Notice of conclusion of administrative review: Stainless steel sinks (SSS 2025 UP1)

Period of investigation

The period of investigation (POI) and the profitability analysis period (PAP) for the administrative review are January 1, 2024 to December 31, 2024.

Administrative review process

On February 24, 2025, the CBSA initiated an administrative review to update the normal values, export prices, and amounts of subsidy of certain stainless steel sinks from China.

At the initiation of the administrative review, information was requested from all known and potential exporters, producers, vendors and importers, concerning shipments of stainless steel sinks released into Canada during the POI. The information was requested for purposes of updating the normal values and export prices and amounts of subsidy for subject goods imported into Canada. The Government of China did not respond to the government subsidy Request for Information (RFI).

As such, on May 7, 2025, CBSA concluded the administrative review concerning the amounts of subsidy of certain stainless steel sinks originating in or exported from China. Please refer to Notice of conclusion—Subsidy review: Stainless steel sinks (SSS 2025 UP1) for further details.

Counsel for the cooperative exporters made representations and argued that the CBSA should use the information submitted by the cooperative exporters to calculate specific amounts of subsidy.^{Footnote 1}

When considering the information available to the CBSA on the administrative record, a fulsome and verified response to the Government Subsidy RFI is essential to provide the CBSA with sufficient assurance that all relevant subsidy programs and corresponding amounts have been fully and accurately disclosed. This approach enables the CBSA to make determinations grounded in comprehensive and verified information, in accordance with the evidentiary and procedural requirements of SIMA.

Therefore, the amounts of subsidy for the subject goods produced or exported from China will be determined pursuant to the ministerial specification, under subsection 30.4(2) of SIMA, as described at the conclusion of the subsidy review.

Regarding the section 20 inquiry, information was requested from all known and potential exporters and producers of stainless steel sinks in China and from the Government of China. The CBSA also sent Surrogate RFIs to all known producers of stainless steel sinks in Australia, India, Italy, Mexico, South Africa and Switzerland to collect domestic pricing and costing information concerning stainless steel sinks to determine normal values under paragraph 20(1)(c) of SIMA. Furthermore, importers were requested to provide information respecting re-sales in Canada of like goods imported from a third country to gather information to determine normal values under paragraph 20(1)(d) of SIMA. The Canadian producers were also requested to submit information regarding costs of production in the case such information was required to determine normal values under Ministerial specification.

On September 29, 2025, the administrative record for the review was closed. As part of the administrative review, case briefs were provided by counsel representing the complainant, Franke Kindred Canada Limited (Franke Canada).^{Footnote 2} The case briefs reaffirmed its arguments and evidence in its previous representations regarding section 20 conditions in the stainless steel sink sector in China.

No other case briefs or replies were received from other parties.

The results of the CBSA’s administrative review are provided below.

Normal values and export prices

Background of the section 20 inquiry

Section 20 is a provision of SIMA that may be applied to determine the normal value of goods in a dumping investigation where certain conditions prevail in the domestic market of the exporting country. In the case of a prescribed country under paragraph 20(1)(a) of SIMA, it is applied where, in the opinion of the CBSA, the government of that country substantially determines domestic prices and there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market.

The provisions of section 20 are applied on a sector basis rather than on the country as a whole. The CBSA proceeds on the presumption that section 20 of SIMA is not applicable to the sector under investigation absent sufficient information to the contrary. The CBSA may form an opinion where there is sufficient information that the conditions set forth in paragraph 20(1)(a) of SIMA exist in the sector under investigation.

The CBSA is required to examine whether the government of that country substantially determines domestic prices. The CBSA is also required to examine the price effect resulting from substantial government determination of domestic prices and whether there is sufficient information on the record for the CBSA to have reason to believe that the resulting domestic prices are not substantially the same as they would be in a competitive market.

Analysis of section 20 conditions

As the Government of China did not respond to the section 20 RFI, the CBSA analyzed section 20 factors and conditions in China with a focus on the elements presented in the representations filed by the complainant, responses to the exporter dumping and section 20 RFIs, and the CBSA’s own research.

Government control analysis

This section will present the CBSA analysis of the extent the Government of China (GOC) exerts control over the stainless steel sink sector in China, by examining the following:

• Government control over the flat-rolled steel sector
• Relevant industry sector under section 20 conditions
• Steel plans, directives and other policy documents affecting stainless steel
• GOC ownership and control of stainless steel manufacturers
• GOC’s provision of subsidies to stainless steel manufacturers
• GOC intervention in the cost of production of stainless steel
• GOC ownership and control of producers of stainless steel sinks
• GOC’s provision of subsidies to producers of stainless steel sinks
• GOC ownership and control of real estate industry

Government control over the flat-rolled steel sector

The CBSA has previously found that a government can indirectly control the prices of the sector being investigated by controlling the prices of the primary inputs. In Aluminum Extrusions, the CBSA found that the GOC’s influence on the aluminum industry in China had a significant impact on the prices in the aluminum extrusion sector. The CBSA made a similar conclusion in Fabricated Industrial Steel Components where it relied on evidence pertaining to the steel industry as a whole to show that the prices in the fabricated structural steel sector were being indirectly controlled by the GOC. The CBSA again made a similar conclusion in Container Chassis where one of the factors that led to the conclusion that the conditions of section 20 exist in the semi-trailer sector was the GOC’s control over steel inputs. More recently, the CBSA found that the GOC’s control in the prices of steel plate, a primary input in the production of Wind Towers, resulted in the distortion of prices in the wind tower sector.

