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

Government control analysis

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

• Government of China’s control over 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 intervention in the cost of production of steel

Government of China’s control over the long products steel sector

[37] 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 34} in 2013
• the concrete reinforcing bar investigation^{Footnote 35} in 2014
• the concrete reinforcing bar re-investigation^{Footnote 36} in 2018 and
• most recently in the wire rod investigation^{Footnote 37} in 2024

[38] 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.

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

Steel plans, directives and other policy documents

[40] 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, including the following:

• In 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 38}
• In August 2023, the Government of China released the “Work Plan for Stabilizing Growth in the Steel Industry” to guide and support the enhancement of supply and demand of steel in China.^{Footnote 39}
• In March 2022, the Government of China released the “Roadmap for high-quality development of iron and steel industry” to guide the development of the iron and steel industry and aiming to rationalize the structure of the industry, ensuring global competitiveness, and technical advancement.^{Footnote 40}
• In February 2022, the Government of China released guidelines for its steel industry to consolidate through mergers and acquisitions in order to “create world-class steel giants and accelerate the sector’s high-quality development.” In addition, financial institutions are urged to provide “comprehensive financial services to iron and steel enterprises pursuing M&As, structural adjustments, transformations and upgrading.”^{Footnote 41}
• In May 2021, Chinese Premier Li Keqiang addressed the State Council at its executive meeting on the topic of rising steel prices, stating that “we must… deal with the excessively rapid increase in commodity prices and its collateral effects” and that such efforts were needed to “keep the economy running smoothly.”^{Footnote 42}
• In March 2021, the Government of China released the “14th Five Year Plan: Part III” which is a directive identifying the transformation of traditional industries and improvements to the “layout and structure of raw material industries including… steel” as part of “implementing the manufacturing powerhouse strategy.”^{Footnote 43}

[41] Based on evidence available on the record, as it relates specifically to the Chinese steel industry, government directives appear to be explicitly followed. The China Iron and Steel Association (CISA), a key industry association in China that works closely with the Government of China, 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 44} In October 2024, CISA urged steel mills “to be disciplined in restraining production” after Government of China stimulus led to increased steel prices.^{Footnote 45}

[42] As shown by the above policies, the Government of China intervenes in the steel industry, including the long products steel sector, by increasing mergers and acquisitions 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 may impact the price of steel in China.

[43] 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.

[44] The CBSA finds that the Government of China’s control over steel capacity and supply may result in distorted selling prices of these goods. The steel plans and directives in place provide support for the conclusion that the government may substantially determine prices in China’s long products steel sector.

Government of China’s ownership and control of steel manufacturers

[45] Many of the largest steel manufacturers in China are State-Owned Enterprises (SOEs).

[46] As shown in the table above, of the top ten steel producers in China, six producers are state-owned. Many of these 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, produces wire rod and steel wire.^{Footnote 48}

[47] The CBSA finds that the significant presence of state-owned and state-controlled enterprises in both the steel sector and long products steel sector, suggests that sales of steel products may be influenced by non-market factors, such as fulfilling the Government of China’s policy objectives. Consequently, domestic selling prices for steel wire in China may not be substantially the same as they would be if they were determined in a competitive market. This significant presence of SOEs supports the conclusion that the government may substantially determine prices in China’s long products steel sector.

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

[48] The recent subsidy notification submitted by the Government of China was criticized by the World Trade Organization Secretariat as lacking transparency.^{Footnote 49} Nevertheless, the available evidence indicates that steel wire manufacturers have received benefits and support from the Government of China.

[49] Chinese steel wire producers with public reporting requirements received direct subsidies worth approximately USD 198 million from the Government of China in 2023.^{Footnote 50} In addition, USD 120 million in subsidies was provided to Chinese steel wire rod producers in 2023.^{Footnote 51} The complainants argue that since the amounts are only reported by companies with public reporting requirements, the actual amount of subsidies received is likely significantly higher.

[50] 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 steel wire, further supports the conclusion that the government may substantially determine prices in the long products steel sector in China.

Government of China’s intervention in the cost of production of steel

[51] The Government of China has taken several measures that may control costs with respect to raw materials for steelmaking. By intervening in upstream raw material inputs, the Government of China can substantially determine the prices of downstream products.

[52] Based on evidence available on the record, the Government of China maintains controls on raw materials for steel products, including steel billets, steel scrap, and iron ore.

[53] In 2021, amid concerns over tax evasion, the Government of China eliminated the VAT rebate for export that was available to exporters of certain steel goods including wire rod. At the same time, in May of 2021, the Government of China eliminated import duties on scrap and billet, allowing for an even greater supply of cheaper steel billet in China.^{Footnote 52} These measures result in an increased supply in the Chinese domestic market causing downward pressure on domestic prices.

