China — State Council Tariff Commission 2022 Tariff Adjustment Plan (税委会〔2021〕18号): ferrochrome export tariff doubled to 40%, ferrosilicon held at 25%

Mechanism

This is China's routine annual tariff-schedule instrument, issued each December by the State Council Tariff Commission and implemented by Customs/MOF from 1 January of the following year — the same instrument type as the 2023 edition already in the register (2022-12-28-china-2023-tariff-adjustment-plan-aluminum-export-tax). The 2022 edition's restrictive component sits in the ferroalloy export schedule:

Ferrochrome (铬铁, HS 72024100 / 72024900). A provisional export tariff of 15% had been raised to 20% on 1 May 2021. The 2022 plan cancels that 20% provisional preferential rate outright, so the standard 40% statutory export rate applies from 1 January 2022 — a doubling of the effective rate exporters face, per MOFCOM-affiliated trade-policy commentary (CACS) analysing the schedule.

Ferrosilicon (硅铁, HS 72022100 / 72022900). No new change in this plan: the products continue at the 25% rate they moved to when their own preferential rate was cancelled in May 2021 — carried over, not newly tightened.

Silicomanganese / ferromanganese. Trade-press aggregation (ferro-alloys.com) states a 20% 2022 export rate for this category alongside the ferrochrome and ferrosilicon figures, but the primary notice and the MOFCOM-affiliated commentary retrieved during filing do not independently confirm a rate or a year-over-year change for it — left out of target_materials/magnitude rather than filed on a single secondary source.

Severity basis

Severity is set at 3, one step above the near-identical 2023 aluminum precedent (severity 2), because the confirmed change here is a doubling of the effective export rate on ferrochrome (20% → 40%) via outright cancellation of a preferential rate, not an incremental percentage-point increase — anchoring severity_basis: quant on the 40% resulting rate. It is not rated higher because the ferrosilicon leg of the same schedule is a carryover, not a fresh restriction, and the whole action remains one line item within a large, mostly-routine annual tariff-schedule instrument rather than a standalone export ban or licensing regime.

Downstream implications

• Ferrochrome exporters lose the preferential provisional rate

entirely and face the full 40% statutory export tariff from 1 January 2022, raising the cost of Chinese-origin ferrochrome to external buyers and reinforcing the incentive to consume it domestically in stainless-steel production.

• Ferrosilicon trade flow is unchanged by this specific plan — the

restrictive step for that product already happened in May 2021; 2022 simply continues it.

• Part of a broader 2021-2022 pattern of China raising or holding high

export tariffs on primary ferroalloys (see also the 2023 aluminum export-tariff action in this register) to push value-add domestically rather than export raw/semi-processed metal inputs.

Open questions

• Whether the silicomanganese/ferromanganese rate reported by trade

press (20%) is accurate and whether it changed from 2021 to 2022 — not independently confirmed from a primary or MOFCOM-affiliated source during filing.

• Global trade volume/value of Chinese ferrochrome exports affected by

the rate reversion was not retrieved during filing.