Statement of reasons—Final determination: Certain Carbon and Alloy Steel Wire (SW 2025 IN)

Government control analysis

[47] This section will present the CBSA’s analysis of the extent of the Government of China’s control over the long products steel sector in China, by examining the following:

• Government of China’s control previously found in the long products steel sector
• Steel plans, directives and other policy documents
• Government of China’s ownership and control of steel manufacturers;
• Government of China’s provision of subsidies to steel wire manufacturers and
• Government of China’s influence over the cost of production of steel

Government of China’s control previously found in the long products steel sector

[48] The CBSA has previously determined that section 20 conditions exist in the long products steel sector in China on four occasions in the following proceedings:

• the galvanized steel wire investigation^{Footnote 38} in 2013
• the concrete reinforcing bar investigation^{Footnote 39} in 2014
• the concrete reinforcing bar re-investigation^{Footnote 40} in 2018 and
• most recently in the wire rod investigation^{Footnote 41} in 2024

[49] The CBSA has previously found that a government can indirectly control the prices of the sector being investigated by controlling the prices of the primary inputs. Given that wire rod is the primary input material in the production of wire, the recent section 20 finding on the wire rod in China is highly relevant to the steel wire case.

[50] The substantial amount of information on the record for these previous findings supports the conclusion that the government substantially determines prices in China’s long products steel sector.

Steel plans, directives and other policy documents

[51] The steel industry is regarded as a key industry by the Government of China. As such, the steel industry in China, including the long products steel sector, is subject to a variety of plans, directives and other policy documents issued by all levels of the Government of China.

[52] This regulatory oversight is constant and pervasive. For instance, the China Iron and Steel Association (CISA), a key industry association that works closely with the government, has explicitly described itself as “guided by the Party’s lines” and that it “participates in making the industrial development planning, and relevant policies, laws and regulations”.^{Footnote 42} This guidance extends to specific market interventions, such as CISA urging mills “to be disciplined in restraining production” in October 2024 after government stimulus led to increased steel prices.^{Footnote 43}

[53] Recent key policy documents include:

Work Plan for Stabilizing Growth (2025–2026)

In September 2025, a new work plan was issued to support the steady operation and structural upgrading of the steel industry. It sets the sector’s average annual value-added output growth target at around four percent for the two-year period.^{Footnote 44} This plan places a much stronger emphasis on quality, efficiency, and environmental compliance, notably mandating that over 80 percent of steel production capacity complete ultra-low emission upgrades by the end of 2025^{Footnote 45}

Suspension of Capacity Replacement (August 2024)

The Government of China issued “Notice of the General Office of the Ministry of Industry and Information Technology on Suspending Steel Production Capacity Replacement Work” requiring the suspension of new steel capacity replacement plans starting August 23, 2024.^{Footnote 46} This move was intended to address loopholes that allowed continued capacity expansion despite policy goals

Work Plan for Stabilizing Growth (2023–2024)

Released in August 2023, this plan marked a formal focus on transitioning the steel sector from sheer volume to high-quality and sustainable development, while addressing oversupply and weak demand. The plan set annual industrial value-added growth targets of 3.5 percent for 2023 and approximately 4 percent for 2024. Key measures centered on strengthening capacity control by strictly limiting new projects, accelerating technological upgrades (including the promotion of Electric Arc Furnaces (EAF)), and enhancing raw material security^{Footnote 47}

High-Quality Development Roadmap (March 2022)

The Government of China released the “Roadmap for high-quality development of iron and steel industry” to rationalize the industry’s structure, ensuring global competitiveness and technical advancement^{Footnote 48}

Consolidation Guidelines (February 2022)

The Government of China released guidelines urging the steel industry to consolidate through mergers and acquisitions (M&As) in order to “create world-class steel giants” and accelerate high-quality development.^{Footnote 49} Financial institutions were urged to provide comprehensive support for these M&As and structural adjustments^{Footnote 50}

Price Control Directive (May 2021)

Chinese Premier Li Keqiang addressed rising steel prices, stating that efforts were needed to “deal with the excessively rapid increase in commodity prices and its collateral effects” and to “keep the economy running smoothly”^{Footnote 51}

14th Five Year Plan (2021-2025)

This plan identified the transformation of traditional industries and improvements to the “layout and structure of raw material industries including… steel” as a core part of “implementing the manufacturing powerhouse strategy”.^{Footnote 52} It outlines the shift to innovation-driven growth and high-quality development, which requires the steel industry to improve product quality, increase the self-sufficiency rate of iron resources, and focus on supplying high-end, specialized steel materials

[54] As shown by the above policies, the Government of China influences the steel industry, including the long products steel sector, by increasing M&A to create larger and more efficient steel companies to guide the growth of the industry. The Government of China also exerts control on steel capacity and supply, which impacts the price of steel in China.