[54] The Government of China also actively takes measures to lower the price of iron ore, a key input in the manufacture of steel. In March 2023, the National Development and Reform Commission (NDRC) issued a warning that it would take measures to curb “unreasonable” iron ore prices and directed trading firms to avoid hoarding and inflating prices.^{Footnote 53}

[55] In July 2022, the Government of China created the China Mineral Resources Group (CMRG) in order to achieve the following main objectives:

• consolidate the iron-ore purchasing activities of approximately 20 of China’s largest steel manufacturers^{Footnote 54}
• provide greater buying power to Chinese steel producers when sourcing their iron ore from global mining companies^{Footnote 55}
• entrust all state-owned iron ore import rights to CMRG^{Footnote 56} and
• manage China’s overseas investments in mining, worth approximately USD 4.3 billion^{Footnote 57}

[56] The CBSA finds that these measures demonstrate the Government of China’s influence on steel production, including long products steel, particularly by distorting the prices of iron ore.

[57] The CBSA finds that 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. As a result, the domestic selling prices of steel wire in China may not be substantially the same as they would be if they were determined in a competitive market.

Summary of government control analysis

[58] The CBSA has previously found that the Government of China’s measures, policies and vested interest in the steel industry substantially determine the prices of steel and long products steel in the domestic industry and that these prices are substantially different than if they were determined in a competitive market.

[59] 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.

[60] 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 mergers and acquisitions. As a result, corporate decisions based on market dynamics of supply and demand compete with the Government of China’s directives and mandates.

[61] 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.

[62] 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. This may contribute to section 20 conditions in the long products steel sector.

[63] Through various actions and measures, the Government of China also influences the prices of the inputs of steel wire including steel billets, steel scrap, and iron ore.

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

Price analysis

[65] For the purposes of the preliminary determination, ten exporters, including two exporters from China, provided domestic sales databases.

[66] The CBSA compared Chinese domestic steel wire prices with those of other subject countries. The comparison showed that Chinese domestic prices of steel wire were generally comparable to those in Malaysia and Thailand. In addition, Vietnam largely had the lowest domestic prices of steel wire.

[67] Based on this price analysis, Chinese prices do not appear to be substantially different as they would be in a competitive market.

[68] The complainants made representations including providing their own price analysis and asserting that wire prices in Malaysia, Thailand, and Vietnam are distorted due to significant volumes of imports from China. Due to the confidentiality of the information provided, the CBSA cannot provide further details. These representations are currently under analysis and consideration. During the final phase of the investigation, the CBSA will continue to examine the pricing data.

PMS factors

[78] The primary PMS conditions, as provided by the complainants, were:

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

Government purchases at established price ceilings

[79] 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 58}

[80] 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 59}

[81] It is the CBSA’s position that a price ceiling could be a factor in a PMS 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.

[82] The Government of Türkiye estimates that public sector projects made up roughly 13.9% of all construction projects in Türkiye during 2024.^{Footnote 60} However, the CBSA is of the opinion that even if the price ceilings are not valid for private construction projects, a large purchaser of a product may have an impact on the purchase prices of other purchasers in the same market as selling prices will reach an equilibrium as purchasers and sellers will attempt to maximize profit.

[83] 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.

[84] Due to the trend comparison coupled with the low volume of projects for which these price ceilings are applicable, the CBSA finds that the established price ceilings are not contributing to a PMS in the steel wire sector for Türkiye.

Volatile economic conditions

[85] 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 61}

[86] 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 62}

[87] The Government of Türkiye took several actions in response to this situation, however the evidence shows that many of these actions had no, 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 63}

[88] 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 64}

[89] 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 65}

[90] The CBSA compared the decline of TRY during the POI versus other currencies used by other countries in the investigation^{Footnote 66} 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.

[91] 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.

[92] From this, 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. This likely mitigated impacts on the domestic selling prices.

[93] 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.

[94] Therefore, while it appears that hyperinflation is occurring, which is leading to currency depreciation that is particular to Türkiye, it is the CBSA opinion 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

[95] The complainants alleged that the acquisition cost by Turkish exporters of wire rod used in the production of steel wire does not reasonably reflect the actual cost of wire rod. Evidence at the initiation of the investigation showed that due to restrictions by several countries on exports from Russia, wire rod, the principal input in steel wire, was entering Türkiye at a reduced price. This was supported by evidence that Russian wire rod has decreased in price and that it is entering Türkiye.^{Footnote 67}

[96] It is the CBSA’s opinion that imports of wire rod at distorted prices may have an impact on the selling price of steel wire in Türkiye because a large portion of the cost of steel wire is due to the cost of wire rod, the primary input. So any fluctuations in wire rod prices will likely cause changes in the price of steel wire. This can occur through lower input costs that result in lower selling prices of steel wire.

