Statement of Reasons—Expiry review determination: Hot-rolled carbon steel plate 7 (PLA7 2025 ER)

Product definition

[28] The goods subject to this expiry review investigation are defined as:

Additional product information

[29] For greater certainty, the subject goods include steel plate which contains alloys greater than required by recognized industry standards provided that the steel does not meet recognized industry standards for an alloy-grade steel plate.

[30] Hot-rolled carbon steel plate is manufactured to meet certain Canadian Standards Association (CSA) and/or American Society for Testing & Materials (ASTM) specifications, or equivalent specifications.

[31] CSA specification G40.21 covers steel for general construction purposes. In the ASTM specifications, for instance, specification A36M/A36 comprises structural plate; specification A572M/A572 comprises high-strength low-alloy steel plate; and specification A516M/A516 comprises pressure vessel quality plate. ASTM standards, such as A6/A6M and A20/A20M, recognize permissible variations for dimensions.

Exclusions

[32] For all full list of exclusions please see the exclusion^{Footnote 15} section on the Measures in Force.

Algoma Steel Inc.

[38] Algoma is a primary iron and steel producer. It has a present capacity to produce approximately 3.7 million metric tonnes (MT) of raw steel and approximately 3.4 million MT of finished steel annually. In 2022, Algoma completed Phase 1 of the Plate Mill Modernization project and completed Phase 2 in 2024. The Plate Mill Modernization project will increase Algoma’s production capacity and improve the quality of the plate produced.

[39] The Algoma Steel Corporation, Limited was originally established in 1901. On June 1, 1992, Algoma became an incorporated company, carrying on the business activities of its predecessor. On January 29, 2002, the company was re-organized under a Plan of Arrangement and Reorganization pursuant to the Companies’ Creditors Arrangement Act (“CCAA”). The company became part of Essar Steel Holdings Limited in June 2007. On May 8, 2008, the company name was changed to Essar Steel Algoma Inc.

[40] Essar Steel Algoma Inc. commenced court-supervised restructuring proceedings under the CCAA on November 9, 2015. On November 30, 2018, a group of creditors purchased the company’s assets, with the company emerging from CCAA protection as “Algoma Steel Inc.”

[41] On May 24, 2021, Algoma announced that it had entered into a merger agreement with Legato Merger Corp., which would result in Algoma becoming a publicly listed company with its common shares traded on the Nasdaq Stock Market. On October 21, 2021, Algoma became public and common shares began trading on the Nasdaq Stock Market and the Toronto Stock Exchange.^{Footnote 16}

Evraz Inc. NA Canada

[42] Evraz produces steel plates, steel sheets, as well as energy and non-energy tubular products, and processes coils in four locations in Canada. Evraz’s manufacturing facilities in Calgary, Red Deer, and Camrose, Alberta produce tubular products. Evraz’s Regina facility is the largest steel industrial complex in Western Canada; it produces steel plates, steel sheets, and tubular products. Evraz only produces steel plate at its Regina facility.

[43] Evraz's facility in Regina was formerly known as IPSCO Inc. (“IPSCO”), which was incorporated in 1956 under the name of Prairie Pipe Manufacturing Co. Ltd. It commenced operations in 1957 with the completion of an electric resistance weld pipe mill in Regina. In 1959, the company acquired assets of Interprovincial Steel Corp. Ltd. and began production of flat rolled steel in 1960, including the subject goods. Since then, the company expanded its manufacturing capabilities and established scrap companies in Canada as well as in the United States through acquisitions and plant constructions.

[44] On July 17, 2007, SSAB, a wholly owned subsidiary of SSAB Svenkst Stahl of Sweden, acquired IPSCO and its subsidiaries through a 100-percent share acquisition. Under SSAB's direction, IPSCO was reorganized to own only the Regina facility and the facilities in Calgary, Camrose, Red Deer, and the formerly owned facility in Surrey including through a wholly owned subsidiary IPSCO Canada Inc.

[45] On June 12, 2008, Evraz Group S.A., now a wholly owned subsidiary of Evraz plc., acquired IPSCO and its subsidiaries from SSAB through a share acquisition.

[46] On October 15, 2008, the names of IPSCO and IPSCO Canada Inc. were changed to Evraz Canada and Evraz Inc. NA Canada West, respectively. On January 1, 2009, Evraz Inc. NA Canada West was amalgamated into Evraz Canada.

[47] On December 13, 2013, Evraz sold its entire cut-to-length plate facility in Surrey, British Columbia to Samuel, Son & Co.

[48] On June 27, 2014, Evraz sold its cut-to-length line and the associated assets thereof, located in Regina, Saskatchewan, to Varsteel. Evraz retained its discrete plate production line in Regina.^{Footnote 17}

Steel service centres

[49] Although steel service centres’ production processes differ to some extent from those of Algoma and Evraz, steel service centres produce and sell the same products in the Canadian market, to the same end-users, for essentially the same applications.^{Footnote 18} Therefore, the Canadian industry for certain hot-rolled steel plate production is also comprised of the following steel service centres:

• Acier Nova Inc.
• Coilex Inc.
• Janco Steel
• Métal Pless
• Russel Metals Ltd.
• Samuel, Son & Co., Limited
• SSAB Central Inc.

Administrative record

[60] The information considered by the CBSA for purposes of this expiry review investigation is contained in the administrative record. The administrative record includes the information on the CBSA’s exhibit listing, which is comprised of the CBSA exhibits and information submitted by interested parties, including information which the interested parties feel is relevant to the decision as to whether dumping is likely to continue or resume absent the CITT finding. This information may consist of expert analysts’ reports, excerpts from trade publications and news articles, orders and findings issued by authorities of Canada or of a country other than Canada, documents from international trade organizations such as the World Trade Organization (WTO) and responses to the ERQs submitted by Canadian producers, exporters and importers.

[61] 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 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 investigation, the administrative record closed on April 2, 2025.

Procedural issues

[62] 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:

• the nature, relevance, materiality and volume of the information
• 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)
• 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
• 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)
• whether acceptance of the information would compromise the ability of the CBSA to conduct the proceedings expeditiously and
• any other factors that are relevant in the circumstances

[63] 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.

[64] On April 10, 2025, the CBSA received a request for leave from counsel on behalf of Algoma seeking approval to file additional documentation onto the administrative record despite the record being closed on April 2, 2025.

[65] 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 as such the submitted materials were rejected and do not form part of the administrative record. The reasoning and decision were placed on the record in accordance with CBSA procedures.^{Footnote 22}

Parties contending that continued or resumed dumping is likely

Algoma

[67] Algoma, a Canadian producer, made representations in its case brief supporting its position that dumping from Brazil, Denmark, Indonesia, Italy, Japan, and South Korea is likely to continue or resume in the event the present order is rescinded. Therefore, Algoma argued that the measures should remain in place.

