Statement of Reasons—Initiation of investigation: Oil and Gas Well Casing 6 (OCTG6 2026 IN)

Complainant

[8] The names and addresses of the complainant is as follows:

Tenaris Canada
530 8 Ave SW, Suite 400
Calgary, Alberta  T2P 3S8

Other producers

Interpro Pipe & Steel Inc.^{Footnote 1}
P.O. Box 1670
100 Armour Road
Regina, SK  S0G 5K0

Welded Tube of Canada Corporation
111 Rayette Road
Concord, Ontario  L4K 2E9

[9] The CBSA is not aware of any other producers of oil and gas well casing in Canada.

Trade unions

[10] Tenaris Canada identified Local Union 9548 as the relevant union for Algoma. Interpro’s relevant USW union locals are Local Union 5890 (Regina) and Local Union 6673 (Calgary). WTC’s relevant USW union local is USW 8328 (Toronto). UNIFOR represents persons employed in casing production at Interpro and WTC facilities in Canada, with the relevant UNIFOR local being UNIFOR 551 (Camrose, AB) for Interpro and UNIFOR 199 (St. Catherines, ON) for WTC. Iron Workers 805 (St. Albert, AB) is another trade union representing persons employed in Interpro’s Casing production.^{Footnote 2}

Exporters

[11] The CBSA identified one exporter of the subject goods from Austria from CBSA import documentation and from information submitted in the complaint. All potential exporters were asked to respond to the CBSA’s dumping request for information (RFI).

Importers

[12] The CBSA identified one importer of the subject goods from CBSA import documentation and from information submitted in the complaint. All potential importers were asked to respond to the CBSA’s importer RFI.

Product definition^{Footnote 3}

[13] For the purpose of this investigation, subject goods are defined as:

Additional product information^{Footnote 4}

[14] For greater certainty, the product definition does not include oil and gas well tubing but it does include semi-finished casing, which is typically referred to as “green tubes” or occasionally “green pipes”. These green tubes, as they are most commonly referred to in the oil country tubular goods (OCTG) industry, are intermediate or in-process pipes which require additional processing, such as threading, heat treatment or testing, before they can be used as fully finished oil and gas OCTG in end-use applications. This product definition includes green tube casing (i.e. green tubes with the necessary characteristics and intended for finishing into casing) and does not include green tube tubing.

[15] Drill pipe is excluded from the product definition for this investigation. Drill pipe consists of heavy (usually seamless) tubing with high-strength tool joints on either end that is manufactured to API specification 5DP or API specification 7-1 and is used for drilling oil and gas wells.

[16] Pup joints are also excluded from the product definition for this investigation. These products are essentially short lengths of OCTG used for spacing in a drill string, and these are excluded where their length is twelve feet or below (with a three-inch tolerance), as defined in API 5CT.

[17] Unattached couplings as well as coupling stock are also excluded from the product definition for this investigation. Couplings are used to connect two pipes together, allowing for the flow of hydrocarbons and other production fluids from the reservoir to the surface. Casing and tubing couplings come in various sizes, materials, and designs, and are made from coupling stock. Coupling stock is similar to other OCTG except that the pipe walls are thicker and the coupling stock pipe itself is used for further processing into couplings or other float equipment.

[18] Insulated tubing and vacuum insulated tubing (IT/VIT) are also excluded from the product definition for this investigation. IT/VIT are a subset of OCTG that are used for thermal-enhanced oil recovery of extremely viscous crude oils. IT/VIT may also be described as insulated steam injected tubing and oil production tubing, including double-walled tubing, with or without insulation. These IT/VIT products are used in steam injection wells in Steam Assisted Gravity Drainage (SAGD) drilling applications deployed in oil sands assets and also in Cyclic Steam Stimulation (CSS) drilling applications deployed in heavy oil assets.

[19] Finally, stainless steel OCTG is excluded from the product definition for this investigation.