[97] 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 68}

[98] Despite the safeguard in place, many Turkish producers are still able to purchase Russian 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 69} This can 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. As such, this will be discussed in more detail in the section on differentiated impacts.

[99] There is also evidence that Chinese wire rod is being imported at cheaper prices compared to wire rod in other markets, is also subject to safeguard measures in Türkiye, and importers may be getting a refund on duties through Türkiye’s Inward Processing Regime.

[100] 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 unrelated.^{Footnote 70}

[101] 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. The evidence submitted by the complainants shows that wire rod prices in Türkiye may be distorted as they are higher than in other markets.

[102] 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 71}

[103] The Government of Türkiye provided import volumes and prices on Türkiye’s top 10 sources of wire rod imports. Comparing the average price of these sources, imports of Chinese and Russian wire rod are amongst the lowest, and the only countries with similar or lower average prices are Malaysia, Kazakhstan, and Iran, all of which have very low import volumes. The Government of Türkiye has also provided evidence that, while imports of wire rod from China are at a lower price than many other countries, they are also of a lower quality grade, which can also explain the difference.^{Footnote 72}

[104] The Government of Türkiye also provided information from the Turkish Steel Producers Association 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 73} This means that Russian origin wire rod is only used in 1.0% of Turkish wire rod consumption and Chinese origin wire rod is only used in 3.1% of Turkish wire rod consumption, for a total of 4.1%.

[105] Distorted inputs accounting for only 4.1% of consumption is not a significant amount. However, this represents the consumption of all wire rod, not just for the production of steel wire. In contrast, responding exporters reported on average, a higher purchase volume of Chinese origin wire rod.

[106] From the above, it does not appear that imports of Russian wire rod are in significant enough volumes to have an impact on steel wire production costs in Türkiye. However, the CBSA is of the opinion that imports of Chinese wire rod may be at significant volumes. Next the CBSA will focus on whether the prices of these imports are distorted.

[107] Looking at the responding exporters’ purchases of imported wire rod, Chinese wire rod was generally less expensive than wire rod produced in Türkiye, however its prices were no different than wire rod imported from other countries.

[108] The CBSA also compared the purchase price of wire rod by all responding exporters in the investigation. The price to purchase wire rod in Türkiye was in the middle, it was the cheapest wire rod in Europe (although not by much), but the most expensive wire rod in Asia. Türkiye is located in both continents.

[109] As mentioned previously, the Government of Türkiye provided evidence that differing grades of wire rod may be causing these differences in price, the CBSA did not have the information to do an analysis by grade of wire rod at this stage, but will endeavor to gather this information for the final determination.

[110] To summarize, there is no evidence that distorted Russian wire rod is having an impact on the selling price of steel wire in Türkiye, due to the negligible volume of Russian wire rod imports. Wire rod from China is being used in large quantities by the Turkish exporters. However, these imports of Chinese wire rod do not appear to have an impact on the price of wire rod in Türkiye as can be seen by the fact that Turkish wire rod prices are not out of line with the other countries analyzed. Further, any difference in price could be explained by differences in quality rather than distortions in price. Therefore, the CBSA is of the opinion that distorted wire rod from China and Russia is not leading to a PMS for steel wire in Türkiye.

Other factors

[111] The 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%.^{Footnote 74} Limited information was provided on this change, but it appears to impact all steel wire from all countries.

[112] The evidence 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 the preceding years.^{Footnote 75} According to the Government of Türkiye’s import statistics, 30.8% of steel wire imported into Türkiye during the POI was from China.^{Footnote 76}

[113] If imports of Chinese steel wire into Türkiye distort the selling prices of all steel wire sold in Türkiye as the complainants allege, this will show a lower domestic selling price of all steel wire in Türkiye. This will be considered as part of the impact on domestic selling prices as discussed in the next section.

Summary

[114] From the information available, there is insufficient evidence to show that ceiling prices within the construction industry set by the Government of Türkiye, hyperinflation and currency fluctuation, or distorted input prices due to imports of wire rod from China and Russia are creating a PMS in Türkiye. Nor is there any evidence that these factors are working together to create a PMS.

Impact on domestic selling prices

[115] Despite the fact that it does not appear that there are any factors leading to a PMS in the steel wire sector in Türkiye, the CBSA still did a pricing analysis to see if the selling price of steel wire in Türkiye is different than in another country.

