Egypt Ministerial Decision No. 399/2025 — Temporary Safeguard on Semi-Finished Steel Billet Imports

Mechanism

Decision No. 399 is the billet-specific leg of Egypt's September 2025 flat/semi-finished steel safeguard trilogy, issued the same day as companion Decisions 398 (cold-rolled/galvanised) and 400 (hot-rolled coil) — see [2025-09-11-egypt-ministerial-decision-400-hrc-safeguard](2025-09-11-egypt-ministerial-decision-400-hrc-safeguard.md). It applies to semi-finished products of iron or non-alloy steel under HS 7207 — the upstream input billets that feed downstream rolling into rebar, wire rod, and flat products. The Trade Remedies Sector's investigation was initiated and the provisional measure notified to the WTO Committee on Safeguards on 10 September 2025 (G/SG/N/6/EGY/18 provisional-measure notification; G/SG/N/7/EGY/14 investigation-initiation notification; G/SG/N/11/EGY/14 serious-injury finding notification), formalised domestically the next day as Ministerial Decision 399/2025.

The duty structure mirrors its HRC sibling: a 16.2% ad-valorem rate on CIF value, with a minimum specific-duty floor of EGP 4,613 per metric ton that applies whenever the ad-valorem calculation would fall below it — again designed to close the invoice-undervaluation gap that a pure percentage-rate safeguard leaves open. As an MFN (all-source) safeguard under WTO Safeguards Agreement Article 2, the duty applies to all WTO Members' billet exports to Egypt except those qualifying for the Article 9.1 developing-country de minimis carve-out.

Billets sit upstream of the other two decisions' product scope, so the trilogy collectively protects Egypt's domestic steel value chain from semi-finished input through finished flat-rolled output — insulating the same five-producer domestic consortium (Egyptian Iron and Steel, Ezz Steel, Suez Steel, Beshay Steel, Egyptian Steel) that petitioned for the HRC and CRC/galvanised measures.

Downstream implications

• Billet-exporting mills into Egypt — chiefly Turkish (Erdemir/İskenderun basin), Ukrainian, Libyan,

and Black Sea (Russian) suppliers — face a 16.2%/EGP 4,613-per-ton cost uplift, on top of the parallel HRC and CRC/galvanised duties under Decisions 400 and 398.

• Because billets are the upstream input to rebar and wire-rod rolling, the duty raises input costs

for Egyptian re-rollers that import billet rather than melt-scrap domestically, creating a potential wedge between vertically-integrated producers (who benefit from the safeguard) and independent downstream rolling mills (who face higher input costs).

• Confirms the trilogy structure flagged in the HRC action's open questions: Decision 399 is the

billet leg referenced there, filed here as its own action per the register's per-instrument filing convention.

• The April 2026 final-determination cycle covering Decisions 398/399/400 (see HRC action's

amendments block) should be checked for whether it also extends 399 specifically to a three-year definitive measure with the same 16.2%/EGP 4,613 parameters.

Open questions

• Did the April 2026 final determination retain the 16.2% / EGP 4,613 rate structure for billets,

or was it adjusted separately from the HRC leg?

• What share of Egypt's billet imports by volume/value is Turkish vs. Black Sea/CIS-origin, and

which suppliers are most exposed to the de minimis carve-out threshold?

• Will independent (non-integrated) Egyptian re-rolling mills seek a downstream-user exemption given

the input-cost pass-through risk?