The Türkiye Ministry of Trade's Imports General Directorate published Communiqué No. 2025/44 in Resmî Gazete on 27 December 2025, imposing a definitive flat-rate 3.95% ad valorem anti-dumping duty on imports of cold-rolled stainless flat steel (CRSS) originating in the People's Republic of China, covering 22 customs-tariff positions under HS headings 7219 and 7220. The duty runs for five years from the date of publication (sunset 27 December 2030). The parallel investigation track into Indonesian-origin CRSS was closed without measures — imports from Indonesia were determined to be at a negligible dumping margin and caused no material injury to the domestic industry. The investigation (initiated as Notice 2024/20, June 2024) was petitioned by the Turkish stainless-steel producer consortium (Posco Assan Stainless TST, Sandvik Karbosan, and ÇağdaşÇelik).

Analyst notesShow

Mechanism

Türkiye's trade-remedy framework operates under Law No. 3577 on the Prevention of Unfair Competition in Imports (1989, as amended) and implementing Council of Ministers Decrees No. 99/13482 and 99/13483. The Imports General Directorate (İthalat Genel Müdürlüğü) under the Ministry of Trade conducts investigations and publishes determinations via Tebliğ instruments in Resmî Gazete.

The CRSS investigation (Notice 2024/20, initiated June 2024) was petitioned by the Turkish stainless-steel producer consortium — Posco Assan Stainless TST (the main domestic manufacturer, majority-owned by POSCO), Sandvik Karbosan (Sandvik Group's Turkish stainless operations), and ÇağdaşÇelik — on grounds of material dumping from China across AISI 304, 316, 430, and 409 grades in both wide (≥600 mm, HS 7219) and narrow (<600 mm, HS 7220) flat-rolled forms. The investigation covered a reference period of 1 January 2021 to 31 December 2023. Chinese imports held a 35.6% share of Turkish CRSS imports in 2021, rising to 57.1% in 2022 and 50.1% in 2023.

The 13 December 2025 Final Disclosure established individual dumping margins ranging from 3.95% to 18% across cooperating Chinese exporters, with a non-cooperation residual above that range. In a notable methodology decision, the 27 December 2025 Communiqué No. 2025/44 imposed a single flat 3.95% rate applicable to all Chinese exporters — the floor of the individual-exporter margin range — rather than the variable company-specific duties disclosed on 13 December. This flat-rate approach simplifies customs administration and eliminates the "all-others" punitive residual structure seen in the parallel 2024/33 HRC determination, but it also materially reduces the in-terrorem effect against non-cooperating producers.

The Indonesian track was closed without measures. Imports from Indonesia were determined to be below the de minimis dumping threshold and to cause no material injury to the domestic industry — a finding of methodological significance given that Indonesia's stainless-steel sector is dominated by Chinese-controlled integrated nickel-stainless complexes (Tsingshan / IMIP / Morowali), suggesting Türkiye applied a strict country-of-origin substantial-transformation test rather than a country-of-controlling-investor test.

Downstream implications

Steel-trade-remedy architecture completion. Communiqué 2025/44 is the

second major Turkish flat-steel AD determination in the 2024–2025 wave (after 2024/33 HRC). Together they form the integrated Turkish flat-steel trade-remedy stack: HRC (carbon, multi-country) + CRSS (stainless, China-only). This moves Türkiye toward the EU/US posture of using formal trade-defence instruments alongside autonomous tariff measures (Decree 8639, Import Regime 10790).

Stainless-steel-using sectors. The 3.95% incremental duty affects

downstream sectors consuming CRSS in Türkiye: kitchen appliances, food- processing equipment, chemical reactors, architectural cladding, and automotive exhaust systems. At 3.95% the pass-through to fabrication costs is modest but the signalling effect on Chinese supplier pricing behaviour is more significant.

Indonesian zero-margin precedent. The termination of the Indonesian track

without measures despite Chinese-majority-controlled production capacity at IMIP / Morowali is a major methodological data-point for EU circumvention investigations (particularly in the context of EU CBAM + EU steel safeguard circumvention-investigation proceedings) and for comparable investigations in India, Brazil, and the US targeting Chinese-controlled Indonesian stainless output.

Chinese exporter positioning. TISCO / Shanxi Taigang, Baosteel Stainless,

and Beihai Chengde now face a permanent 3.95% duty on Türkiye-bound CRSS. At the current margin level this is unlikely to materially redirect Chinese stainless-export flows but may marginally enhance the competitive position of European producers (Outokumpu, Acerinox, Aperam) and Indian producers (Jindal Stainless) in the Turkish market.