[55] Based on the substantial amount of information on the record of previous findings related to steel products, including the long products steel sector, and evidence discussed above, the CBSA finds that the Government of China actively releases plans, directives, policies, and guidelines for its domestic steel producers to follow in order to control its steel industry, including steel wire producers.

[56] The CBSA finds that the Government of China’s steel plans and directives in place provide support for the conclusion that the government substantially determines prices in China’s long products steel sector.

Government of China’s ownership and control of steel manufacturers

[57] The steel industry in China remains heavily state-dominated with the Government of China exercising significant ownership and control over the sector, including manufacturers of downstream products like wire rod and steel wire.

[58] The majority of China’s largest steel manufacturers are state-owned enterprises (SOEs), providing the government with unparalleled leverage over the sector’s output and strategic direction. As illustrated below, of the top ten steel producers in China by volume in 2024, six were state-owned, accounting for approximately 30 percent of the country’s total steel production that year.

[59] China Baowu Group, AnSteel Group and Shougang Group are directly owned by China’s State-owned Assets Supervision and Administration Commission (SASAC), a special administration of the State Council of the People’s Republic of China, while HBIS Group is wholly-owned by the Hebei provincial government.^{Footnote 55} This structure enables the Government of China to issue and enforce specific industrial plans, direct investment, and utilize these SOEs as instruments to meet national economic and policy objectives, overriding purely commercial considerations.

Consolidation and indirect control

[60] The Government of China is actively pursuing consolidation to increase its share of the steel market, directly fueling the rapid growth of China Baowu Group. This SOE’s expansion is driven by key acquisitions, such as the acquisition of Shandong Iron and Steel Group and SD Steel Rizhao Co. Ltd. in late 2023, solidifying its leading role in the national industry.^{Footnote 56} While the top ten steel firms currently account for 44 percent of China’s total steel production, this concerted consolidation effort is designed to meet the government’s long-term goal of consolidating over 60 percent of the nation’s steel capacity in the hands of its top ten steelmakers by the end of 2025.^{Footnote 57}

[61] Furthermore, government influence extends beyond direct ownership. Other prominent Chinese steel manufacturers have significant indirect ties to the government or are subject to substantial government intervention. For example, while Shagang Group is generally considered a private company, its ownership structure includes historical sales of equity to the Jiangsu SASAC and a labour union which was controlled by the Government of China. Shagang has also acquired other entities with state ties^{Footnote 58} and has members of the Government of China in its senior management and board of directors.^{Footnote 59}

Policy compliance in downstream products

[62] State presence is equally significant in downstream markets. Many of the state-owned steel producers also produce downstream products such as wire rod and steel wire. For example, China Baowu Group, the largest steel producer in China, is a key producer of long steel products (including wire rod and steel wire).^{Footnote 60} State-owned status ensures compliance with policies and mandates.

[63] Multiple wire rod and steel wire producers have also publicly announced their affiliations with the Government of China and their commitment to government policies.^{Footnote 61}

[64] The CBSA finds that the significant presence of state-owned and state-controlled enterprises in both the overall steel sector and long products steel sector, suggests that sales of steel products such as steel wire may be influenced by non-market factors, such as fulfilling the Government of China’s policy objectives. The significant presence of SOEs supports the conclusion that the government substantially determines prices in China’s long products steel sector.