The primary input material for stainless steel sinks is stainless steel sheets/coils. The Chinese flat-rolled steel sector includes the cold-rolled stainless steel sheets/coils. Given that stainless steel sheets/coils are the primary input material in the production of stainless steel sinks, it is appropriate to look at the flat-rolled sector as part of an analysis of the factors impacting the final selling price of stainless steel sinks in China.

The GOC’s control in the flat-rolled sector likely influences the price of stainless steel sheets/coils contributing to the section 20 conditions in the stainless steel sink sector and indirectly impacts the prices of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

Relevant industry sector under section 20 conditions

As it relates to the flat-rolled steel sector, the CBSA has previously formed opinions in respect of the following steel product industry sectors that domestic prices are substantially influenced by the GOC and that they are not substantially the same as they would be if they were determined in a competitive market:

• corrosion-resistant steel sheet (2018)^{Footnote 3}
• cold-rolled steel (2018)^{Footnote 4}
• flat hot-rolled carbon and alloy steel sheet and strip (2015)^{Footnote 5}
• hot-rolled carbon steel plate (2010)^{Footnote 6}

The substantial amount of information on the record of these previous findings supported the opinion that section 20 conditions exist in the flat-rolled steel sector in China.

The key input material for cold-rolled steel sheet is usually hot-rolled steel sheet, which uses semi-finished casting products, such as a billet^{Footnote 7} or slab^{Footnote 8}. In the proceedings cited above, the CBSA found that the GOC’s control of inputs, including billet was one of the main reasons that section 20 conditions existed in the flat-rolled steel sector.

As such, the GOC’s control of the flat-rolled sector appears to influence the price of stainless steel sheets/coils contributing to the section 20 conditions in the stainless steel sink sector and indirectly impacting the prices of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

Steel plans, directives and other policy documents affecting stainless steel

The steel industry, including the flat-rolled steel sector, in China is subject to a variety of plans, directives and other policy documents issued by all levels of the Chinese government, including the following:

• In August 2024, the GOC issued “Notice of the General Office of the Ministry of Industry and Information Technology on Suspending Steel Production Capacity Replacement Work” requiring the suspension of new steel capacity replacement plans starting August 23, 2024^{Footnote 9}
• In August 2023, the GOC released the “Work Plan for Stabilizing Growth in the Steel Industry” to guide and support the enhancement of supply and demand of steel in China^{Footnote 10}
• In March 2022, the GOC released the “Roadmap for high-quality development of iron and steel industry” to guide the development of the iron and steel industry and aiming to rationalize the structure of the industry, ensuring global competitiveness, and technical advancement^{Footnote 11}
• In February 2022, the GOC released guidelines for its steel industry to consolidate through mergers and acquisitions (“M&As”) to “create world-class steel giants and accelerate the sector’s high-quality development.” In addition, financial institutions are urged to provide “comprehensive financial services to iron and steel enterprises pursuing M&As, structural adjustments, transformations and upgrading.”^{Footnote 12}
• In May 2021, Chinese Premier Li Keqiang addressed the State Council at its executive meeting on the topic of rising steel prices, stating that “we must… deal with the excessively rapid increase in commodity prices and its collateral effects” and that such efforts were needed to “keep the economy running smoothly.”^{Footnote 13}
• In March 2021, the GOC released the “14th Five Year Plan: Part III” which is a directive identifying the transformation of traditional industries and improvements to the “layout and structure of raw material industries including… steel” as part of “implementing the manufacturing powerhouse strategy.^{Footnote 14}

As it relates specifically to the Chinese stainless steel industry, government directives are explicitly followed. Take for instance the Stainless Steel Council of China Iron and Steel Association (“CSSC”) which is China’s industrial association for stainless steel producers, and the CSSC which is part of the greater China Iron and Steel Association (“CISA”) representing Chinese steelmakers. The CISA is closely linked with the GOC, and has explicitly described itself as “guided by the Party’s lines” and that it “participates in making the industrial development planning, and relevant policies, laws and regulations”.^{Footnote 15} In addition, the CSSC clearly notes that group members must comply with national industrial policies and adhere to the Chinese Communist Party’s line, principles, and policies.^{Footnote 16} Through the CISA and CSSC, the GOC intervenes to regulate the price of various steel products. For example, in October 2024, CISA urged steel mills “to be disciplined in restraining production” after GOC stimulus led to increased steel prices.^{Footnote 17}

Based on the substantial amount of information on the record of previous findings related to steel products, including the flat-rolled steel sector, and evidence discussed above, the CBSA finds that the GOC actively releases plans, directives, policies guidelines for its domestic steel producers to follow in order to control its steel industry, including stainless steel producers.