Product specifications and usage^{Footnote 5}

[20] Casing is used to prevent the walls of the bored hole from collapsing, both during drilling and after the well has been completed. It must be able to withstand outside pressure and internal yield pressures within the well. In addition, it must have sufficient joint strength to hold their own weight and must be equipped with threads sufficiently tight to contain the well pressure where lengths are joined. Threading may be performed by the manufacturer or a third-party threading operation. Various factors limit the total amount of open hole that can be drilled at any one time, and it may be necessary to set more than one string of Casing concentrically for certain portions of the well depth.

[21] Heat-treated seamless casing requires steel of a particular chemistry and careful heat treatment to obtain the necessary combination of mechanical properties and/or resistance to corrosion and environmental cracking. The required characteristics could include, for example, maximum strength (P110 and Q125), high-strength with low ductility (normally proprietary enhancements of API grades), or high-strength combined with resistance to corrosion and environmental cracking (e.g. C110, T95 and proprietary enhancements).

[22] A green tube for a higher strength grade can have a chemistry that meets a lower grade like H40 or J55 that does not require heat treatment and can be tested and threaded to meet the lower grade.

[23] There are a wide range of possible proprietary enhancements that exceed API minimum requirements, including proprietary “subgrades”. Examples of proprietary subgrades include Tenaris Canada’s Improved Collapse (IC such as a P110 IC) or Improved Collapse and Yield (ICY, such as L80 ICY).

Production process^{Footnote 6}

[24] Casing may be by either the seamless or the electric resistance welded (ERW) process. The complainant, Tenaris Canada, employs both the seamless and the ERW processes at its Algoma manufacturing facility in Sault Ste. Marie, Ontario.

[25] The seamless production process starts with its purchasing of steel bars (also known as billets) which are imported from sister companies. The steel bar is cut into a billet and then loaded into the rotary furnace to be heated and readied for the Hot Rolling Mill (HRM). Once the HRM has transformed the billet into a tube it enters into a reheat furnace and then the stretch reduction/sizing mill produces the final dimensions. Depending on the grade desired, the next process may involve heat treatment. Finishing operations include Non-Destructive Testing (NDT), electromagnetic inspection (EMI) testing, hydrotesting, thread inspection, coupling, varnishing, stenciling and railcar loading for shipment.

[26] All Casing produced by Algoma are green tubes before they are finished. While Algoma has its own threading, coupling and heat-treating capabilities, some product of Algoma is threaded, usually with a Casing premium connection (and coupling/protector applied), at the Hydril facility in Alberta. The products that are threaded at Hydril facility products are reported as sales by Algoma.

[27] Algoma currently produces seamless casing in diameters ranging from 4.5 to 9.875 inches for API and proprietary grades and well as ERW casing in diameters ranging from 4.5 to 12.75 inches.

[28] ERW Casing is produced by slitting flat hot-rolled steel in coil form of a predetermined thickness (skelp) to the proper width required to produce the desired diameter of pipe. The skelp is then sent through a series of forming rolls that bend it into a tubular shape. As the edges of the skelp come together under pressure in the final forming rolls, an electric current is passed between them. The resistance to the current heats the edges of the skelp to the welding temperature, and the weld is formed as the two edges are pressed together.

[29] Steel tubes are formed by either the seamless or the ERW methods and are then cut to length. Depending on the API specifications required, Casing may also be heat-treated at this point. The product is then sent to the finishing line where it is tested (NDT, EMI and hydro) beveled and threaded on both ends. Tubing may undergo a separate process of upsetting and normalizing prior to threading. Finally, a coupling and coupling protector are applied to one end of the Casing and a thread protector is applied to the other end before it is ready for shipment. Finishing operations also include cooling, straightening, inspection, testing, coating, and/or bundling.

