/corporate/ir/integrated_report/pdf/integrated_report2024_digest_en_02.pdf.

For more details on the historical ownership situation, see here: https://www.nst.nipponsteel.com/en/news/assets/pdf/Optimization%20of%20the%20Domestic%20Coil%20Center.pdf, or the current situation here: https://www.nstcoil.co.jp/company/profile.html, which shows Nippon Steel, Nippon Steel Trading and SCGM as owners of NST (formerly NSM) Coil Centre.

(15) As explained by Nippon Steel, such kumiai would be an agreement officially establishing a limited liability partnership.

(16) See Commission Implementing Regulation (EU) 2024/2754 of 29 October 2024 imposing a definitive countervailing duty on imports of new battery electric vehicles designed for the transport of persons originating in the People’s Republic of China (OJ L, 2024/2754, 29.10.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/2754/oj).

(17) See, e.g. recitals 152 and 518 of Implementing Regulation (EU) 2024/2754.

(18) And as also reported as such by, for example, Moody’s Orbis database (https://orbis.bvdinfo.com).

(19) This entity requested and was granted anonymity throughout the investigation.

(20) On a product type basis, prices were lower for product types sold to both related and unrelated entities for 99 % of all quantities sold to the EU by Nippon Steel, 98 % of quantities sold on the domestic market by Nippon Steel, and 88 % of all quantities sold to the EU by MISI. They were lower for 51 % of all quantities sold to the EU by MISEA for product types sold to both related and unrelated entities. However, this included one specific product type which accounted for 50 % of the quantities sold where the price was higher to related entities than to unrelated, which was considered an outlier.

(21) Council Regulation (EC) No 2380/95 of 2 October 1995 imposing a definitive anti-dumping duty on imports of plain paper photocopiers originating in Japan (OJ L 244, 12.10.1995, p. 1, ELI: http://data.europa.eu/eli/reg/1995/2380/oj).

(22) Council Regulation (EC) No 428/2005 of 10 March 2005 imposing a definitive anti-dumping duty on imports of polyester staple fibres originating in the People’s Republic of China and Saudi Arabia, amending Regulation (EC) No 2852/2000 imposing a definitive anti-dumping duty on imports of polyester staple fibres originating in the Republic of Korea and terminating the anti-dumping proceeding in respect of such imports originating in Taiwan (OJ L 71, 17.3.2005, p. 1, ELI: http://data.europa.eu/eli/reg/2005/428/oj).

(23) Case C-260/20 P, Commission v Hansol Paper, ECLI:EU:C:2022:370.

(24) Commission Implementing Regulation (EU) 2019/159 of 31 January 2019 imposing definitive safeguard measures against imports of certain steel products (OJ L 31, 1.2.2019, p. 27, ELI: http://data.europa.eu/eli/reg_impl/2019/159/oj).

(25) Steel Sheet Market Outlook, Juillet 2024, © CRU International Limited confidential.

(26) Commission Implementing Regulation (EU) 2017/1795 of 5 October 2017 imposing a definitive anti-dumping duty on imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Brazil, Iran, Russia and Ukraine and terminating the investigation on imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Serbia (OJ L 258, 6.10.2017, p. 24, ELI: http://data.europa.eu/eli/reg_impl/2017/1795/oj).

(27) Implementing Regulation (EU) 2017/1795, recital (232).

(28) Commission Implementing Regulation (EU) 2023/1122 of 7 June 2023 imposing a definitive anti-dumping duty on imports of certain hot-rolled flat products of iron, non- alloy or other alloy steel originating in People’s Republic of China following an expiry review pursuant to Article 11(2) of Regulation (EU) 2016/1036 of the European Parliament and of the Council (OJ L 148, 8.6.2023, p. 45, ELI: http://data.europa.eu/eli/reg_impl/2023/1122/oj).

(29) 25 185 000 tonnes as reported by 21 EU producers in the previous expiry investigation regarding China.

(30) Commission Implementing Regulation (EU) 2024/1782 of 24 June 2024 amending Implementing Regulation (EU) 2019/159, including the prolongation of the safeguard measure on imports of certain steel products (OJ L, 2024/1782, 25.6.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/1782/oj).

(31) Council Regulation (EC) No 1420/2007 of 4 December 2007 imposing a definitive anti-dumping duty on imports of silico-manganese originating in the People’s Republic of China and Kazakhstan and terminating the proceeding on imports of silico-manganese originating in Ukraine. (OJ L 317, 5.12.2007, p. 5, ELI: http://data.europa.eu/eli/reg/2007/1420/oj).

(32) Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism (OJ L 130, 16.5.2023, p. 52, ELI: http://data.europa.eu/eli/reg/2023/956/oj).

(33) ‘Eurometal represents a significant portion of the intermediate steel processing market in Europe – comprising nearly 50 % of deliveries in the EU’. https://eurometal.net/eu-steelmakers-distributors-demand-whole-value-chain-support/.

(34) https://www.EUROFER.eu/assets/publications/brochures-booklets-and-factsheets/european-steel-in-figures-2023/FINAL_EUROFER_Steel-in-Figures_2023.pdf.

(35) WT/DS184/AB/R, paras. 196–197.

(36) Ibidem.

(37) Email: TRADE-TDI-NAME-CHANGE-REQUESTS@ec.europa.eu; European Commission, Directorate-General for Trade, Directorate G, Wetstraat 170 Rue de la Loi, 1040 Brussels, Belgium.

(38) Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on the financial rules applicable to the general budget of the Union (OJ L, 2024/2509, 26.9.2024, ELI: http://data.europa.eu/eli/reg/2024/2509/oj).