Government of China’s provision of subsidies to steel wire manufacturers

[65] The Government of China continues to provide substantial market-distorting subsidies to its steel industry, including manufacturers of wire rod, a fact highlighted in international trade investigations and reports, including the United States (U.S.) Department of Commerce’s sunset review for carbon and certain alloy steel wire rod from China in August 2025^{Footnote 62} and the CBSA’s final determination of dumping for certain wire rod from China in September 2024.^{Footnote 63}

[66] The Organisation for Economic Cooperation and Development (OECD) found that the global steel market was “distorted by non-market forces, where producers which do not benefit from the subsidies cannot compete on an equal footing.”^{Note de bas de page 64} Based on the OECD’s report entitled “The drivers and impacts of subsidies to steel firms”, the Chinese government’s financial support to its steel industry remains exceptionally high, distorting global markets and exacerbating overcapacity. This financial assistance, channeled primarily through cash grants, below-market borrowings, and corporate income tax concessions, is disproportionately directed toward SOEs, larger firms, and those with higher indebtedness.^{Footnote 65}

[67] The September 2021 subsidy notification from the Government of China was criticized by the World Trade Organization Secretariat for its lack of transparency.^{Footnote 66} Despite this, the available evidence shows that Chinese steel wire manufacturers have received state-support including:

State-Directed Mergers

China Baowu Steel, the largest steel manufacturer in China, received significant government support during its creation in 2016 which resulted from the merger of Baosteel Group Corporation and Wuhan Iron and Steel Corporation (WISCO).^{Footnote 67} This support continued to subsequent, often free, equity transfers, including the acquisition of Sinosteel Group (2022)^{Footnote 68}, Xinyu Iron & Steel Group Co., Ltd. (Xinyu Steel) (2022)^{Footnote 69}, Taiyuan Iron & Steel (Group) Co., Ltd (TISCO) (2020)^{Footnote 70}, and Magang (Group) Holding Company Limited (Maasteel) (2019)^{Footnote 71}

Direct Government Funds

The government of Hebei established the Hebei Steel Industry Transformation and Upgrading Fund in order to support steel manufacturers. As an SOE of the Government of Hebei, HBIS benefitted from direct state support in 2020 to upgrade and improve its operations.^{Footnote 72} The available evidence also shows that Chinese steel wire producers with public reporting requirements received direct subsidies worth approximately USD 198 million from the Government of China in 2023.^{Footnote 73} In addition, USD 120 million in subsidies was provided to Chinese steel wire rod producers in 2023.^{Footnote 74} Since the amounts are only reported by companies with public reporting requirements, the actual amount of subsidies received is likely significantly higher

Strategic Policy Support

Wholly-owned by the SASAC, Shougang has received direct funding from both the central and Beijing governments. The CBSA notes that Shougang is included as part of Beijing’s 14th Five-Year Plan covering 2021-2025, necessitating significant financial support to achieve the city’s political and strategic objectives^{Footnote 75}

[68] The CBSA acknowledges that although the total amount of subsidies provided to Chinese exporters during the POI is unclear without a response to the RFI from the Government of China, there is a longstanding history of direct subsidies made available to SOEs in the steel industry, including the long products steel sector.

[69] Subsidization of steel production enables the Government of China to influence the price of downstream products such as steel wire, as producers can purchase input materials below fair market value and reduce their production costs. These subsidies may, therefore, distort the domestic selling price of steel wire in China. The widespread presence of subsidies in the steel industry, including in the long products steel sector, further supports the conclusion that the government substantially determines prices in the long products steel sector in China.

Government of China’s influence over the cost of production of steel

[70] The Government of China has implemented several measures that influence the cost of raw materials used in steelmaking. By influencing upstream raw material inputs, the government can substantially determine the prices of downstream products, including steel wire.

[71] The government exerts immense influence on iron ore pricing. It actively pursues policies designed to reduce the cost of this critical input for domestic steel manufacturers, enhancing resource security. To stabilize the market and maintain reasonable prices, the National Development and Reform Commission (NDRC), China’s central government agency responsible for national economic and social development plans, has continued its policy of strong market oversight throughout 2024 and 2025. Following its 2023 warning against hoarding and price inflation, the NDRC has consistently signaled that it would intervene to curb “unreasonable” iron ore price spikes and directed trading firms to avoid hoarding and inflating prices.^{Footnote 76}

[72] A major institutional development was the establishment of the China Mineral Resources Group (CMRG) in July 2022. This central SOE has become the dominant force in China's US$130 billion iron ore import market. As of June 2025, it reportedly represents more than half of Chinese steelmakers in negotiations with global suppliers.^{Footnote 77} This central SOE was established with several key objectives:

• Consolidate iron-ore purchasing activities of approximately 20 of China’s largest steel manufacturers^{Footnote 78}
• Strengthen the bargaining power of Chinese steel producers in sourcing iron ore globally^{Footnote 79}
• Centralize state-owned iron ore import rights under CMRG^{Footnote 80} and
• Manage China’s overseas mining investments, valued at approximately USD 4.3 billion^{Footnote 81}

[73] By consolidating purchasing power, the CMRG exerts downward pressure on iron ore prices, thereby lowering production costs for Chinese steel mills.

