Egypt Ministerial Decree — Definitive 3-Year Safeguard on Flat-Rolled Steel Imports (HRC, CRC, HDG, PPGI)

Mechanism

The definitive safeguard is issued under Egypt's Law No. 161 of 1998 (Anti-Dumping, Anti-Subsidy and Safeguard Law) following the Trade Remedies Sector's affirmative final determination of serious injury and causal link. The decree consolidates the outcome of two parallel WTO-notified investigations:

1. HRC investigation (launched April 2025): finalises the 200-day provisional safeguard of Ministerial Decision No. 400/2025 (effective 14 September 2025). Between 2021 and 2024, imports of hot-rolled flat steel increased by 116%.

2. CRC + HDG + PPGI investigation (launched September 2025): a separate proceeding covering cold-rolled, galvanized, and pre-painted flat steel whose provisional phase ran concurrently; imports of CRC/HDG/PPGI rose 86% over the same 2021–2024 baseline. Egypt simultaneously terminated the parallel anti-dumping probe on CRC/HDG/PPGI from China and Turkey (31 March 2026) without imposing AD duties — making the definitive safeguard the sole operative instrument for all flat products.

Rate structure (three-tier declining duty):

HRC rates follow the structure confirmed in the final determination on the HRC investigation, building on the provisional 13.6%/EGP 3,673/t floor rate.

The measure applies on an MFN (most-favoured-nation), all-source basis consistent with WTO Safeguards Agreement Article 2. Dual-rate architecture (percentage ad-valorem + USD minimum specific floor) prevents CIF-value undervaluation circumvention.

Context: 2025–26 MENA and global steel safeguard wave

Egypt's definitive safeguard sits within the broader 2024–2026 cycle of flat-steel trade remedies:

• India imposed definitive flat-steel safeguards in December 2025
• EU activated its steel safeguard successor regulation in April 2026
• Türkiye is running parallel flat-steel AD proceedings (2026/17 and others)
• Egypt is now the first African jurisdiction to complete a comprehensive flat-steel safeguard

trilogy (HRC + CRC/HDG/PPGI + billets) in this cycle

Major exporter routes affected: Chinese, Turkish, CIS (Russian/Ukrainian), and Indian HRC/CRC exporters face effective cost uplift into Egypt, the MENA region's largest flat-steel import market (import volumes ~USD 500M+ annually pre-safeguard). Black Sea corridor re-routing and diversion pressures could follow.

Downstream implications

• Steel-consuming downstream sectors in Egypt (pipe manufacturing, structural steel fabricators,

automotive stamping, appliance manufacturers, construction) bear upstream cost-pass-through risk from the combined safeguard trilogy covering HRC, CRC, HDG, PPGI, and billets.

• The declining-duty structure signals a planned ramp-down toward 2028-2029 expiry, but Article XIX

extension proceedings could extend protection through the mid-2030s.

• Egypt's concurrent termination of AD probes on CRC/HDG/PPGI (without AD duties) simplifies the

legal architecture by consolidating into a single safeguard instrument — reducing exporter uncertainty while eliminating the risk of layered AD-plus-safeguard duties.

• Hoa Sen Group (Vietnam) coverage of the Egyptian safeguard reflects that Southeast Asian exporters

are also affected despite lower bilateral trade volumes.

Open questions

• Exact HRC definitive rate in Year 1 (the provisional was 13.6%/EGP 3,673 per ton — does the

definitive maintain this, adjust to a USD floor, or shift the percentage?).

• WTO notification timeline: when will Egypt notify the Committee on Safeguards of the definitive

measure under Article XIX:1(b) and trigger the consultation-request window?

• Will the companion billets safeguard (Decisions 398/399 of 2025) receive a separate filing or is

it embedded in this definitive decree?

• Article 7 WTO extension review: if injury persists, will Egypt seek a post-2028 extension?