[68] The main factors identified by Algoma can be summarized as follows:

• COVID-19 and the international marketplace for plate
• Resumed dumping need not be in large volumes
• Subject goods imported into Canada over the POR have been dumped
• International steel market conditions
• Conditions in the subject countries
• Export reliance of subject country producers
• Recent and past behaviour of subject country exporters
• Imposition of anti-dumping and countervailing measures by other countries
• Canadian market conditions
• Subject country exporters’ continued interest in Canada’s steel market

COVID-19 and the international marketplace for plate

[69] Algoma noted that in assessing the evidence and applying the factors of SIMR, the CBSA should be cognizant of the effects of COVID-19 pandemic (COVID-19) had on plate markets over the POR. COVID-19 caused significant price volatility in plate markets around the world. Algoma contended that prices in North America dropped to a low in August 2020 following the onset of the pandemic in Q1-Q2 2020. Algoma further stated that demand in the construction industry recovered following the initial phase of the pandemic, with prices rising to a peak in mid 2022. They further noted that this was a global trend, with each market tracked by MEPS showing the same substantial rise in prices from the fourth quarter of 2020 to at least the second quarter of 2022.^{Footnote 23}

[70] COVID-19 caused widespread supply shortages across the global economy in 2021 as demand recovered. Algoma submitted that during the initial COVID-19 lockdowns, many producers emptied their steel stocks and idled production capacities. When demand recovered, supply chains were unprepared to meet the demand. Algoma argues that the stress on supply coupled with the global shortage in shipping containers explains the spike in plate prices in described above.^{Footnote 24}

Resumed dumping need not be in large volumes

[71] Algoma presented a table showing the import volume that each subject country represented during the original inquiry, and then applied these ratios to the current volume of imports in 2024. Algoma contends that the 2024 equivalent of as little as 4,000 MT of subject goods was sufficient to support the imposition of a SIMA measure in the original inquiry that that if there is a likelihood that any subject country would sell this volume or even lower volumes to Canada at dumped prices, the CBSA must continue the order against that country.^{Footnote 25}

Subject goods imported into Canada over the POR have been dumped

[72] Algoma noted that CBSA compliance statistics show that $238,548 in SIMA duties were paid over the POR on shipments of subject goods.^{Footnote 26}

International market conditions

[73] Algoma submitted that the international market conditions provide important context for macro-economic trends effecting plate. Specifically, it was argued that several global developments are currently affecting the market for plate which would make the Canadian domestic industry susceptible to resumed dumping if the order is rescinded. These developments are further explained below.

Excess global steelmaking capacity

[74] Algoma stated that the global capacity continues to expand at a vigorous pace despite a weak outlook for steel demand and the global economy generally. At the October 2024 Global Forum on Steel Excess Capacity (GFSEC) Ministerial Meeting at the OECD, ministers and high-level representatives from 27 countries expressed grave concerns about the worsening trend of global crude steel excess capacity and the detrimental effects on their steel industries. According to the Ministerial Meeting report, “global excess capacity may have resulted in the loss of 134,000 to 190,000 steel jobs in GFSEC member economies over the past decade”.^{Footnote 27}

[75] Algoma referenced several reports on current and projected global steelmaking capacity. According to the Organisation of Economic Co-operation and Development (OECD), 2024 saw the largest increase in global steelmaking capacity since 2013, increasing by 50 million MT and reaching 2.482 billion MT in total capacity. This capacity exceeds production by 573 million MT and despite this gap between capacity and production in 2024, global capacity is expected to increase by an additional 146 million MT between 2025 and 2027.^{Footnote 28}

[76] Statements from the CITT in previous proceedings related to hot-rolled steel plate were cited as support for the effect that global overcapacity can have on trade, particularly the plate market. Previously, the CITT held that global excess capacity was directly linked to opportunistic dumping of plate in markets that can yield a higher price, in particular, the Canadian market.^{Footnote 29}

[77] Algoma submits that this excess capacity largely stems from China’s implementation of market distorting measures that increase steel production to absorb fixed costs and increase utilization. Because of the high fixed costs associated with steel production, producers globally face a production imperative to produce as much as possible to recoup these costs. Given this production imperative and excess capacity, Algoma argues that a demand imbalance is created and there is incentive to produce and export steel at injuriously low prices. Algoma submits that this situation extends to subject countries, who maintain significant excess plate production capacity.^{Footnote 30}

Weakening demand and volatile global economic conditions

[78] In terms of demand, Algoma contends that struggles in China’s property sector and subdued demand in the United States will more than offset demand growth in emerging markets and India. Steel consumption growth is projected to average 0.6% from 2024-2028, which follows consumption declines of 2.7% and 1.1% in 2022 and 2023, respectively. Furthermore, adverse geopolitical factors such as the conflict in the Middle East and rising global steel market protectionism will cause further demand volatility and drag down prices in the medium term.^{Footnote 31}

Conditions in China are exacerbating global oversupply

[79] Algoma submits that the Chinese steel market is in a state of crisis and given China’s share of global steel production, this translates into a global crisis. In 2024, finished steel export volumes from China rose 22.7% year-on-year, while the first 8 months of 2024 the value of steel exports fell 10.7% compared to the first 8 months of 2023. Algoma contends that these general trends for steel are also true for plate specifically.^{Footnote 32}

Global plate market conditions

[80] Algoma argued that production and capacity growth in the global plate market has been comparable to the trends seen in steel market as a whole, while suffering from similarly weak, if not weaker, demand levels.

Capacity and production

[81] With respect to capacity and production, Algoma has filed on the record detailed capacity, production and demand data for steel plate as reported by CRU, a business intelligence company that provides analysis, news and data for metal markets. Algoma noted that CRU’s figures likely underrepresent the true amount of global production capacity due to underreporting by China. However, based on CRU data, Algoma provided a table summarizing global production capacity on equipment that can be used to produce plate; the production volume from that equipment; and demand for the products produced on that equipment. In addition, the table highlighted excess capacity and capacity utilization on all equipment that can be used to produce plate.^{Footnote 33}

[82] Based on information presented in the Table 3 of Algoma’s case brief, capacity on equipment that can be used to produce plate has increased consistently for the past four years. Despite calls for capacity reduction from the OECG and the Global Forum on Steel Excess Capacity (GFSEC), CRU forecasts steady capacity growth on equipment that can be used to produce plate through to 2027.^{Footnote 34}

[83] While the total utilization rate for reversing mills is high and projected to increase, Algoma argues that the projected increase in reversing mill production in 2026 alone is greater than the combined volume of plate sales in Canadian market from 2020-2023. Algoma contends that in this context, Canada’s market remains significantly exposed to the millions of tonnes of excess reversing mill plate production capacity that will remain through 2027.^{Footnote 35}

Pricing

[84] Algoma stated that plate prices rose dramatically in 2021 and 2022 following a downturn at the beginning of the COVID-19 pandemic but have declined since. Algoma provided CRU data for domestic transaction prices for steel plate in select markets to illustrate the global trend albeit varying fluctuations from market-to-market. Algoma contends that pricing for USA Midwest is a reasonable proxy for Canadian pricing trends. The data indicates US plate prices will remain substantially higher than prices in other regions.^{Footnote 36}

Proliferation of trade restrictions on steel

[85] Algoma notes that at least 14 trade anti-dumping and countervailing measures affecting products matching the subject goods description are in force or have been initiated by 5 WTO members, including Canada. In addition, there are safeguard measures in the European Union (EU) that cover steel plate, extended to at least June 20, 2026, and a proposed safeguard measure in India on flat steel products, including plate. Mexico has also imposed a 25% duty on steel products from countries without free-trade or preferential tariff agreements with Mexico. Canada imposed their own 25% surtax on steel and aluminum products from China. Algoma contends, in part because of these trade restrictions, China has diverted exports from North America into other markets, including subject country markets, compelling subject country producers to increase their exports at lower prices.^{Footnote 37}

