COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL addressing the negative trade-related effects of global overcapacity on the Union steel market
Date: 2025-10-07
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: EU market, EU production, competitiveness, import (EU), iron and steel industry, surveillance concerning imports, tariff quota, third country

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 7.10.2025  SWD(2025) 780 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL addressing the negative trade-related effects of global overcapacity on the Union steel market {COM(2025) 726 final}  
 
 
1.  Political background  

The steel sector is central to Europe’s competitiveness and security. President von der Leyen 
in her State of the Union address on 10 September 2025, recalled the unequivocal commitment 
to propose a new, long-term trade instrument to succeed the expiring steel safeguards to protect 
the steel industry against the negative trade-related effects of global overcapacity. 

EU  leaders  adopted  the Budapest  Declaration1  in  November  2024  highlighting  the  urgent 
need  and  determination  to  make  the  EU  more  competitive  through  a  new  European 
competitiveness deal. Furthermore, leaders declared their commitment to ensuring an industrial 
renewal  and  decarbonisation  allowing  the  EU  to  remain  an  industrial  and  technological 
powerhouse.  To  this  end,  leaders  committed  to  developing  a  European  industrial  policy  to 
ensure  the  growth  of  tomorrow’s  key  technologies,  while  paying  particular  attention  to 
traditional industries in transition.  

The Commission Communication: A Competitiveness Compass for the EU, adopted on 29 
January  2025,  establishes  industrial  competitiveness  as  a  core  priority  and  sets  outs  cross-
sectoral actions for the next years. It recognises decarbonisation as a powerful driver of growth 
when integrated with industrial, competition, economic and trade policies. The Communication 
identified steel and metals as key areas for action.   

The  Clean  Industrial  Deal2  published  on  26  February  2025  highlights  energy  intensive 
industries as focal sectors requiring urgent support to decarbonise, electrify, as well as confront 
high  energy  costs,  unfair  global  competition  and  complex  regulations,  harming  their 
competitiveness and announces the Steel and Metals Action Plan which “will propose concrete 
actions for both ferrous and non-ferrous metals industries, as well as steel and metals  – the 
backbone of EU industry for centuries – are essential for the clean and digital transformations.” 

Additionally, the Clean Industrial Deal announced a new regulatory initiative, the Industrial 
Decarbonisation Accelerator Act (IDAA), which will introduce resilience and sustainability 
criteria to foster clean European supply for energy-intensive sectors. One objective of the IDAA 
is  to  “create  lead  markets  for  the  development  of  European  clean  and  resilient  industrial 
technologies and products and develop a label on the carbon intensity of industrial products, 
starting with steel”.  

On 4 March 2025, a Strategic Dialogue on Steel was set up, involving stakeholders across the 
whole steel supply chain. President von der Leyen stated that "The steel industry is a key sector 
of our European single market. At the same time this industry is of utmost importance in our 
fight against climate change. The Strategic Dialogue will help develop a concrete Action Plan 
to  tackle  the  unique  challenges  of  this  sector  in  the  clean  industrial  transition.  We  want  to 
ensure that the European steel industry is both competitive and sustainable in the long-term”.3 
The  Dialogue  reflected  the  critical  challenges  faced  by  the  sector  and  the  need  for  urgent 
actions.  

1 https://www.consilium.europa.eu/en/press/press-releases/2024/11/08/the-budapest-declaration/   
2 Clean Industrial Deal - European Commission: https://commission.europa.eu/topics/eu-competitiveness/clean-
industrial-deal_en  
3 https://ec.europa.eu/commission/presscorner/api/files/document/print/nl/ip_25_611/IP_25_611_EN.pdf  

1 

 
 
 
 
 
 
 
 
On  19  March  2025,  the  Commission  adopted  a  Steel  and  Metals Action  Plan  (SMAP)4, 
outlining ambitious actions across different policy areas, including trade.  

Lastly, other EU institution, the European Parliament, in its Resolution on Energy Intensive 
Industries5 from April 2025 called on the Commission to make full and efficient use of trade 
defence  instruments  and  to  find  a  permanent  solution  to  address  unfair  competition  and 
structural overcapacity, before the expiry of current steel safeguard measure.  

1.1.1.  Interplay with existing instruments 

The steel trade measure is being prepared in a broader context where initiatives in other policy 
areas have been put in place or are being developed, as listed below. 

Climate  

Energy  

Climate Law, EU Emission Trading System (EU ETS), Industrial Emissions 
Directive, CBAM   

Electricity  and  gas  Market  Regulations  and  Directives,  the  Renewable 
Energy  Directive,  the  Energy  Efficiency  Directive  the  Gas  and  Hydrogen 
Decarbonisation Package, Action Plan for Affordable Energy.  

Product  

Construction  Product  Regulation  (CPR),  Eco-design  for  Sustainable 
Products Regulation (ESPR). 

Competition   Clean Industrial Deal State Aid Framework (CISAF), Climate, Energy and 

Environmental Aid Guidelines. 