The GOC’s control over the production levels of its domestic steel and stainless steel producers lead to the selling prices of these goods being distorted. As a result, the domestic selling prices of downstream products such as stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC ownership and control of stainless steel manufacturers

Many of the largest stainless steel manufacturers in China are SOEs. China’s seven largest stainless steel manufacturers are state-owned, while other prominent Chinese stainless steel manufacturers have indirect ties to the government.

• Taiyuan Iron & Steel Group (“TISCO”) was China’s largest stainless steel manufacturer in 2024.^{Footnote 18} In 2020, TISCO had a 12.94 million tonne annual production capacity – more than a third of which was stainless steel.^{Footnote 19} In the same year, China Baowu Steel Group (“Baowu”), bought a 51 percent majority stake in TISCO from the Shanxi Provincial government (retained the other 49 percent). Baowu is wholly owned by China’s State-owned Assets Supervisions and Administration Commission (“SASAC”) and is the largest steel-producing company in the world
• Angang Lianzhong Stainless Steel Corporation (“LISCO”) was among the top Chinese stainless steel manufacturers in 2024.^{Footnote 20} LISCO is a subsidiary of the Ansteel Group (“Ansteel”)^{Footnote 21} the third largest steel producer in the world in 2023 as reported by the World Steel Association.^{Footnote 22} Ansteel is also owned by China’s SASAC^{Footnote 23}
• Jiuquan Iron and Steel Group (“JISCO”) is among China’s largest stainless steel manufacturers and is entirely owned by the Gansu Province SASAC^{Footnote 24}
• Taishan Iron and Steel Group is among China’s largest stainless steel manufacturers and is considered to be a large state-owned enterprise^{Footnote 25}
• The HBIS Group (“HBIS”) was the fifth largest steel-producing company in the world in 2023, including stainless steel.^{Footnote 26} HBIS is wholly-owned by the Government of Hebei Province^{Footnote 27}
• Shougang Group (“Shougang”) was the ninth largest steel manufacturer in the world in 2023, including stainless steel.^{Footnote 28} Shougang is wholly-owned by the SASAC^{Footnote 29}
• Jiangsu Delong Steel (“JDS”) was the largest steel manufacturer in the world in 2023 and the third largest stainless steel producer in China.^{Footnote 30} While previously a privately held company, JDS is under government supervision as a result of bankruptcy proceedings and will likely remain under the control of the GOC following the conclusion of the proceeding^{Footnote 31}
• Ningbo Baoxin Stainless Steel (“Baoxin”) is a stainless steel manufacturer and joint venture between Baoshan Steel Co., Ltd. (“Baoshan”) and Japanese partners.^{Footnote 32} Baoshan is 62% owned by Baowu, which itself is wholly-owned by the SASAC^{Footnote 33}
• The Beihai Chengde Stainless Steel Group, a major Chinese stainless steel producer covering the entire process from smelting to cold-rolled finished product, is a joint venture consisting of the Guangdong Foshan Chengde Special Steel Co., Ltd and the Guangxi Beibu Gulf International Group^{Footnote 34}, a “large wholly state-owned enterprise directly under the People’s Government of Guangxi Zhuan Autonomous Region.”^{Footnote 35}

The CBSA notes that China’s focus on acquisitions of stainless steel manufacturers in recent years have led to even more stainless steel production falling under GOC ownership as it pursues its goal of consolidating over 60 percent of China’s steel capacity in the hands of its top ten steelmakers over the next five years.^{Footnote 36}

Evidence on the record indicates that the GOC, in general, exercises control over these enterprises. For examples:

• In April 2024, in its Staff Working Document, the European Union Commission indicated that the GOC exercises meaningful control over steel SOEs, which are obliged to follow governmental plans and policies^{Footnote 37}
• In the 2017 Antidumping Duty Investigation of Stainless Steel Sheet and Strip from China, the United States Department of Commerce found that “government majority ownership entitles the government entity the ability to control, and an interest in controlling, the operations of the company, including, but not limited to, the ability to select certain board members, who in turn, have the ability to appoint certain managers, and deputy managers.”^{Footnote 38}
• On its website, the Shougang Group notes that “since the founding of New China, the Party and state have attached great importance to the development of the Shougang Group. Dozens of Party and state leaders have visited Shougang for inspection and guidance … [and] thoroughly implements the decision-making arrangements of the Beijing Municipal Party Committee and Government^{Footnote 39}
• FitchRatings observes that, in the case of Baowu, the GOC “exerts control over the company’s board and senior management, and has strong influence over the group’s major strategies and investment decisions”.^{Footnote 40} This is corroborated on HBIS website, which indicates “guided by Xi Jinping’s socialist ideology with Chinese characteristics for a new era, HBIS endeavors to bring high-quality development to a new height, earnestly live up to our duty and contribute our efforts in promoting Chinese-style modernization.”^{Footnote 41}
• FitchRatings has determined that deep ties of control exist between HBIS Group and the GOC, noting that it has assessed “the government’s decision-making and oversight over HBIS as ‘Strong’”, and that the company is economically important to the region.^{Footnote 42}