[116] The complainants alleged that Southern Europe is an appropriate benchmark for a pricing comparison.^{Footnote 77} Southern Europe typically consists of Portugal, Spain, and Italy. All three of these countries are named in this investigation and have exporters that responded to the CBSA’s RFI, however, only two responses from exporters in Portugal were considered substantially complete for the preliminary determination.

[117] Further, Türkiye is primarily located in Asia, with only a small portion in Europe. The majority of the responding Turkish exporters are located in Asia. This investigation is also looking at exports from several Asian countries and there are responses of several exporters from Asia on the record that include selling prices of steel wire.

[118] The CBSA compared the selling prices of steel wire in each country named in the investigation. This is the most appropriate information as the complainants were only able to provide selling prices of wire rod and not steel wire. From this, Türkiye has the highest domestic selling prices of steel wire.

[119] The CBSA observed that steel wire pricing varies based on a variety of factors, such as carbon content, coating, size, etc. Therefore the CBSA also looked at the selling price of different benchmark products. From this, the CBSA observed that some types of wire sell for nearly the same price in Türkiye as in other markets, while other types of wire are more expensive in Türkiye compared to other markets. In no case was steel wire less expensive in Türkiye.

[120] From the information available, there is sufficient evidence to show that the selling price of some types of steel wire in Türkiye is higher than in other markets. However, as indicated earlier, there is no evidence that there is a PMS that is causing this difference in prices.

Existence of PMS that precludes proper comparison

[121] Despite the fact that there does not appear to be a PMS in the steel wire sector in Türkiye, the CBSA still considered what it would analyse to form an opinion that there is not a proper comparison with the sales in Türkiye and the sales of the goods to the importer in Canada.

[122] The hyperinflationary situation described previously has led to significant depreciation of the Turkish lira versus the Canadian dollar. In particular, the complainants have argued that the domestic selling price in Türkiye of a product would not be comparable to the selling price to Canada, even during the same 60 day period as the currency can fluctuate greatly during this short time.^{Footnote 78}

[123] It can also be seen that the CAD/TRY exchange rate did fluctuate, but it is primarily due to a large dip in March 2024 and a second one in August 2024, otherwise the fluctuations are similar to other countries. The complainants’ analysis for depreciation of the TRY focused on a very large period, and by focusing on just the POI the depreciation is not as significant.

[124] In addition, Turkish exporters typically do not sell in Turkish lira, which reduces the impact that currency fluctuations will have on selling prices, and ensures there is no difference between how goods are sold between markets.

[125] With the introduction of safeguard measures on wire rod, imported wire rod now faces duties when they are imported. However, these duties can be refunded through Türkiye’s Inward Processing Regime (IPR) if the imported wire rod is used in exported steel wire. During the POI, safeguard duties were equal to 175 USD / Ton.^{Footnote 79} If an exporter in Türkiye imports distorted inputs, they are more likely to use them in production of export goods to recover these costs, making export sales to Canada more impacted by distorted prices than domestic sales. Therefore, a proper comparison may not exist between goods exported to Canada and goods sold domestically due to the disproportionate use of distorted-priced inputs in exported goods.

[126] However for purposes of the preliminary determination, there is no evidence on the record that an exporter made use of Türkiye’s IPR program to avoid safeguard duties on goods destined for Canada.

China, Türkiye, Malaysia, Portugal, Thailand and Vietnam

[135] On a country basis, the CBSA examined the difference between the estimated normal value and the estimated export price for each individual transaction of the cooperative exporters, and considered that the highest amount (expressed as a percentage of the export price), 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.

[136] As a result, based on the facts available, for all other exporters that did not provide a response to the dumping RFI, normal values of subject goods originating in or exported from China, Türkiye, Malaysia, Portugal, Thailand and Vietnam were estimated based on the highest amount by which an estimated normal value exceeded the estimated export price, on an individual transaction basis for the cooperative exporters in the same 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. One anomaly was removed from the all others rate for China as it was significantly higher than the rest.

[137] The CBSA considered that the information submitted on the CBSA customs entry documentation was the best information on which to estimate the export price of the goods as it reflects actual import data.

Chinese Taipei, India, Italy, and Spain

[138] The CBSA did not receive any timely and substantially complete responses from exporters of steel wire located in Chinese Taipei, India, Italy, and Spain.

[139] The CBSA examined the difference between the estimated normal value and the estimated export price for each individual transaction of the cooperative exporters from other subject countries, and considered that the highest amount (expressed as a percentage of the export price), was an appropriate basis for estimating 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.

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

[141] Using the above methodologies, for the preliminary determination, the estimated margin of dumping for all other exporters is as follows: