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Circular SECEX nº 33, dated 29 April 2026 (published in the Diário Oficial da União on 30 April 2026), issues the preliminary determination in the antidumping investigation of hot-rolled stainless steel flat products from China, India and Indonesia under Lei 9.019/1995 and its implementing Decree 8.058/2013.
Product scope: hot-rolled stainless steel flat products in coils or sheets, thickness ≥ 2 mm and ≤ 50.8 mm, covering NCM positions:
Preliminary dumping margins (DECOM Phase 1 determination):
| Origin | Dumping margin |
|---|---|
| China | 50.1% |
| Indonesia | 25.3% |
| India | 17.9% |
No provisional duties: Despite the affirmative preliminary finding on dumping and material injury, DECOM chose not to recommend imposition of provisional anti-dumping duties at this stage. The circular cites three justifications: (i) case complexity arising from the three-origin scope; (ii) the significant volume of information submitted by interested parties requiring further adversarial proceedings; and (iii) the adequacy of full investigation proceedings to protect the domestic industry given the timeline to final determination.
Final determination: Department of Commercial Defense (DECOM) is scheduled to issue its final determination by 25 November 2026. If affirmative, the Ministry of Finance (through GECEX/CAMEX) would then publish a definitive anti-dumping duty order (typically a GECEX Resolução) covering the same NCM positions.
Indonesian angle — Tsingshan / IMIP / Morowali nexus: The 25.3% preliminary margin on Indonesian-origin product is materially significant. Indonesia's emergence as a major stainless steel exporter is largely driven by Tsingshan Holdings' integrated nickel pig iron (NPI)→ stainless slab→hot-rolled coil facilities at the Indonesia Morowali Industrial Park (IMIP) in Central Sulawesi, which produces ~3–4 Mtpa of stainless HRC. Brazil (~USD 200–300M/year of Indonesian stainless HRC imports) is a material destination for IMIP output, and the preliminary margin would structurally shift Indonesian supply if confirmed in November.
2026 BR stainless architecture: This preliminary determination expands Brazil's steel protection architecture in two dimensions: (i) it adds hot-rolled stainless (7219/7220) to the existing cold-rolled flat steel (GECEX nº 854), coated flat steel (GECEX nº 856), pre-painted steel (GECEX nº 849), and GNO electrical steel (GECEX nº 857) defensive posture; (ii) it introduces Indonesia as a named target in the Brazil AD register for stainless steel, alongside the existing China-dominant AD architecture.
Global stainless AD architecture: This is the Brazilian complement to filed 2025-12-27-turkiye-crss-china-ad (Türkiye's Communiqué nº 2025/44 on cold-rolled stainless from China, 3.95% duty). Together they represent a developing multi-jurisdiction anti-dumping perimeter on Chinese + Indonesian stainless flat products: Türkiye on cold-rolled (CRSS); Brazil on hot-rolled (HRSS); the European Union on both (existing duties expiring November 2026 per Mysteel noting EU sunset review).
automotive trim) face potential cost increases on ~USD 200–300M/year of imports if duties are imposed in November 2026.
one of the primary EM export channels for IMIP's 3–4 Mtpa capacity and would accelerate IMIP's diversification to other developing markets (Turkey, Gulf, ASEAN).
exporter): the 17.9% preliminary margin is below the threshold typically triggering immediate trade diversion, but any confirmed definitive duty above 15% materially reprices India's Brazil business.
is at the level where Chinese supply effectively exits the Brazilian market if confirmed.
up for sunset review in late 2026, EU + Brazil + Turkey form a converging multi-jurisdiction AD perimeter on Asian stainless flat products.
the risk of import surges during the pending period.
final finding?
against Indonesia given the documented state subsidisation of IMIP/Tsingshan operations?