Statement of Reasons—Expiry review determination: Concrete Reinforcing Bar 3 (RB3 2026 ER)

Administrative record

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which parties feel is relevant to the decision as to whether dumping is likely to continue or resume if the finding is rescinded.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

[31] 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 June 10, 2026. 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)

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

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

• The Commodity Nature of the Subject Goods^{Footnote 20}
• International Steel Market Conditions^{Footnote 21}
• Market Conditions in the Subject Countries^{Footnote 22}
• Propensity of Subject Country Exporters to Dump and Risk of Trade Diversion^{Footnote 23}
• Export Orientation of Rebar in Subject Countries^{Footnote 24}
• Subject Country Pricing and Costs are Indicative of Dumping^{Footnote 25}
• Canadian Market Conditions^{Footnote 26}
• Product Shifting^{Footnote 27}

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

Parties contending that continued or resumed dumping is unlikely

Importers

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

Exporters and foreign producers

[37] The Hoa Phat Group made representations in their case brief opposing the position that dumping from Algeria, Egypt, Indonesia, Italy, Malaysia, Singapore and Vietnam is likely to continue or resume in the event the present finding is rescinded. Therefore, the Hoa Phat Group argued that the measures should be rescinded insofar as the finding relates to Vietnam.

[38] The main factors identified by the Hoa Phat Group in support of their position are summarized as follows:

• Exporting at prices above cost of production^{Footnote 28}
• Imports from Vietnam are not dumped during the period^{Footnote 29}
• Market Demand in Vietnam Increasing^{Footnote 30}

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

Common factors

Commodity nature of rebar

[42] Rebar is a commodity product that competes on the basis of price. The CITT made this finding in all five inquiries involving rebar since 2015.^{Footnote 31} In the most recent Rebar 5 inquiry, the Tribunal stated that “rebar is a commodity product that competes on the basis of price and is interchangeable regardless of whether it is domestic or imported.”^{Footnote 32}

[43] Given the commodity nature of the subject goods, when measures are in place for one country, other sources of rebar emerge. This is evident from the number of measures in place in Canada for rebar and other long products.

[44] As previously noted by the CITT, steel mills are capital intensive with high fixed costs. In order to recover fixed expenses, steel mills must run at high levels of production capacity. When home market demand drops, producers will search out foreign markets to maintain capacity utilization to ensure that these fixed costs are recovered.

International steel market conditions

[45] The International Monetary Fund (IMF) reports that the global economy is facing threats, primarily due to US tariffs shaping international trade and conflict in the Middle East shocking the global economy. Amid these developments, global uncertainty remains historically high. As a result, global economic growth is expected to slow from 3.4% in 2025 to 3.1% in 2026, before increasing to3.2% in 2027.^{Footnote 33}

[46] Global steel capacity continues to grow despite a weak outlook for steel demand and the global economy more generally. Global steel excess capacity increased to 640 million MT in 2025 and is projected to increase through 2028, mostly occurring in Asia. The gap between demand for steel and the capacity to produce steel is expected to grow to 721 million MT, reaching the highest level in a decade.^{Footnote 34}

[47] High fixed costs encourage steel producers to maintain steel production in order to recover fixed costs even while margins worsen. Coupled with the concerns of overcapacity in the industry, global steel producers are incentivized to find export markets to maintain production levels rather than idle their mills. The CBSA has acknowledged the impact that these two dynamics have on the steel industry in previous expiry reviews. Excess capacity concerns combined with the need to maintain production levels incentivize producers facing worsening domestic conditions to export their steel products.

[48] Construction activity is the primary driver of rebar demand and has slowed significantly in major global markets. Oxford Economics forecasted that global construction activity would fall by 4.5% over 2025 due to high interest rates, weak housing markets, and broader economic uncertainty.^{Footnote 35} This is particularly evident in China, where approximately 31% of all steel is used domestically. Considering China produces over half of the world’s steel production, the notable decline in China’s real estate sector^{Footnote 36} has led to a record 131 million MT of steel being exported from China in 2025.^{Footnote 37}

[49] In Europe, the construction sector was already experiencing prolonged weakness following contractions throughout 2023 and 2024, with forecasts suggesting that construction activity will likely remain below pre-pandemic levels for the foreseeable future.^{Footnote 38}

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

[50] Broadly speaking, the number and scale of trade protectionist measures affecting rebar have grown significantly during the period of review. Global trade of rebar continues to be disrupted by geopolitical tensions and an expanding range of protectionist trade measures. Since 2025, these measures have been further reinforced through reduced quota limits and higher out of quota duties. Global trade of rebar has become fragmented and regionalized with fewer countries participating in free cross-border trade.^{Footnote 39}

