Statement of Reasons—Expiry review determination: Concrete Reinforcing Bar (RB1 2025 ER)

Administrative record

[33] 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 the CITT’s administrative record at initiation of the expiry review, CBSA exhibits, and information submitted by interested persons, including information which parties feel is relevant to the decision as to whether dumping and/or subsidizing is likely to continue or resume if the order is rescinded.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, exporters and foreign producers as well as by the Government of China.

[34] 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.” For this expiry review investigation, the closing of the record date was September 18, 2025. This deadline allows parties time to prepare their case briefs and reply submissions based on the information that is on the administrative record.

Parties contending that continued or resumed dumping is likely

Domestic Producers – AMLPC, AltaSteel, Gerdau, MANA and IRM (Collectively, the Canadian Producers)

[36] In their ERQ response and case briefs, the Canadian producers argued that continued or resumed dumping is likely should the order be allowed to expire. The Canadian producers each provided the CBSA with additional information prior to the close of the record in support of its position. Each party further expanded and elaborated on their position in their respective case briefs. The following section summarizes the arguments of the Canadian producers collectively.

[37] The factors identified by the Canadian producers in support of their position are summarized as follows:

• Commodity nature of rebar
• Current international market conditions
• Current domestic market conditions;
• Inability to compete at dumped prices
• Substantial global excess capacity
• Propensity to dump and trade diversion threats
• Factors specific to China
• Factors specific to South Korea and
• Factors specific to Türkiye

Commodity nature of rebar

[38] The Canadian producers state that it is a well-known and well-established fact that the subject rebar are commodity products. To this effect, the Canadian producers noted that the CBSA found “… concrete reinforcement bars are a commodity product and are sold typically on the basis of price.” while the CITT found that the “Tribunal has consistently held that imported and domestically produced rebar products are fully interchangeable commodity products that compete with one another in the Canadian market based on price.”^{Footnote 18} The Canadian producers further reiterate that producers in subject countries must manufacture rebar to National Standard of Canada CAN/CSA-G.30.18 M92 for Billet steel bar (National Standard), which makes domestically produced rebar and rebar produced in subject countries perfectly interchangeable.^{Footnote 19}

[39] Canadian producers argue that without the order, subject goods would be sold into Canada at increasingly dumped and subsidized prices to gain competitive advantage.

Current international market conditions

[40] The Canadian producers argue that international market conditions for rebar have deteriorated significantly since a temporary recovery after the COVID-19 pandemic. Specifically, the global excess capacity crisis for steel has worsened and is expected to continue to worsen through 2027. The sluggish growth in global demand for steel is currently significantly outpaced by the rate of growth in capacity around the world. On the demand side, excess capacity will increase as demand for steel in China weakens. Meanwhile, on the supply side, excess capacity will increase, with Asia accounting for approximately 60 percent of this capacity growth.^{Footnote 20}

[41] The Canadian producers continued their argument by discussing the uncertainty in the global economy due to United States (U.S.) tariffs and inflation. The trade environment created by U.S. Section 232 tariffs has cast uncertainty on the outlook for global steel demand. To emphasize the unprecedented uncertainty in the international market, the Canadian producers reference the delay in the World Steel outlook for 2025. The International Rebar Producers and Exporters Association noted a wait and see approach that buyers are taking in response to U.S. tariffs along with expectations of high volumes of low-priced rebar to continue to flow from China.^{Footnote 21}

[42] Excess capacity remains a significant challenge in the steel industry with the Canadian producers arguing that the availability of large levels of excess capacity incentivize rebar producers to aggressively find new markets, maximize output and spread fixed costs over a higher total production output. This imbalance between rising production and slow demand growth is creating instability in the global steel market.

[43] Despite calls for global collaboration on the overcapacity issues, capacity developments are expected to continue. An emerging trend in the steel industry is Chinese steel companies investing in third economies representing 62% of the investments in steel manufacturing of the 165 million tonnes of new steelmaking capacity.^{Footnote 22} Steel producers in China and Chinese-owned factories abroad continue to increase capacity despite the slowing demand globally.

[44] Ongoing trade uncertainty is significantly impacting the steel industry leading to trade restrictions, with the U.S. leading the way on these protectionist measures. On June 3, 2025, the U.S. imposed increased Section 232 measures on various steel and steel derivative products to 50% from various countries. The Canadian producers argue these measures are likely to divert a significant volume of subject goods into other markets, including Canada. The Canadian producers referenced the European Union’s (EU) steel safeguard measure extensions to June 2026 which maintain an out-of-quota duty of 25% on steel imports that cover China, South Korea and Türkiye as another example of continued restrictive measures on steel trade.^{Footnote 23}

[45] The Canadian producers also argued that although Canada has implemented unilateral trade restriction measures above anti-dumping/countervailing duties, surtax measures against Chinese steel and the TRQ’s imposed on all countries incentivize exporters to reduce prices in order to sell steel products into Canada, and that export prices are calculated on an ex-factor basis, rather than with surtax costs included in the price calculation. Absent anti-dumping/countervailing duties, an exporter would be free to lower its prices to absorb any surtaxes and continue to export with minimal impact to the importer.

[46] The Canadian producers argue that international market conditions make it likely that subject countries will export large volumes of rebar to Canada at dumped prices in the next 12 to 24 months absent anti-dumping/countervailing duties. International market conditions are very volatile and are expected to remain so in the short to medium term. Despite all this, rebar production capacity is increasing, which the Canadian producers argue puts substantial pressure on rebar prices.

Current domestic market conditions

[47] The Canadian producers argue that domestic conditions make Canada an attractive market for subject goods. Although the volatility of the global trade environment in 2025 has weighed on the Canadian economy, the Bank of Canada expects the growth rate to re-stabilize through 2026 and 2027 as uncertainty in the global trade system wanes.^{Footnote 24} In comparison, the Canadian producers reference China, South Korea and Türkiye, which all expect to experience economic slowdowns.^{Footnote 25}

[48] The Canadian producers argue that market conditions in the construction sector in Canada are a good indicator of rebar demand and show that Canada remains an attractive market for subject goods.

[49] The Canadian construction sector has shown strong and consistent growth in recent years, which directly impacts rebar demand due to its extensive use in residential and non-residential building projects. Between 2020 and 2024, total construction investment rose from $185.39 billion to $250.81 billion, with a brief dip in 2023.^{Footnote 26} Apartment starts—a key driver of rebar demand—have increased significantly, with 154,927 units started in 2024, and continued growth into 2025. The first half of 2025 alone saw 80,388 apartment starts, surpassing the same period in 2024.^{Footnote 27} Additionally, CMHC data from July 2025 shows a substantial rise in dwellings under construction, particularly apartments, which now make up 83% of all units under construction in metropolitan areas.^{Footnote 28}

[50] Government initiatives at both federal and provincial levels are actively promoting new housing development, especially apartments and multiplexes. These include financial incentives like GST removal for new rental projects, increased capital cost allowances, and expanded mortgage bond limits.^{Footnote 29} While the federal government is prioritizing Canadian steel in its housing programs, its direct investment remains a small fraction of total residential construction spending—only $250 million in 2024 compared to $171.27 billion in total residential investment. This means the private sector, driven by cost-efficiency, will continue to dominate construction activity and influence rebar sourcing decisions.^{Footnote 30}

[51] Investment trends in infrastructure, apartment construction, and non-residential buildings further reinforce the rising demand for rebar. From 2019 to 2024, infrastructure investment grew from $85.2 billion to $133.4 billion, apartment construction from $47.9 billion to $75.3 billion, and non-residential building investment from $57.9 billion to $79.5 billion.^{Footnote 31} These increases across all major rebar-consuming sectors suggest a robust and expanding market. Given this growth, exporters from countries like China, Korea, and Türkiye may be incentivized to re-enter the Canadian market if trade protections are lifted, as the demand and pricing environment remain attractive.

Inability to compete at dumped prices

[52] The Canadian producers argue that subject countries are unable to compete without dumping in order to gain market share. Since the original finding, the Canadian rebar market has experienced a number of challenges with low-priced imports, prompting four additional trade measures. In 2022, Türkiye exported 255,848 tonnes of rebar at dumped prices. This demonstrated a clear risk of dumping to gain market share.

[53] The Canadian producers argue that Chinese rebar producers cannot compete in the Canadian market, referencing large amounts of anti-dumping duties paid between 2022 and 2024, suggesting a significant amount of the subject rebar that was imported was dumped.^{Footnote 32} Canadian producers argue that despite the China Surtax and the TRQ measures imposed against China, rescinding the order would increase the likelihood of dumping because the Chinese producers could absorb tariff costs, as demonstrated in the U.S. market.

[54] The Canadian producers argue that Turkish rebar producers cannot compete in the Canadian market at dumped prices and if the order was rescinded, would continue dumping into the Canadian market. In 2023, when normal values were updated to reflect current market conditions, volume of subject rebar declined from 255,848 MTs in 2022 down to 8 MTs in 2024. When normal values reflect updated market conditions, Turkish rebar producers were unable to compete in Canada.^{Footnote 33}

Substantial excess capacity in subject countries

[55] The next argument made by the Canadian producers is regarding the excess capacity in the long products steel sector globally and the significant impact that has had on the rebar market.

[56] Canadian producers cite increased production capacity in long products and rebar production specifically since the stimulus package launched by the Government of China during the COVID-19 pandemic.^{Footnote 34} The Chinese domestic conditions for rebar are declining, but steelmaking capacity continues to remain stable at 1,141.5 mmts.^{Footnote 35}

[57] Prior to August 2024, the Chinese government had implemented the “Implementation Measures for Capacity Replacement in the Steel Industry”, which required producers to take old production capacity offline before commencing new projects.^{Footnote 36} However, in reality, the industry began to intensely upgrade existing equipment and new facilities were much more productive. In the first half of 2024 for example, 16.16 million tonnes of new crude steel capacity was commissioned while 12.11 million tonnes of production capacity was decommissioned.^{Footnote 37}

[58] Given rebar is a commodity product with fixed production costs, rebar producers have a strong incentive to maintain a high level of production and capacity utilization. In May of 2025, Chinese rebar producers had a 49.7% capacity utilization rate.^{Footnote 38} China exported 839,687 tonnes of rebar, which is 112% higher compared to one year earlier.^{Footnote 39}

[59] The Canadian producers argue that the combination of rising rebar production capacity and persistently low utilization rates in the context of slowing demand increases the likelihood that South Korean producers and/or exporters will resume or continue exporting subject goods to Canada at dumped prices if the finding were to be rescinded.

[60] The Canadian producers argue that the available excess capacity in Türkiye incentivizes Turkish producers to seek other markets to export to, increasing the likelihood of dumping in the event of the order being rescinded.

[61] Türkiye ranks eighth worldwide in rebar manufacturing, with a number of companies that can produce over one million tonnes annually. The Canadian producers reference capacity utilization rates of Turkish rebar producers of 62.6% compared to 75-80% globally.^{Footnote 40} Despite the decrease in demand forecasted for rebar use in Türkiye, excess capacity has increased. With producers seeking to maintain output and reduce marginal costs, Canadian producers argue that it is highly likely that Turkish producers would look to export to markets like Canada in the event of the order being rescinded.

Propensity to dump and threat of diversion

[62] The subject countries have a number of anti-dumping or countervailing measures imposed on steel products. The following table lists anti-dumping measures on steel products originating in the subject countries by Canada:

[63] The number of measures imposed on subject countries indicates that in the event of the order being rescinded, producers from the subject countries would likely have significant interest in the Canadian market.

[64] Outside of Canada, a number of other trade restrictive measures have been imposed on rebar and other goods produced on the same equipment from the subject countries. 34 different goods are impacted by trade restrictive measures on the subject countries, according to the WTO.^{Footnote 42}

[65] The United States imposed a 25% tariff on various steel imports under section 232 and increased to a 50% tariff effective June 4, 2025. The EU’s steel safeguard measures were also extended to June 30, 2026 and apply to various steel long products, including rebar. Vietnam^{Footnote 43}, the United Kingdom^{Footnote 44} and Mexico^{Footnote 45} have also imposed their own safeguards in response to the US surtaxes. The wide-ranging trade barriers that implicate the subject countries increase the likelihood that exporters will continue or resume shipping subject goods into Canada at dumped prices if the order was set to expire.

Position in regards to China

[66] The Canadian producers state that expiring the order will result in continued or resumed dumping of rebar from China and that information on the record indicates that: Chinese producers and exporters cannot compete at fair market prices, substantial excess capacity exists among Chinese rebar producers, weak domestic demand intensifies export pressures, a historical propensity to dump rebar into other markets exists, and Chinese market conditions increase the likelihood of diversion of dumped goods into Canada. Some of these factors have been addressed above.

Chinese producers are experiencing weak domestic demand and pressure to export

[67] China accounts for approximately 50% of global steel consumption.^{Footnote 46} However, its domestic market is under severe strain due to a significant slowdown in construction. Falling property prices, stagnant investment and unsold housing stock has led to this slowdown. Despite government efforts to stimulate the sector, demographic shifts and weakening consumer confidence have played significant roles. Major financial institutions like Oxford Economics^{Footnote 47}, UBS^{Footnote 48}, Morgan Stanley^{Footnote 49}, and HSBC forecast continued weakness in China’s real estate and construction sectors through at least 2026, with infrastructure and energy projects offering limited relief.^{Footnote 50}

[68] This domestic slowdown has led to a significant contraction in steel and rebar demand. Rebar demand, in particular, has shrunk by 19% from 2022 to 2024 and is expected to continue declining annually through 2027. With only a small fraction of steel mills remaining profitable, producers are reluctant to idle operations due to high costs.^{Footnote 51} Instead, they are increasingly turning to exports, often selling at low prices to maintain throughput and offset domestic losses.

[69] The oversupply and weak domestic demand have created conditions that encourage exports, including rebar. Fastmarkets noted that the domestic market demand for steel products cannot support the industry, requiring producers to turn to exports to prop up steel prices.^{Footnote 52}

[70] State-owned enterprises like Baowu Steel are actively seeking new markets, contributing to a 24% rise in exports.^{Footnote 53} The combination of excess capacity, declining prices, and limited profitability among producers heightens the risk of aggressive export strategies, especially if trade protections like anti-dumping measures are lifted. This poses a significant challenge for international markets, including Canada.

Position in regards to South Korea

Korean steel producers are export oriented

[71] Korean steel producers are export oriented, referencing UN Comtrade data showing Korea is a significant global exporter of rebar and other steel products. Korea exported 28 million tonnes of steel in 2024 and 559 thousand tonnes of rebar, ranking 3rd and 9th respectively.^{Footnote 54}

[72] Korean rebar exports have increased substantially since 2022. In the first seven months of 2025, rebar and other hot-rolled bars have increased 27% compared to the same period in 2024.^{Footnote 55} Korean rebar exporters are expanding into new markets amid weak domestic demand. For example, a South Korean mill started offering rebar to Singapore for shipments in February and March 2025.^{Footnote 56}

[73] The Canadian producers reference corporate materials from major Korean rebar producers that reinforce this position.^{Footnote 57} According to the South Korean Iron & Steel Association, rebar exports have increased over 50% between Jan-Jul 2025 and the same period a year prior.^{Footnote 58}

Economic Conditions in Korea Increase the Likelihood of Resumed Exports to Canada in the Absence of the Order

[74] The Canadian producers reference the economic challenges in Korea which is likely to result in weak domestic demand for rebar, incentivizing Korean producers to export more rebar. The new Korean president characterized Korea’s economic and political situation as a “tangled web of overlapping crises’ … ‘in all areas’ including the economy, national security and democracy.”^{Footnote 59} It is also facing a drastically and “unprecedented” aging population, where one in five Koreans are over the age of 65, a significant economic and social risk for South Korea.^{Footnote 60}

[75] Canadian producers noted that high costs and shrinking orders have led to a significant drop-off in construction activity in Korea.^{Footnote 61} This stagnant construction output is forecasted to remain tempered by inflation.^{Footnote 62} While value may increase overall in the long-term, the Korean construction sector, and therefore Korean domestic demand for rebar, is presently in a less-than ideal state.

[76] Korean steel producers are being undercut domestically by a flood of cheap imports from China.^{Footnote 63} This has led to uncertainty within the Korean steel industry and is one of the major drivers of a slowdown in Korean steel production along with global oversupply and U.S. tariff measures. Korean steel producers know that their domestic market share is threatened and they are likely to seek out other markets to sell into.

[77] Chinese imports flooding the Korean market and reduced domestic construction demand has had a significant detrimental impact on Korean rebar exporters.^{Footnote 64} Hyundai Steel reported in its 2024 year-end financial update that long steel “profits decrease{d} due to {a} slow domestic construction market”.^{Footnote 65} Hyundai’s most recent report for 2025 Q2 noted that demand remains “slow”.^{Footnote 66} As the Tribunal noted in RR-2021-006, rebar producers face a production imperative for rebar, and this imperative may drive them to have to choose between exporting and scaling back production.^{Footnote 67} Korean rebar producers have been forced to temporarily suspend operations and close facilities due to their inability to find enough demand to fill their mills. In April 2025, Hyundai Steel, Korea’s second largest steel producer, suspended rebar production at its Incheon plant for one month^{Footnote 68} and Dongkuk Steel announced in May 2025 that it would close its Incheon rebar plant indefinitely “to help stabilize rebar supply”.^{Footnote 69} If the Canadian rebar market is left unprotected by the expiry of the Order, these exporters could opt to reopen facilities and ramp up exports to Canada to fill this idle capacity.

Position in regard to Türkiye

Turkish producers have a sustained interest in the Canadian market

[78] Turkish producers have a sustained interest in the Canadian market as shown in 2022 when the normal values for rebar did not reflect current market conditions. According to Statistics Canada, this is higher than the volume exported to Canada in any single year from 2012 to 2018.^{Footnote 70}

[79] Although Canada has implemented tariff rate quotas (TRQs) on steel imports including rebar, the HS codes do not cover all products covered in the scope of the product definition. There is significant room in the TRQ from Türkiye currently and in the event the order expires the Turkish exporters would have the means to regain significant market share in the Canadian market within the current TRQ framework.

Domestic demand in Türkiye is forecasted to contract significantly in the coming years

[80] Rebar demand in Türkiye has weakened since the prior expiry review, driven by significant challenges in the country’s construction sector—the primary driver of rebar demand.^{Footnote 71} The decline in Turkish rebar demand is likely to push Turkish producers to seek export opportunities wherever they arise—including to Canada in the case that anti-dumping duties are not renewed—to maintain production throughput.

[81] High interest rates in Türkiye have made financing construction projects difficult. This restricts access to financing for construction projects, including mortgages and commercial loans, thereby reducing demand for new construction and consequently domestic rebar demand. Moreover, construction input costs have risen significantly, with labor costs up 105 percent year-over-year in 2024 with material prices also sharply rising over the same period. This increase limits the feasibility of new projects and slows down activity, further reducing Turkish rebar demand. Shortages of qualified construction workers, partly due to rebuilding efforts after earthquakes, have also delayed project completion and starts.^{Footnote 722}

[82] The Government of Türkiye unveiled its Public Savings and Efficiency Package which encourages a slowdown of new projects to manage fiscal constraints, creating a backlog of postponed projects that weigh on contractors and reduce immediate steel demand.^{Footnote 73} This package also includes the suspension of purchase and construction of new buildings for three years, except in regions affected by earthquakes.^{Footnote 74} This measure directly limits new public construction projects, contributing to slower project starts and postponements that reduce steel demand.^{Footnote 75} Data from 2024 showed a significant decrease (around 22 percent) in new building permits, especially in residential units (nearly 30 percent drop), reflecting less construction startup activity and therefore less domestic rebar demand.^{Footnote 76}

Parties contending that continued or resumed dumping is unlikely

Importers

[83] No case briefs or reply submissions were submitted contending that the dumping of the subject concrete reinforcing bar from China, South Korea and Türkiye is not likely to continue or resume if the order is rescinded.

Exporters and foreign producers

[84] No case briefs or reply submissions were submitted contending that the dumping of the subject concrete reinforcing bar from China, South Korea and Türkiye is not likely to continue or resume if the order is rescinded.

Common factors

Commodity nature of rebar

[87] Generally speaking, rebar produced either by a Canadian manufacturer or by a foreign manufacturer are physically interchangeable. Consequently, the sale of rebar is highly price sensitive. As noted by the CITT in Expiry Review RR-2019-003: “The Tribunal determined that the subject goods and domestic goods are commodity products that compete with one another in the Canadian marketplace on the basis of price and are otherwise fully interchangeable. The Tribunal found that they are used for the same purposes, sold through the same channels of distribution and used by the same end users.”^{Footnote 77}

[88] Given the commodity nature of rebar and the corresponding price sensitivity of purchasers, producers and exporters are likely to engage in price undercutting as a strategy to capture market share. If the order were to expire, manufacturers from the subject countries would have a strong incentive to reduce prices in order to gain a competitive foothold in the Canadian market, which may increase the likelihood of continued or resumed dumping of subject goods into Canada.

Current international market conditions

[89] The global steel market, particularly for rebar, is facing worsening conditions due to excess capacity and sluggish demand. Post-COVID recovery was short-lived, and now the imbalance between growing production—especially in Asia—and weakening demand, notably in China, is expected to persist through 2027.^{Footnote 78} This oversupply is creating instability and incentivizing producers to seek new markets to maintain output and reduce costs. Despite international challenges, Canada is seen as a relatively stable and attractive market for rebar exports over the next 12–18 months.

[90] Global economic uncertainty, driven by U.S. tariffs and inflation, is exacerbating the situation. The U.S. has imposed significant trade restrictions, including increased Section 232 tariffs, which threaten steel products to be diverted to other markets such as Canada. The delay in the World Steel outlook and cautious buyer behavior discussed above reflect the unpredictability of the global trade environment.^{Footnote 79} Other regions, like the EU, Vietnam, the UK and Mexico have also extended safeguard measures, meaning subject countries have limited options for exporting rebar from subject countries.

[91] Without anti-dumping and countervailing duties, exporters from subject countries may lower prices to offset tariffs and maintain access to the Canadian market. This could lead to large volumes of dumped rebar entering Canada, further pressuring domestic prices. In addition, the volatility and oversupply in the steel market is expected to persist due to a number of factors, including investments in steel production by Chinese firms in third economies.^{Footnote 80}

[92] Poor international market conditions in general for rebar increase the likelihood that exporters from subject countries will continue or resume dumping subject goods into the Canadian market in the event that the order is rescinded. These weak international market conditions exist in the three named countries, which all have their own country specific issues, mainly a weak outlook for construction demand.

Current domestic market conditions

[93] The current domestic economic conditions make Canada an appealing destination for rebar exports from subject countries. While global trade volatility has impacted Canada’s economy in 2025, forecasts from the Bank of Canada suggest a return to stable growth by 2026–2027.^{Footnote 81} In contrast, China, South Korea, and Türkiye are expected to face economic slowdowns, making Canada’s relatively stable outlook more attractive for exporters seeking reliable markets.^{Footnote 82}

[94] A major factor contributing to Canada’s appeal is the strength of its construction sector, which directly drives demand for rebar. Between 2020 and 2024, construction investment rose significantly, with apartment starts reaching record highs in 2024 and continuing to grow in 2025.^{Footnote 83} Data from CMHC shows that apartments now dominate new construction in metropolitan areas, indicating sustained demand for rebar.^{Footnote 84} Government incentives—such as GST removal on rental projects and increased capital cost allowances—are encouraging further development, although most construction spending remains driven by the private sector, which prioritizes cost-efficiency in sourcing materials.

[95] Investment growth across infrastructure, apartment construction, and non-residential buildings further reinforces the optimistic outlook for rebar demand in Canada. From 2019 to 2024, these sectors saw substantial increases in spending, suggesting a strong and expanding market.^{Footnote 85} Given this favorable environment, exporters from subject countries may be incentivized to re-enter the Canadian market with low-priced rebar if the order is rescinded, potentially undermining domestic producers.

Inability to compete at dumped prices

[96] Information on the administrative record indicates that exporters from subject countries are unable to compete in the Canadian rebar market without dumping. Compliance data shows that during the POR, subject goods were either imported into Canada with SIMA duties paid or there were no imports. For example, Türkiye exported rebar at significantly below-market prices in 2022, and throughout the POR Chinese imports were charged SIMA duties. There were no imports from South Korea, indicating an inability to compete in the market at fair prices, despite the interest in the market. These imports disrupted the domestic market and demonstrated dumping to gain market share.

[97] Following the implementation of trade protections under the Rebar 5 finding, import volumes from subject countries declined sharply, allowing domestic producers to recover and sell at sustainable prices. In early 2025, domestic rebar was priced competitively, and imports from non-subject countries were even higher-priced, indicating a healthier market dynamic. However compliance data from subject countries shows that there is clearly an interest in the Canadian market from subject countries, even with anti-dumping duties in place, and that other producers are likely to resume dumping, forcing Canadian producers back into an import parity pricing model that undermines profitability.^{Footnote 86}

[98] Specifically, Chinese and Turkish producers are highlighted as unable to compete fairly. Chinese and Turkish rebar was assessed millions in anti-dumping duties between 2022 and 2024, suggesting significant dumping activity. Despite existing surtaxes and TRQs, producers from subject countries could absorb these costs and continue dumping, as seen in the U.S. market.^{Footnote 87} Similarly, Turkish exporters saw their volumes collapse when normal values were updated, indicating they could not compete at fair market prices. This reinforces the argument that trade protections are essential to maintain a stable and fair Canadian rebar market.

Substantial global excess capacity

[99] Excess capacity problems in the steel industry continue to be a key influence over capital investment, production, prices, environmental decisions and trade risks. Excess capacity in the steel sector globally undermines the market dynamics of the steel industry globally, and each subject country faces their own specific capacity related issues in their domestic steel market.

[100] In China, production capacity for steel and rebar increased dramatically over the last 25 years. During the COVID-19 pandemic, stimulus packages launched by the Government of China increased production capacity for long steel products.^{Footnote 88} Prior to August 2024, the Chinese government had implemented the “Implementation Measures for Capacity Replacement in the Steel Industry”, which required producers to take old production capacity offline before commencing new projects.^{Footnote 89} However, the industry began to intensely upgrade existing equipment and build new facilities that were much more productive. In the first half of 2024 for example, 16.16 mmt of steel capacity was commissioned while 12.11 mmt of production capacity was decommissioned.^{Footnote 90}

[101] Given rebar is a commodity product with fixed production costs, rebar producers have a strong incentive to maintain a high level of production and capacity utilization. In May of 2025, Chinese rebar producers had a 49.7% capacity utilization rate.^{Footnote 91} China exported 839,687 tonnes of rebar, which is 112% higher than compared to one year earlier.^{Footnote 92} This available capacity creates a strong incentive for Chinese producers to resume dumping into the Canadian market in the event that the order expires.

