[SMM Anti-Dumping Analysis] Some Thoughts on Thailand's Initiation of Anti-Circumvention Investigation on High-Carbon Wire Rods from China

• Timeline
  August 5, 2025
  Thailand has officially initiated an anti-circumvention investigation on high-carbon wire rod products originating from China. The products under investigation are hot-rolled high-carbon wire rods with a circular cross-sectional diameter of less than 14 millimeters and a carbon content (by weight) ranging from 0.66% to 0.76%. Three specific Chinese enterprises are involved: Jiangsu Yonggang Group Co., Ltd., Jiangsu Shagang Group Co., Ltd., and Zenith Steel Group Co., Ltd. The HS codes for the products under investigation include: 7227.9010.042, 7227.9010.049, 7227.9010.090, 7227.9090.040, 7227.9090.041, 7227.4090.043, 7227.4090.044, 7227.9090.045, 7227.9090.046, 7227.9090.049, and 7227.9090.090.
  The investigation stems from allegations that importers are circumventing the existing anti-dumping duties by importing wire rod products with slightly lower carbon content. Currently, Thailand imposes anti-dumping duties ranging from 12.26% to 36.79% on high-carbon wire rods with a carbon content of 0.76%-0.92%. The products under investigation are suspected of evading these duties by adjusting their carbon content.
  May 15, 2025
  The Department of Foreign Trade, Ministry of Commerce of Thailand, announced that, in response to applications from domestic enterprises, Thailand has initiated a second sunset review investigation on high-carbon wire rods originating from China. During the investigation period, anti-dumping duties on the products under investigation will be collected in the form of deposits, effective from May 16, 2025, with a validity period not exceeding one year. The announcement takes effect from the date of its issuance.
  May 15, 2020
  Thailand issued its final ruling on the first sunset review of this case, deciding to continue imposing anti-dumping duties on the Chinese products under investigation based on the Cost, Insurance, and Freight (CIF) price. The measures were terminated on May 15, 2025.

Table 1 - Enterprises Involved and Anti-Dumping Duties

• May 15, 2019
  Thailand initiated its first sunset review investigation on high-carbon wire rods originating from China.
  November 29, 2012 - October 17, 2014
  Thailand initiated an anti-dumping investigation on high-carbon wire rods originating from China, and issued preliminary and final anti-dumping rulings, imposing anti-dumping duties ranging from 5.17% to 33.98% CIF on the Chinese products under investigation.

• The Export Volume Trend of the Products Under Investigation to Thailand Aligns with the Total Export Value Trend in China, with the Monthly Average Value Increasing Again in 2025

Figure 1 - Total Export Volume and YoY Growth of the Products Under Investigation from China from January 2021 to June 2025 (10,000 mt)

According to data from the General Administration of Customs, since 2021, the export volume of the products under investigation from China has shown a year-on-year increase. In 2023, the annual export volume of the products under investigation increased significantly YoY, reaching 243.77%, with a total volume of 1.0961 million mt. As of June this year, the export volume was 869,100 mt, up 33.98% YoY (the export volume in the same period of 2024 was 648,700 mt), with a monthly average of 144,800 mt.

Figure 2 - Total Export Volume and YoY Growth of the Products Under Investigation from China to Thailand from January 2021 to June 2025 (10,000 mt)

The total export volume of the products under investigation from China to Thailand has increased year by year since 2021, with a significant increase in the growth rate also occurring in 2023, exceeding 900% YoY, reaching 337,100 mt. Based on the data for the first six months of this year, China exported a total of 371,600 mt of the products under investigation to Thailand, up approximately 53.17% YoY (the export volume in the same period of 2024 was 242,600 mt). From an absolute value perspective, the monthly average for the first six months was 61,900 mt, accounting for 42.75% of the monthly average export volume of domestic products under investigation.

• The Proportion of China's Export Volume of the Products Under Investigation to Thailand Has Increased Year by Year, with the Risk Not to Be Underestimated

Table 2 - Proportion of Total Export Volume of the Products Under Investigation to Thailand in China's Total Export Volume from January 2021 to June 2025

Based on the data of the total export volume of the products under investigation to Thailand as a proportion of China's total export volume, the overall proportion has shown a year-by-year increase. By the first six months of 2025, this proportion had reached 42.75%.
In summary, although this is the first time Thailand has initiated an anti-circumvention investigation on high-carbon wire rods from China, it actually initiated an anti-dumping investigation on the Chinese products under investigation as early as November 2012, followed by a final ruling on a sunset review, and filed another sunset review case on May 15, 2025. Based on the timeline, a final ruling on the sunset review may be issued in mid-2026. Considering that anti-dumping measures have been in place for many years and cover a wider range of products, the actual impact of anti-dumping on the products under investigation has already been reflected in previous years.
However, due to allegations that importers are circumventing the existing anti-dumping duties by importing wire rod products with slightly lower carbon content, an anti-circumvention investigation has been initiated on the Chinese products under investigation. According to data from the General Administration of Customs, the total export volume of the products under investigation from China to Thailand in the first six months of 2025 was 371,600 mt, accounting for 42.75% of China's total export volume of the products under investigation, with an overall significant impact. In extreme cases, this may lead to a decrease of 371,600 mt in China's total export volume in 2026.
Data shows that the top five countries in terms of export volume of the products under investigation from China are Thailand, Vietnam, South Korea, Malaysia, and Indonesia. Thailand ranks first. Meanwhile, in the ranking of changes in the total export destinations of China's steel products from January to June 2025, Thailand also ranks second in terms of incremental volume. Thailand has already imposed relevant anti-dumping duties on most of China's steel products and initiated an anti-circumvention investigation on China's cold-rolled steel plate products in July 2025, which will further increase the difficulty of exporting domestic steel products to Thailand.

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