[74] The CBSA finds that these measures demonstrate the Government of China’s influence on iron ore. As a result of these measures, the Government of China creates an environment where domestic prices of steel may be artificially low, which benefit the producers of steel wire.

Summary of government control analysis

[75] The CBSA has previously found that the Government of China substantially determines the prices of steel and long products steel in the domestic industry and that these prices are not substantially the same as if they were determined in a competitive market.

[76] Specifically, the CBSA has previously issued opinions in respect of three steel products in the long products steel sector, namely, galvanized steel wire, concrete reinforcing bar and wire rod.

[77] The Government of China exerts control on the steel industry in general but also on the long products steel sector specifically, through various plans, directives and other policy documents that impact steel wire producers. In making corporate decisions, Chinese steel wire producers must adhere to the Government of China’s macro-economic policies including measures related to steel production capacity and M&As. As a result, corporate decisions based on market dynamics of supply and demand compete with the Government of China’s directives and mandates.

[78] The Government of China has significant ownership and control of steel manufacturers, including wire rod and steel wire manufacturers, in China. The presence of state-owned and state-controlled enterprises that produce steel necessitate that private companies supplying steel would have to compete with these state-owned and state-controlled enterprises operating under non-market conditions.

[79] Furthermore, the subsidization of the steel industry in general, and the long products steel sector in particular, demonstrates the Government of China’s intent to exert control to maintain domestic prices at a certain level. These subsidies allow steel manufacturers to sell their products at prices below fair market value to producers of steel wire, who in turn, are able to sell their products at distorted prices.

[80] Through various actions and measures, the Government of China also influences the price of iron ore, a key input in the production of steel.

[81] Overall, the cumulative impact of the Government of China’s policies and actions indicate that the Government of China substantially determines prices in the long products steel sector in China.

Price analysis

[82] For the purposes of the final determination, 12 exporters, including four exporters from China, provided complete and verified domestic sales databases. The CBSA also received U.S. pricing information from Davis Wire.

[83] The CBSA compared Chinese domestic steel wire prices with those of other countries. The CBSA conducted a price analysis by model, based on the key product characteristics, to account for differences in product mix in each country.

[84] The CBSA’s price analysis demonstrated that there is a pattern of significantly lower Chinese domestic prices of steel wire compared to other countries. The complainants provided their own price analysis by model, which showed similar results as the CBSA’s price analysis.

[85] The complainants also provided benchmark pricing for wire rod, the key input in the production of steel wire. The benchmark pricing showed the Chinese wire rod prices were consistently and significantly lower than all other markets compared.

[86] Overall, the price analysis shows that domestic prices in the long product steel sector in China are not substantially the same as they would be in a competitive market.

PMS factors

[94] The primary PMS factors analysed were:

• Government purchases at established price ceilings
• Volatile economic condition
• Distorted inputs due to imported Russian and Chinese wire rod in Türkiye and
• Government support programs

Government purchases at established price ceilings

[95] The evidence on the record shows that several ministries in Türkiye are required, pursuant to Presidential Decree, to provide price ceilings at which they will purchase inputs, including steel wire, for large infrastructure projects.^{Footnote 82}

[96] Both the Ministry of National Defence and the Ministry of Environment, Urbanization, and Climate Change established a price ceiling of 28.50 Turkish lira (TRY) per kilogram for galvanized steel wire during 2024. Evidence was also provided that the Turkish government is planning several development projects that are expected to take place over the next few years for a total cost of over 1 trillion TRY ($35 billion Canadian dollars). Of these projects, the aforementioned Ministry of Environment, Urbanization, and Climate Change will be a key player.^{Footnote 83}

[97] A price ceiling could be a factor in a PMS analysis because by placing a price ceiling on certain products, producers may not be able to sell steel wire domestically to a large purchaser (the government) at a market rate and will be forced to settle for prices which are less than they would be able to obtain elsewhere. Alternatively, a price ceiling may also encourage a producer to sell at the posted price, even if it is above the current market rate.