[102] South Korea’s rebar capacity has remained relatively stable, but excess capacity is projected to rise. Utilization rates are expected to stay low, only gradually increasing by 2027. These low utilization rates, combined with excess capacity, create strong incentives for South Korean producers to resume or continue exporting to Canada at dumped prices if the order was rescinded.

[103] Similarly, Türkiye ranks eighth globally in rebar production, with several companies capable of producing over one million tonnes annually. Turkish producers currently operate at a utilization rate of 62.6%, well below the global average of 75–80%.^{Footnote 93} Domestic demand for rebar in Türkiye is forecasted to decline, further increasing excess capacity. To maintain output and reduce marginal costs, Turkish manufacturers would likely seek export markets such as Canada if the order were rescinded.

Tariffs and safeguard measures on steel imports and diversion of certain concrete reinforcing bar into Canada

[104] The subject countries have a number of anti-dumping or countervailing measures imposed on rebar and similar goods. As shown in the arguments provided by the Canadian producers, there are a number of active anti-dumping measures against steel products from the subject countries which cover a wide range of steel products from each country.

[105] The number of measures indicates that subject countries have a key interest in the Canadian market and that in the event that the order is rescinded producers from the subject countries would be interested in exporting to Canada again.

[106] The United States imposed a 25% tariff on various steel imports under section 232 and changed to a 50% tariff effective June 4, 2025. The EU’s steel safeguard measures were also extended to June 30, 2026 and apply to various steel long products, including rebar. Vietnam,^{Footnote 94} the United Kingdom^{Footnote 95} and Mexico^{Footnote 96} have also imposed their own safeguards in response to the US surtaxes. The wide-ranging trade barriers that implicate the subject countries increase the likelihood that exporters will continue or resume shipping subject goods into Canada at dumped prices if the order was set to expire.

[107] The Section 232 measures are likely to divert a significant volume of steel products into other markets with no sign of these measures being removed in the short to medium term. With the US steel market being closed off to the subject countries, exporters will look to other markets to fill significant quantities of subject goods. While these tariffs remain in effect, subject goods are likely to be diverted from the U.S. to other markets without tariff measures in place. This risk is amplified by the size of the U.S. market. Even a relatively modest volume of goods diverted from the U.S. could overwhelm a smaller market such as Canada.

[108] In response to the increased protection measures in the US, other countries have introduced or increased their own protectionary measures. For example, as noted in a previous expiry review proceeding, diversion of exports as a result of the Section 232 tariffs was part of the rationale for extending the duration of safeguard measures on steel in the EU, with EU officials stating:

[109] China, South Korea and Türkiye are all among the main exporting countries that are covered by EU safeguards. As of April 2025, the EU has also reduced the TRQs allowed under the safeguard by 15% to prevent diverted steel destined for the US to enter the European market.^{Footnote 98} The measures imposed by the EU make it an unlikely alternative destination for diverted rebar from the subject countries.

[110] Canada has implemented its own unilateral measures to offer further protection to the domestic steel industry, above the anti-dumping or countervailing duties imposed. The Canadian government applied 25% tariffs on Chinese steel products that were imposed October 2024.^{Footnote 99} It also imposed tariff rate quotas on a number of steel products to stabilize Canada’s steel sector.^{Footnote 100} A 50% surtax applies for free trade partners above 100 percent of 2024 imports and 50 percent of 2024 imports for countries without a free trade agreement.

[111] Although these measures are intended to protect Canadian industry, evidence on the record indicates that prices to the U.S. fell from January 1, 2025 to June 30, 2025. Without anti-dumping duties in place, exporters could reduce prices to absorb surtaxes. The example provided in the case of rebar prices declining suggest that there was likely attempts to get in before surtaxes increased, and were sold at lower prices.

[112] Due to the geographic proximity of the US to Canada and the size of the American market for rebar, the imposition of these measures will likely cause rebar, including from subject countries, to be diverted to Canada. This diversionary pressure can be expected to be exacerbated by the protectionary measures in other jurisdictions, increasing the likelihood that dumped goods are diverted into Canada.

China

[113] In assessing the likelihood of continued or resumed dumping from China should the CITT’s order be rescinded, the CBSA relied on the information on the administrative record which includes the responses to the various ERQs from all interested parties.

[114] The CBSA solicited information from potential producers and exporters of subject rebar in China; it received no responses to the Exporter/Foreign Producer ERQ from companies located in China. Furthermore, no importers of subject rebar from China filed a case brief or reply submission.

China’s rebar production and overcapacity

[115] The long products steel sector faces the same challenges as other segments of the steel industry, facing substantial capacity related pressures.

[116] Prior to August 2024, the Chinese government had implemented the “Implementation Measures for Capacity Replacement in the Steel Industry”, which required producers to take old production capacity offline before commencing new projects.^{Footnote 101} However, the industry began to intensely upgrade existing equipment and these new facilities were much more productive. In the first half of 2024 for example, 16.16 million tonnes of new crude steel capacity was commissioned while 12.11 million tonnes of production capacity was decommissioned.^{Footnote 102}

[117] Given rebar is a commodity product with fixed production costs, rebar producers have a strong incentive to maintain a high level of production and capacity utilization. In May of 2025, Chinese rebar producers had a 49.7% capacity utilization rate.^{Footnote 103} China exported 839,687 tonnes of rebar, which is 112% higher compared to one year earlier.^{Footnote 104}

[118] Based on the available evidence, the CBSA finds that current and potential production capacity of rebar in China is substantial and that excess production capacity exists in China. The capital-intensive nature and high fixed costs associated with rebar production incentivizes producers to pursue sales even at low prices in order to increase capacity utilization. As such, should the CITT’s order expire, Canada represents an attractive market for rebar producers in China 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 China

[119] Chinese producers have a history of dumping rebar in many markets other than Canada and in the event of a rescinded order of the anti-dumping duties against China, producers would likely resume dumping into the Canadian market.