Classification of imports

[30] The subject goods are normally imported under the following tariff classification numbers:

1. 7304.29.00.12
2. 7304.29.00.13
3. 7304.29.00.14
4. 7304.29.00.15
5. 7304.29.00.16
6. 7304.29.00.17
7. 7304.29.00.19
8. 7304.29.00.22
9. 7304.29.00.23
10. 7304.29.00.24
11. 7304.29.00.25
12. 7304.29.00.26
13. 7304.29.00.27
14. 7304.29.00.29
15. 7306.29.00.12
16. 7306.29.00.13
17. 7306.29.00.14
18. 7306.29.00.15
19. 7306.29.00.16
20. 7306.29.00.17
21. 7306.29.00.19
22. 7306.29.00.22
23. 7306.29.00.23
24. 7306.29.00.24
25. 7306.29.00.25
26. 7306.29.00.26
27. 7306.29.00.27
28. 7306.29.00.29

[31] The listing of tariff classification numbers is for convenience of reference only. The tariff classification numbers include non-subject goods. Also, subject goods may fall under tariff classification numbers that are not listed. Refer to the product definition for authoritative details regarding the subject goods.

Like goods and class of goods^{Footnote 7}

[32] Subsection 2(1) of SIMA defines “like goods” in relation to any other goods as:

[33] In considering the issue of like goods, the Canadian International Trade Tribunal (CITT) typically looks at a number of factors, including the physical characteristics of the goods, their market characteristics, and whether the domestic goods fulfill the same customer needs as the subject goods.

[34] The complaint stated that the oil and gas casing covered by this complaint is a single class of goods, whether produced by the seamless or electric resistance welded (ERW) method. In support, they cited as an example, the Seamless Casing investigation, and subsequent expiry reviews,^{Footnote 8} where the CITT found that the like goods were casing of the same size range of the subject goods. The CITT did not expand the scope of like goods beyond the scope of the subject goods to include other types of OCTG (e.g. tubing or pup joints) or larger sizes of casing (e.g. with an outer diameter of 16” or greater).

[35] The complainant confirmed that given its usage, technical requirements and lack of substitutability, tubing does not form part of the like goods to subject casing for this complaint.^{Footnote 9}

[36] The inclusion of green tubes was justified on the basis that they harm the domestic industry in the same way as the finished good, citing previous CITT decisions, which affirm this position in support.^{Footnote 10}

[37] For the purposes of this analysis, like goods consist of domestically produced oil and gas well casing described in the product definition.

[38] After considering questions of use, physical characteristics, and all other relevant factors, the CBSA is of the opinion that subject goods and like goods constitute only one class of goods.

Domestic producers

[39] Based on the information supplied in the complaint, the complainant identified three domestic producers of like goods in Canada, Algoma Tubes, Interpro and Welded Tube of Canada (WTC). The CBSA is not aware of any other producers of oil and gas well casing in Canada.

Standing

[40] Pursuant to subsection 31(2) of SIMA, the following conditions must be met in order for an investigation to be initiated:

1. the complaint is supported by domestic producers whose production represents more than 50% of the total production of like goods by those domestic producers who express either support for or opposition to the complaint and
2. the production of the domestic producers who support the complaint represents 25% or more of the total production of like goods by the domestic industry

[41] Subsection 31(2.1) of SIMA provides that where a domestic producer is an importer of, or is related to an exporter or importer of, allegedly dumped or subsidized goods, any such producer may be excluded from the definition of “domestic producers”, for purposes of determining the standing under subsection 31(2). Similarly, subsection 31(3) stipulates that such producers may also be excluded from the definition of “domestic industry,” for purposes of standing.

[42] Subsection 31(4) provides guidance for determining whether a domestic producer is related to an exporter or importer for purposes of standing. There are criteria for control and behavior in relation to the domestic producer and both must be satisfied in order for the domestic producer to be deemed related to either party for purposes of not being considered for standing.

[43] The criteria in respect of control states:

1. the producer either directly or indirectly controls, or is controlled by, the exporter or importer
2. the producer and the exporter or the importer, as the case may be, are directly or indirectly controlled by a third person or
3. the producer and the exporter or the importer, as the case may be, directly or indirectly control a third person

[44] The criteria in respect of the behavior requires that there are “grounds to believe that the producer behaves differently towards the exporter or importer than does a non-related producer.”

[45] Subsection 2(1.3) of SIMA further clarifies that a person is deemed to control another person where the first person is legally or operationally in a position to exercise restraint or direction over the other person.

