Statement of Reasons—Expiry review determination: Heavy Plate (HP 2026 ER)

Administrative record

[27] The information considered by the CBSA for purposes of this expiry review investigation is contained on the administrative record. The administrative record includes the information on the CBSA’s Exhibit Listing, which is comprised of CBSA exhibits and information submitted by interested persons, including information which parties feel is relevant to the decision as to whether dumping is likely to continue or resume if the finding is rescinded. This information may consist of expert analyst reports, excerpts from trade magazines and newspapers, orders and findings issued by authorities of Canada or of a country other than Canada, documents from international trade organizations and responses to the ERQs, if any, submitted by domestic producers, importers, as well as exporters and foreign producers.

[28] For purposes of an expiry review investigation, the CBSA sets a date after which no new information submitted by interested parties will be placed on the administrative record or considered as part of the CBSA’s expiry review investigation. This is referred to as the “closing of the record date” and is set to allow participants time to prepare their case briefs and reply submissions based on the information that is on the administrative record as of the closing of the record date. For this expiry review investigation, the administrative record closed on February 25, 2026.

Procedural issues

[29] The CBSA will normally not consider any new information submitted by participants subsequent to the closing of the record date. However, in certain exceptional circumstances, it may be necessary to permit new information to be submitted. The CBSA will consider the following factors in deciding whether to accept new information submitted after the closing of the record date:

1. the nature, relevance, materiality and volume of the information
2. the difficulties encountered by the participant in obtaining or submitting the information by the date specified (for example, the availability of the information or emergence of new or unforeseen issues)
3. whether the information can reasonably be taken into consideration by the CBSA for purposes of the proceedings including whether there is sufficient time to verify the information
4. whether other parties are likely to be prejudiced if the information is used (for example, the opportunity for other participants to respond to the information)
5. whether acceptance of the information would compromise the ability of the CBSA to conduct the proceedings expeditiously and
6. any other factors that are relevant in the circumstances

[30] Participants wishing to file new information after the closing of the record date, either separately or in case briefs or reply submissions, must identify this information so that the CBSA can decide whether it will be included in the record for purposes of the determination.

[31] On March 4, 2026, the CBSA received a request for leave from counsel on behalf of Algoma seeking approval to file additional amended documentation onto the administrative record despite the record being closed on February 25, 2026.

[32] After reviewing the relevant criteria and policy regarding late filed submissions, the CBSA determined that the documentation provided did not meet the necessary thresholds for late filed submissions and would not have materially affected its assessment; therefore, the submitted materials were rejected and do not form part of the administrative record.^{Footnote 11}

Parties contending that continued or resumed dumping is likely

Domestic producers: Algoma

[33] Algoma, a Canadian producer, made representations in its case brief supporting its position that dumping from Chinese Taipei and Germany is likely to continue or resume in the event the present finding is rescinded. Therefore, Algoma argued that the measures should remain in place.

[34] The main factors identified by Algoma in support of their position are summarized as follows:

• International steel market conditions^{Footnote 12}
• Domestic market conditions in the subject countries^{Footnote 13}
• Export reliance of subject country producers^{Footnote 14}
• Imposition of anti-dumping and countervailing measures by other countries^{Footnote 15}
• Canadian market conditions^{Footnote 16}
• Subject country exporters’ continued interest in Canada’s steel market^{Footnote 17}
• Resumed exports would be at dumped prices^{Footnote 18}

[35] The CBSA has carefully reviewed and considered the evidence and submissions provided by the party. In conducting its analysis, the CBSA has taken into account those facts, arguments, and information it determined to be most relevant and persuasive with respect to the applicable expiry review factors set out in subsection 37.2(1) of the Special Import Measures Regulations (SIMR). Importers

[36] No case briefs or reply submissions were submitted contending that the dumping of the subject goods is not likely to continue or resume if the finding is rescinded.

Exporters and foreign producers

[37] No case briefs or reply submissions were submitted contending that the dumping of the subject goods is not likely to continue or resume if the finding is rescinded.

Common factors

Commodity nature of heavy plate

[40] With respect to hot-rolled steel plate in general, when it is produced to the same specifications, it is physically interchangeable regardless of the country of production. In their published reasons in proceeding RR-2019-01, the CITT noted that “in numerous past cases, all other criteria being equal, plate is a commodity product that competes on the basis of price”^{Footnote 19}. Goods therefore compete with one another regardless of origin, share the same channels of distribution, and are sold to the same potential customers. As a result, hot-rolled steel plate competes in an extremely price-sensitive market, in which price is one of the primary factors influencing customers’ purchasing decisions.

[41] This dynamic also applies to heavy plate. In its preliminary reasons in PI-2020-001, the CITT observed that respecting heavy plate, “domestic and imported plate are interchangeable commodity products”^{Footnote 20} that trade on basis of price. Given this high degree of price sensitivity, prices in a given market have historically tended to converge over time toward the lowest available price offering. The commodity nature of the goods and the high degree of price sensitivity may increase the likelihood of dumping by incentivizing subject exporters to undercut prices as a primary means of competition in the Canadian market.

