[SMM Hot Topic] Some Thoughts on Thailand's Initiation of Anti-Circumvention Investigation on Cold-Rolled Steel Coils from China

• Background

The Department of Foreign Trade (DFT) of Thailand announced the initiation of a circumvention investigation into cold-rolled steel sheet products (both in coil and non-coil forms, referred to as CRS and CRC) imported from China. This investigation was initiated in response to a complaint from the domestic producer, Thai Cold Rolled Steel Sheet Public Company Limited, which alleged that Chinese exporters were circumventing anti-dumping duties, thereby causing material injury to the domestic industry. The Chinese exporters accused of circumventing anti-dumping measures include Baoshan Iron & Steel Co., Ltd., Baogang Group, and Ma'anshan Group. The products under investigation fall under Thailand's customs tariff code 7225.50.90.090.

• The export trend of the involved varieties to Thailand aligns with the overall domestic export value trend, with an 11.52% MoM increase in the 2025 monthly average.

Figure 1 - Total Export Volume and YoY Growth of the Involved Varieties from China (January 2022 to May 2025, in 10,000 mt)

According to data from the General Administration of Customs, since 2022, the export volume of the involved products from China has shown a year-on-year increase. By 2024, the annual export volume of the involved products reached 452,600 mt. As of May this year, the export volume was 173,100 mt, down 17.31% YoY (with 204,700 mt exported in the same period of 2024), and the monthly average was 34,600 mt.

Figure 2 - Total Export Volume and YoY Growth of the Involved Varieties from China to Thailand (January 2022 to May 2025, in 10,000 mt)

The total volume of cold-rolled steel exported from China to Thailand initially increased and then decreased, rising from 33,000 mt/year in 2022 to 45,700 mt/year in 2023, and then declining to 41,600 mt/year in 2024. Based on data from the first five months of this year, China exported a total of 16,300 mt of HRC to Thailand, up approximately 11.52% YoY (with 14,600 mt exported in the same period of 2024). However, in absolute terms, the monthly average for the first four months was 3,300 mt, accounting for 9.39% of the domestic monthly average export volume of cold-rolled steel sheet.

• The proportion of the involved products exported from China to Thailand is as high as 9.39%, but the absolute value is relatively small.

Table 1 - Proportion of the Total Export Volume of the Involved Varieties to Thailand in China's Total Export Volume (January 2022 to May 2025)

In terms of the proportion of the total export volume of the involved varieties to Thailand in China's total export volume, the overall ratio fluctuates between 9% and 12%, representing a significant share. In 2025, the trend of the total export volume of the involved varieties to Thailand aligns with the trend of the total export volume of the involved varieties.

Overall, although this is the first time Thailand has initiated an anti-circumvention investigation against cold-rolled steel from China, in reality, an anti-dumping investigation against cold-rolled steel products from China was initiated as early as August 2012. Subsequently, a final ruling on a sunset review was conducted, and on January 23, 2025, another sunset review case was filed. From a timeline perspective, a final review ruling may be made in early 2026. Considering that the anti-dumping investigation has been ongoing for many years and involves a wider range of product categories, the actual impact of anti-dumping measures on the involved product categories has already been reflected in previous years.

However, due to claims by Thai domestic producers, such as Thai Cold Rolled Steel Sheet Public Company Limited, that Chinese exporters are evading anti-dumping duties, Thailand has once again initiated an anti-circumvention investigation against China. According to data from the General Administration of Customs, the total volume of the involved product categories exported from China to Thailand in the first five months of 2025 was 16,300 mt, accounting for 9.39% of China's total exports of the involved product categories, indicating a relatively significant overall impact. In extreme cases, this may lead to a decrease of 81,500 mt in China's total exports in 2026.

Data shows that the top five countries in terms of China's exports of the involved product categories are Colombia, Indonesia, Brazil, Thailand, and Oman. Thailand ranks high, but compared to the large base volume of China's steel exports, this figure may be considered insignificant for now, only affecting domestic export product categories and potentially further impeding the export channels of cold-rolled products to Thailand.

SMM will keep real-time track of the progress and impact of overseas anti-dumping investigations on steel products. Stay tuned for relevant reports. For more information, follow SMM's official account~