United States Section 232 Tariffs

[86] Algoma noted that on March 12, 2025, the United States implemented 25% tariffs on all steel and aluminum imports with no exceptions or exemptions. Algoma further notes the 2018 232 tariffs on steel created a substantial diversionary threat, to the extent that Canada government self-initiated a safeguard. Importantly the 2018 measures had carved out exemptions for Canada, Mexico, Argentina, Brazil, South Korea and Australia, and as mentioned, the 2025 232 tariffs contain no such exemption. Further, Algoma pointed out that these 232 tariffs are cumulative with any other tariff rates faced by the exporting country, leading some of the subject countries to face a much higher effective tariff rate than 25% in the United States.^{Footnote 38}

[87] Algoma submits that the recency and unpredictability of the new Section 232 measures enhance the likelihood that subject country exporters will target Canada if the order is rescinded. Specifically, Algoma highlights the reduced opportunity in the US market due to tariffs, the possible reduction in US competition in the Canadian market because of any retaliatory tariffs, and the increased attractiveness of dumped prices because of higher prices in Canada.^{Footnote 39}

Conditions in the subject countries

Excess capacity and production trends

All subject countries

[88] Algoma asserted that the subject countries have significant and persistent excess capacity on equipment that can be used to produce plate. In support of this position, Algoma cited CRU data indicating that subject countries have significant excess capacity. They argue that this excess capacity dwarves Canada’s total plate market, demonstrating an even small increase in capacity utilization could be sufficient to flood the Canadian market.^{Footnote 40}

Brazil

[89] Algoma cited information on the record regarding Brazil’s significant production capacity for subject goods and utilization rates that are consistently below 80% for POR, and under 50% for reversing mills. Algoma submitted that a key reason for this under utilization is rising imports, particularly from China, supressing production through lower prices. Reversing mill production capacity has grown by over 100,000 MT since 2012.^{Footnote 41}

Denmark

[90] Algoma cited information on the record regarding the production capacity of Denmark’s sole producer of steel plate, NLMK DanSteel. Although no information was available on the administrative record for plate production in Denmark, Algoma provided a methodology based on information on the record to estimate reversing mill production capacity and production in Denmark. Algoma further noted that Danish plate capacity has grown significantly since the original investigation, increasing 46% from 2012 to present.^{Footnote 42}

Indonesia

[91] Algoma cited information on the record from CRU that showing that Indonesia plate capacity increased substantially, driven by a 3 million MT per year capacity hot strip rolling mill launched by the Dexin Group in April of 2024. Algoma cited further information for projects that would add an additional 3 million MT per year in capacity not captured by the CRU estimates. Reversing mill capacity has increased more than six-fold from 2012 to 2025, and excess capacity on reversing mills is projected to more than double from 2024 to 2027.^{Footnote 43}

Italy

[92] Algoma cited information on the record that shows that the utilization rate of both reversing mill and total equipment capable of producing steel plate entered a sharp decline in 2024 and is projected to remain at this lower level into 2027. Algoma submits this decline in utilization rate is result of high existing capacity and a lack of sufficient demand. Italian steelmakers are facing rising import competition from Asia, low prices and high energy and production costs, leading to a leading Italian steel maker, Acciaierie d'Italia being placed under special administration by the Italian government, pending the potential sale to Baku Steel. Despite the ongoing challenges in the Italian steel industry, Metinvest group is planning to open a facility capable of producing 2.7 million MT of hot-rolled coil per year when operational in 2027, which is not factored into the production capacity numbers provided by CRU.^{Footnote 44}

Japan

[93] Algoma submits that data on the record from CRU for Japan’s production and capacity contains reporting errors but have been provided for completeness. Algoma instead relies on just the reversing mill production and capacity, as it is not impacted by the reporting error. In terms of reversing mill excess capacity, Japan had the highest excess capacity of any of the subject countries from 2021-2023, dropping to third highest in 2024, closely behind Italy and South Korea. Algoma notes that there is uncertainty about the ongoing potential closure, suspension or re-organization of Nippon Steel’s Kashima plate rolling mill, with the blast furnace being suspended but the future of the plate lines inconclusive. Algoma further notes that the CRU capacity data fails to include projected production capacity from a new 6 million MT per year facility announced by Nippon Steel at Nagoya steelworks to open in 2026.^{Footnote 45}

South Korea

[94] Algoma submits that data on the record demonstrates that South Korea has extremely high levels of excess capacity on both reversing mill plate equipment and total equipment capable of producing plate. South Korea reversing mill excess capacity in each year from 2025-2027 is projected to substantially exceed the total plate consumption in Canada for 2024. Algoma contends that reversing mill utilization rate is projected to notably drop from 2024 to 2025, reflecting a broader crisis in South Korea’s steel industry, with the three largest steel producers facing substantial drops in their year on-year operating profits.^{Footnote 46}

Worsening domestic conditions in the subject countries

Weak domestic demand and economic outlook

[95] Algoma provided a table regarding total steel plate and reversing mill plate consumption trends and forecasts for Brazil, Indonesia, Italy, Japan, South Korea and EU+UK. With respect to Denmark, Algoma contends that since a significant portion of Denmark’s production is exported based on UN Comtrade Data, regional European plate consumption trends are more accurate indicator of Denmark’s demand outlook than plate consumption in Denmark. The table shows that global reversing mill plate consumption is projected to contract from 2024 through 2026, growing slightly in 2027.^{Footnote 47}

Brazil

[96] Brazilian demand for reversing mill plate consumption is projected to be lower in 2027 than in 2022. Algoma contends that even this forecast is optimistic, given critical vulnerabilities in plate-reliant sectors. Algoma contends that the Brazilian government is facing fiscal constraints including a primary budget deficit of 0.5% of GDP and 80% debt-to-GDP ratio that will limit the government’s ability to fund planned industrial investments. Private infrastructure projects that require steel plate like bridges and industrial complexes also face higher borrowing costs with. Brazilian industrial production is also in a period of contraction, with month over month declines in output in October, November and December of 2024. Increased borrowing costs are also being faced by manufacturers, delaying capital expenditures on equipment and expansion. Algoma cites ArcelorMittal’s decision to postpone indefinity a significant investment of R$4 billion in its primary steel production facility as indicative of the extent to which industrial contraction and fiscal austerity are undercutting demand drivers in Brazil.^{Footnote 48}

Denmark’s primary export markets

[97] Algoma contends that Denmark’s export markets are a more suitable proxy for Danish plate demand that their domestic market. The vast majority of Danish plate is exported either within the EU or to Norway, with Germany has absorbed nearly a third of Danish exports in each year from 2021 to 2024. Algoma submits that Germany faces a dismal economic outlook. To support this, Algoma notes that German construction industry is estimated to have shrunk by 4.4% in 2024 and is projected to contract again in 2025. Algoma notes that the European steel and commodity plate markets have significantly more supply than demand and have seen continued contraction since April 2022. Both steel consumption and plate consumption fell in the EU for 2024. Algoma submits that NLMK DanSteel faces intense competition from low-priced imports into this European market from Asia. This is further exacerbated by a structural decline in the European shipbuilding sector, a key end-user for their plates.^{Footnote 49}

Indonesia

[98] Algoma cites evidence on the record that plate consumption in Indonesia is expected to decline significantly from 2024 to 2025 and is forecasted to remain below 2024 levels through 2027. A major downstream demand driver for Indonesia’s steel plate is heavy equipment, 40% of which is used in mining. Algoma contends that slumping coal prices as well as declining bauxite and tin production indicates weaker demand for heavy equipment and therefore Indonesia’s steel plate industry. Another possible source of significant demand, the Nusantara project, has faced significant delays and budget cuts, meaning any uptick in steel plated demand tied to the project will now materialize far more slowly if at all.^{Footnote 50}