[46] The complainant submitted that WTC should be excluded from the domestic industry for purposes of determining standing pursuant to 31(2) of SIMA based the conditions outlined in subsection 31(4) of SIMA. Specifically, the complainant submitted evidence showing that WT USA is a wholly owned subsidiary of WTC, who legally and operationally controls this entity. The complainant has also observed that this relationship results in WTC behaving differently towards WT USA, as a related producer and exporter of oil and gas well casing, than they do towards unrelated producers and exporters.^{Footnote 11}

[47] Subject exports from WT USA accounted for a substantial amount of the alleged dumped subject goods in the complaint. Consequently, it was reasonable for the President to exercise the discretion afforded under subsection 31(2.1). This is consistent with the approach taken in the recent Oil Country Tubular Goods 5 investigation.^{Footnote 12} As such, for purposes of standing, WTC was excluded from the definition of “domestic producer” as per the aforementioned SIMA provisions.

[48] With only one other producer of like goods in Canada, Interpro, the information on the record confirmed that the complainant satisfies the requirements for standing under both paragraphs 31(2)(a) and 31(2)(b) of SIMA.^{Footnote 13}

The Canadian market

[49] Detailed information regarding the sales from domestic production cannot be divulged for confidentiality reasons. Consequently, the following focuses on imports of goods meeting the description of the subject goods.

[50] The complainant, using Statistics Canada and Global affairs data, estimated the total value of imports of subject goods and goods of the same description from all other countries from January 1, 2022 to September 30, 2025.^{Footnote 14}

[51] The CBSA conducted its own independent review of imports of certain oil and gas well casing from the CBSA’s Electronic Facility Information Retrieval Management (E-FIRM) database and the CBSA Assessment and Revenue Management (CARM) system using the tariff classification numbers under which the subject goods are imported from the subject countries and exporters/producers and all other countries. In addition, the CBSA reviewed its Accelerated Commercial Release Operations Support System (ACROSS) data to correct any errors and remove non-subject imports.

[52] The CBSA has prepared the following tables to show estimated imports of certain oil and gas well casing into Canada from January 1, 2022 to September 30, 2025. Volumes are expressed in metric tonnes (MT) and values expressed in Canadian dollars (CAD).^{Footnote 15}

[53] The import data generated by the CBSA shows comparable trends to those provided by the complainant in terms of the quantity of imports and relative share of imports of subject goods in comparison to other countries.

[54] The CBSA will continue to gather and analyze information on the volume of imports during the period of investigation (POI) of December 1, 2024 to November 30, 2025 as part of the preliminary phase of the dumping investigation and will refine these estimates.

Normal value

Complainants' estimates of normal value

[56] The complainant’s allegations of dumping were based on a comparison of their estimated normal values for the allegedly dumped goods with their estimated export prices.

Section 15

[57] The complainant stated that they were unable to find any market pricing for like goods sold domestically in Austria as there is minimal consumption of casing in the country, with very low oil production.^{Footnote 17}

Section 19

[58] In absence of usable information for section 15 normal values, the complainant estimated normal values for Austria using a paragraph 19(b) constructed cost-plus profit methodology, based on the aggregate of estimates of the cost of production of the subject goods, a reasonable amount for administrative, selling, and other costs and a reasonable amount for profits.^{Footnote 18} The costs are based on a related affiliate, Tenaris Dalmine (Italy), from average production costs over the July 2024 through June 2025 period.^{Footnote 19}

[59] Tenaris provided a cost build-up for eight seamless casing products. Their final margin of dumping calculations were based on five products.^{Footnote 20}

Cost of production

[60] For the purposes of estimating the cost of raw materials (steel billet), the complainant used the material and transformation costs (non-labour) of Italian producer and affiliate, Tenaris Dalmine.

[61] The complainant rationalized that Tenaris Dalmine has a cost structure for seamless casing that is considered to reflect those in other competitive markets, is based in Europe and shares many of the same market characteristics and costs as the producer, Voestalpine (Voest) would in Austria. Therefore, Tenaris Dalmine’s costs, including materials, energy, and overhead, were used in estimating Voest’s costs.^{Footnote 21}

[62] The complainant was able to adjust their costs to reflect the estimated higher cost of labour in Austria as compared to Italy.^{Footnote 22}

[63] The complainant explained that as an integrated producer, Tenaris Dalmine’s costs of production are its actual cost of manufacturing steel bars cut into billets, and pierced by a mandrel. Given that Voest is an integrated producer that produces its own billet,^{Footnote 23} Voest’s billet costs are likely tied to the cost of production in the same way as that of Tenaris Dalmine.^{Footnote 24}

[64] Since Tenaris Dalmine’s standard costs do not track overhead associated with regular annual maintenance (but rather tracks it separately), the complainant allocated a slight upwards adjustment to their costs estimates so as to not understate costs.^{Footnote 25}

[65] Tenaris also allocated an amount for scrap recovery, which varied depending on the grade of final product.^{Footnote 26}

[66] The complainant submitted that labour costs in Austria are higher than Italian labour costs.^{Footnote 27} Information available from the European Union was cited, which reported that the Austrian average hourly manufacturing labour cost was higher than the Italian average hourly manufacturing labour cost.^{Footnote 28} As a result, an Austrian labour premium over Tenaris Dalmine’s labour was added to Voest’s labour cost of production.^{Footnote 29}

[67] In addition, the complainant added an estimated additional amount of labour cost that Voest allegedly incurs.^{Footnote 30}

GS&A and profit

[68] The complainant estimated GS&A using the most recently available public financial statements for Voest.^{Footnote 31} A detailed calculation worksheet on how they arrived at this figure was provided alongside the cost build-up and normal value calculation worksheets.^{Footnote 32} The ratio expressed as a percentage of Voest’s costs was 13%.

[69] The complainant made extensive representations as to why it would not be appropriate to use Voest’s financial statements to estimate its amount for profit. The complainant opted instead to use the public financial statements from two European producers that also produce seamless casing, Benteler and Vallourec.^{Footnote 33} The Benteler amount for profit was 6.7% and the Vallourec amount for profit was 18%. They used a simple average to arrive at 12.4% as their estimated profit for Voest.

CBSA's estimate of normal value

Section 19

[70] In the absence of home market pricing in Austria, the CBSA concurred with the complainant’s approach to estimate normal values for Austria, using a constructed cost-plus method under a paragraph 19(b) methodology, on the aggregate of the cost of production of the subject goods, a reasonable amount for administrative, selling, and other costs and a reasonable amount for profits.

Cost of production

[71] The CBSA generally accepted the complainant’s estimates of steel and transformation costs with some minor modifications.

[72] The CBSA was able to verify that the steel cost estimates (i.e. steel bar) were reasonable. Dalmine’s costs were cited in part to support the estimates.^{Footnote 34} The CBSA downgraded the costs slightly, including the yield loss calculation based on its analysis of the information.^{Footnote 35}

[73] Given the dated nature of what the complainant used to estimate labour differentials between Austria and Italy, the CBSA cited two sources for its labour adjustment factor, including one derived from 2025.^{Footnote 36} The result downgraded the labour factor adjustment slightly. The CBSA also reduced the estimated additional amount of labour cost that the complainant had allocated.

GS&A and profit

[74] The CBSA made no adjustment to the GS&A estimate from the complainant of 13% of costs, as it was found to be reasonable and well supported.

[75] The complainant stated in relation to determining an amount for profits that “in no case is it permissible under the law to rely on an amount for profit based on export sales.”^{Footnote 37}

[76] The CBSA noted, however, that each of the two financial statements cited by the complainant also include exports and sales made by foreign affiliates abroad, including sales of OCTG.

[77] Benteler, for example, had substantial sales to the United States.^{Footnote 38} Benteler also reported a mix of welded and seamless, so it is not purely a seamless pipe producer. The report provided is also somewhat antiquated with a fiscal period ending December 31, 2024. Nonethless, the amount for profit derived from the Benteler financial report was not unreasonably high.