[120] There are eleven anti-dumping measures against Chinese rebar in other jurisdictions and some countries have applied surtaxes on steel products, including the U.S. and Canada.^{Footnote 105} When tariffs were imposed by the U.S. against Chinese exports, there was a rush of Chinese manufactured exports in the first half of 2025. The significant tariff measures against Chinese rebar creates a risk that absent anti-dumping duties Chinese rebar imports into Canada would increase substantially.^{Footnote 106}

[121] Specific to Canada, as of November 4, 2025, the CBSA has anti-dumping measures in force for 19 steel products originating in or exported from China.^{Footnote 107}

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

Continued interest in the Canadian market and evidence of continued dumping

[123] Chinese rebar continued to be sold into Canada during the POR, indicating a continued interest in Canada. The continued interest in the market despite anti-dumping and countervailing duties being in place suggests that not only do the Chinese rebar producers have an interest in the Canadian market but importers are willing to pay anti-dumping duties. While not delineated into countervailing and anti-dumping duties, evidence on the record shows that duties continue to be assessed on imports of subject goods from China.^{Footnote 108}

[124] Based on the available evidence, the CBSA finds that Chinese exporters of subject goods show a continued interest in the Canadian market, even with an order in effect. Additionally, Chinese exporters have maintained their interest even when selling below normal values or without normal values, as evidenced by the SIMA duties collected during the POR. As such, should the CITT’s order expire, it is likely that exporters from China would intensify their interest in 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: China

[125] Based on evidence on the record the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of dumping into Canada of certain concrete reinforcing bar originating in or exported from China.

South Korea

[126] In assessing the likelihood of continued or resumed dumping from South Korea should the CITT’s order be rescinded, the CBSA relied on the information on the administrative record which includes the responses to the various ERQs from all interested parties.

[127] The CBSA solicited information from potential producers and exporters of subject rebar in South Korea; however, it did not receive any responses. No producers or exporters submitted case briefs or reply submissions for the CBSA to consider in making a determination. Furthermore, no importers of subject rebar from South Korea filed a case brief or reply submission.

Korean steel producers are export oriented

[128] The export orientation of Korean steel producers is well documented and has been recognized on several occasions by the CBSA, including the last rebar expiry review.^{Footnote 109} According to the World Steel Association, Korea exported 28 million tonnes of steel in 2024, making it the third largest exporter of steel worldwide.^{Footnote 110} Korea exports substantial quantities of rebar as well, ranking 9th in the world in exports of rebar in 2024, according to UN Comtrade data.^{Footnote 111}

[129] Korean rebar producers highlight their export oriented business models which emphasize that export markets are significant for these companies. For example, Dongkuk Steel Mill Co., Ltd. advertises its American offices and that it possesses a global network.^{Footnote 112} Kosteel’s website prominently features its recent growth in global markets, stating it is up 61.5% from global markets.^{Footnote 113} These are just a few examples that highlight Korean rebar producers having business models that require exports to be successful, especially due to unfavourable conditions in the domestic market in Korea, discussed in detail below.

[130] The export oriented nature of Korean rebar companies is publicly advertised on their websites showing key interest in the North American market. This coupled with the other factors in consideration indicate that in the event of rescinding the order of anti-dumping duties on Korean rebar, there would be interest in exporting to markets without anti-dumping duties in place.

Economic conditions in Korea increase the likelihood of resumed exports

[131] Economic challenges facing the Korean economy have been highlighted in the arguments provided by the Canadian producers above. The CBSA’s own position on this will be emphasized below, without repeating specific details that have been previously elaborated on in prior sections of this report.

[132] The economic challenges in Korea are likely to result in weak domestic demand for rebar, incentivizing Korean producers to seek export opportunities. Modest growth rates, uncertainty in the construction sector, trade tensions weighing on export performance, demographic issues and high levels of household debt all negatively impact the forecast for the Korean economy. In the absence of a solid domestic industry for Korean rebar to be sold to, Korean rebar producers are likely to look elsewhere to maintain production levels of their factories.

[133] The economic conditions in the construction sector have led to a significant drop-off in construction activity in South Korea.^{Footnote 114} This stagnant construction output is forecasted to remain tempered by inflation.^{Footnote 115} While value may increase overall in the long-term, the Korean construction sector, and therefore Korean domestic demand for rebar, is presently in a less-than ideal state.

[134] Korean steel producers are being undercut domestically by a flood of cheap imports from China.^{Footnote 116} China’s significant production capabilities of steel coupled with the economic slowdown in China’s domestic economy means more steel is being exported to other markets. South Korea is highly susceptible to these exports from China. This has led to uncertainty within the Korean steel industry and is one of the major drivers of a slowdown in Korean steel production along with global oversupply and U.S. tariff measures. Korean steel producers know that their domestic market share is threatened and they are likely to seek out other markets to sell into.

[135] Chinese imports flooding the Korean market while Korea has suffered a significant downturn in construction demand has had a significant detrimental impact on Korean rebar exporters and has likely made these producers desperate for export markets. Hyundai Steel reported in its 2024 year-end financial update that long steel profits decreased due to a slow domestic construction market.^{Footnote 117} Hyundai’s most recent report for 2025 Q2 noted that demand remains “slow”.^{Footnote 118} As the Tribunal noted in RR-2021-006, rebar producers face a production imperative for rebar, and this imperative may drive them to have to choose between exporting and scaling back production.^{Footnote 119} Some Korean rebar producers have been forced to temporarily suspend operations and close facilities due to their inability to find enough demand to fill their mills. In April 2025, Hyundai Steel, Korea’s second largest steel producer, suspended rebar production at its Incheon plant for one month^{Footnote 120} and Dongkuk Steel announced in May 2025 that it would close its Incheon rebar plant indefinitely “to help stabilize rebar supply”.^{Footnote 121}

[136] Chinese exports have grown substantially in recent years due to slowing domestic demand and capacity increases continuing, despite calls for capacity reductions. South Korea has been an economy that has been significantly impacted by these Chinese imports, which are causing domestic producers to decide whether to idle their mills or find export destinations. In the event that the order is rescinded these exporters will be able to reconsider their idling decisions and ramp up exports to Canada to fill this idle capacity seen due to the economic conditions discussed above.

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

[137] As previously mentioned, tariff-related disruptions impact South Korean producers substantially, since Korean steelmakers previously benefitted from relatively generous tariff-free quotas into major markets, including the U.S. and the E.U.^{Footnote 122} The Bank of Korea estimated that U.S. measures would reduce Korean exports by 0.3% from the U.S. measures alone.^{Footnote 123}

[138] Korean steel producers are subject to several other antidumping and countervailing measures currently in place targeting Korean rebar and long products produced on similar equipment. The United States and Australia both have measures imposed against Korean long product producers.^{Footnote 124}

[139] These measures, particularly in the United States, have decreased rebar exports from Korea to the U.S. from 40,258 tonnes in 2022 to 32,424 in 2024.^{Footnote 125} The Section 232 measures are likely to contribute to further decreases. However, Korean exports have increased over that same period due to the impact of Chinese imports in Korea, as discussed above. Global exports of rebar from Korea have increased from 507,054 tonnes up to 558,449 in 2024.^{Footnote 126} Due to Chinese import competition and weakening domestic demand in the steel industry, South Korean producers face the choice of idling their mills or finding other export markets to continue production.