[98] The Government of Türkiye estimates that public sector projects made up roughly 13.9% of all construction projects in Türkiye during 2024.^{Footnote 84} The CBSA analyzed the exporter responses and found no evidence that exporters sold steel wire at these prices or to government entities during the POI. Further, the selling prices realized by the exporters did not appear to be impacted by these ceiling prices.

[99] Due to the low volume of projects for which these price ceilings are applicable, and the fact that the price ceilings appear to have had no impact on the overall selling prices of steel wire in Türkiye, the CBSA finds that the established price ceilings are not contributing to a PMS in the steel wire sector in Türkiye.

Volatile economic conditions

[100] There is evidence on the record that a hyperinflationary situation existed in Türkiye during the POI. The complainants provided the general requirements that must exist for a country to be considered in a hyperinflationary environment and then provided supporting evidence as to how the Turkish economy meets these requirements, such as the inflationary rates in Türkiye.^{Footnote 85}

[101] Further, several large accounting firms and banks considered Türkiye to be in a hyperinflationary situation that started in 2022 and continued during the POI.^{Footnote 86}

[102] The Government of Türkiye took several actions in response to this situation, however the evidence shows that many of these actions had no effect or the opposite effect on eliminating the hyperinflationary situation. For example, the Government of Türkiye cut interest rates, underreported inflation, and prohibited companies from using the International Financial Reporting Standards’ recommended hyperinflationary accounting practices.^{Footnote 87}

[103] During the POI, the inflation rate began to improve, but was still considered hyperinflationary. Further, the Government of Türkiye eased up its restrictions on using hyperinflationary accounting practices, where businesses earning less than 50 million TRY will not make inflation adjustments, but others will.^{Footnote 88}

[104] The complainants alleged that the hyperinflation experienced in Türkiye has led to depreciation of the TRY and that this does not allow for a proper comparison to be made between the sales in Türkiye and Canada. Evidence on the record shows a sharp decline of the TRY versus the Canadian dollar in 2022, and a continued devaluation since then.^{Footnote 89}

[105] The CBSA compared the decline of TRY during the POI versus other currencies used by other countries in the investigation^{Footnote 90} as well as the United States Dollar (USD). TRY was the only currency that depreciated as compared to the Canadian dollar during the POI. All other currencies either stayed relatively flat, or increased during the second half of the POI.

[106] To assess whether the currency depreciation had any impact on the selling price of steel wire in Türkiye, the CBSA compared the trend in the average monthly exchange rate to the average monthly selling prices in Türkiye by the Turkish exporters.

[107] Based on this analysis, the average domestic selling prices did not change significantly throughout the POI despite the downward trend in average exchange rates, including a few sharp declines. One reason for this is that the Turkish exporters did not typically sell goods domestically in TRY, instead all prices were quoted using USD or EUR, which mitigated impacts on the domestic selling prices.

[108] The CBSA compared the monthly average selling prices of steel wire in Türkiye with the selling prices in the markets of the other countries that are part of this investigation and where exporters responded. The CBSA found that the selling price of steel wire in Türkiye followed the same relatively stable trend as in the other markets during the POI. This is despite these other markets having very different currency fluctuation patterns during the POI.

[109] Therefore, while it appears that hyperinflation is occurring, which is leading to currency depreciation that is particular to Türkiye, the CBSA finds that it does not have an impact on the domestic selling prices of steel wire in Türkiye.

Distorted inputs due to imported Russian and Chinese wire rod in Türkiye

[110] The complainants alleged that the acquisition cost of wire rod used by Turkish exporters/producers in the production of steel wire does not reasonably reflect the actual cost of wire rod. Wire rod is the principal input into steel wire production and represents a large proportion of its cost of production, typically over half the cost of production of steel wire is due to wire rod. Therefore, it is reasonable to expect that imports of wire rod at distorted prices could impact the selling price of steel wire in Türkiye.