The significant presence of state-owned and controlled enterprises in the production and supply of stainless steel suggests that the GOC will have an impact on the selling of stainless steel and that the selling decisions of stainless steel may be based on non-market factors, such as meeting GOC policy objectives. Therefore, the selling prices set by these state-owned stainless steel manufacturers may not be at market prices, which can cause an impact on the selling prices of stainless steel sinks in China.

Evidence on the record indicates that cooperative exporters have purchased stainless steel from manufacturers that are either state-owned or have government ties, as follows:

• Yongjin Metal Technology Co. Ltd. – established its Party Committee in September 2023 affirming that the company is “inseparable from the support of national policies and the wise leadership of the Party. The Group has always adhered to the guidance of Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era, giving full play to the vanguard and exemplary role of Party member^{Footnote 43}
• Baosteel-Foshan Stainless^{Footnote 44}
• Ningbo Baoxin Stainless Steel Co. Ltd.^{Footnote 45}

The information also available indicates that the volume of purchases from the above three stainless steel manufacturers are significant, representing a majority of all inputs purchased by the cooperating exporters during the period of investigation.

The GOC’s control and ownership of stainless steel manufacturers leads to the selling prices of stainless steel being distorted in China. As a result, producers of stainless steel sinks may acquire stainless steel at distorted prices, which has direct impact on the costs of production and therefore the selling prices of stainless steel sinks. Ultimately, the domestic selling prices of stainless steel sinks may not be substantially the same as they would be if they were determined in a competitive market.

GOC’s provision of subsidies to stainless steel manufacturers

The recent subsidy notification submitted by the GOC was criticized by the World Trade Organization Secretariat as lacking transparency.^{Footnote 46} Nevertheless, the available evidence indicates that the stainless steel manufacturers have received benefits and support from the GOC, as follows:

• Baowu received “significant support” during its creation in 2016 which resulted from the merger of Baosteel Group Corporation and Wuhan Iron and Steel Group. Moreover, the GOC has further supported Baowu via asset transfers.^{Footnote 47} As noted earlier, Baowu is the largest steel manufacturer in China and now controlling entity of TISCO, the largest stainless steel producer in China
• The government of Hebei established the Hebei Steel Industry Transformation and Upgrading Fund to support steel manufacturers and aid companies in their strategic transition. In 2020, as a state-owned entity of the Government of Hebei, HBIS benefitted from direct state support to upgrade and improve its operations^{Footnote 48}
• Wholly-owned by the SASAC, Shougang has received direct funding from both the central and Beijing governments over the past decade to support its progress at becoming a diversified public-service provider.^{Footnote 49} The CBSA notes that Shougang is included as part of Beijing’s 14th Five-Year Plan covering 2021-2025. As such, to achieve the political objectives of the city, Beijing has provided substantial financial support to the company^{Footnote 50}
• According to Global Trade Alert, Chinese stainless steel manufacturers received direct subsidies worth approximately USD 276 million from the GOC in 2023.^{Footnote 51}

In addition to the benefits received above, stainless steel manufacturers in China also have access to the following subsidy programs made available by the GOC:

• The Export-Import Bank of China currently provides export buyer’s credits whereby the Bank provides local and foreign-currency loans to overseas borrowers for facilitating the export of Chinese products, technologies, and services^{Footnote 52}
• The GOC provides a number of tax deduction programs, including, “200 percent of eligible R&D expenses incurred by enterprises.” These tax deductions were available since January 2023^{Footnote 53}
• The European Union Commission has found that Chinese steel manufacturers benefit from state support measures from financial institutions, typically by giving access to financing at non-commercial terms. This preferential and concessionary access to capital gives Chinese steel companies the ability to lower their costs relative to their counterparts overseas.^{Footnote 54}

Subsidization of stainless steel production effectively permits the GOC to influence the price of downstream products such as stainless steel sinks as producers can purchase input materials at less than fair market value and lower their cost of production. In short, these subsidies distort the domestic selling price of stainless steel in China. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC intervention in the cost of production of stainless steel

The GOC has taken several and persistent measures to ensure control with respect to raw materials for steelmaking. By intervening in upstream raw material inputs, the GOC can effectively influence the prices of downstream products. These measures affecting stainless steel manufacturers are summarized below:

Export taxes and export restrictions

In 2023 and 2024, the GOC imposed a 40% export tax on stainless steel scrap and ferrochrome and 5% to 15% export tax on nickel.^{Footnote 55} Ferrochrome, nickel and chromium are inputs to stainless steel. Further, the GOC mandated a licensing requirement for the export of chromium making it more difficult for chromium producers to export to foreign markets.