[140] In 2022, U.S. import quotas restricted imports of Korean steel pipe, which led to a 10.6% decrease from 2021. Over the first eight months of 2022 steel pipe exports to Canada increased by 131%.^{Footnote 127} This example provides some context into the threat of trade diversion that rebar producers in Canada would be subject to in the event that the order is rescinded.

[141] As of November 4, 2025, the CBSA has anti-dumping measures in force for eight steel products originating in or exported from South Korea.^{Footnote 128}

• Carbon steel welded pipe 2
• Cold-rolled steel
• Corrosion-resistant steel sheet
• Hollow structural sections
• Line pipe 2
• Oil country tubular goods 2
• Steel plate
• Steel strapping (provisional finding)

[142] 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 order expire, rebar 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.

Excess rebar production and capacity in South Korea

[143] The Canadian producers cite CRU data showing South Korea’s rebar capacity remained relatively stable while excess capacity is expected to grow by 1.3 million MT in 2025. Utilization rates are expected to remain low at 58% in 2025, although forecasts project that utilization rates will increase to 76% in 2027, which is similar to 2022-2023 rates.

[144] The Canadian producers argue that the combination of rising rebar production capacity and persistently low utilization rates in the context of slowing demand increases the likelihood that South Korean producers and/or exporters will resume or continue exporting Subject Goods to Canada at dumped prices if the Finding expires.

Determination regarding likelihood of continued or resumed dumping: South Korea

[145] Based on evidence on the record the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of dumping into Canada of certain concrete reinforcing bar originating in or exported from South Korea.

Türkiye

[146] In assessing the likelihood of continued or resumed dumping from Türkiye should the CITT’s order be rescinded, the CBSA relied on the information on the administrative record which includes the responses to the various ERQs from all interested parties.

[147] The CBSA solicited information from potential producers and exporters of subject rebar in Türkiye, it did not receive any responses. No producers or exporters submitted case briefs or reply submissions for the CBSA to consider in making a determination. Furthermore, no importers of subject rebar from Türkiye filed a case brief or reply submission.

Domestic conditions in Türkiye have significantly decreased the demand for steel

[148] Conditions in Turkey indicate that the exportation of dumped Subject Goods to Canada is likely to continue or resume due to the fact that Turkish prices and costs demonstrate that Turkey is exporting rebar at dumped prices, Turkish rebar prices are declining, domestic demand grew during the POR but is forecasted to contract significantly in 2025 and remain weak through 2027, there is significant excess capacity in Turkey, Turkish rebar exports increased significantly in H1 2025, and exporters are subject to various trade restrictive measures in other jurisdictions.

[149] According to the International Monetary Fund, Türkiye’s GDP is set to slow rapidly in the coming years, from 5.5% in 2022 to 3.2% in 2026.^{Footnote 129} Türkiye is facing a downturn in investment, slowing export demand and trade uncertainties leading to stagnant growth, according to the European Bank.^{Footnote 130}

[150] Türkiye is continuing to experience very high rates of inflation, which reached a high of 72% in 2022, but is expected to slow to 19% in 2026.^{Footnote 131} These high inflation rates in the domestic market encourage producers to seek opportunities in stable currencies like the U.S. dollar, encouraging exports.

[151] Domestic challenges coupled with the global uncertainty in the steel sector have impacted Turkish producers significantly. As a result, in the event that the order is rescinded, Turkish producers and exporters would likely resume exporting to Canada.

Turkish companies have a sustained interest in the Canadian Market

[152] During the POR, CBSA compliance stats show significant volumes of rebar sold to Canada. In 2022 alone, 255,848 MTs of rebar was sold to Canada.^{Footnote 132} Imports during the POR indicate that Turkish producers have an interest in the Canadian market. Without anti-dumping duties in place, it’s likely that Turkish companies would be interested in continuing to sell rebar to Canada, and the POR indicates that these goods would likely be dumped in order to regain market share.

[153] Türkiye is facing significant restrictions in two other major export markets: the U.S. and the E.U. Turkish exporters face a 50% surtax in the United States and have reduced their exports to that market.^{Footnote 133} As for the E.U., the Carbon Border Adjustment Mechanism (CBAM) which is set to come into force January 1, 2026, is expected to impose new and significant costs on steel imports from Türkiye, raising the price of these products for EU imports, likely reducing the overall import volumes.^{Footnote 134} The reduced exports to the U.S. and likely reduction in exports to the E.U. in 2026, there is a threat of these products being diverted into the Canadian market in the event that the order is rescinded.

Excess capacity issues in Türkiye

[154] Türkiye ranks eighth globally and second in Europe. The country’s major rebar producers are all among companies with significant production capacities – exceeding 1 million tonnes annually. Despite rebar demand conditions declining since the last expiry review, major Turkish steel producers continue to add production capacity.

[155] Major Turkish rebar producers have announced large-scale investment plans. Kardemir plans to invest $1.5 billion USD in the next five years to increase steel production from 2.5 to 3.5 million tonnes in the short term, with a “goal of opening up to new markets.”^{Footnote 135} Ekinciler is actively investing $25.2 million USD to increase billet and rebar capacity at its Iskenderun plant.^{Footnote 136}

[156] The capacity utilization rate in the Turkish steel industry is currently 62.6%. The general secretary of the Turkish Steel Producers Association said that the objective is to reach 70% in 2025.^{Footnote 137} Considering the expected demand slowdowns in the domestic construction sector discussed above, it’s likely that production capacity increases would be done through seeking new export markets. In times of contraction previously, Turkish steelmakers usually adopt a strategy of avoiding cutting the workforce by reducing the number of shifts, prioritizing maintenance and repair work, explore product diversification, and turn to alternative export markets.^{Footnote 138}

[157] Given the available capacity in the Turkish steel sector and the strategies adopted to minimize downtime, it is likely that Turkish producers would seek to export to Canada again in the event that the order is rescinded.

Turkish producers remain export oriented

[158] The OECD noted that the Turkish economy rebalanced from its previous overreliance on domestic consumption towards a stronger contribution of net exports.^{Footnote 139} Turkish steel producers increased its exports of steel products by 18% in January-May 2025 compared to the same period in 2024.

[159] Turkish Producers Kaptan Demir Celik Endustrisi ve Ticaret A.S. (Kaptan Demir), Kroman Çelik Sanayii A.Ş. (Kroman) and İçdas Çelik Enerji Tersane ve Ulaşım A.Ş. (İçdas) are among the top exporters in Türkiye along with a number of other rebar producers.

[160] İçdas notes that a significant portion of its products are exported, including rebar.^{Footnote 140} The Government of Türkiye’s Twelfth Development Plan (2024-2028) indicates that rebar producers in Türkiye will continue to expand their exports as it is a key objective and list the “Basic Metal Industry” as a priority sector under the plan.^{Footnote 141}

[161] Based on the information available on the administrative record, the export oriented nature of Turkish rebar producers mean that it’s likely exports would resume in the event that the order is rescinded.