[51] The EU replaced the expiring safeguard regime with a new framework known as the EU Steel Regulation, which reduced the total volume of duty-free import quotas by 47% compared to the 2024 reference system. Out of quota volumes are charged a 50% duty, significantly raising the cost of imports exceeding the allocated volumes.^{Footnote 40}

[52] Other jurisdictions have also implemented measures to protect their steel industries, including rebar. In 2026, the U.S. announced three new anti-dumping measures on rebar from Algeria, Egypt and Vietnam.^{Footnote 41} Additional measures in force on long products in other jurisdictions will be discussed in the analysis of each subject country in the next section.

[53] Given its geographic proximity to Canada, the size of the U.S. steel market, and the substantial escalation of Section 232 and other tariffs, the U.S. measures imposed represent a significant source of potential trade diversion of subject goods that might otherwise have been destined for the U.S. These pressures are compounded by safeguard and trade remedy actions in other major markets, the decline in domestic demand in China leading to record levels of exports, and increased capacity in the long products sector. In this context, Canada becomes a more attractive market for excess rebar production, increasing the likelihood that imports will be diverted to Canada.

Canadian market conditions

[54] Effective June 27, 2025, Canada introduced a tariff rate quota on steel imports during the POR, setting quarterly rebar limits based on free-trade agreement status. Countries without an FTA, Currently, quota volumes for rebar from countries without an FTA, such as Algeria, Egypt and Vietnam, can ship up to 13,445 metric tons combined per quarter, with individual country shipments capped at 3,899 metric tons. In contrast, FTA partners are allocated up to 28,710 metric tons total each quarter, with a per-country limit of 12,920 metric tons. Over quota volumes are subject to a 50% surtax but are not subject to price discipline within the quota limits. Countries compete for first-come first-served allocation of volumes in the current system.^{Footnote 42} Furthermore, a 25% surtax is applied to certain steel goods imported into Canada that contain materials melted and poured in China.

[55] General economic conditions in Canada have significant uncertainty in forecasts due to ongoing global conflicts, North American trade negotiations, and weakening conditions in the construction sector.^{Footnote 43} New construction builds are projected to decline to approximately 243,000 in 2026 from 259,000 in 2025, with condominium presales in Toronto and Vancouver deteriorating significantly.^{Footnote 44}

[56] Forecasts for key rebar-consuming sectors in Canada are mixed. 2025 was a strong year for the Canadian construction industry which continued into early 2026. However, housing construction is expected to slow due to the aforementioned decline in new construction builds. Information on the record indicates that the Canadian rebar market was relatively stable throughout the POR.^{Footnote 45} Despite significant challenges currently facing the sector, the resilience of the market with attractive pricing relative to markets outside North America makes Canada an appealing export market for subject goods. While the TRQ framework limits the total volume of subject goods entering the market each quarter, there is no mechanism within the framework to prevent dumping.

Algeria

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

[58] The CBSA solicited information from potential producers and exporters of subject rebar in Algeria. It did not receive any responses. Furthermore, no importers of subject rebar from Algeria filed a case brief or reply submission.

[59] CBSA enforcement data indicates that significant volumes of subject goods from Algeria were exported to Canada over the period of review. In addition, SIMA duties were assessed on Algerian rebar imports in every period.^{Footnote 46}

[60] The consistent volume of rebar shipped from Algeria indicates a clear interest in the Canadian market and the significant SIMA duties collected indicates that dumping occurred during the period.

Determination regarding likelihood of continued or resumed dumping: Algeria

[61] Based on evidence on the record 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 concrete reinforcing bar originating in or exported from Algeria.

Egypt

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

[63] The CBSA solicited information from potential producers and exporters of subject rebar in Egypt. 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 Egypt filed a case brief or reply submission.

[64] Egyptian rebar producers are exhausting their Tariff Rate Quota (TRQ) volumes of both rebar and wire rod to the EU. Over quota volumes are subject to 50% surtaxes. With limited access to this key market, Egyptian producers will need to actively search for other markets for their rebar originally destined for major markets they now have limited access to.^{Footnote 47}

[65] On January 13, 2026, the USDOC issued a preliminary countervailing measure on Egyptian rebar with duties between 34.2 and 52.73% and the parallel CVD investigation assigned the Ezz Group a 29.51% subsidy rate. This measure, along with existing anti-dumping duties in place against Egyptian rebar producers by the USDOC, is likely to increase the risk of diversion if the finding is rescinded.^{Footnote 48} With limited access to major markets due to safeguard measures, existing trade remedy measures and the imposition of new trade remedy measures, Egyptian producers are likely to actively seek open export markets for these volumes.

