On June 3^rd, 2025, the publication of SECEX Ordinance No.39/2025 initiated an antidumping investigation on Brazilian imports of hot-rolled flat products originating from China. The product under investigation is usually classified under subitems 7208.10.00, 7208.25.00, 7208.26.10, 7208.26.90, 7208.27.10, 7208.27.90, 7208.36.10, 7208.36.90, 7208.37.00, 7208.38.10, 7208.38.90, 7208.39.10, 7208.39.90, 7208.40.00, 7208.53.00, 7208.54.00, 7208.90.00, 7211.13.00, 7211.14.00, 7211.19.00, 7211.90.10, 7211.90.90, 7225.30.00, 7225.40.90, and 7226.91.00 of the Mercosur Common Nomenclature (“NCM”).

The opening of the investigation was motivated by a petition filed on October 30^th, 2024, by ArcelorMittal Brasil S.A., Gerdau Açominas S.A. and Usinas Siderúrgicas de Minas Gerais S.A. After a preliminary analysis, the Foreign Trade Secretariat (SECEX), through the Department of Trade Remedies (DECOM), found sufficient evidence of dumping, injury to the domestic industry, and a causal link.

The main information regarding the investigation is summarized below:

• Petitioners: ArcelorMittal Brasil S.A., Gerdau Açominas S.A. e Usinas Siderúrgicas de Minas Gerais S.A.

• Origin: China
• Period of Investigation:

Dumping: July 2023 to June 2024
Injury: July 2019 to June 2024

• Product under investigation:

Classification: Usually classified in sub-items 7208.10.00, 7208.25.00, 7208.26.10, 7208.26.90, 7208.27.10, 7208.27.90, 7208.36.10, 7208.36.90, 7208.37.00, 7208.38.10, 7208.38.90, 7208.39.10, 7208.39.90, 7208.40.00, 7208.53.00, 7208.54.00, 7208.90.00, 7211.13.00, 7211.14.00, 7211.19.00, 7211.90.10, 7211.90.90, 7225.30.00, 7225.40.90, and 7226.91.00 of the NCM;
Description: flat-rolled products of iron or alloy steel or of non-alloy steel, hot-rolled, not clad, plated or coated, of any width, in the uncoiled state, of a thickness of less than 4.75 mm, or in the coiled state, of any thickness.

• Dumping margins for initiation purposes:

The participation of interested parties — including domestic producers, importers, exporters and governments of the countries under investigation — must necessarily be carried out through petitions in the Electronic Information System (SEI) of the Ministry of Development, Industry, Trade and Services (MDIC).

Questionnaires will be sent to the identified interested parties, who will have 30 (thirty) days from the date of the notification to send their responses. Parties not initially identified at the beginning of the proceeding, but who consider themselves interested, may request to be admitted to the case by June 23^rd, 2025.

During the investigation, provisional antidumping measures may be applied if sufficient evidence of unfair trade practices is found and if it is understood that such measures are necessary to prevent injury to the domestic industry during the investigation.

The investigation must be completed within 10 (ten) months, extendable for up to 8 (eight) additional months. If the initial claims are confirmed, definitive antidumping measures may be applied for a period of up to 5 (five) years.

The team of specialists at Nasser Advogados is available to clarify any questions.