Turkish producers have a history of dumping

[162] During the POR, subject goods from Türkiye were dumped. Approximately $38 million dollars were collected in SIMA duties in 2022 alone on rebar from Türkiye.

[163] Based on the available evidence on the administrative record, it’s likely that Turkish producers would resume dumping into Canada in the event that the order is rescinded.

Determination regarding the likelihood of continued or resumed dumping: Türkiye

[164] Based on evidence on the record the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of dumping into Canada of certain concrete reinforcing bar from Türkiye.

Parties contending that continued or resumed subsidizing is likely

Domestic producers

[165] Gerdau, AMLPC and AltaSteel provided case briefs supporting its position that subsidizing from China is likely to continue or resume in the event the order is allowed to expire.^{Footnote 142}

[166] The Canadian producers contend many factors relate to both dumping and subsidization that have already been presented in the dumping section of this report:

• Current international market conditions
• Current domestic market conditions
• Commodity nature of rebar
• Factors specific to China

[167] These positions will not be re-iterated here, please refer to the relevant section in the dumping portion for a summary of the Canadian producer’s position on these factors.

[168] The Canadian producers provided an additional factor to support their argument that continued or resumed subsidization is likely if the order expires, that China rebar imports remained subsidized during the POR.

Chinese subsidization of subject goods is likely to continue

[169] The Canadian producers noted that SIMA duties, which include amounts collected for subsidy, collected from exports of subject goods from China were present in every year of the period of review.^{Footnote 143}

[170] In every investigation and expiry review involving Chinese steel since the POR where subsidization was alleged, the CBSA found that Chinese producers were subsidizing those steel goods or were likely to continue subsidizing those steel goods.^{Footnote 144}

Parties contending that continued or resumed subsidizing is unlikely

[171] No case briefs or reply submissions were submitted contending that the subsidizing from China is not likely to continue or resume if the order is rescinded. No submissions were received from the GOC.

China

[173] In assessing the likelihood of continued or resumed subsidization from China should the CITT’s order be rescinded, the CBSA relied on the information on the administrative record which includes the responses to the various ERQs from all interested parties.

[174] The CBSA solicited information from potential producers and exporters of subject rebar in China, it received no responses to the Exporter/Foreign Producer ERQ.

[175] No producers nor exporters submitted case briefs or reply submissions for the CBSA to consider in making a determination. No importers of subject rebar from China filed a case brief or reply submission. Furthermore, the Government of China did not provide a response to the Subsidy ERQ, nor did the Government of China provide a case brief or reply submission.

Tariffs and safeguard measures on steel imports and diversion into Canada

[176] The diversionary threat outlined in the dumping portion of this report is likewise applicable to subsidized goods. Please review the aforementioned section for a full analysis.

[177] Due to the geographic proximity of the US to Canada and the size of the American market for rebar, the imposition of these measures will likely cause steel rebar, including rebar exported from China, to be diverted to Canada. This diversionary pressure can be expected to be exacerbated by the protectionary measures in other jurisdictions, increasing the likelihood that subsidized goods are diverted into Canada.

Imposition of countervailing measures by Canada and other jurisdictions on China

[178] As of November 1, 2025, there are over 50 countervailing measures in force in effect per reporting members impacting base metals and articles of base metal against China.^{Footnote 145}

[179] Specific to Canada, as of November 1, 2025, the CBSA has countervailing measures in force for 14 steel products originating in or exported from China:^{Footnote 146}

• Carbon steel welded pipe
• Cast iron soil pipe (preliminary determination)
• Cold-rolled steel
• Container chassis
• Fasteners
• Large line pipe
• Line pipe
• Oil country tubular goods
• Piling pipe
• Pup joints
• Seamless casing
• Stainless steel sinks
• Steel grating
• Steel strapping (preliminary determination)
• Sucker rods
• Wind towers

[180] The existence of numerous countervailing measures in place in Canada against a variety of Chinese steel products, as well as numerous countervailing measures imposed by other jurisdictions on steel and other base metal products demonstrate that the Government of China continues to subsidize its steel industry. As such, it is likely that exporters from China will benefit from continued or resumed subsidizing if the order expires.

Continued availability of subsidy programs for rebar exporters/producers in China

[181] Although no responses were received from exporters or the Government of China in this expiry review investigation, the CBSA has consistently found a likelihood of resumed or continued subsidization since the finding was put in place.

[182] The OECD completed a study regarding subsidies to the steel industry in 2023.^{Footnote 147} The report highlighted some of the ongoing issues in the steel industry and highlighted the magnitude of subsidy programs that were being offered to Chinese steel producers,^{Footnote 148} and found that countries with steel production targets were more likely to engage in subsidization of their steel industries.^{Footnote 149} Furthermore, in May of 2025, the OECD further reported that Chinese steel subsidies were distorting the global market for steel.^{Footnote 150} The OECD also noted that “China's steel subsidisation rate (as a percentage of firm revenues) is five times higher than the average for other partner economies”, which is already twice as high as in OECD countries.^{Footnote 151} Likewise, in its 2025 global steel outlook report, the OECD notes that China continues to subsidize its steel sector far above the average rate of subsidization of both the OECD and non-OECD average rates of subsidy.

[183] The OECD report further suggests that Chinese steel subsidies are closely tied to state ownership and company size. Firms with at least 25% state ownership receive four to six times more subsidies than those with less. Larger producers also get more subsidies per unit of capacity than smaller ones. Additionally, subsidies correlate with capacity expansion, suggesting they incentivize continued growth in steelmaking.^{Footnote 152}

[184] China has introduced new policies to support its steel industry. The “Two New” policy provides funding for equipment modernization and subsidies for buyers of Chinese products.^{Footnote 153} Additionally, the 2023 “Work Plan for Stabilizing Growth in the Steel Industry” aims to boost fiscal, tax, and financial support for steel companies.^{Footnote 154}

[185] Information on the administrative record shows that Chinese steel subsidies have been provided to rebar producers. Global Trade Alert reported that Xinyu Iron & Steel Co. Ltd., a major Chinese producer of rebar,^{Footnote 155} had received USD 12 million in Chinese subsidies in 2023 based on its annual reports. Maanshan Steel, another Chinese rebar producer, announced in January of 2024 that it has received over RMB 340 million in subsidies in 2023.^{Footnote 156}

[186] As a result of the aforementioned continued availability of subsidy programs for rebar exporters in China, there is an increased likelihood that rebar exported from China to Canada will resume or continue to be subsidized, if the CITT’s order expires.

Determination regarding likelihood of continued or resumed subsidizing

[187] Based on evidence on the record, the CBSA has determined that the expiry of the order is likely to result in the continuation or resumption of subsidizing of certain concrete reinforcing bar originating in or exported from China.