[111] Evidence on the record shows that, due to restrictions by several countries on exports from Russia, wire rod was entering Türkiye at a reduced price during the POI. The complainants supported this by providing evidence that Russian wire rod was decreasing in price and entering Türkiye during the POI.^{Footnote 91}

[112] Evidence on the record also shows that wire rod from China is being imported at cheaper prices compared to wire rod in other markets, and that the CBSA has previously found that that the Chinese steel industry, including the wire rod sector, is not operating in accordance with market economy principles. It is alleged that because wire rod prices in China were previously found to be determined by the government and not the same as if they were determined in a competitive market, this is having an impact on the price of wire rod imported into Türkiye from China.^{Footnote 92}

[113] Evidence on the record shows that a Turkish safeguard measure concerning wire rod came into force in June of 2024, midway through the POI. One of the reasons cited in the Government of Türkiye’s decision for implementing a safeguard measure was that many countries put restrictions on Russian goods, but as Türkiye did not, Russian products freely entered the Turkish market and in 2022, 50% of all wire rod imports into Türkiye were from Russia. The safeguard measure placed a duty rate of $175 USD/ton on imports of wire rod during the POI for all countries, except there is a quota where developing countries can export up to a total of 33,900 tons of wire rod to Türkiye duty free.^{Footnote 93}

[114] Despite the safeguard in place, many Turkish producers are still able to purchase wire rod and receive a refund on the duties paid because of Türkiye’s Inward Processing Regime (IPR), where these duties are refunded if the finished steel wire is subsequently exported,^{Footnote 94} which could lead to a differentiated impact between the domestic and export selling prices as imported input materials are more likely to be used for export sales.

[115] The complainants provided an analysis showing the correlation between wire rod selling prices in Türkiye and Southern Europe (typically Italy, Spain, and Portugal), as well as between Türkiye and Northern Europe (typically Germany, Belgium, and Netherlands). The complainants showed that before the Russian invasion of Ukraine, prices between these markets were heavily correlated, but after that period they became uncorrelated.^{Footnote 95}

[116] The evidence provided by the complainants show that wire rod prices in Türkiye are higher than in other European markets. However, despite a price increase and decrease during the fall of 2024, the prices in Türkiye appear to follow the same trend as the other European markets.

[117] The Government of Türkiye provided import statistics showing the volume and value of imports of wire rod into Türkiye during the POI. Imports of wire rod from China and Russia made up roughly 25% of all imports of wire rod into Türkiye during the POI. Further, imports of wire rod from Russia dropped to a negligible amount after the implementation of safeguards on imports of wire rod, which came into force on June 15, 2024.^{Footnote 96}

[118] The CBSA used this data to compare the average import price of wire rod from different countries by carbon content and found that the Russian and Chinese wire rod was always lower priced than the average of all other countries, sometimes as much as 8% lower.

[119] The Government of Türkiye also provided information from the Turkish Steel Producers Association (TSPA) on the production and consumption of wire rod in Türkiye. However, they were unable to provide the same information on steel wire in Türkiye. This information shows that only 15.8% of wire rod consumed in Türkiye is from imported sources.^{Footnote 97} This means that Russian origin and Chinese origin wire rod only accounts for 1.0% and 3.1% of Turkish wire rod consumption respectively, for a total of 4.1%. However, Turkish exporter responses indicated that that they use more Russian and Chinese wire rod than what the TSPA reported, albeit only of the low carbon variety.

[120] The CBSA also analysed the Turkish exporters’ purchases of wire rod from all countries and found that Chinese and Russian wire rod costs less than Turkish wire rod, but is not priced differently than wire rod imported from other countries. Purchases from these countries also only occurred during a few months of the POI. Further, given that the Turkish wire rod was higher priced than imports throughout the POI, it does not appear that Chinese wire rod imports have a significant impact on Turkish wire rod prices.

[121] When compared to the responding exporters in other countries, wire rod available in Türkiye (including imported wire rod) was priced no differently than wire rod in other countries, meaning that the low prices of Russian and Chinese wire rod did not have a significant impact on the selling price of wire rod as a whole in Türkiye.

[122] As discussed in the Volatile economic conditions section, the CBSA compared the selling price of steel wire in Türkiye with other countries, and found no substantial differences. This means that even if wire rod in Türkiye was cheaper than in other markets, the cost of wire rod does not appear to have an impact on the selling price of the like goods.

[123] To summarize, producers of steel wire in Türkiye are purchasing low carbon wire rod from China and Russia, but are not purchasing substantial quantities of wire rod of any other carbon content from those countries. Based on the Government of Türkiye’s import data, there is evidence that wire rod from these countries is cheaper than that from other countries, but there is no evidence that this is the case for the cooperative Turkish exporters. Further, there is no evidence that these cheaper input costs have any impact on the selling price of wire rod in Türkiye as the selling prices of wire rod are not significantly different between Türkiye and other countries. Finally, even if wire rod in Türkiye was cheaper than in other markets, the cost of wire rod does not appear to have an impact on the selling price of the like goods.

