Brazil's Foreign Trade Chamber Executive Committee (GECEX/CAMEX) adopted Resolução GECEX nº 854 on 12 February 2026, imposing a five-year definitive antidumping duty on cold-rolled flat carbon steel products originating from China, covering 14 NCM tariff headings under subheadings 7209.xx, 7211.xx, 7225.50.90, and 7226.92.00. The duty is collected as a specific tariff fixed in US dollars per metric tonne, following a Usiminas petition of 23 April 2024 alleging material injury to the domestic flat-steel industry from Chinese dumping. The measure was published in the Diário Oficial da União on 13 February 2026 (Edição 31, Seção 1, Pág. 5) and republished on 18 February 2026 (Edição 32) to correct errors in the Article 1 tariff table.

Analyst notesShow

Mechanism

Resolução GECEX nº 854, adopted at the GECEX extraordinary meeting of 12 February 2026, imposes a definitive antidumping duty for up to five years on cold-rolled flat carbon steel products — whether or not alloyed, in sheets or coils of any width or thickness — originating from China. The duty is collected as a specific tariff fixed in US dollars per metric tonne, structured around a multi-rate table in Article 1 covering 14 NCM tariff codes across two product families:

NCM 7209.xx / 7211.xx (standard cold-rolled flat): Subheadings 7209.15.00, 7209.16.00, 7209.17.00, 7209.18.00, 7209.25.00, 7209.26.00, 7209.27.00, 7209.28.00, 7209.90.00, 7211.23.00, 7211.29.10, 7211.29.20 — includes sheets and coils of carbon steel, any width or thickness, laminados a frio. Key downstream uses: automotive outer body panels, white-goods enamel sheet, construction cladding pre-coat substrate, can-manufacturing tinplate precursor stock.

NCM 7225.50.90 / 7226.92.00 (alloy-grade cold-rolled flat): Covers cold-rolled alloy and high-strength flat products used in automotive structural components, heavy machinery, and electrical-grade steel adjacent applications.

The investigation was initiated by a petition filed by Usiminas on 23 April 2024 alleging that Chinese-origin cold-rolled flat steel was entering the Brazilian market at dumped prices causing material injury to the domestic industry. The principal domestic petitioners (Usiminas, ArcelorMittal Brasil, CSN, Gerdau) form the same coalition that has driven the broader 2025-26 Brazilian trade-remedy wave. The original DOU publication of 13 February 2026 (Edição 31, Seção 1, Pág. 5) contained errors in the Article 1 tariff rate table and was republished on 18 February 2026 (DOU Edição 32) with the corrected rates; the measure is enforceable from the original 13 February publication date.

The measure is adopted under the authority of Lei nº 9.019/1995 (Brazil's foundational AD/CVD/safeguards enabling statute) and the WTO Anti-Dumping Agreement (Article VI GATT 1994).

Downstream implications

Cold-rolled flat typology closure: Res 854's NCM 7209.xx/7211.xx coverage extends Brazil's enforcement to wider-gauge and thicker cold-rolled flat categories beyond the thin tin-plate/chromium-oxide-coated grades covered by Res 765 (August 2025, NCM 7210.12/7210.50/7212). Together they span the full dimensional range of cold-rolled flat carbon steel from China entering Brazil.
Nova Indústria Brasil operationalisation: The measure enforces the defensive-trade pillar of the 2024 Nova Indústria Brasil (NIB) strategy (2024-01-22-brazil-nova-industria-brasil-nib) at the granular HS-code level for the most widely consumed flat-steel product category.
Brazilian 2025-26 trade-remedy wave architecture: Res 854 joins Res 765 (thin carbon-steel sheets, CN, Aug 2025), Res 849 (pre-painted flat steel, CN+IN, Jan 2026), Res 829/837 (optical fibre/cable, CN, Dec 2025), and Res 778 (synthetic polyester, CN, Sep 2025) — confirming DECOM/GECEX is running a systematic across-category defensive campaign against Chinese industrial overcapacity exports.
Automotive supply-chain exposure: Cold-rolled flat is the dominant substrate for automotive body panels in Brazil. OEM assemblers importing Chinese-origin steel for body-in-white production face direct cost pass-through from the specific duty; this incentivises domestic procurement from Usiminas and ArcelorMittal Brasil.
Companion CVD investigation risk: The pattern seen in paperboard (parallel AD + anti-subsidy probe against Indonesia and China) and the scale of Chinese steel export subsidies may prompt DECOM to open a countervailing duty investigation as a follow-on to Res 854.

Open questions

Exact USD/tonne rates by NCM subheading in the corrected Article 1 table (DOU Edição 32) — needed for tariff-weighted impact scoring; rate table is multi-row and differentiated by producer/exporter grouping.
Whether DECOM will initiate a companion CVD investigation against cold-rolled flat from China.
Usiminas capacity utilisation and contract backlog response as the AD protection accumulates through H1 2026.

Sources

Primary: MDIC DECOM 2026 DOU Publications — official government index of Gecex AD resolutions

Secondary: LegisWeb — full text Resolução GECEX nº 854 de 12/02/2026 · SINDASP CAD nº 063/26 — DOU 18 Feb 2026 customs-broker bulletin (Res 854 + 855 + 856 trio) · InfoMoney — Gecex-Camex approves antidumping measure on cold-rolled steel from China

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Mechanism

The measure is adopted under the authority of Lei nº 9.019/1995 (Brazil's foundational AD/CVD/safeguards enabling statute) and the WTO Anti-Dumping Agreement (Article VI GATT 1994).

Downstream implications

Cold-rolled flat typology closure: Res 854's NCM 7209.xx/7211.xx coverage extends Brazil's enforcement to wider-gauge and thicker cold-rolled flat categories beyond the thin tin-plate/chromium-oxide-coated grades covered by Res 765 (August 2025, NCM 7210.12/7210.50/7212). Together they span the full dimensional range of cold-rolled flat carbon steel from China entering Brazil.

Nova Indústria Brasil operationalisation: The measure enforces the defensive-trade pillar of the 2024 Nova Indústria Brasil (NIB) strategy (2024-01-22-brazil-nova-industria-brasil-nib) at the granular HS-code level for the most widely consumed flat-steel product category.

Brazilian 2025-26 trade-remedy wave architecture: Res 854 joins Res 765 (thin carbon-steel sheets, CN, Aug 2025), Res 849 (pre-painted flat steel, CN+IN, Jan 2026), Res 829/837 (optical fibre/cable, CN, Dec 2025), and Res 778 (synthetic polyester, CN, Sep 2025) — confirming DECOM/GECEX is running a systematic across-category defensive campaign against Chinese industrial overcapacity exports.

Automotive supply-chain exposure: Cold-rolled flat is the dominant substrate for automotive body panels in Brazil. OEM assemblers importing Chinese-origin steel for body-in-white production face direct cost pass-through from the specific duty; this incentivises domestic procurement from Usiminas and ArcelorMittal Brasil.

Companion CVD investigation risk: The pattern seen in paperboard (parallel AD + anti-subsidy probe against Indonesia and China) and the scale of Chinese steel export subsidies may prompt DECOM to open a countervailing duty investigation as a follow-on to Res 854.

Open questions

Exact USD/tonne rates by NCM subheading in the corrected Article 1 table (DOU Edição 32) — needed for tariff-weighted impact scoring; rate table is multi-row and differentiated by producer/exporter grouping.

Whether DECOM will initiate a companion CVD investigation against cold-rolled flat from China.

Usiminas capacity utilisation and contract backlog response as the AD protection accumulates through H1 2026.