Brazil SECEX Circular nº 18 — Initiation of Anti-Dumping Investigation on Graphite Electrodes (diameter ≥ 350 mm) from China and India

Mechanism

Circular SECEX nº 18, dated 12 March 2026, formally opens an antidumping investigation under Lei 9.019/1995 and its implementing regulations into imports of machined graphite electrodes (NCM 8545.11.00, diameter equal to or greater than 350 mm, assembled or unassembled) from the People's Republic of China and the Republic of India.

Petitioner: GrafTech Brasil Participações Ltda, the Brazilian subsidiary of GrafTech International Holdings LLC (NYSE: EAF), a global graphite-electrode manufacturer with major production facilities in Clarksburg, West Virginia and Monterrey, Mexico. GrafTech alleges that Chinese and Indian producers have been exporting electrodes to Brazil at below-cost prices, causing material injury to Brazilian domestic production.

Preliminary dumping margins (DECOM Phase 1 indicative assessment):

• China PR: 54.9%
• India: 57.3%

Product scope: Machined graphite electrodes ≥ 350 mm in diameter used in electric-arc furnace (EAF) steelmaking, cast iron smelting, ferroalloy production (ferro-manganese, ferro-chromium, ferro-silicon), metal-oxide reduction, and related industrial processes.

Procedural milestones:

• Interested-party registration deadline: 1 April 2026 (importers, exporters, Brazilian

end-users wishing to participate in the proceeding).

• Provisional AD duties may be imposed if DECOM finds a preliminary affirmative determination

(typically 120–180 days into the investigation under Lei 9.019/1995 procedural standards).

• Final determination timeline: 12–18 months from initiation (no stated deadline in Circular);

a positive finding can result in AD duty of up to five years.

Parallel US investigation: GrafTech simultaneously filed with the US Department of Commerce and US International Trade Commission in March 2026 on large-diameter graphite electrodes from China and India — the Brazil and US proceedings represent a coordinated two-jurisdiction trade-defense response to the same alleged dumping pattern, structurally peer to the 2023–2024 Brazil + EU + US coordinated investigations on carbon steel and optical fibre products.

Downstream implications

• EAF steelmakers in Brazil (Gerdau, CSN, Usiminas, Ternium Brasil, ArcelorMittal Brasil)

are the primary end-users of graphite electrodes ≥ 350 mm; AD duties would raise their input costs if Chinese / Indian electrode supply is restricted or priced up.

• Chinese electrode producers already face severe overcapacity headwinds domestically;

coordinated Brazil + US AD investigations close two significant export-market channels.

• Indian electrode producers (HEG Limited, Graphite India Limited) face a 57.3% preliminary

margin; Brazil has been a growing destination for Indian electrode exports as North American and European markets tightened post-2022; this investigation redirects Indian supply to other markets or forces price restructuring.

• China graphite export architecture: This investigation targets the downstream processed

electrode product; the upstream filed 2023-10-20-china-mofcom-graphite-export-controls restricted Chinese natural-graphite exports. Together they trace the graphite value chain from raw material (China's export restriction) to finished electrode (Brazil's AD investigation).

Open questions

• Will DECOM impose provisional AD duties pending the final determination (~Q3–Q4 2026)?
• Will major Brazilian EAF steelmakers register as interested parties opposing the petition

on input-cost grounds?

• Final-determination coordination with US Commerce: do both jurisdictions converge on

methodology and timing?