On 25 July 2025, the International Trade Administration Commission of South Africa (ITAC) announced the initiation of a safeguard measure investigation against the increased imports of flat-rolled products of iron or non-alloy steel, of a width of 600mm or more, clad, plated or coated, with aluminium-zinc alloys, of a thickness of 0.45mm or more, classifiable in tariff subheadings 7210.61.40 and 7210.61.90, and flat-rolled products of non-alloy or other alloy steel, of a width of 600mm or more, otherwise plated or coated with zinc, of a thickness of 0.45mm or more, classifiable in tariff subheadings 7210.49.40, 7210.49.50, 7210.49.90, 7225.92.45, 7225.92.55 and 7225.92.90. Comment is due by 01 September 2025.
ArcelorMittal South Africa Limited (AMSA) stated that a confluence of events formed the basis of the unforeseen development that supported this application, which is, ultimately the considerable oversupply of steel, and consequently the oversupply of corrosion-resistant steel coil products in the world today, causing a surge in the volume of imports of the subject product into the Southern African Customs Union (SACU).
AMSA stated that during the General Agreement on Tariffs and Trade (GATT) Uruguay Round Negotiations from 1986 to 1994, South Africa did not foresee the following events:
- The decision to split the subject product into two main Harmonized System (HS) categories, namely non-alloy steel (tariff heading 7208) and alloy steel (tariff heading 7225) resulting in a tug and pull effect, whereby the increase in duties payable on one tariff subheading leads to a direct increase in the import volumes for the other due to their interchangeability in function;
- The implementation of the European Union (EU) Carbon Border Adjustment Mechanism (CBAM) and similar measures by other developed countries, which disproportionately affect developing countries like South Africa that rely on coal-based electricity for steel production;
- Domestic energy challenges, including load-shedding and electricity price increases far exceeding inflation; and
- The considerable oversupply of the subject product in the world today which is causing a surge in imports into the SACU, which AMSA broke down into four main issues, namely:
- Studies show that the People’s Republic of China (China) did not become a fully fledged market economy as it assured World Trade Organization (WTO) members it would during negotiations;
- Chinese economic activity has consistently declined since 1994, and large steel producers follow aggressive export strategies, fuelled by an oversupply of steel products;
- China’s extraordinary economic growth is slowing down dramatically, and the Chinese domestic market for steel is retracting. As a result of all of the above factors, Chinese producers have to increase their exports further, at reduced prices, to rid themselves of excess stocks; and
- Worldwide, countries are taking urgent action to raise tariffs and impose trade remedies to protect their domestic steel industries. It is expected that the surge in imports that SACU has been experiencing will be augmented by the recent economic slowdown in China and the fact that China’s export markets are contracting rapidly.
ITAC decided that AMSA had submitted prima facie information indicating that the events cited by AMSA were regarded as unforeseen developments, which, in conjunction with the effects of the obligations incurred under GATT 1994, had led to the alleged surge in imports of the subject product, as per the provisions of Article XIX of GATT 1994.
Allegation of serious injury and causal link
The period of investigation for data evaluation, aimed at determining the allegation of serious injury, spans 01 December 2021 to 30 November 2024. Furthermore, this application contains information with regard to increased quantities of imports and the related serious injury for the surge period, being (01 December 2021 to 30 November 2022) to (01 December 2022 to 30 November 2023).
The injury analysis is based on information submitted by AMSA, the major producer of the subject product in the Southern African Customs Union (SACU).
AMSA alleged and submitted prima facie evidence indicating that it is experiencing serious injury in the form of a decline in net profit, market share and an increase in price depression, price suppression and cash flow during the period of surge, being (01 December 2021 to 30 November 2022) to (01 December 2022 to 30 November 2023).
Furthermore, an analysis for the period of investigation from 01 May 2021 to 30 April 2024, indicates that AMSA has experienced serious injury in the form of a decline in net profit, market share, price suppression, price depression and negative cash flow.
On this basis, ITAC found that prima facie evidence had been submitted to indicate that the SACU industry was experiencing serious injury which could be causally linked to the recent, sudden, serious, and significant surge in imports of the subject products.