[SMM Analysis] Reflections on Thailand's Initiation of Anti-Circumvention Investigations Against Hot-Dip Galvanizing Cold-Rolled Steel Coils and Non-Coiled Materials from China

• Timeline

✔ October 27, 2025 – Initiation of Anti-Circumvention Investigation
The Department of Foreign Trade of Thailand’s Ministry of Commerce announced the initiation of an anti-circumvention investigation in response to an application filed by a domestic Thai enterprise concerning the anti-dumping case on hot-dip galvanized cold-rolled steel sheet and coil originating from China. The investigation will examine whether the subject products are being exported to Thailand through minor modifications to circumvent the existing anti-dumping measures. The products under investigation are hot-dip galvanized aluminum-magnesium alloy cold-rolled steel sheet and coil. The case involves products under the following Thai HS codes: 7210.49.14.081, 7210.49.14.082, 7210.49.14.083, 7210.49.14.090, 7210.49.15.081, 7210.49.15.090, 7210.49.16.081, 7210.49.16.090, 7210.49.91.000, 7210.49.99.000, 7212.30.11.081, 7212.30.11.090, 7212.30.12.081, 7212.30.12.090, 7212.30.13.081, 7212.30.13.090, 7212.30.19.051, 7212.30.19.090, 7212.30.90.000, 7225.92.20.081, 7225.92.20.082, 7225.92.20.083, 7225.92.20.084, 7225.92.20.085, 7225.92.20.090, 7226.99.11.030, 7226.99.11.090, 7226.99.91.030, and 7226.99.91.090.

Table 1 – Ten Relevant Chinese Producers

Thailand previously imposed anti-dumping duties ranging from 0% to 37.54% on hot-dip galvanized cold-rolled steel sheet and coil from China. The current investigation examines whether the products are being exported to Thailand through minor modifications to circumvent the existing anti-dumping measures.

✔ September 6, 2021 – Final Determination in the Original Investigation
Thailand’s Committee on Dumping and Subsidy Investigations issued an announcement affirming the final affirmative determination in the anti-dumping investigation on hot-dip galvanized cold-rolled steel sheet and coil originating from China. The decision imposed anti-dumping duties based on CIF (cost, insurance, and freight) value, with rates ranging from 0% to 37.54%, effective for five years. The announcement took effect the day after its publication in the Government Gazette. The Thai HS codes for the subject products were 7210.4912.021, 7210.4912.022, 7210.4912.023, 7210.4912.024, 7210.4912.031, 7210.4912.032, 7210.4912.033, 7210.4912.034, 7210.4912.090, 7210.4913.021, 7210.4913.031, 7210.4913.090, 7210.4919.021, 7210.4919.031, 7210.4919.090, 7210.4991.000, 7210.4999.000, 7212.3011.021, 7212.3011.031, 7212.3011.090, 7212.3012.021, 7212.3012.031, 7212.3012.090, 7212.3013.011, 7212.3013.090, 7212.3019.011, 7212.3019.090, and 7225.9290.090.

Table 2 – Thailand’s Final Anti-Dumping Duty Rates on Hot-Dip Galvanized Cold-Rolled Steel Sheet and Coil from China

✔ August 3, 2020 – Preliminary Determination in the Original Investigation
Thailand’s Ministry of Commerce announced the preliminary determination in the anti-dumping investigation on hot-dip galvanized cold-rolled steel sheet and coil originating from China, deciding to impose a provisional anti-dumping duty of 35.67% on the subject products based on CIF value.

✔ February 21, 2020 – Initiation of the Original Investigation
Thailand initiated an anti-dumping investigation on hot-dip galvanized cold-rolled steel sheet and coil originating from China.

The HS codes involved in this anti-circumvention case are not entirely consistent with those in the final determination of the earlier anti-dumping case. Except for 72104991000, 72104999000, 72123011090, 72123012090, 72123013090, and 72123019090, all other HS codes are newly added. Under the impact of previous anti-dumping measures,

• China's exports of the involved products to Thailand accounted for less than 4%.

Figure 1- Total Export Volume of China's Involved Products and YoY Change (10kt), 2021-September 2025

According to data from the General Administration of Customs, since 2021, the export volume of the involved products from China has shown a year-on-year growth trend. In 2024, the annual export volume of the involved products increased sharply, up 125.03% YoY, reaching 3.8007 million mt. From January to September this year, exports reached 3.3945 million mt, up 20.34% YoY (exports in the same period of 2024 were 2.8209 million mt), with a monthly average of 377,200 mt.

Figure 2- Total Volume of China's Involved Products Exported to Thailand and YoY Change (10kt), 2021-September 2025

China's total exports of the involved products to Thailand decreased in 2022, with a YoY decline of 46.17%, and the total export volume was only 15,600 mt. This was mainly due to Thailand's final ruling on anti-dumping against related products, imposing a maximum anti-dumping duty of 37.45%. Based on data from the first nine months of this year, China exported 133,100 mt of the involved products to Thailand, up about 3.90% YoY (exports in the same period of 2024 were 128,100 mt). In absolute terms, the monthly average for the first nine months was 14,800 mt, accounting for 3.92% of the monthly average export volume of China's involved products.

• Although the proportion of China's involved products exported to Thailand is relatively small, the export inclination remains significant.

Table 3- Ratio of Total Volume of Involved Products Exported to Thailand to China's Total Exports, 2020-September 2025

Regarding the ratio of the total volume of involved products exported to Thailand to China's total exports, the overall impact of anti-dumping measures is significant. Before the final anti-dumping ruling, this ratio was as high as 18.89%, with an absolute value also exceeding 1 million mt. After the final anti-dumping ruling was confirmed, both the ratio and the absolute export volume dropped sharply. It was not until 2024 that the total export volume and the ratio rebounded, but they still remain at relatively low levels.

Overall, although this is the first time Thailand has initiated an anti-circumvention investigation against China's hot-dip galvanized cold-rolled coil, in fact, as early as February 2020, Thailand launched an anti-dumping investigation against the involved products from China. On September 6, 2021, it confirmed the imposition of anti-dumping duties ranging from 0% to 37.54% on the involved products from China. 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 this involved product has already been reflected in previous years.

This time, Thailand initiated an anti-circumvention investigation against the involved products from China. According to data from the General Administration of Customs, the total volume of China's involved products exported to Thailand in the first nine months of 2025 was 153,400 mt, accounting for 3.92% of China's total exports of the involved products, indicating a relatively limited overall impact. In an extreme scenario, this could lead to a decrease of 153,400 mt in China's total exports in 2026.

Data show that the top five countries for China's exports of the involved products in 2025 were the Philippines (25.35%), Indonesia (7.34%), Brazil (5.59%), Vietnam (5.21%), and Thailand (3.92%). In 2020, the top five countries were Thailand (18.89%), South Korea (7.34%), the Philippines (5.59%), Vietnam (5.21%), and Myanmar (3.92%). It is evident that while Thailand has increased anti-dumping and anti-circumvention investigations against China's involved products, domestic export traders are actively seeking new export destinations to hedge against the pressure. However, currently, China's exports of the involved products to the Philippines account for 25.35%, which is excessively high and requires vigilance against potential investigations by the Philippines on China's involved products.

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

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