[66] During the POR, Egyptian rebar grew significantly in total volume. As a result, rebar exports as a share of total production increased, indicating a growing reliance on export markets while facing increased restrictions from major markets abroad.^{Footnote 49}

[67] Egypt has a significant amount of available capacity for long products relative to the size of the Canadian market.^{Footnote 50} In the event that the finding were rescinded, Egyptian producers have the capacity to export significant volumes to the relatively attractive Canadian market.

[68] Based on the available evidence, the CBSA finds that rebar producers in Egypt possess substantial current and potential production capacity and significant excess capacity.

[69] During the original CBSA investigation’s POI, Egyptian goods represented 4.4% of all rebar imports.^{Footnote 51} There were no Egyptian imports during the POR of the expiry review investigation, indicating that they are unable/unwilling to compete at non-dumped prices. Upon exiting the Canadian market for rebar, the CBSA launched an anti-dumping investigation into wire rod from Egypt, ultimately leading to a finding of dumping. Egyptian wire rod accounted for 11.6% of total wire rod imports into Canada in 2023.^{Footnote 52} The transition from products made on the same equipment after the rebar finding was imposed suggests that Egyptian producers would likely produce rebar destined for Canada on the same equipment used to produce wire rod that is now being sold in limited volumes since the finding was imposed.

Determination regarding likelihood of continued or resumed dumping: Egypt

[70] Based on evidence on the record 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 concrete reinforcing bar originating in or exported from Egypt.

Indonesia

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

[72] The CBSA solicited information from potential producers and exporters of subject rebar in Indonesia. 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 Indonesia filed a case brief or reply submission.

[73] During the original investigation, Indonesian goods represented 9% of all rebar imports.^{Footnote 53} There were no Indonesian imports during the POR of the expiry review investigation, suggesting that they are unable/unwilling to compete at non-dumped prices.

[74] Information on the record suggests that demand for rebar in Indonesia was strong throughout the POR. The construction industry is forecasted to grow by 5.4% in 2026, supported by investments in infrastructure and energy projects, easing inflation and higher budget allocations.^{Footnote 54}

[75] Despite the strong demand conditions in the domestic market, Indonesia’s long product capacity rates were around 50% throughout the POR. While CRU forecasts an increase in production, capacity rates remain very low. The total volume of excess capacity in Indonesia for rebar products is significantly greater than the size of the entire Canadian market.^{Footnote 55}

[76] Throughout the POR, nearly two-thirds of all imports of rebar into Indonesia were from China at significantly lower prices than imports for all other destinations. Nearly 1 million MTs of Chinese rebar was imported during the POR for at least $396 USD/MT less than imports from all other countries.^{Footnote 56}

[77] Anti-dumping findings against Indonesian rebar have been imposed by the US and Australia,^{Footnote 57} in addition to Canada, as well as the proliferation of other trade restrictions such as the EU steel safeguard measures and section 232 duties in the US.

Determination regarding the likelihood of continued or resumed dumping: Indonesia

[78] Based on evidence on the record 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 concrete reinforcing bar from Indonesia.

Italy

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

[80] The CBSA solicited information from potential producers and exporters of subject rebar in Italy. 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 Italy filed a case brief or reply submission.

[81] During the original investigation, Italian rebar represented 21.9% of all rebar imports.^{Footnote 58} There were no Italian imports during the POR of the expiry review investigation, suggesting that they are unable/unwilling to compete at non-dumped prices.

[82] Domestic conditions in Italy have been negatively impacted by high public debt, limited growth, and global conflicts.^{Footnote 59} These worsening conditions have led to limited growth forecasts in construction activity and rebar demand as a result. Despite weakening demand, rebar production is forecasted to increase. Utilization rates remain low and provide ample opportunity to seek export markets to sell their excess production.

[83] Italian rebar producers are export oriented. Italy exported over 1.5 million MT of rebar each year between 2023-2025.^{Footnote 60} A significant portion of total production is exported. With limited access to key markets like the US, Italian producers are likely to seek open markets to fill production volumes.

[84] Finally, excess capacity rates are expected to remain very low through 2028.^{Footnote 61} This low utilization rate coupled with the commodity nature of rebar and other factors described above encourage producers to maintain throughput in order to recover fixed costs.

Determination regarding the likelihood of continued or resumed dumping: Italy

[85] Based on the evidence on the record 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 concrete reinforcing bar from Italy.

Malaysia

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

[87] The CBSA solicited information from potential producers and exporters of subject rebar in Malaysia. 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 Malaysia filed a case brief or reply submission.

[88] During the original investigation, Malaysian rebar represented 3.5% of all rebar imports.^{Footnote 62} There were no Malaysian imports during the POR of the expiry review investigation, suggesting that they are unable/unwilling to compete at non-dumped prices.

[89] Domestic conditions in Malaysia are projected to experience modest declines in growth and heightened exposure to geopolitical and global energy price fluctuations.^{Footnote 63} These worsening conditions have led to volatile forecasts in construction activity and rebar demand as a result. Utilization rates of long products are forecasted to remain low in the coming years and provide ample opportunity to seek export markets to sell their sizable excess production capacity.^{Footnote 64}

[90] Malaysian rebar producers are export oriented. Malaysia exported over 1 million MT of rebar each year between 2023-2024 and exports were likely underreported in 2025.^{Footnote 65} A significant portion of total production is exported. With limited access to key markets like the US, Malaysian producers are likely to seek open markets to fill production volumes.

[91] Chinese imports represented a significant portion of total rebar imports and were consistently lower than Malaysia’s total weighted average import price throughout the POR.^{Footnote 66}

[92] Malaysian rebar producers are subject to multiple anti-dumping measures from the US and Australia. Furthermore, Vietnam has an anti-dumping finding on goods produced on the same equipment.^{Footnote 67} Combined with limited access to major markets like the US and the EU, Malaysian producers will actively seek other export markets in the event that the finding is rescinded.

Determination regarding the likelihood of continued or resumed dumping: Malaysia

[93] Based on evidence on the record 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 concrete reinforcing bar from Malaysia.

Singapore

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

[95] The CBSA solicited information from potential producers and exporters of subject rebar in Singapore. 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 Singapore filed a case brief or reply submission.

[96] During the original investigation, Singaporean rebar represented 11.5% of all rebar imports.^{Footnote 68} There have been no Singaporean imports since the finding was imposed five years ago, suggesting that they are unable/unwilling to compete at non-dumped prices.

[97] Information on the record indicates that imports from China are becoming increasingly present in the domestic rebar sector. Over the period of review, the volume of Chinese imports grew from 79,000 MT in 2023 to 582,500 MT in 2025. The price of Chinese imports into Singapore declined significantly during this time, from US$748/MT in 2023 to US$501/MT in 2025.^{Footnote 69}

Determination regarding the likelihood of continued or resumed dumping: Singapore

[98] Based on evidence on the record 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 concrete reinforcing bar from Singapore.

Vietnam

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

[100] The CBSA solicited information from potential producers and exporters of subject rebar in Vietnam. 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 Vietnam filed a case brief or reply submission.

[101] During the original investigation, Vietnamese rebar represented 9.2% of all rebar imports.^{Footnote 70} CBSA enforcement data indicate that there were shipments of subject goods from Vietnam, albeit in modest volumes. SIMA duties were assessed in each year of the period of review.^{Footnote 71}

[102] Domestic conditions in the Vietnamese economy remain optimistic despite challenging external factors. The GDP growth forecasts can be mainly attributed to weaker demand for exports abroad due to ongoing trade disputes.^{Footnote 72} Weakening domestic conditions in rebar consuming sectors due to fuel shortages and rising costs linked to the US-Iran conflict are expected to disrupt project execution and threaten momentum.^{Footnote 73}

[103] Vietnam’s capacity for rebar is forecast to grow in 2026 with significant total excess capacity, despite strong utilization rates.^{Footnote 74} Capacity expansion projects are continuing, with multiple projects underway to add additional capacity to the market.^{Footnote 75}

[104] Information on the record suggests that Vietnamese producers remain export oriented and have now experienced significant trade measures imposed on goods destined for the US.^{Footnote 76} With limited access to this major market, producers will likely look to other open markets to maintain production levels.

[105] The EU and UK safeguard measures and Section 232 tariffs on exports to the US currently in force significantly limit total exports of Vietnamese products to these major markets. With the various trade restrictive measures imposed alongside country specific trade remedy measures, Vietnamese producers will actively seek other markets to export to.

[106] Trade remedy measures in other jurisdictions indicate that if the finding were to be rescinded, it is likely that producers would price aggressively to regain access to the Canadian market. Vietnamese producers are subject to measures imposed on similar goods in Canada and by Australia, Thailand and the United States.

Determination regarding the likelihood of continued or resumed dumping: Vietnam

[107] Based on evidence on the record 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 concrete reinforcing bar from Vietnam.