Trade  

Funding  

Trade  Defence  Instruments,  Foreign  Direct  investment,  Free  Trade 
Agreements 

Current multiannual financial framework (MFF), post 2027 MFF, Industrial 
Decarbonisation Bank, Horizon Europe, Research Fund for Coal and Steel, 
Innovation Fund, European Competitiveness Fund.  

1.1.2.  Interplay with ongoing initiatives 

There are also several ongoing initiatives that will have an important impact on the steel sector.  

Status 

Ongoing  

Proposal for a Regulation on 
the  End-of-Life  Vehicles 
(ELV)   

Harmonised methodology for reporting of 
life-cycle CO2 emissions of passenger cars 
and  light  commercial  vehicles,  mandate 
by Regulation (EU) 2019/631  

Planned 
2025  

for 

Industrial  Decarbonisation 
Accelerator Act 

Greening Corporate Fleets 

Revision of CBAM  
Circular Economy Act  

for 

Electrification Action Plan   

Planned 
2026 

4https://single-market-economy.ec.europa.eu/document/download/7807ca8b-10ce-4ee2-9c11-
357afe163190_en?filename=Communication%20-%20Steel%20and%20Metals%20Action%20Plan.pdf 
5 https://www.europarl.europa.eu/doceo/document/TA-10-2025-0065_EN.html  

2 

 
 
 
 
 
 
 
 
 
 
 
 
1.2.  The EU steel sector and its key challenges 

Steel is an essential material for the EU economy, including for its green transition. Steel is 
used  in  a  wide  variety  of  sectors,  such  as  buildings,  infrastructure,  railways,  automotive, 
shipbuilding, windmills, industrial tools and machinery, household appliances, amongst others. 
Steel is also of strategic importance for increasing the defence and military capabilities of the 
EU6. In this regard, the White Paper for European Defence – Readiness 20307 noted that 
‘existing value chains or manufacturing capacities (such as steel) can find new opportunities 
in  repurposing  and  supplying  a  growing  footprint  of  a  defence  industrial  base’,  and  it 
concluded that  ‘a surge in defence investment would have positive spillover effects across the 
economy, contributing to competitiveness, job creation and innovation in many sectors, from 
aeronautics to shipbuilding, from steel to space’. 

The  EU  steelmaking  industry  is  the  world’s  third  largest  steel  producer.  It  employs  around 
300,000  people  directly  and  it  is  estimated  that  it  generates  2,5  million  jobs  (indirect  and 
induced)8. There are many steel production sites across more than 20 EU Member States. Steel 
plants  sustain  many  regional  economies,  underlining  their  socio-economic  and  political 
importance. A previous Commission Staff Working Document9 “Towards a competitive and 
clean  European  steel”  concluded  that  ‘Steel  is  a  crucial  input  to  several  downstream 
ecosystems,  such  as  construction,  mobility  and  automotive,  or  for  mechanical  engineering 
companies. […] Companies active in these sectors, many of which are small and medium-sized 
enterprises (SMEs), employ millions of workers in Europe and depend on EU steel production’. 
Thus, underlining the key role of steelmaking in preserving a strong supply chain and quality 
jobs in the EU. 

6 https://commission.europa.eu/topics/defence/future-european-defence_en  
7https://defence-industry-space.ec.europa.eu/document/download/98add398-b006-4c68-be28-
a276688b0890_en?filename=White%20paper%20for%20European%20defence%20%E2%80%93%20Readines
s%202030.pdf 
8https://www.eurofer.eu/assets/publications/brochures-booklets-and-factsheets/european-steel-in-figures-
2025/European-Steel-in-Figures-2025_23062025.pdf  
9  Commission  Staff  Working  Document:  Towards  competitive  and  clean  European  steel  Accompanying  the 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions  Updating  the  2020  New  Industrial  Strategy:  Building  a 
stronger Single Market for Europe's recovery; SWD (2021) 353 final. 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 1. Map of EU steel production sites10 

Source: EUROFER 

The EU steel industry is facing critical challenges which weaken its competitiveness in a global 
market  and  seriously  threaten  its  long-term  viability,  creating  high  risks  for  the  industry’s 
existence and its ability to make new investments. Over the last years, the EU steel industry 
has  been  facing  a  significant  and  sustained  import  pressure,  both  in  volumes  and  prices, 
resulting from unsustainable levels of global overcapacity, which are negatively impacting the 
EU steelmaking industry’s economic performance. Furthermore, the EU steel demand in the 
EU  has  been  depressed.  Consequently,  EU  production  has  shrunk,  and  its  current  capacity 
utilisation is well below profitable levels11, undermining EU steelmakers’ ability to invest and 
as such, jeopardising EU’s decarbonisation objectives. In fact, several EU steelmakers have 
halted ambitious and costly investments in green steel projects needed to remain competitive 
and decarbonise its production as part of the EU’s green agenda. These critical challenges are 
taking place in an overall difficult context, as the steel sector is facing a lack of a level playing 
field, as well as higher energy and manufacturing costs.  