Capital-intensive nature of steel production

[42] As previously noted by the CITT, steel mills are “capital intensive with high fixed costs,”^{Footnote 21} and therefore must operate at high levels of capacity in order to recover those costs. When demand in the home market declines, producers are inclined to seek sales in foreign markets to maintain capacity utilization and support cost recovery.

[43] This dynamic that incentivizes high utilization is often referred to as the economics of steel production. Conditions of overcapacity exacerbate this characteristic as a producer may find it more feasible to sell excess production in foreign markets at depressed prices rather than reduce production, as long as the producer’s variable costs are covered.

Tariffs and safeguard measures on steel imports and diversion of steel plate into Canada

[44] Initially implemented in 2018, U.S. Section 232 tariffs on steel were set at 25 percent and included country-specific exemptions. In 2025, the application of these measures was expanded to apply on a more uniform basis, while the tariff rate was first maintained at 25 percent and later increased to 50 percent in June of 2025, where it currently stands. In the case of China, exports are subject not only to the Section 232 tariffs but also to additional duties imposed under Section 301, which apply cumulatively on top of the Section 232 measures.^{Footnote 22}

[45] Partly in response to the U.S. tariffs introduced in 2018, the EU implemented steel import safeguard measures in the form of tariff-rate quotas, under which imports exceeding specified volume limits are subject to a 25 percent duty. These measures have been extended until June 2026, the maximum duration permitted under WTO rules. In anticipation of their expiry, the EU has developed proposals for replacement measures that would substantially reduce tariff-free import volumes and increase the out-of-quota tariff from 25 percent to 50 percent, to take effect once the current safeguard measures expire.^{Footnote 23}

[46] Other jurisdictions have also implemented measures to protect their steel industries, including steel plate. In late 2025, India announced definitive safeguard measures on a broad range of flat steel products for a period of three years, following provisional measures applied earlier in 2025.^{Footnote 24} Similarly, in November 2025, South Korea imposed anti-dumping duties on imports of Chinese medium and heavy plate for a period of five years.^{Footnote 25}

[47] Given its geographic proximity to Canada, the size of the U.S. steel market, and the substantial escalation of Section 232 and other tariffs, the U.S. represents a significant source of potential diversionary pressure. These pressures are compounded by safeguard and trade remedy actions in other jurisdictions, such as the EU, South Korea and India, which further constrain alternative export destinations. In this context, Canada becomes a more attractive market for excess steel plate production, increasing the likelihood that dumped imports will be diverted to Canada.

Chinese Taipei

Canadian producers as well as other information on the administrative record, in considering whether the dumping of certain heavy plate from Chinese Taipei is likely to resume or continue if the finding was to expire.

Chinese Taipei steel producer overcapacity

[49] Evidence on the record from the Commodities Research Unit (CRU), as submitted by Algoma, indicates that plate producers in Chinese Taipei maintained a stable and significant reversing mill production capacity throughout the POR. Over this period, declining capacity utilization from 2022 to 2025 led to increased excess capacity.^{Footnote 26}

[50] Evidence indicates that reversing mill utilization rates in Chinese Taipei remained comparatively low and declined year-over-year from 2022 to 2025, resulting in substantial excess capacity in each period of the POR. Forecast utilization rates through 2028 are insufficient to absorb available capacity.^{Footnote 27} Overall, producers in Chinese Taipei possess excess capacity that exceeds the total apparent Canadian market in every period of the POR.

[51] Based on the available evidence, the CBSA finds that both the current and potential production capacity of heavy plate producers in Chinese Taipei is substantial and that significant excess production capacity exists. Given the capital-intensive nature of heavy plate production and the high fixed costs associated with mill operations, producers have a strong incentive to pursue sales at low prices in order to improve capacity utilization. Accordingly, should the CITT’s finding expire, Canada would represent an attractive export market for producers in Chinese Taipei to absorb excess production capacity, thereby increasing the likelihood of continued or resumed dumping of subject goods into Canada.

Continued interest in and dumping into the Canadian market over the period of review

[52] CBSA enforcement data indicate that significant volumes of subject goods from Chinese Taipei were exported to Canada over POR, cumulatively reaching tens of thousands of metric tonnes over the entire period. In addition, SIMA duties were assessed in every period, amounting to more than $300,000 between 2022 and interim 2025.

[53] In October 2023, the CBSA issued a notice of initiation of a re-investigation into heavy plate, representing the first review of normal values since the original finding.^{Footnote 28} This update to normal values coincided with a sharp decline in export volumes of subject goods from Chinese Taipei, with 2023 clearly representing the peak year.

[54] However, the evidence on the record indicates that the 2023 peak is not necessarily indicative of a corresponding peak in exporter interest in the Canadian market. Total plate sales from Chinese Taipei to Canada during the interim period from January 1, 2025, to September 30, 2025, exceeded full-year 2024 volumes and, when extrapolated to a full year, were on pace to approach 2023 levels. This growth was driven by an increasing relative share of non-subject plate compared to subject goods.^{Footnote 29} This continued interest in the Canadian market is further reinforced by Chinese Taipei exporter participation in the CBSA’s 2025 administrative review.