Government support programs

[124] After the initiation of the investigation, the complainants provided evidence on the various government support programs available to the steel industry in Türkiye. This was primarily in the form of a list of various financial contributions that could be attributable to the subject goods.

[125] Most of the evidence concerned steel in general and not steel wire specifically. Some of the evidence did concern wire rod specifically, but as discussed earlier, the pricing of wire rod available in Türkiye was not substantially different than in other countries. Therefore, any financial contributions impacting wire rod in Türkiye do not appear to pass through to steel wire produced in Türkiye.

[126] The complainants also mentioned the Government of Türkiye’s involvement in the production of wire, specifically through the existence of SOEs that constitute producers of inputs, energy producers, or trade associations. However, the information provided was primarily theoretical and did not provide evidence on how this actually impacts steel wire production in Türkiye. Further, the Turkish exporters did not report purchasing any inputs from an SOE.

[127] As there is no evidence on the record clearly linking these support programs to steel wire and the Turkish exporters, there is no support for the allegation that government support programs are leading to a PMS in the steel wire sector in Türkiye.

Other factors

[128] Evidence on the record shows that the Government of Türkiye recently increased import duties on several types of steel wire ranging from 5% to 25%. The evidence provided shows that this change did not come into force until January 1, 2025, which is after the POI. This means that whatever prompted this change in rates was possibly in effect during the POI. From the information in the complaint, this change may have been caused by a large volume of Chinese steel wire imported into Türkiye at distorted prices during the POI as well as in the preceding years.^{Footnote 98} According to the Government of Türkiye’s import statistics, 30.8% of steel wire imported into Türkiye during the POI was from China.^{Footnote 99} With the limited information on the record, there is insufficient evidence to show that these changes to steel wire duties are leading to a PMS.

[129] The complainants conducted a correlation analysis to show that a distortion in wire rod pricing occurred in Türkiye after the Russian invasion of Ukraine, using the pre-invasion period as a baseline.^{Footnote 100} This analysis did not show substantial changes in the prices between the period before Russia’s invasion of Ukraine and the POI, nor did it explain why this would have an impact on Türkiye’s correlation with China, nor did it cover steel wire itself.

China

[133] Where section 20 conditions exist, the CBSA may determine normal values using the selling prices, or the total costs of production and profit, of like goods sold by producers in a surrogate country designated by the President, in accordance with the provisions of paragraph 20(1)(c) of SIMA.

[134] While the CBSA received information from producers of steel wire in Türkiye, Malaysia, Portugal, Thailand and Vietnam, the CBSA could not determine normal values from Thailand and Vietnam to avoid divulging confidential information of one producer. Additionally, the goods produced and sold by producers in Türkiye, Malaysia and Portugal were not like goods to the goods exported from China to Canada. Specifically, the physical characteristics of the goods exported to Canada from China differ from the goods from the surrogate countries such that they are not identical or similar goods, but rather fall in the same general category.

[135] Where normal values cannot be determined under paragraph 20(1)(c), SIMA provides an alternative methodology to calculate normal values under paragraph 20(1)(d), using re-sales in Canada of like goods imported from a third country. The CBSA determined that this provision could also not be used given that the importers did not provide sufficient re-sale information.

[136] As a result, and in the absence of sufficient information to determine normal values under section 20 of SIMA, normal values were determined pursuant to a ministerial specification in accordance with subsection 29(1) of SIMA, on the basis of facts available.

[137] In establishing the methodology for determining normal values, the CBSA analyzed all the information on the administrative record, including the complaint filed by the domestic industry, the CBSA’s estimates at the initiation of the investigation, information submitted by interested parties and CBSA import documentation.

[138] The CBSA determined normal values for the subject goods from China using an approach that reflects the methodology of subparagraph 20(1)(c)(ii) of SIMA, based the aggregate of the cost of production of steel wire sold for domestic consumption, plus a reasonable amount for administrative, selling and all other costs and a reasonable amount for profits found for producers in a surrogate country, Türkiye.