Italy

[99] Algoma cites evidence on the record from Italy’s National Statistics Institute (Istat) that they believe demonstrates concerning trends for Italy’s plate sector. Algoma points to a drop in fixed investment growth in 2024 as compared to 2023 and a contraction in industrial production in the same period. A scaling back of the Superbonus tax scheme progressively from 110% deduction to 65% deduction from 2020 to 2025 is in part responsible for a projected 0.9% contraction in the construction industry for 2025. Italy faced a significant decline in plate consumption from 2023 to 2024, and while forecasts project plate consumption growth in 2026 and 2027, overall consumption is projected to be lower than each year of 2021 through 2023.^{Footnote 51}

Japan

[100] Algoma cites evidence on the record, showing forecasted plate consumption would remain flat from 2024 to 2027, ending lower than 2021 or 2022. Industrial output fell for the third consecutive year in 2024, declining 2.3% from 2023. Algoma also cites sources that show a weak outlook for construction activity in Japan, with the residential building sector anticipated to contract at an average annual rate of 3.4% from 2025-2034. Algoma submits that the stagnation in downstream plate-consuming sectors is compounded by competition from low-costs imports from China, straining the Japanese steel industry.^{Footnote 52}

South Korea

[101] Algoma cites evidence on the record that shows that South Korea has experienced the largest decline in domestic plate since 2023 of all subject countries in respect to volume. This slump in demand can mainly be attributed to South Korea’s struggling construction sector, which is facing a declining population and already high urbanization rates, with construction orders and completions being lower in 2024 than 2023.^{Footnote 53}

Rising import competition

[102] Algoma cites evidence on the record that shows that in aggregate, plate imports into subject countries have steadily increased from 2021 to 2023. Algoma notes that the data for 2024 is incomplete due to import data not being available for all subject countries. Algoma contends that import competition is particularly pronounced for South Korea and Indonesia, respectively seeing plate imports more than double and quadruple from 2021 to 2023. Chinese plate accounts for the bulk of the import growth experienced by Indonesia, Japan and South Korea. In the first ten months of 2024, China exported over 1 million MT of plate to South Korea, accounting for 62.7% of South Korea’s total plate imports.^{Footnote 54}

[103] South Korea has announced provisional anti-dumping duties on Chinese hot-rolled plate; however, Algoma submits this may have limited effectiveness at curbing Chinese imports. This is attributed to the structure of the South Korean plate market, which has a substantial amount of plate sold to shipbuilders who can avoid paying duties or taxes through the bonded factory system. Algoma contends that South Korea plate producers will further prioritize exports in an effort to offset losses to Chinese import competition.^{Footnote 55}

[104] Algoma argues that Japan and Indonesia are facing similar problems in their plate industries with the influx of cheaper Chinese imports. In the April to September period of 2024, Japan reached a ten year high in terms of steel imports. Despite anti-dumping measures against Chinese plate, Indonesian imports of Chinese plate increased substantially from 2021 to 2023. Continued slowdown in Chinse demand and growing regional steel capacity mean the situation is unlikely to improve for Indonesia.^{Footnote 56}

[105] Italy has also seen a rise in steel plate imports from 2021 to 2024, with plate imports from South Korea leading the way. Algoma contends that the rise of South Korean imports into Italy is the result of displacement caused by Chinese imports into South Korea. Brazil has taken a permissive stance on steel plate imports, and Algoma submits that this combined with subdued domestic demand growth will likely place sustained downward pressure on local plate prices. Overall, Algoma contends that import saturation in the subject countries will ultimately limit subject country producers’ ability to rely on their domestic markets to absorb additional plate production.^{Footnote 57}

Reliance of Danish and Italian plate producers on Russian slab imports

[106] In 2022, Canada imposed sanctions that prohibited the importation of Russian steel. The EU similarly sanctioned Russian steel imports; however, Algoma notes the EU carved out an exception for Russian-owned plate mills, including in Denmark and Italy, allowing them to continue sourcing Russian slab. Algoma contends that the CBSA must consider the potential presence of a Particular Market Situation (PMS) to assess the likelihood of resumed dumping. Algoma notes that NLMK DanSteel in Denmark sources 74% of it’s slab from Russia and NLMK Verona in Italy supplies approximately 70% of their slab from Russian sources. Algoma argues that Russian slab pricing has diverged to the downside in comparison to global pricing and NLMK DanSteel and Verona’s purchase of Russian slab distorts their production costs, potentially resulting in a PMS in these markets.^{Footnote 58}

Export reliance of subject country producers

Strong growth in plate exports from the subject countries over the POR

[107] Algoma cites evidence on the record that shows that in aggregate, plate exports from subject countries increased significantly from 2021 to 2023. Every individual subject country showed export growth with the exception of Indonesia. Algoma submits that the export levels are significant, representing a substantial portion of the annual reversing mill plate production from subject countries for 2021-2023.^{Footnote 59}

[108] Exports accounted for the majority of Italian production in 2023, and nearly one third of production in both Japan and South Korea. Brazil, which had the lowest portion of exports, still saw exports as a share of production increase by seven percentage points from 2021 through 2023. Denmark’s exports have also increased since 2018, the last year of the POR for the previous expiry review. Algoma argues subject country producers are growing increasingly reliant on exports and this strongly indicates that they would return to Canadian market, directly or indirectly, if the order were rescinded.^{Footnote 60}

Displacement of subject countries’ positions in existing export markets

[109] Algoma argues that, despite export growth in the subject countries, new trade restrictions and environmental regulations threaten their presence in key foreign markets. In 2023, over half of Indonesia’s total plate exports were sent to the EU; however, stricter environmental regulations beginning in 2026 are expected to make Indonesia a less attractive supplier for EU importers. South Korea faces challenges in two of its primary markets: the United States, due to the blanket 25% Section 232 tariffs, and the EU, where duty-free quotas on hot-rolled steel have been reduced. Meanwhile, India has proposed a 12% safeguard on flat steel products, impacting another major export market for steel plate. The Danish plate industry is struggling with an oversupplied European market. While the US is not a major destination for Danish plate, the displacement of EU plate exports to the US could further exacerbate oversupply in European markets.^{Footnote 61}

Recent and past behaviour of subject country exporters

The subject countries have a proven tendency to resume dumping

[110] Algoma notes that the order is not the first SIMA measure to have been imposed on plate from the subject countries, stating Brazil and Denmark in Plate 1, Italy and South Korea in Plate II, and Brazil in Plate IV all had measures against them that were subsequently rescinded.^{Footnote 62}

Inability or unwillingness to sell at normal values

[111] Algoma argues that normal values issued to Korean exporters had become out of date and ineffective, until being updated during normal value reviews that concluded in December of 2023. Algoma submits that CBSA’s import data from all subject countries supports an inference that producers and exporters from subject countries either struggle or are unable to sell plate at un-dumped prices to Canada.^{Footnote 63}

Dumping by the subject countries of other products in Canada

[112] Algoma provided a table containing a list of the other SIMA findings in place for steel products from the subject countries. Brazil and Italy are included in one other finding, Indonesia and Japan in two other findings, and South Korea in six other findings, with only Denmark not having any other SIMA findings for steel products against them. Algoma notes that Hollow Structural Sections (HSS) for Brazil as well as Cold-Rolled Steel (CRS) and Corrosion-resistant steel sheet (COR) for South Korea implicate producers who also manufacture plate, underlining the propensity of these producers to dump in the Canadian market.^{Footnote 64}