[78] Vallourec also reported the majority of their revenue from OCTG,^{Footnote 39} whereby nearly half of their total tube revenue comes from North America,^{Footnote 40} which Vallourec states is largely the United States.^{Footnote 41} Some of the total OCTG revenue is even generated in China, where Vallourec has an OCTG affiliate.^{Footnote 42}

[79] Consequently, the information used by the complainant also includes profits derived from sales made outside of Europe and is largely consolidated to such a degree that it is not possible to segregate the data into something more closely aligned with sales of OCTG in Europe.

[80] As such, the CBSA used the most recent full-year financial statement information on the record, for Voestalpine’s Metal Engineering division, which is the division that includes tubular goods.^{Footnote 43}

[81] Using information from the actual exporter is preferable, notwithstanding stated flaws, which as noted above, will exist regardless of the source. Using the company’s own financial results is consistent with the CBSA’s approach in the last investigation concerning OCTG from Austria, where amounts for profit were determined under a ministerial specification.^{Footnote 44}

[82] The resulting amount for profit for Voest for purposes of estimating normal values was 5.22%.

Export price

Complainants’ estimates of export price

[83] The export price of goods sold to an importer in Canada is generally determined in accordance with section 24 of SIMA as the lesser of the exporter’s sale price for the goods and the price at which the importer has purchased or agreed to purchase the goods adjusted by deducting all costs, charges, expenses, and duties and taxes resulting from the exportation of the goods.

[84] The complainant stated that the import data from StatsCan is not sufficiently granular to distinguish between different Voest casing products.^{Footnote 45}

[85] The complainant submitted that their best information available regarding export prices for subject goods from Voest sold in Canada during the POI^{Footnote 46} is from Tenaris Canada’s account-specific allegations of sales lost to Voest products. Tenaris Canada cited commercial intelligence relating to quotes that it provided to purchasers for specific requests for seamless casing for which Tenaris Canada subsequently learned that the purchaser allegedly chose to purchase a Voest product instead. Tenaris Canada submitted that it has commercial intelligence as to the amount by which Voest undercut Tenaris Canada’s prices. These account-specific allegations are set out in the complaint.^{Footnote 47}

[86] The complainant’s estimation of Austrian export prices begins with a price quote in the Canadian market it believes it was competing with, then backs out a distributor mark-up, intra-European freight, ocean freight from Italy to Thunder Bay and freight within Canada from Thunder Bay to Edmonton.^{Footnote 48}

[87] The complainant cited evidence on the record to support its estimates for distributor margins and cost of delivery.^{Footnote 49}

CBSA’s estimates of export price

[88] In order to estimate export prices, the CBSA relied on information available through E-FIRM, for the period of October 1, 2024 to September 30, 2025. The CBSA reviewed customs data for goods imported within the tariff classification numbers under which subject goods are imported.

[89] For all subject goods, the CBSA estimated exports prices in accordance with section 24 of SIMA based on the import data available. The descriptive data currently available through E-FIRM provided sufficient detail to enable the CBSA to calculate export prices at a more granular product level, than what was available to the complainant working only with harmonized classification codes.

Estimated margins of dumping

[90] For the purposes of the initiation of the investigation, the CBSA has estimated a margin of dumping using normal values based on the methodology of paragraph 19(b)of SIMA for subject imports from Austria, as explained above.

[91] Based on the normal values estimated under paragraph 19(b), the CBSA estimated the margin of dumping for subject goods from Austria by comparing the estimated normal values with the estimated export prices for the period of October 1, 2024 to September 30, 2025. The CBSA estimates that subject goods from Austria were dumped by a weighted average margin of 9.0%, expressed as a percentage of the export price.

Price undercutting

[99] Tenaris stated that “prices of Subject Goods from Austria have fallen rapidly since 2024 and there is material threat of further drops in pricing.”^{Footnote 55}

[100] The complainant argued that the allegedly dumped goods have undercut the prices of like goods, leading to lost sales volumes and revenues for the domestic industry. To support this allegation, the complainant provided analysis of average unit values from the period spanning 2023 to Q3-2025, while acknowledging the challenges of aggregate analyses due to product mix variations in OCTG (i.e. grades, diameters, end-finishes, etc.).^{Footnote 56}

[101] Tenaris stated in regards to Austria that “import prices are falling, and falling faster than the rest of the market, including Tenaris Canada’s domestic selling prices and market prices generally.”^{Footnote 57}

[102] Additional analysis submitted by the complainant focuses on the apparent decline in average pricing of seamless casing from Austria.