The CBSA finds that export taxes and export restrictions increase the supply of the restricted products in the domestic Chinese market, thereby putting downward pressure on domestic prices and at the same time increase world market prices by limiting supply to the rest of the world. As a result of these measures, the GOC creates an environment where domestic prices of stainless steel, are artificially low, which benefit the producers of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC influence over iron ore prices

In July 2022, the GOC created the China Mineral Resources Group (“CMRG”) to achieve the following main objectives:

• consolidated the iron-ore purchasing activity of approximately twenty of China’s largest steel manufacturers^{Footnote 56}
• entrusted all state-owned iron ore import rights to CMRG^{Footnote 57}
• provided greater buying power to Chinese steel producers when sourcing their iron ore from global mining companies^{Footnote 58}
• the CMRG is also tasked with managing China’s overseas investments in mining, worth approximately USD 4.3 billion^{Footnote 59}

In March 2023, the National Development and Reform Commission (“NDRC”) issued a warning that it would take measures to curb “unreasonable” iron ore prices and directed trading firms to avoid hoarding and inflating prices.^{Footnote 60}

Finally, the GOC through its Steel Plans has emphasized the acceleration of iron ore development in China by increasing domestic output from 270 million tons (2020) to 370 million tons (2025). Similarly, the GOC aims to increase the share of overseas iron ore production from 120 million tons (2020) to 220 million tons (2025).^{Footnote 61}

The CBSA finds that these measures demonstrate the GOC’s influence on steel production, including stainless steel, particularly by distorting the prices of iron ore. As a result of these measures, the GOC creates an environment where domestic prices of steel, including stainless steel, are artificially low, which benefit the producers of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC Influence Over Nickel Prices

China has invested heavily in new production of nickel, especially in Indonesia, helping Indonesia to grow from supplying 7 percent of global nickel output to 55 percent in the last decade. The new Indonesian production is controlled by China-based mining companies with ties to the GOC.^{Footnote 62}

Further, the GOC is an active buyer in the nickel market for state reserves.^{Footnote 63}

The CBSA finds that these measures taken demonstrate the GOC’s influence on steel production, including stainless steel, particularly by distorting the prices of nickel. As a result of these measures, the GOC creates an environment where domestic prices of steel, including stainless steel, are artificially low, which benefit the producers of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC influence over chromium prices

In December 2022, Baowu, the largest crude steel producer in the world and wholly-owned by the SASAC, acquired the Sinosteel Group (“Sinosteel”). Notably, Sinosteel own the world’s largest chromium reserves.^{Footnote 64}

According to Fastmarkets, Baowu and its affiliate, TISCO, continue to set prices in the Chinese market to “lower purchase price of raw materials, like ferro-chrome.”^{Footnote 65}

The CBSA finds that these measures taken demonstrate the GOC’s influence on steel production, including stainless steel, particularly by distorting the prices of chromium. As a result of these measures, the GOC creates an environment where domestic prices of steel, including stainless steel, are artificially low, which benefit the producers of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC influence on energy inputs

In 2022, the NDRC imposed price caps on coal to ensure an adequate electricity supply for generators. These controls continued into 2023, with the NDRC again warning that it will impose penalties on coal suppliers who renege on contracts to sell coal at set prices.^{Footnote 66}

Further, the GOC places price ceilings on the cost of electricity that is sold from coal-fired power generators. This has significant impact as coal accounts for 60 percent of China’s total energy generation and supply^{Footnote 67} and the steel industry is one of the largest industrial consumers, accounting for 14% of energy consumption in China.^{Footnote 68}

The CBSA finds that these measures taken demonstrate the GOC’s influence on steel production, including stainless steel, particularly by distorting the prices of coal and electricity. As a result of these measures, the GOC creates an environment where domestic prices of steel, including stainless steel, are artificially low, which benefit the producers of stainless steel sinks. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC ownership and control of producers of stainless steel sinks

Besides state-ownership and control of the stainless steel manufacturers upstream, there is evidence on the record which indicates GOC ownership of the following stainless steel sink producers:

• Zhuhai Grand Kitchenware Co. Ltd. is wholly-owned by the Guanxing Holding Group, which in turn is wholly-owned by the SASAC^{Footnote 69}
• Feidong Import and Export Co., Ltd. is a state-owned enterprise which is 92.2% controlled by the Chinese Trade Bureau^{Footnote 70}

There is also evidence on the record which indicates stainless steel sink producers have strong connections with the GOC:

• HIGOLD Group Co. (“HIGOLD”) is partially owned by Guangdong Shunde Science and Technology Innovation Fund Investment Co., which is a state-owned enterprise through Guangdong Shungao Investment Venture Capital Co., Ltd., and ultimately the State-owned Assets Supervision and Administration Bureau of Shunde District, Foshan City^{Footnote 71}
• Chen Jianfa, the founder and Chairman, of Zhuhai Primy Kitchen & Bathroom Co., is a representative of the Eighth National People’s Congress of Zhuhai, which is both expected and constitutionally obligated to follow central CCP policies and directives^{Footnote 72}
• Jiumu Kitchen & Bathroom maintains a Party Committee that “adheres to the guidance of Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era.”^{Footnote 73} This Party Committee plays a central role in the company given that Lin Xiaofa serves as the company’s Chairman and the Secretary of the Party Committee^{Footnote 74}
• Huadi Co. maintains a Party Committee that works closely “around the production and operation of the enterprise.”^{Footnote 75}
• Arrow Housewares Group maintains a Party Committee/Branch. Huo Zhibiao is the director of the general manager’s office, chairman of the board of supervisors and secretary of the party branch.^{Footnote 76}

The presence of state-owned and controlled enterprises that produce stainless steel sinks would necessitate that private Chinese companies supplying stainless steel sinks would have to compete with these SOEs. As a result, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

GOC’s provision of subsidies to producers of stainless steel sinks

Due to non-response of the GOC to the Government Subsidy RFI the CBSA was unable to determine the extent to which producers and exporters of stainless steel sinks benefited from government programs and subsidies.

However, available evidence on the record indicates that in addition to subsidies benefitting stainless steel manufacturers, the GOC provides various categories of subsidies to stainless steel sink producers, as follows:

• In May 2024, the Government of Guangdong Province issued a “Special Implementation Plan for Guangdong Province to Further Increase the Efforts to Attract and Utilize Foreign Investment” which provides a number of measures which constitute subsidies until 2027.^{Footnote 77} For example, financial grants up to USD 690,000 are available for eligible foreign-invested firms located in certain municipalities in Guangdong Province.^{Footnote 78} The CBSA is aware of at least nine producers and exporters of stainless steel sinks located in these municipalities^{Footnote 79}
• In March 2023, the Government of Guangdong Province issued a “Notice of the General Office of the Guangdong Province’s People’s Government on Issuing Several Policies and Measures for Promoting High-Quality Investment Promotion in Guangdong Province.”^{Footnote 80} These measures would be available to producers and exporters of stainless steel sinks in Guangdong Province

Subsidization of stainless steel sinks effectively permit the GOC to directly influence the price of stainless steel sinks by lowering the cost of production of producers of stainless steel sinks. As a result, these subsidies may distort the domestic selling price of stainless steel sinks in China, which contribute to the section 20 conditions in the stainless steel sink sector.

GOC ownership and control of real estate industry

The domestic real estate industry is one of the largest consumers of sinks in China. Evidence on the record indicates that China’s largest real estate developers are state-owned and controlled by the GOC. Purchases of stainless steel sinks by state-owned or controlled enterprises can influence prices in stainless steel sink sector in China.

According to the China Real Estate Information Corporation, the top five real estate developers based on contracted sales revenue in 2023, were state-owned or controlled by the GOC:^{Footnote 81}

• Poly Developments and Holdings Group Co., Ltd (“Poly Group”) (CNY 424.6 billion in sales) – As noted on its website, the Poly Group “is a large central enterprise approved by the State Council and the Central Military Commission and directly managed by State-owned Assets Supervision and Administration Commission (“SASAC”) of the State Council.^{Footnote 82} The Poly Group acts on the GOC’s development goals and “[have] deeply learned and grasped the major strategic deployment of the central government”^{Footnote 83}
• China Vanke Co., Ltd. (“Vanke”) (CNY 375.5 billion in sales) – Vanke is a publicly traded company; however, in 2017, Shenzhen Metro Group became Vanke’s largest shareholder,^{Footnote 84} which operates under the supervision of the SASAC^{Footnote 85}
• China Overseas Land & Investment Ltd. (“COLI”) (CNY 309.8 billion in sales) – a subsidiary of China Overseas Property Holdings Ltd. (parent company) and the China State Construction Engineering Corp., Ltd. (ultimate parent company), which is 56% indirectly owned by the SASAC. Further, COLI has been a key contributor to government housing policy discussions and has assisted the government in refining housing policies^{Footnote 86}
• China Resources Land Ltd. (CNY 307 billion in sales) – a subsidiary of China Resources (Holdings) Co., Ltd. (“China Resources”)^{Footnote 87}. Since its establishment in 1938 the company has had longstanding connections with the state. However, in 2003, China Resources has been operating under the supervision of the SASAC^{Footnote 88}
• China Merchants Shekou Industrial Zone Holdings Co., Ltd. (“CMSK”) (CNY 293.6 billion in sales) – is a state-owned enterprise with the GOC owning majority shares of CMSK directly and majority shares of its parent company, China Merchants Group. The SASAC holds 65.58% of the shares of CMSK.^{Footnote 89}

