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

• (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.

• (263) As described in recital (261), the Commission revised the injury margins. Therefore, the final injury elimination level for the cooperating exporting producers and all other companies is as follows:

6.2.   Examination of the margin adequate to remove the injury to the Union industry

• (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.

6.3.   Conclusion on the level of measures

• (265) Following the above assessment, definitive anti-dumping duties should be set as below in accordance with Article 7(2) of the basic Regulation:

7. UNION INTEREST

• (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.

7.1.   Interest of the Union industry

• (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.

7.2.   Interest of unrelated importers and users

• (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.

7.3.   Other arguments

• (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.

7.4.   Conclusion on Union interest

• (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.

8. DEFINITIVE ANTI-DUMPING MEASURES

8.1.   Definitive measures

• (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.

• (293) On the basis of the above, the definitive anti-dumping duty rates, expressed on the CIF Union border price, customs duty unpaid, should be as follows:

• (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.

8.2.   Definitive collection of the provisional duties

• (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.

8.3.   Retroactive collection

• (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.

• (306) The Commission’s analysis showed no further substantial rise in imports in addition to the level of imports which caused injury during the investigation period, as prescribed by Article 10(4)(d) of the basic Regulation. For this analysis, the Commission compared the monthly average import volumes of the product concerned during the investigation period (column 2) with the monthly average import volumes during the period from the month following the initiation of this investigation until the last full month preceding the imposition of provisional measures (column 3). Also, when comparing the monthly average import volumes of the product concerned during the investigation period with the monthly average import volumes during the period from the month following the initiation of this investigation up to and including the month in which provisional measures were imposed (column 4), no further substantial increase could be observed, rather the contrary, imports decreased significantly:

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

9. FINAL PROVISION

• (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

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.

ELI: http://data.europa.eu/eli/reg_impl/2025/1919/oj

ISSN 1977-0677 (electronic edition)