[103] The complainant summarized the undercutting from Voest by stating:

[104] The complainant also cited publicly available statistics to emphasize the decline in pricing from Austria relative to other export sources.

[105] While the Austrian decline has been greater than China’s, it is still well above those prices and China has very little current presence in the Canadian OCTG market. Furthermore, the Mexican prices are not at arm’s length^{Footnote 63} and changes in product mix can explain some of the movements in prices from the United States and Austria. The complainant conceded that the data does not lend itself well to isolate product mix.^{Footnote 64}

[106] The complainant made numerous other arguments concerning the decline in Austrian pricing relative to other sources, citing data which was largely redundant to the information above.^{Footnote 65}

[107] The CBSA’s analysis of selling prices from Austria was more nuanced, able to identify where product mix may have changed over time, leading to the differences seen in aggregate pricing changes. This information cannot be disclosed due to the protected nature of the data.

[108] Based on the CBSA’s estimates and analysis of selling prices, the CBSA finds that the data provides a reasonable indication that the alledgedly dumped subject goods threaten injury to the domestic industry in the form of price undercutting.

Likely increase in volume on diversion from United States

[109] On March 12, 2025, the United States imposed duties under Section 232 of the US Trade Expansion Act of 1962 (“Section 232”), which authorize the President of the United States to restrict imports on national security grounds.^{Footnote 66} This initially imposed a global tariff on steel and aluminum of 25%. On June 4, 2025, tariffs on steel and aluminum increased to 50%.

[110] The complainant made frequent references to the imposition of these duties causing a clear diversionary effect on subject goods.

[111] The complainant cited recent determinations from the CITT in support of this position:

[112] These comments arose in the preliminary injury determination regarding Steel Strapping in July 2025. Shortly thereafter, Canada imposed its own tariff rate quota (TRQ),^{Footnote 68} which has potentially significant ramifications.

[113] Consequently, while significant portions of the complaint spoke of diversion of goods due to US duties,^{Footnote 69} appropriate context around the imposition of the TRQ in respect of Austria is merited.

[114] Austria falls under the listing of Free Trade Agreement (FTA) countries, which excludes CUSMA partners.^{Footnote 70}

[115] According to the original Order in Council, there was a transitional period of August 1 to September 25, 2025. This is the“Q1” period. That limit on OCTG imports was 8,042 MT. The Order stated that no surtax is payable if this quota is not surpassed. Usage of the quota is updated regularly through Global Affairs Canada.^{Footnote 71}

[116] For the “Q1” period limit of 8,042 MT, Austria accounted for 3,590 MT, which is only 44.64% of the quota. These results run counter to the speculation that they may exceed the quota.

[117] This was also reflected in the “Q2” period, where the quota was 13,068 MT and ran from September 26 through December 25, 2025.^{Footnote 72} In that period, Austria used only 44% of the OCTG quota at 5,741 MT. The maximum volume they could have exported in this quarter was 11,238 MT, which is 86% of 13,068 MT. Other countries accounted for over 47% of the quota.

[118] On November 26, 2025, Canada announced a reduction in the quota from 100% of 2024 levels, to 75% of 2024 levels. That means instead of the quarterly limit on OCTG being 13,068 MT, it will now be 9,801 MT for “Q3”.^{Footnote 73} The single country maximum will lower to 8,429 MT.^{Footnote 74}

[119] The current “Q3” period runs through March 25, 2026. As of January 15, 2026, 23% of the quota has been used, none by Austria.^{Footnote 75}

[120] The complainant also provided data citing Austria’s share of exports to other countries, demonstrating that Canada was the third largest export destination for its OCTG in 2024, behind the United States and Saudi Arabia.^{Footnote 76} Although the complaint stated that the volumes to Saudi Arabia were anomalous due to a particular project in 2024, the UN Comtrade historical data demonstrated that Austria has shipped even larger quantities than what was reported in 2024 going back to 2013-2014.^{Footnote 77}

[121] Based on the CBSA’s estimates and analysis of import volumes, the CBSA finds that an increase in volume of subject goods is unlikely, in large part due to the presence of the TRQ.