Another real estate developer, Evergrande, a state-tied property conglomerate, has come under increasing GOC control during its financial collapse which began in 2021.^{Footnote 90} Even before Evergrande’s financial distress, the group was state-owned, with the Shenzhen government holding a majority share. Further, the GOC is also tied indirectly to Evergrande since the Ministry of Finance’s CITIC Group is a known shareholder of the group.^{Footnote 91} As a shareholder, the GOC has made efforts to restructure Evergrande to avoid direct bailouts by directing state investors to acquire assets and ownership shares.^{Footnote 92}

Further, evidence on the record indicate that partially state-owned and privately-held real estate developers are under the influence of the GOC:

• Greentown China Holdings Limited (“Greentown China”) – the seventh largest Chinese real estate development based on 2023 contracted sales values. As of December 2024, the SASAC (through the China Communications Construction Company (“CCCC”)) owned 28.94% of Greentown China’s shares. In March of 2025, Greentown China announced the appointment of Liu Chengyun a member of the Party Standing Committee and Vice President of China Communications Construction Company as Board Chairmen for Greentown China. This appointment would “further strengthen the influence of the major shareholder CCCC [and] Greentown China has achieved significant improvements in credit enhancement, financing capacity, and cost reduction.”^{Footnote 93}
• Country Garden – a privately owned real estate developer, established its first CCP party branch in 1995 and later re-established to a CCP party committee in 2007. According to its website, “Country Garden is determined to follow the party and promote the construction of its corporate culture of devotion to the party and the country.”^{Footnote 94}

Finally, according to the Wall Street Journal, among China’s top 100 developers, the market share of state-owned developers grew to 70 percent in 2024, from 32 percent in 2019. These SOEs, including local government financing vehicles, bought 85 percent of the land for sale in 2024, compared to just 61 percent in 2021.^{Footnote 95}

Given the prevalence of state-owned and controlled real estate developers in China, who are one of the largest consumers of stainless steel sinks in China, the CBSA finds the GOC’s influence may impact the selling prices of stainless steel sinks and contribute to the conditions of section 20 in the stainless steel sink sector.

Analysis of domestic price in China

Stainless steel price analysis

Information available on the record indicates that the domestic selling prices of stainless steel sheets/coils in China are distorted.

The CBSA conducted a comparison of the annual average price per tonne of cold-rolled stainless steel sold in China versus other regional markets: United States, North Europe and East Asia (excluding China). However, due to confidentiality reasons, the detailed pricing information published by Fastmarkets cannot be disclosed.^{Footnote 96}

Based on the analysis, the prices of stainless steel sheet/coils in China are consistently lower than in the rest of the world between 2021 and 2024. Between 2021 and 2024, the price for Chinese 2mm stainless steel grade 304 has been between 26.4% to 54.8% percent cheaper than average prices for stainless steel with the same grade and thickness in the United States, North Europe, and non-China East Asian markets.

Considering the government control analysis in the previous section, the stainless steel pricing analysis supports the conclusion that the flat-rolled steel sector is under section 20 conditions and that the prices of stainless steel in China are distorted.

As stainless steel is the main input material used by the producers of stainless steel sinks, the domestic selling prices of stainless steel sinks in China may not be substantially the same as they would be if they were determined in a competitive market.

Stainless steel sinks price analysis

Information available on the record also indicates that the domestic selling prices of stainless steel sinks in China are distorted.

The CBSA conducted a comparison of the average selling prices of stainless steel sinks reported by the four cooperative exporters in China with the average selling prices of stainless steel sinks reported by the producers in Italy, India, South Africa and Switzerland. However, due to confidentiality reasons, the detailed pricing information of the parties cannot be disclosed.

Accounting for number of bowls, type and steel gauge of stainless steel sinks, the average domestic selling prices of Chinese exporters are significantly less than the average domestic selling prices sold by producers in Italy, India, South Africa and Switzerland.

Specifically, for single bowl sinks, the percent ratio between the four cooperative exporters’ average domestic selling price of sinks and the Italian surrogate producer’s average domestic selling price was between 13% to 43%. Further, during the period of investigation, for single bowl sinks, the average domestic selling prices in China of the four cooperative exporters were between 40% to 87% below non-Chinese average prices in the respective domestic home market.

Similarly, for double bowl sinks, the percent ratio between the four cooperative exporters’ average domestic selling price of sinks and the Italian surrogate producer’s average domestic selling price was between 20% to 25%. Further, the average domestic selling prices in China of the four cooperative exporters were between 50% to 91% below non-Chinese average prices in the respective domestic home market.

In summary, the domestic pricing analysis demonstrate that prices of stainless steel sink in China are significantly lower than the selling prices in all categories during the period of investigation. Considering the government control discussed previously and combined with the stainless steel and stainless steel sink pricing analysis and the commodity nature of stainless steel sinks, the data demonstrates that Chinese domestic stainless steel sinks prices are not substantially the same as they would be if they were determined in a competitive market.

