US Decision to Maintain Anti-Dumping Duty
On April 9, 2025, the U.S. Department of Commerce published a notice confirming the continuation of the anti-dumping (AD) duty order on diffusion-annealed, nickel-plated flat-rolled steel products from Japan. This ruling follows a sunset review process under U.S. trade law. The sunset review determines whether an existing AD duty should continue or be revoked. The review concluded that revoking the duty would likely lead to the continuation or recurrence of dumping practices and would harm the U.S. industry, thus justifying the continuation of the AD order.
This action ensures that anti-dumping duties will continue to be imposed on nickel-plated steel products from Japan, helping to protect the U.S. steel industry from potentially unfair trade practices, such as dumping—where goods are sold at unfairly low prices in foreign markets, harming domestic producers.
Key Background: The Diffusion-Annealed, Nickel-Plated Steel Products
The steel products in question are flat-rolled steel products that are:
• Cold-reduced, meaning the steel has been processed through a cold-rolling process to thin the material.
• Nickel-plated, with a layer of nickel or nickel-based alloys applied to the surface of the steel.
• Diffusion-annealed, meaning the steel undergoes a heat treatment process that allows the nickel to diffuse into the surface, improving its properties.
The products covered by the AD order are less than or equal to 2.0 mm in nominal thickness and may also be painted, varnished, or coated with plastics or other materials. These products are used in a variety of industries, particularly in manufacturing and electronic sectors, for their corrosion-resistant and durable properties.
The scope of the AD duty includes various HTSUS (Harmonized Tariff Schedule of the United States) codes:
• 7212.50.0000
• 7210.90.6000
• 7210.70.6090
• 7212.40.1000
• 7212.40.5000
• 7225.99.0090
These codes help in the classification and tracking of these steel products entering the U.S. market.
The Sunset Review Process and Its Findings
The sunset review process initiated by the U.S. International Trade Commission (ITC) and the Department of Commerce concluded that removing the AD duty could lead to a recurrence of dumping—the practice of selling products at lower-than-normal prices in the U.S. market. The review also highlighted that such dumping could result in material injury to the U.S. steel industry, specifically affecting domestic producers of nickel-plated steel.
The U.S. ITC made its determination public on March 31, 2025, confirming that the removal of the AD order would likely result in harm to the U.S. industry. As a result, the Department of Commerce decided to continue the AD duty on these products.
Implications for the U.S. Market and Trade Relations
This continuation of the AD order has important implications both for the U.S. steel industry and for international trade relations.
• Protection for U.S. Steel Producers: The primary goal of maintaining the AD duty is to protect U.S. manufacturers of diffusion-annealed, nickel-plated flat-rolled steel products. Without these duties, foreign producers, particularly from Japan, could flood the market with steel at unfairly low prices, harming local manufacturers.
• Increased Import Costs: The continuation of the AD duty will mean higher costs for importers of these products from Japan. U.S. importers will be required to pay anti-dumping duties on steel products that meet the scope outlined in the order. These duties are typically paid as cash deposits to U.S. Customs and Border Protection (CBP) at the rates in effect at the time of entry.
• Strained Trade Relations with Japan: The decision could exacerbate trade tensions between the U.S. and Japan, as Japan might view this continued duty as an unfair trade barrier. Japan could potentially seek to challenge the ruling through diplomatic channels or dispute resolution mechanisms under the World Trade Organization (WTO).
• Economic Impact on U.S. Consumers: While the duty protects domestic producers, it may result in higher prices for consumers and industries that rely on these specific steel products. Industries such as automotive manufacturing, electronics, and construction could face higher raw material costs.
Continuation of Anti-Dumping Measures
The anti-dumping duty on Japanese diffusion-annealed, nickel-plated flat-rolled steel products will remain in effect as of March 31, 2025, and continue indefinitely unless reviewed or modified by future reviews or determinations.
U.S. Customs and Border Protection will continue to collect the anti-dumping cash deposits at the rates in effect at the time of entry for all imports of subject merchandise. These duties will be applied to the imported steel products based on their classification under the relevant HTSUS codes.
Key Takeaways:
• The U.S. Department of Commerce has decided to continue the anti-dumping (AD) duty order on diffusion-annealed, nickel-plated flat-rolled steel products from Japan.
• The decision follows a sunset review which found that revocation of the duty could lead to the recurrence of dumping and material injury to the U.S. steel industry.
• The AD duty will remain effective as of March 31, 2025, continuing indefinitely unless subject to future reviews.
• The affected steel products are cold-reduced, nickel-plated, and diffusion-annealed, with a maximum thickness of 2.0 mm.
• U.S. Customs and Border Protection will continue to collect anti-dumping cash deposits on imports of these steel products.
• The decision ensures protection for U.S. steel manufacturers but may result in higher costs for consumers and industries relying on nickel-plated steel products.
• The decision may lead to trade tensions with Japan, as the country could challenge the decision through diplomatic or WTO dispute resolution mechanisms.