Market share

[122] The complainant alleged the injurious dumping, particularly from Austria was “an extremely aggressive pricing strategy designed to capture market share in the long-term.”^{Footnote 78} The complaint further alleged that “Canada is the largest accessible market for oil and gas well casing and Voest has worked to gain market share and take sales using unfair prices.”^{Footnote 79}

[123] However, the complainant’s analysis of the Canadian market reflects Austria holding a diminishing presence, through Q3-2025, which is less than half the share they had in 2023. Meanwhile, Tenaris has grown its market share over the same period.^{Footnote 80} The specific figures related to market share cannot be divulged for confidentiality reasons.

[124] As such, the evidence does not disclose a threat of increased tonnage from Austria, even before the TRQ went into effect.

[125] The complainant also provided projections for Canada’s oil drilling to support its position that Canada will remain a strong export destination, resulting in further loss of market share. Much of the support for this position was, however, based on dated information.^{Footnote 81}

[126] More recent information, for example, indicated that oil patch drilling has slowed as oil prices have sagged and “is expected to slide further in 2026.”^{Footnote 82}

[127] Other projections stated that the “benchmark North American crude blend known as West Texas Intermediate, or WTI, is currently priced below $60 US, and the U.S. Energy Information Administration projects prices will decline to an average of $55 US in 2026. Projections vary, but others see prices headed even lower in 2027.”^{Footnote 83}

[128] For comparison sake, the price of a barrel of WTI oil was as high as $116 US in 2022, averaging $95 US for the year.^{Footnote 84} Consequently, OCTG demand and pricing was more robust at that time.

[129] Based on the CBSA’s estimates and analysis of the Canadian market, the CBSA finds that while an increase in market share is unlikely, a continued presence of Austrian oil and gas well casing in the market is likely, providing a reasonable indication that the alleged dumped subject goods will threaten injury to the domestic industry in the form of lost market share.

Adverse impact on financial performance and profitability

[130] The complainant alleged that the result of factors like price undercutting, suppression^{Footnote 85} and increased imports via diversion from the US^{Footnote 86} are that the dumped goods threaten to have an adverse impact on the complainant’s financial performance and profitability.

[131] The complainant made extensive arguments that “the marketplace has devolved into a pricing war that has led to a price spiral. Dumped goods from Austria have been a leading cause of this spiral.”^{Footnote 87} Evidence provided in the complaint demonstrated little change in financial performance over the five quarters running from Q4-2024 through Q3-2025, although this performance is substantially lower than in 2022 and 2023.^{Footnote 88}

[132] Based on the information contained in the complaint, as well as in its own analysis, the CBSA finds that the there is a reasonable indication that the alleged dumped subject goods threaten injury to the domestic industry in the form an impaired financial performance.

Negative effects on existing development and investments

[133] The complainant alleged that their investments are at risk of unfairly priced imports from Austria. They cited several examples of planned investments, which they said are contingent on a fair competitive environment for casing in Canada.^{Footnote 89}

[134] Numerous examples of these investments were detailed in the complaint, which can be categorized as those geared towards improving capacity, efficiency and product range and those aimed at improving infrastructure.^{Footnote 90}

[135] Tenaris provided substantial planned investment figures, divided roughly between seamless and ERW production in Canada.^{Footnote 91}

[136] Based on the information contained in the complaint, as well as the CBSA’s analysis, the CBSA finds that there is a reasonable indication that the alleged dumped subject goods threaten injury to the domestic industry in the form a reduction to the return on investment, including the recent investments to produce grade T95 in Canada.

Causal link: Dumping and threat of injury

[139] The CBSA finds that the complainant has sufficiently linked the threat of injury to the alleged dumping.

[140] In summary, the CBSA is of the opinion that the information provided in the complaint has disclosed a reasonable indication that the alleged dumping from Austria is threatening to cause injury to the Canadian domestic industry.