[SMM hot topic] Some Thoughts on Brazil's Initiation of Anti-dumping Investigation against HRC from China

• Background

The Ministry of Commerce announced that the Secretariat for Foreign Trade of Brazil issued Notice No. 39 of 2025 in the official gazette on June 3, deciding to initiate an anti-dumping investigation into hot-rolled coil (HRC) imports from China (Portuguese: Laminados a quente) in response to applications from three companies: ArcelorMittal Brasil S.A., Gerdau Açominas S.A., and Usinas Siderúrgicas de Minas Gerais S.A. The NCM codes of the products under investigation are 72081000, 72082500, 72082610, 72082690, 72082710, 72082790, 72083610, 72083690, 72083700, 72083810, 72083890, 72083910, 72083990, 72084000, 72085300, 72085400, 72089000, 72111300, 72111400, 72111900, 72119010, 72119090, 72253000, 72254090, and 72269100. The dumping investigation period for this case is from July 2023 to June 2024, and the injury analysis period is from July 2019 to June 2024.

• HRC Exports to Brazil Surge YoY in 2025, But Monthly Average Remains Below 60,000 mt

Figure 1 - Total Export Volume and YoY Comparison of China's Products Under Investigation from 2022 to April 2025

According to data from the General Administration of Customs, the export volume of the products under investigation in China has shown a year-on-year increase since 2022, with exponential growth in 2023. By 2024, the annual export volume of the products under investigation reached 25.1053 million mt. As of April this year, the export volume has already reached 7.8073 million mt, representing a YoY increase of 16.77% (the export volume in the same period of 2024 was 6.6862 million mt), with a monthly average of 1.9518 million mt.

Figure 2 - Total Export Volume and YoY Comparison of China's Products Under Investigation to Brazil from 2022 to April 2025

The total volume of HRC exported from China to Brazil has also grown rapidly in recent years, increasing from 100,000 mt/year in 2022 to 600,000 mt/year in 2024, a sixfold increase. Based on data from the first four months of this year, China exported a total of 211,000 mt of HRC to Brazil, representing a YoY increase of approximately 130.02% (the export volume in the same period of 2023 was 91,700 mt). However, in absolute terms, the monthly average for the first four months is still less than 60,000 mt, which is significantly different from the monthly average export volume of domestic HRC.

• China's Share of HRC Exports to Brazil Accounts for Less Than 3%, with Negligible Impact from Anti-Dumping

Table 1 - Ratio of Total Export Volume of Products Under Investigation to Brazil to China's Total Export Volume from 2022 to April 2025

In terms of the total export volume of the products under investigation to Brazil as a proportion of China's total export volume, the overall ratio fluctuates between 1% and 3%. In 2022, this ratio was only about 1%, indicating minimal effective impact. In 2025, the total export volume of the products under investigation to Brazil has decreased month by month, while the total export volume of the products under investigation has increased month by month, indicating that China is increasing the proportion of exports of the products under investigation to other countries.

Overall, according to data from the General Administration of Customs, the total export volume of HRC from China to Brazil in the first four months of 2025 was only 211,000 mt, accounting for 2.70% of China's total HRC exports, with limited overall impact. Data from 2025 shows that the top five countries for China's HRC exports are Vietnam, Pakistan, Saudi Arabia, South Korea, and the UAE. Among them, Vietnam and South Korea have initiated anti-dumping investigations into China's HRC. Vietnam has already imposed provisional anti-dumping measures, and there have even been recent rumors that wide coils, which were previously excluded from the anti-dumping scope, may be added to the anti-dumping list again. On March 4 this year, South Korea officially announced the initiation of an anti-dumping investigation into China's HRC coils. Currently, China's HRC, the largest exported steel product, is facing an increasing number of anti-dumping investigations. Perhaps for export traders, exploring ways to increase the export volume of products that are not yet subject to anti-dumping measures could be a wise strategy.

SMM will track the progress and impact of overseas anti-dumping investigations into steel products in real time. Please stay tuned for relevant reports. For more information, follow SMM's official account.