Evidence that the subject countries are dumping in other markets

[113] Algoma argues that subject country producers and exporters have a propensity to dump in other export markets. Algoma points first to the US DOC decision to increase anti-dumping duties on hot-rolled steel sheet from Nippon Steel, based on a review of October 2022 to September 2023, a closely related product to steel plate.^{Footnote 65}

[114] In addition to the above, Algoma submits that a comparison of generalized export and home market pricing can indicate a clear pattern of selling below home market pricing in export pricing. Algoma argues that where such a pattern does not exist, this should not be taken as an indication that exporters from the country in question do not dump on export markets. Algoma submits that evidence suggests a general pattern of selling below their home market pricing in most quarters for Denmark, Japan, and South Korea.^{Footnote 66}

[115] Algoma submits that because MEPS, CRU and Fastmarkets do not specifically publish Danish plate price data, MEPS Nordic Steel Prices are the most appropriate proxy for Danish home market prices. Compared to the average of high and low of MEPS pricing, Danish export prices were lower in four out of ten of the quarters analyzed. Algoma contends, based on an analysis of price extras for different plate grades that DanSteel was likely selling, Denmark may in fact have been underselling its home market by an even greater margin.^{Footnote 67}

[116] Algoma cites evidence on the record to show that Japan exhibits the widest and most sustained price gap between export and home market prices over the POR of any subject country. The table Algoma provides displays a negative price differential for every quarter and every year of the POR, a differential that has increased over the POR.^{Footnote 68}

[117] Algoma excluded exports to the United Staes from South Korea when calculating export prices in calculating the home market and export market price comparison for South Korea. Algoma submits that exports to the US were subject to anti-dumping and countervailing duties that would render those export prices incomparable with likely pricing to Canada in absence of the order. While 2024 pricing was not available, South Korea’s plate export prices were lower than home market prices in five of eight quarters in 2022 and 2023, using this methodology.^{Footnote 69}

[118] Algoma submits that upon revocation of anti-dumping duties against Brazilian hot-rolled plate by the US DOC in 2023, Brazilian exporters re-entered the market in substantial volumes and price points that were lower than Brazil’s home market pricing, underscoring their propensity to dump in the North American market.^{Footnote 70}

Imposition of Anti-Dumping and Countervailing Measures by other Countries

[119] Algoma provides Table 23, which lists the current measures in force for plate from the subject countries. Algoma notes that of the 13 measures provided, 10 were imposed after the imposition of the original PLA7 finding in 2014.^{Footnote 71}

Canadian market conditions

General economic conditions

[120] Aided by receding inflationary pressures, Algoma asserted that the Canadian economy is entering a period of moderate growth that would make it attractive to subject country exporters if the order were to expire. In January of 2025, the Bank of Canada (BOC) announced that Canada’s economic growth would accelerate to 1.8% in 2025 and 2026, compared to 1.3% in 2024 while the IMF projects growth of 2.0% in 2025 and 2026.^{Footnote 72}

[121] Algoma notes that despite positive trends, economic growth may face challenges including an increase in CPI inflation and depreciation of the Canadian dollar. Further, escalation of trades tensions with the United States could weigh heavily on the economics outlook for 2025 and 2026, as the US remains the largest market for Canada’s manufactured goods.^{Footnote 73}

Canadian plate market conditions

[122] Algoma provided a table that provided actual and forecasted domestic plate consumption for reversing mill plate in Canada for the period of 2021 to 2027. The table showed a stabilizing plate market in 2024, with mild growth in 2025 to 2027. Algoma argues that this stability and growth are now less likely in the fact of US tariffs on Canada. Algoma submits that prior to this imposition of tariffs, Canada had demand trends that were more robust than subject countries.^{Footnote 74}

[123] After volatility in 2020 and 2021 related to the pandemic, Canada returned to pre-COVID-19 consumption levels quickly, with growth in demand being maintained since 2023. This contrasts sharply with the subject countries, with Japan, South Korea and Italy having plate consumption in 2024 that was far lower than in 2019. Indonesia saw growth from 2019 to 2024, but this growth is expected to reverse in 2025 to 2027. This leaves only Brazil exhibiting comparable demand stability to Canada.^{Footnote 75}

[124] Algoma submits that Canada’s 25% retaliatory tariffs on US steel products, which includes plate, will likely displace a significant portion of US supply. From the period of 2022-2024, the US represented over half of all plate imports. Algoma argues that this presents an attractive opportunity for subject exporters to replace these US imports with their own product.^{Footnote 76}

Attractiveness of the Canadian and North American plate market

[125] Algoma contends that Canada is a key import destination for steel globally, including for reversing mill plate. Algoma argues that Canada is an attractive market for plate exporters due to relatively higher prices for plate in Canada than other markets. Algoma presented a table demonstrating that Canada had higher prices than other markets aside from the US since 2021. Algoma contends these price differences make Canada a particularly attractive market for subject country exporters. Algoma notes that domestic prices have continued to rise in Canada in the first months of 2025, alongside rises in US prices in the same period. Algoma also notes that Canada could be attractive to South Korean and Danish exporters in regard to specifically plate used in ship building and wind tower industries.^{Footnote 77}

Low-priced competition from other import sources

[126] Algoma argues that there has been a significant growth in low priced imports of steel plate to Canada from other countries including France, Taiwan and Turkey that subject exporters would need to compete with if the order were rescinded. To support this, Algoma submits volume share of these countries, in addition to South Korea, for the years 2020 to 2024 as well as average unit value of imports compared with US unit values. Algoma notes that the delta between the aforementioned countries and the US did compress in 2024, they argue that this compression has reversed in the beginning of 2025. Ultimately, Algoma argues that the presence of low-priced imports would require subject exporters to price aggressively to gain market share should the order be rescinded, incentivizing exporters to dump into Canada.^{Footnote 78}

Subject country exporters’ continued interest in Canada’s steel market

[127] Algoma submits that while there is evidence that supports subject country exporters’ strong interest in the Canadian market for non-subject steel plate and other flat products, exporters need not have direct interest in the Canadian market to sell plate into Canada. Algoma supported this by citing both Nova Steel’s letter of support and their own employee to describe the system of distributors and brokers who will source plate from a range of countries and mills and will shift sources when a Canadian trade measure is imposed.^{Footnote 79}

Exports of non-subject steel plate

[128] Algoma cited evidence on the record that shows that large volumes of non-subject and smaller quantities of subject plate, mostly from South Korea, entered Canada over the POR. Algoma argues that South Korean exporters have chosen to sell under product and producer exclusions, avoiding sales of product covered by the order, particularly after normal values were updated for subject producers Dongkuk and POSCO. Algoma also cited evidence that Japan had sold non-subject plate into Canada in each year of the POR, maintaining a presence in the Canadian plate market.^{Footnote 80}

Traders and exporters targeting growth in Canada

[129] Algoma argues that POSCO provides contradictory statements in their ERQ response. Algoma notes that while on one hand POSCO argues it will not return to the Canadian market should the order be rescinded, POSCO also urges the CBSA to initiate a proceeding to update POSCO’s normal values. Algoma quotes POSCO’s own ERQ response:

Exports of other flat products by subject country exporters

[130] Outside of South Korea, Algoma submits that steel exporters and producers from other subject countries have also demonstrated their attraction to the Canadian market through the importation of non-plate steel product in significant volumes. Algoma provided a table for the imports of various flat-rolled product categories for the subject countries and noted in their brief which products each subject country was involved in for the period of 2020 to 2024. They further provided similar information for the beginning of 2025. Algoma contended that this represents footholds in the Canadian market that provide established channels for plate from the subject countries should the order be rescinded.^{Footnote 83}