[55] The shift toward non-subject plate indicates a continued and sustained exporter interest in the Canadian market, an interest further corroborated by the participation of a Chinese Taipei exporter in the CBSA’s 2025 administrative review. At the same time, the pronounced peak in subject exports in 2023, immediately prior to the update of normal values, may suggest a willingness to capitalize on outdated values while they remained in effect. Accordingly, should the CITT’s finding expire, exporters from Chinese Taipei would likely re-intensify exports of subject goods to the Canadian market, thereby increasing the likelihood of continued or resumed dumping into Canada.

Imposition of trade measures by Canada and other jurisdictions on Chinese Taipei

[56] Evidence on the record indicates that there are multiple antidumping measures in force in other jurisdictions including Australia, Thailand and the U.S. on steel flat products originating in Chinese Taipei. Additionally, when looking at steel products more broadly, there are dozens of measures currently in force.^{Footnote 30}

[57] In addition to these measures, at the time of this expiry review, the CBSA has anti-dumping measures in force for the following steel products originating in or exported from Chinese Taipei.^{Footnote 31}

• Corrosion-resistant steel sheet
• Carbon steel welded pipe
• Fasteners
• Oil Country tubular goods
• Concrete reinforcing bar and
• Steel wire

[58] The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in Chinese Taipei have a propensity to dump. Should the CITT’s finding expire, heavy plate producers in Chinese Taipei would be attracted to the Canadian market which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Determination regarding likelihood of continued or resumed dumping

[59] Based on evidence on the record, the CBSA determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain heavy plate originating in or exported from Chinese Taipei.

Germany

[60] The CBSA did not receive an ERQ response, case brief or reply submission from the exporters in Germany. The CBSA, therefore, relied on information submitted by the Canadian producers as well as other information on the administrative record, in considering whether the dumping of certain heavy plate from Germany is likely to resume or continue if the finding was to expire.

German steel producer overcapacity and export orientation

[61] Evidence on the record from CRU indicates that German plate producers maintained significant reversing mill capacity throughout the POR, unchanged since the beginning of 2022 and projected to remain stable through 2028. In contrast, German plate production declined consecutively from 2022 to 2025, resulting in a steadily increasing level of excess reversing mill capacity. As a result, capacity utilization of reversing mills in Germany declined from a markedly high level in 2022 to a comparative low by 2025.^{Footnote 32} This comparative low utilization in 2025 translated into excess capacity that exceeded the total apparent Canadian market in that period.

[62] Evidence on the record indicates that steel production in Germany declined during the POR, falling by 9% in 2025 compared to 2024, which was itself an already weak year. German steel production levels in 2025 were comparable to those last observed in 2009, during the global financial crisis.^{Footnote 33} Plate production followed the broader trend in the German steel sector and declined over the POR. Notwithstanding this contraction in production, exports of plate from Germany increased over the same period, rising from 859,000 metric tonnes in 2022 to a projected 952,000 metric tonnes in 2025.^{Footnote 34} As a result, plate exports as a share of total production increased substantially over the POR, indicating a growing reliance on export markets as a means of offsetting rising excess capacity.

[63] Based on the available evidence, the CBSA finds that heavy plate producers in Germany possess substantial current and potential production capacity and significant excess capacity. In the context of declining production and utilization, German producers have become increasingly export-oriented, with plate exports accounting for a growing share of total production. Given the capital-intensive nature of heavy plate production and high fixed costs, producers are incentivized to pursue low-priced export sales to improve utilization. Accordingly, should the CITT’s finding expire, Canada would represent an attractive market to absorb excess capacity, increasing the likelihood of continued or resumed dumping of subject goods into Canada.

Inability to compete at non-dumped prices

[64] During the original CBSA investigation’s POI, German goods represented 16.0% of heavy plate imports.^{Footnote 35} In comparison, based on information gathered during the POR, the relative volume of German goods had declined substantially by 2022, falling further by interim 2025. German exporters remain interested in the Canadian market, as evidenced by participation in both the re-investigation and the subsequent administrative review, in which the participating exporter was found cooperative and assigned normal values. Notwithstanding this participation, imports of German goods into Canada have declined significantly following the coming into force of the finding.

[65] While import volumes of German heavy plate were small during the POR, SIMA duties were nevertheless assessed on the imported goods, with the exception of 2023. This continued imposition of duties, together with the pronounced decline in import volumes following the implementation of the finding, indicates that German heavy plate producers are unable to compete in the Canadian market at non-dumped prices. In the event that the finding was rescinded, this would increase the likelihood of continued or resumed dumping of German heavy plate into Canada.

Determination regarding likelihood of continued or resumed dumping

[66] Based on evidence on the record, the CBSA determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain heavy plate originating in or exported from Germany.