Summary of the results of the section 20 inquiry

The wide range and material nature of the GOC measures have resulted in significant influence on the stainless steel sector and the stainless steel sink sector in China. Based on the preceding, the CBSA is of the opinion that:

• domestic prices of stainless steel sinks in China are substantially determined by the GOC
• there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market

Normal value

Where section 20 conditions exist, the CBSA may determine normal values using the selling prices, or the total costs and profit, of like goods sold by producers in a surrogate country designated by the President in accordance with the provisions of paragraph 20(1)(c) of SIMA.

The CBSA did not receive sufficient information to determine normal values under paragraph 20(1)(c) of SIMA as only one surrogate producer, Franke S.p.A. (Franke Italy) located in Italy, responded to the Surrogate Producer RFI.

Where normal values cannot be determined under paragraph 20(1)(c), SIMA provides an alternative methodology to calculate normal values under paragraph 20(1)(d), using re-sales in Canada of like goods imported from a third country. The CBSA determined that this provision could also not be used given that the importers did not provide sufficient re-sale information.

As normal values cannot be determined under paragraph 20(1)(c) or paragraph 20(1)(d), the CBSA determined normal values pursuant to a ministerial specification in accordance with subsection 29(1) of SIMA, on the basis of facts available.

In establishing the methodology for determining normal values, the CBSA analyzed all the information on the administrative record, including information submitted by interested parties.

Franke Italy provided a substantially complete response to the Surrogate Producer RFI, including a database of domestic sales of stainless steel sinks during the period of investigation (POI).

Where there were sufficient profitable sales of like goods, normal values were determined in a similar methodology of subparagraph 20(1)(c)(i), using the Franke Italy’s domestic prices of stainless steel sinks in Italy.

Where there were insufficient profitable domestic sales of like goods, or where there were no domestic sales of like goods, normal values were determined using the methodology of subparagraph 20(1)(c)(ii) of SIMA, based on the aggregate of the cost of production of the goods, a reasonable amount for administrative, selling and all other costs and a reasonable amount for profits.

The cost of production was calculated in accordance with paragraph 11(1)(a) of the Special Import Measure Regulations (SIMR), based on Franke Italy’s verified cost data associated with the like goods produced in Italy. The amount for administrative, selling, and all other costs was calculated in accordance with subparagraph 11(1)(c)(ii) of the SIMR, based on Franke Italy’s selling and administrative expenses incurred during the Profitability Analysis Period (PAP). The amount for profits was determined in accordance with subparagraph 11(1)(b)(ii) of the SIMR, based on Franke Italy’s sales of stainless steel sinks in their domestic market, during the PAP, of the same general category as the subject goods sold to Canada.

Where normal values cannot be determined with the methodologies described above, the CBSA used information received from one Canadian Producer, Franke Kindred Canada Limited (Franke Canada), located in Ontario, Canada. Franked provided cost of production information on like goods produced in Canada. The CBSA determined normal values for the subject goods from China using a similar approach that reflects the methodologies of subparagraphs 20(1)(c)(i) and (ii) of SIMA, based on the aggregate of the cost of production of stainless steel sinks produced in Canada but adjusted for the cost of material, labour, factory overhead in Italy, plus a reasonable amount for administrative, selling and all other costs and a reasonable amount for profits, as determined for the surrogate producer in Italy.

The specific normal values for future shipments are effective today, October 31, 2025.

Beginning July 1, 2026, normal values for all subject goods established as part of this administrative review shall serve as base values and be indexed semi-annually.

The indexed normal values shall come into effect, beginning July 1, 2026 and updated in the same manner every six months thereafter.

Exporter responsibility

All parties are cautioned that, where there are increases in domestic prices and/or costs, the export price should be increased accordingly to ensure that any sale made to Canada is not only above the normal value but at or above selling prices and full costs and profit of the goods in the exporter’s domestic market. If exporters do not adjust export prices accordingly, retroactive assessments of anti-dumping duties may be warranted. Please refer to the Memorandum D14-1-8: Administrative Review Policy – Special Import Measures Act (SIMA) for details.

Importer responsibility

Importers are reminded that it is their responsibility to declare their anti-dumping and countervailing duty liability. If importers are using the services of a customs broker to clear importations, the brokerage firm should be advised that the goods are subject to anti-dumping and countervailing measures and be provided with sufficient information necessary to clear the shipments. To determine their liability for anti-dumping and countervailing duty, importers should contact the exporters to obtain the applicable normal values and amounts of subsidy. For further information on this matter, refer to Memorandum D14-1-2: Disclosure of normal values, export prices, and amounts of subsidy established under the Special Import Measures Act.

The Customs Act applies, with any modifications that the circumstances require, with respect to the accounting and payment of anti-dumping and countervailing duties. As such, failure to pay the duties within the prescribed time will result in the application of the interest provisions of the Act.

Should the importer disagree with the determination made on any importation of goods, a request for re-determination may be filed. For more information on how to file a request for re-determination, please refer to the Guide for appealing a duty assessment.

Contact us

Email: simaregistry-depotlmsi@cbsa-asfc.gc.ca