Account-specific evidence

[131] Algoma stated that their own commercial intelligence indicates that certain subject country exporters have been very active in offering and exporting low-priced flat steel to the Canadian market, particularly South Korea, Japan and Italy. To support their position, Algoma filed commercial evidence showing specific instances pertaining to sales of flat rolled product from subject exporters into Canada that under cut Algoma’s own pricing from the aforementioned countries. Algoma noted that all of the instances they reported came from exporters that also produced subject goods as well.^{Footnote 84}

Evraz

[132] Evraz stated they support Algoma’s position that should the order be allowed to expire, exporters from Brazil, Denmark, Indonesia, Italy, Japan, and South Korea are likely to resume dumping subject goods into the Canadian market.^{Footnote 85}

[133] Evraz pointed to economic conditions in the subject countries, arguing that poor home economic markets in the subject countries will encourage subject country producers to turn to more attractive export markets, including Canada. Evraz also pointed to steeper-than-expected downward trend in the European steel market in 2024 and 2025, meaning this market will not provide a viable alterative for subject country producers.^{Footnote 86}

[134] Evraz argues that the trade restrictions in the United States, including quota restrictions on EU exports, section 232 tariffs and reciprocal tariffs imposed by President Trump in 2025 which will restrict access to the otherwise attractive US market, which required subject country producers to seek other markets including Canada. Additionally, Evraz argues that despite the aforementioned bearish demand conditions, subject country producers have not reduced their production capacity. Evraz contends that a lack of imports into Canada from subject countries demonstrates an inability for subject country producers to maintain sales at normal values and requiring them to offer dumped prices to gain sales should the order be rescinded.^{Footnote 87}

Nova

[135] Nova provided a case brief that supported the position that should the order be allowed to expire, exporters from Brazil, Denmark, Indonesia, Italy, Japan, and South Korea are likely to resume dumping subject goods into the Canadian market. Nova submitted that producers from a diverse range of countries are able to access the Canadian market through foreign and North American steel trading companies. These trading companies will solicit steel mills in different countries to develop the most attractive offers for customers in Canada. Nova argues that this means foreign mills need not have any direct relationships or connections with Canadian customers in order to sell into the Canadian market at prices that bear no relationship with Canadian market pricing.^{Footnote 88}

Other Canadian producers

[136] Two Canadian service centres, SSAB^{Footnote 89} and Janco Steel Ltd.^{Footnote 90}, submitted letters endorsing the case brief filed by Algoma, supporting the notion that if the order were to expire, it would likely result in the continuation and/or resumption of dumping of subject goods from Brazil, Denmark, Indonesia, Italy, Japan, and South Korea.

Parties contending that continued or resumed dumping is unlikely

[137] One party—a producer and exporter of certain steel plate from South Korea, POSCO—contended that there was no likelihood that POSCO would resume dumping should the order be rescinded. To support this position, in their ERQ response, POSCO provided what they called a sample Normal Value Request for Information response, which they argue demonstrates the great care they take to ensure that any pricing of its products sold to Canada are above any normal values.^{Footnote 91}

[138] In addition to the information provided in their ERQ response, POSCO provided reply submissions directed at the case briefs provided to the CBSA by Algoma and Evraz. Respecting allegations of South Korea and by extension POSCO’s high levels of excess capacity for reversing mill plate equipment and total equipment capable of producing plate, POSCO argues that due to their responsibility to maintain a stable supply of various steel products as the largest South Korean steel producer, they cannot increase the production of thick plate products.^{Footnote 92}

[139] Respecting assertions that Algoma and Evraz made that POSCO’s capacity utilization is declining, POSCO argued this is inexact, pointing to their ERQ response appendices. POSCO contends that the data contradicts allegations that POSCO had reduced their steel production in 2024.^{Footnote 93}

[140] POSCO addresses the Canadian market and acknowledges that current market conditions are uncertain. POSCO reiterates information they provided in their ERQ response regarding their particular interest in meeting the demand for specialty steels, which POSCO argues they are uniquely qualified to address. This includes high-quality steel for the US market for industries including automobile, power generators, and defense steel, making the US their most important export market. Further, POSCO sees demand for domestic ship building industry and shipbuilding industry in the US. POSCO notes that the steel plate designed for their domestic industry differ from the plate utilized in the Canadian ship building industry and POSCO has no plans to sell shipbuilding plate into Canada.^{Footnote 94}

[141] POSCO contends that Algoma has failed to take into consideration the requirement for specialty steel in Canada. POSCO argues that Canadian mills may not have such capacity to supply these required specialty steel products, but that POSCO does. They further argue that POSCO’s current export volumes to Canada have been steady and comparatively low, reflecting their fulfillment of speciality product demand otherwise unavailable in Canada.^{Footnote 95}

Brazil

[151] The CBSA did not receive an ERQ response, case brief or reply submission from the known producer in Brazil. The CBSA, therefore, relied on information submitted by participating parities, as well as other information on the administrative record in considering whether the dumping of subject goods from Brazil is likely to resume or continue if the order were to expire.

Brazil’s steel plate production and overcapacity

[152] Evidence on the record indicates that Brazil has substantial production capacity for subject goods during the POR. Brazil’s reversing mill capacity remained stable during the POR, and their total capacity for equipment capable of producing subject goods increased from slightly from 2022 to 2024.^{Footnote 100}

[153] Evidence shows that utilization rates of Brazil’s reversing mills were below 50% for each year of the POR, starting at 49.5% in 2022 and declining to 45.8% by 2024. As such, Brazil possessed excess reversing mill capacity that more than exceeded the total apparent Canadian market in each year of the POR based on figures in Table 2.^{Footnote 101}

[154] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in Brazil. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for steel plate producers in the Brazil to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Imposition of trade measures by Canada and other jurisdictions on Brazil

[155] Evidence on the record suggests that there are at least eleven other measures in other jurisdictions including Argentina, Chinese Taipei, European Union, Mexico, Thailand, Türkiye United Kingdom, and the United States on various steel products from Brazil.^{Footnote 102} With respect to anti-dumping findings for plate products specifically, Brazil has had three findings against them, from Chinese Taipei, India and the United States.^{Footnote 103}

[156] In addition to these measures, as of April 2, 2025, the CBSA has anti-dumping measures in force for one additional steel product, Flat Hot-Rolled Carbon And Alloy Steel Sheet And Strips, originating in or exported from Brazil.^{Footnote 104}

[157] The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in Brazil have a propensity to dump. Should the CITT’s finding expire, steel plate producers in Brazil 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: Brazil

[158] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; Brazil’s steel plate production and overcapacity; and the imposition of trade measures by Canada and other jurisdictions on Brazil, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from Brazil.

Denmark

[159] The CBSA did not receive an ERQ response, case brief or reply submission from the known producer in Denmark. The CBSA, therefore, relied on information submitted by participating parities, as well as other information on the administrative record in considering whether the dumping of subject goods from Denmark is likely to resume or continue if the order were to expire.

Denmark’s steel plate production and overcapacity

[160] NLMK DanSteel, Denmark’s sole plate producer, reports an annual production capacity of 550,000 MT on its website.^{Footnote 105} However, UN Comtrade data^{Footnote 106} indicates that exports for HS Codes 7208.51 and 7208.52 have consistently exceeded this volume each year of the POR, as well as in 2021.