[139] The CBSA finds Türkiye to be an appropriate surrogate country as it is a participant in this investigation with two or more exporters; has significant domestic production of steel wire; and produces a wide range of steel wire including categories of wire that are produced by the Chinese exporters. Furthermore, Türkiye is the second largest exporter of subject goods to Canada, after China. The information on the record suggests that prices and costs of steel wire in Türkiye are determined in a competitive market, allowing them to be considered as a reliable and fair source for purposes of the final determination.

[140] The CBSA determined normal values for steel wire based on the information available on the record, contained in the RFI responses provided by BMS and Özyaşar. The CBSA determined an amount per metric tonne (MT) normal value for each 60-day period during the period of investigation for exporters from China, calculated as the weighted-average constructed cost normal value determined for producers/exporters from Türkiye.

[141] As described above, for the purposes of the final determination, the normal values were determined by combining information of the exporters/producers in Türkiye.

All other countries

[142] For the 10 cooperative exporters from countries other than China, who submitted complete responses to the dumping RFI, normal values were either determined using the methodology of section 15 of SIMA based on domestic selling prices of like goods or paragraph 19(b) of SIMA, based on the aggregate of cost of production, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits. The costs of production were determined pursuant to paragraph 11(1)(a) of SIMR, based on the costs associated with the production of the subject goods.

[143] For two exporters, TSN and HPSW, the costs of production were adjusted pursuant to SIMR paragraph 11.2(1)(b), to account for the supply of raw materials from their associated supplier(s).

[144] The amounts for profit were determined in accordance with paragraph 11(1)(b) of the SIMR. The following table summarizes the cooperative exporters’ determination of normal values.

[145] During the POI, all of the subject goods exported to Canada by the cooperative exporters were sold to unrelated importers. Export prices were determined using the methodology of section 24 of SIMA, as described in the Export price section above.

China, Türkiye, Malaysia, Portugal, and Thailand

[148] On a country basis, the CBSA examined the difference between the normal value and the export price for each individual transaction of the cooperative exporters, and considered that the highest amount (expressed as a percentage of the export price) found in each subject country, was an appropriate basis for estimating normal values. This methodology relies on information related to goods that originated in each subject country and in general, provides an incentive for exporters to participate by ensuring that exporters who have provided the necessary information requested in a dumping investigation will always have a more favourable outcome than those who have not participated.

[149] As a result, based on the facts available, for all other exporters from China, Türkiye, Malaysia, Portugal, and Thailand, normal values of subject goods were determined based on the highest amount by which a normal value exceeded the export price, on an individual transaction basis for the cooperative exporters in that country during the POI. The transactions were examined to ensure that no anomalies were considered, such as very low volume and value, effects of seasonality or other business factors. Two anomalies were removed from the all others rate for China as it was significantly higher than the rest.

Chinese Taipei, India, Italy, Spain, and Vietnam

[150] The CBSA did not receive timely and complete responses, or were unable to verify the information provided by exporters of steel wire located in Chinese Taipei, India, Italy, and Spain.

[151] While the CBSA received a complete dumping RFI response from HPSW from Vietnam, this exporter only had a limited number of transactions shipped to Canada during the POI. The CBSA determined that basing Vietnam’s all other’s rate on these limited transactions would not be representative.

[152] The CBSA examined the difference between the normal value and the export price for each individual transaction, and considered that the highest amount (expressed as a percentage of the export price) from the other countries, was an appropriate basis for determining normal values. This methodology relies on information related to goods that originated in the other subject countries and in general, provides an incentive for exporters to participate by ensuring that exporters who have provided the necessary information requested in a dumping investigation will always have a more favourable outcome than those who have not participated.

[153] As a result, based on the facts available, for all exporters from Chinese Taipei, India, Italy, and Spain and all other exporters from Vietnam, normal values of subject goods were determined based on the highest amount by which a normal value exceeded the export price, on an individual transaction basis for the cooperative exporters from other subject countries during the POI.

[154] The export prices were based on the declared selling prices on import documentation of steel wire. The CBSA considers this the best available information on which to base the export prices of goods for all other exporters as it reflects actual import data.

[155] Using the above methodologies, for the final determination, the margin of dumping for all other exporters is as follows:

[156] If the CITT finds that the dumped imports from the subject countries are causing injury, the CBSA will impose anti-dumping duty on these goods. Based on the methodology described above, in the event of a finding by the CITT, the normal value for all other exporters from the subject countries will be determined by advancing the export price by the percentages listed in Table 6 above, pursuant to a ministerial specification under subsection 29(1) of SIMA.