[161] Given that actual export volumes surpass the producer’s stated capacity, the CBSA considers the evidence on the administrative record that indicates NLMK DanSteel maintained an annual reversing mill plate production capacity that exceeds the 550,000 MT figure to be more reliable. While the exact capacity figure is confidential, the figure reflects a 45.9% increase since the POI of the original investigation and a 37.5% rise from 2020.^{Footnote 107}

[162] While direct evidence on Danish plate production was not available on the administrative record, given that the UN Comtrade data shows that Danish plate exports represented a sizable majority of Denmark’s annual plate production capacity in each year of the POR, those export volumes represent a reasonable estimate for Danish production volumes.

[163] During the POR, capacity utilization remained relatively stable, with excess capacity being at least 100,000 MT annually in each year of the POR. When compared to Canadian domestic sales volumes in those years, the excess capacity represented a significant portion of the domestic sales volumes as reported in Table 2.^{Footnote 108}

[164] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in Denmark. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for the steel plate producer in the Denmark to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Denmark’s high export dependency and the weak market conditions in the destination of its plate exports

[165] As previously indicated, direct evidence on Danish plate production was not available on the administrative record. However, the UN Comtrade data shows that Danish plate exports represented a sizable majority of Denmark’s annual plate production capacity in each year of the POR. The data demonstrates a clear high dependence on exports to absorb plate production in Denmark.

[166] The UN Comtrade data shows that destination for the vast majority of Denmark’s plate exports are within the EU or to Norway, with Germany taking nearly one third of exports in each year of the POR. Evidence on the record indicates that economic conditions in Germany are declining, with consecutive years of annual GDP contractions, in 2023 and 2024.^{Footnote 109} In particular areas that generate downstream plate demand, the declines may be even more serious. The German construction industry shrank 4.4% in real terms in 2024 and is projected to decline again in 2025.^{Footnote 110}

[167] Evidence on the record indicates that the broader European steel market is facing difficulties. Steel consumption in the EU contracted by 9% in 2023 and a further 2.3% in 2024.^{Footnote 111} This weakness has extended to a key end-use market for NMLK DanSteel’s plate^{Footnote 112}, the shipbuilding sector. When looking at the European, UK and Norwegian shipbuilding sectors in aggregate, completions fell 25.9% and orders fell by 27.2% comparing 2019 to 2023.^{Footnote 113}

[168] Based on the available evidence, the CBSA finds that NLMK DanSteel’s high export dependency in combination with weak economic conditions in their traditional export destinations increase the likelihood of continued or resumed dumping of subject goods into Canada that should the CITT order be expired.

Determination regarding likelihood of continued or resumed dumping: Denmark

[169] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; Denmark’s steel plate production and overcapacity; and Denmark’s high export dependency and the weak market conditions in the destination of its plate exports, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from Denmark.

Indonesia

[170] The CBSA did not receive an ERQ response, case brief or reply submission from the known producer in Indonesia. The CBSA, therefore, relied on information submitted by participating parities, as well as other information on the administrative record in considering whether the dumping of subject goods from Indonesia is likely to resume or continue if the order were to expire.

Indonesia’s steel plate production and overcapacity

[171] Evidence on the record from CRU shows that Indonesia’s total production capacity for equipment capable of producing subject goods is substantial and increased during the POR. Reversing mill capacity also increased over the POR. The 2024 reversing mill capacity demonstrates the rapid growth in capacity since the original investigation POI, increasing more than six-fold from their 2012 capacity.^{Footnote 114}

[172] Evidence on the record shows that an additional 3 million MT in production capacity, above and beyond the increases documented by CRU, for equipment capable of producing subject goods were commissioned during the POR, stemming from projects announced by New Asia International^{Footnote 115} and PT Lautan Baja.^{Footnote 116}

[173] Capacity utilization for both all equipment capable of producing subject goods and reversing mill plate rose during the POR. Capacity utilization for reversing mills rose from 76.3% in 2022 to 87.2% and 86.9% in 2023 and 2024 respectively.^{Footnote 117} Evidence on the record indicates that this higher capacity utilization rate is anticipated to fall back to below 2022 levels in 2025 through 2027. While reversing mill capacity utilization rates were high and rose during the POR, excess capacity in reversing mills was still substantial, exceeding the total apparent Canadian market in some years of the POR, based on figures from Table 2.

[174] Given Indonesia’s rapid expansion of reversing mill capacity and aforementioned project announcements of further production facilities capable of producing subject goods, the excess capacity for steel plate is likely to only increase.

[175] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in Indonesia. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for the steel plate producers in the Indonesia to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Imposition of trade measures by Canada and other jurisdictions on Indonesia

[176] Evidence on the record suggests that there are at least sixteen other measures in other jurisdictions including Australia, China, Chinese Taipei, The European Union, Malaysia, South Korea, Thailand, Türkiye, The United States, and Vietnam on various steel products from Indonesia.^{Footnote 118} With respect to anti-dumping findings for plate products specifically, Indonesia has had two findings against them, from Chinese Taipei and the United States.^{Footnote 119}

[177] In addition to these measures, as of April 2, 2025, the CBSA has anti-dumping measures in force for two additional steel products, Concrete Reinforcing Bar 3 and Oil Country Tubular Goods 2, originating in or exported from Indonesia.^{Footnote 120}

[178] The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in Indonesia have a propensity to dump. Should the CITT’s finding expire, steel plate producers in Indonesia 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: Indonesia

[179] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; Indonesia’s steel plate production and overcapacity; and the imposition of trade measures by Canada and other jurisdictions on Indonesia, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from Indonesia.

Italy

[180] The CBSA did not receive an ERQ response, case brief or reply submission from the known producer in Italy. The CBSA, therefore, relied on information submitted by participating parities, as well as other information on the administrative record in considering whether the dumping of subject goods from Italy is likely to resume or continue if the order were to expire.

Italy’s steel plate production and overcapacity

[181] Evidence on the record from CRU showed that producers in Italy have substantial production capacity for subject goods, and this production capacity remained stable throughout the POR and is projected to remain stable through 2027.^{Footnote 121}

[182] However, additional evidence on the record indicates that Italy’s production capacity for equipment capable of producing subject goods will increase. Italy and the large steel maker Metinvest have signed a declaration regarding the construction of a steel plat in Piombino that will be capable of producing 2.7 million MT of hot-rolled coils per year and anticipated to be operational in 2027.^{Footnote 122}

[183] Both total production and reversing mill production declined noticeably from 2022 to 2024, leading to a marked decline in utilization rates and a sharp increase in excess capacity over the same period. Respecting reversing mill utilization, this declined from 57.6% in 2022 to 46.6% in 2024.^{Footnote 123} Based on these utilization rates, Even the smaller excess capacity in 2022 represents a figure that is several times larger the apparent Canadian market based on Table 2. Further, given the afore mentioned project announcement of another production facility capable of producing subject goods, the excess capacity for steel plate is likely to only increase in the future.^{Footnote 124}

[184] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in Italy. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for the steel plate producers in the Italy to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Imposition of trade measures by Canada and other jurisdictions on Italy

[185] Evidence on the record suggests that there are at least nine other measures in the United States on various steel products from Italy.^{Footnote 125} With respect to anti-dumping findings for plate products specifically, Italy has had one finding against them, from the United States.^{Footnote 126}

[186] In addition to these measures, as of April 2, 2025, the CBSA has anti-dumping measures in force for one additional steel product, Concrete Reinforcing Bar 3, originating in or exported from Italy.^{Footnote 127}

The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in Italy have a propensity to dump. Should the CITT’s finding expire, steel plate producers in Italy 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: Italy

[187] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; Italy’s steel plate production and overcapacity; and the imposition of trade measures by Canada and other jurisdictions on Italy, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from Italy.

Japan

[188] The CBSA did not receive an ERQ response, case brief or reply submission from the known producer in Japan. The CBSA, therefore, relied on information submitted by participating parities, as well as other information on the administrative record in considering whether the dumping of subject goods from Japan is likely to resume or continue if the order were to expire.

Japan’s steel plate production and overcapacity

[189] As noted earlier in this report, there are reporting errors in information on the record from CRU respecting the production capacity and utilization rates for equipment capable of producing the subject goods for Japan. However, the information on reversing mill capacity and utilization is not impacted by these errors. As such, only the reversing mill production and utilization will be outlined.

[190] Evidence on the record showed that producers in Japan have substantial production capacity for subject goods. Japan’s reversing mill capacity declined during the POR. However, even this reduced reversing mill capacity in 2024 represented very significant capacity capabilities.^{Footnote 128}

[191] Some of this capacity reduction was offset by falling production, resulting in relatively stable utilization rates of 79.4% in 2022, 73.7% in 2023 and 83.4% in 2024.^{Footnote 129} As such, Japan had an excess reversing mill capacity that ranged from the highest to the third highest amongst subject countries during the POR. This represented excess capacity that was far in excess of the total apparent Canadian market based on Table 2.

[192] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in Japan. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for the steel plate producers in the Japan to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Imposition of trade measures by Canada and other jurisdictions on Japan

[193] Evidence on the record suggests that there are at least twenty other measures in other jurisdictions including Australia, China, The European Union, India, Indonesia, Malaysia, Mexico, South Korea, Thailand, and The United States on various steel products from Japan.^{Footnote 130} With respect to anti-dumping findings for plate products specifically, Japan has had two findings against them, from Mexico and the United States.^{Footnote 131}

[194] In addition to these measures, as of April 2, 2025, the CBSA has anti-dumping measures in force for two additional steel products, Concrete Reinforcing Bar 2 and Large Line Pipe, originating in or exported from Japan.^{Footnote 132}

The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in Japan have a propensity to dump. Should the CITT’s finding expire, steel plate producers in Japan 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: Japan

[195] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; Japan’s steel plate production and overcapacity; and the imposition of trade measures by Canada and other jurisdictions on Japan, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from Japan.

South Korea

[196] The CBSA received an ERQ response and reply submissions from one exporter located in South Korea, POSCO. POSCO expressed an opinion on the likelihood of continued or resumed dumping of certain steel plate if the CITT’s finding were to expire.

South Korea’s steel plate production and overcapacity

[197] Evidence on the record shows that producers in South Korea have extremely significant production capacity for subject goods. Total production capacity for equipment capable of producing subject goods remained stable from the beginning to the end of the POR. This was also true for reversing mill capacity, which was little changed from the beginning to the end of the POR.^{Footnote 133}

[198] Evidence on the record shows that utilization rates for equipment capable of producing subject goods increased modestly during the POR, from 85.9% in 2022, 92.5% in 2023 and 90.0% in 2024. Reversing mill utilization rates and therefore excess capacity remained relatively stable: 80.2% in 2022, 83.0% in 2023, 80.8% in 2024.^{Footnote 134}

[199] In their reply submission, POSCO pushed back against allegations from Algoma that this evidence demonstrates that South Korea and by extension POSCO have high levels of excess capacity. As summarized previously in this report, POSCO argues that due to their responsibility to maintain a stable supply of various steel products as the largest South Korean steel producer, they cannot increase the production of thick plate products.^{Footnote 135}

[200] The CBSA notes, even with taking into consideration POSCO’s claims about an inability to increase plate production, in the lowest year of excess capacity as reported by POSCO themselves, they still had very significant capacity when compared to the total apparent Canadian market according to Table 2.^{Footnote 136}

[201] Based on the available evidence, the CBSA finds that current and potential production capacity of steel plate producers is large, and that excess production capacity exists in South Korea. The capital-intensive nature of steel plate production and high fixed costs provides an incentive for mills to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s finding expire, Canada represents an attractive market for the steel plate producers in the South Korea to eliminate excess production capacity which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

South Korea’s continued interest in the Canadian Market

[202] Evidence on the record shows that exporters from South Korea continued to sell meaningful volumes of subject goods to Canada during each year of the POR. While the volume of subject goods exported declined from 2022 to 2024, this may not represent a real decline in interest in the Canadian market. Evidence on the record indicates that when looking at the total volume of both subject and non-subject plate, the import volume was actually higher in 2024 than 2022.^{Footnote 137}

[203] In 2023, the CBSA initiated and concluded two normal values reviews, providing updated normal values to the cooperative exporters of subject goods from Korea, Dongkuk Steel Mill Co., Ltd. (Dongkuk)^{Footnote 138} and POSCO^{Footnote 139}, for this first time since the original investigation concluded in 2014. This update to their normal values coincided with the decline in export volumes of subject goods.

[204] POSCO in their ERQ response argued that Canada represented a very minimal share of their total exports during the POR, and that due to demand in other markets, they would not have product available for sale into the Canadian market for 2025.They further noted that the US market was the most important export market for them.^{Footnote 140}

[205] While this may provide a picture that shows minimal interest in the Canadian market, POSCO notes that they hope to sell what they term specialty plate into the Canadian market in the future. To this end, POSCO indicates in their ERQ that they would urge the CBSA to initiate an administrative review to provide them with updated normal values should the order be continued. Indeed, POSCO provided a fulsome sample Normal Value Request for Information response as part of their ERQ response.^{Footnote 141}

[206] Based on the available evidence, the CBSA finds that South Korean exporters of subject goods show a continued interest in the Canadian market, even with a finding in effect. As such, should the CITT’s finding expire, exporters from South Korea would intensify their interest in the Canadian market, which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Imposition of trade measures by Canada and other jurisdictions on South Korea

[207] Evidence on the record suggests that there are at least fifty other measures in other jurisdictions including Australia, Brazil, China, Chinese Taipei, The European Union, India, Indonesia, Japan, Malaysia, Mexico, Pakistan, Thailand, Türkiye, The United States and Vietnam on various steel products from South Korea.^{Footnote 142}

With respect to anti-dumping findings for plate products specifically, South Korea has had four findings against them from Brazil, Chinse Taipei, India, and the United States.^{Footnote 143}

[208] In addition to these measures, as of April 2, 2025, the CBSA has anti-dumping measures in force for seven additional steel products originating in or exported from South Korea:^{Footnote 144}

• Carbon Steel Welded Pipe 2
• Cold-rolled Steel
• Concrete Reinforcing Bar
• Corrosion-resistant Steel Sheet
• Hollow Structural Sections
• Line Pipe 2
• Oil Country Tubular Goods 2

[209] The CBSA finds that the imposition of the numerous anti-dumping measures on various steel products demonstrates that producers in South Korea have a propensity to dump. Should the CITT’s finding expire, steel plate producers in South Korea 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: South Korea

[210] Based on evidence on the record in respect of: commodity nature of steel plate; capital-intensive nature of steel production; tariffs and safeguard measures on steel imports and diversion of steel plate into Canada; South Korea’s steel plate production and overcapacity; South Korea’s continued interest in the Canadian Market; and the imposition of trade measures by Canada and other jurisdictions on South Korea, the CBSA has determined that the expiry of the finding is likely to result in the continuation or resumption of dumping into Canada of certain steel plate originating in or exported from South Korea.