This  situation  also  poses  risks  related  to  the  EU’s  strategic  autonomy. As  noted  in  the 
European Economic Security Strategy, the loss of European-based production capacities and 
know-how in critical sectors could leave the EU overly dependent on imports in key segments 
of the economy. 

The combination of challenges is having a heavy impact on jobs. In fact, the EU steel industry 
has been seriously decimated, losing nearly 100 000 direct jobs since 2008 (around 25% of its 
workforce) and closing or reducing installed capacity in numerous factories across many EU 

10 Source: EUROFER [providing an indicative visual overview of the plants  - few of the sites included in the 
map may no longer be operational] 
11 See Section 3.3. for further details 

4 

 
 
 
 
 
 
 
 
 
Member  States.  The  current  situation  is  very  fragile,  and  risks  to  seriously  worsen  if  the 
challenges are not effectively addressed.  

Trade defence measures make an essential contribution to the continued existence of the EU 
steel sector. The EU has 80 trade defence measures in place on the steel sector, out of a total of 
229 measures, including since 18 July 2018 an erga omnes safeguard12 on a wide scope of steel 
finished products (carbon flats and longs, stainless steel and tubes and pipes), protecting nearly 
224,000 jobs in the steel sector (of those, almost 174 000 by the steel safeguard).  The trade 
defence instruments are effective, and their impact is significant with imports in the steel sector 
dropping by an average of 55% overall after measures are imposed, although this drop varies 
across  specific  products. The  drop  in  imports  subject  to  measures  can  be  as  high  as  100%. 
However, TDIs’ purpose and design are not appropriate to deal effectively, as the main tool, 
with the widespread trade-related effects of global overcapacity. 

Yet,  import  pressure  has  continued  to  grow  throughout  the  years  because  of  growing 
overcapacities. At the same time, the safeguard measure, which has been in place since 18 July 
2018, will legally expire after 30 June 2026 and if not replaced, would leave a substantial gap 
in the level of protection currently afforded to the EU steel industry. 

The SMAP recognised that the steel sector is vital for the EU’s economic security and social 
stability13. In the field of trade, the SMAP sought to take actions to promote and protect EU 
industrial capacities. In this regard, the SMAP concluded that global overcapacities severely 
threaten the profitability and competitiveness of European industries, and that it is therefore 
necessary to introduce an appropriate and effective protective measure beyond 30 June 2026 
that will contribute to preserving a competitive and sustainable EU steel industry. 

The SMAP committed to have a Commission proposal for a trade measure replacing the steel 
safeguard ready in the third quarter of 2025: 

Action under SMAP 

No  later  than  Q3  2025,  the  Commission  will  propose  a  trade  measure  replacing  the  steel 
safeguards as of 1 July 2026, providing a highly effective level of protection against negative 
trade-related effects caused by global overcapacities. 

This accelerated timeframe was necessary given the magnitude of the challenges faced by the 
industry, intensified by the upcoming expiry of the safeguard measure and the imposition of 
tariffs on steel imports by third countries, including the United States.  

The SMAP thus showcased the urgent need to address effectively the challenges posed by the 
negative trade-related effects caused by global overcapacities and by the proliferation of trade-
restrictive measures across third countries. 

As part of the process leading up to a proposal for a trade measure, the Commission published 
a call for evidence14 and a targeted consultation15 to collect views from stakeholders. 

2.  Trade-related challenges and market evolution and outlook 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14781-Trade-measure-addressing-

12 A detailed description of the safeguard measure is provided in Section 4. 
13  SMAP, at p. 1. 
14 
the-negative-trade-related-effects-of-global-excess-capacity-on-the-EU-steel-sector_en  
15 
steel-sector-unfair-trade-practices-2025-07-18_en  

https://policy.trade.ec.europa.eu/news/commission-launches-consultation-future-measures-safeguard-eu-

5 

 
 
 
 
 
 
 
 
2.1.  Evolution of consumption and forecast in the EU and worldwide 

The  world’s  steel  consumption  continues  to  show  a  weak  evolution  since  2022,  and  the 
prospects  going  forward  are  not  particularly  positive.  Demand  is  expected  to  only  increase 
modestly in 2025, only recovering 2023 levels, according to World Steel16.  

              Source: World Steel (2025) 

The outlook for 2025 is also confirmed by OECD data as shown in the table below. Looking 
beyond 2025, the OECD concluded that world steel demand has weakened over the last three 
years. A sharp decline in demand in the People’s Republic of China (“China”) largely offset 
solid  steel  demand  growth  in  many  emerging  markets  during  2024.  In  many  advanced 
economies,  steel  producers  experienced  slowdowns  due  to  weaker  demand,  economic 
uncertainty and high energy costs. As with demand, world steel production reached a record 
level in 2021, then generally declined through 2024. Growth of slightly less than 1% per year 
is expected for world steel demand and production through 2030.17 

https://worldsteel.org/data/world-steel-in-figures/world-steel-in-figures-2025/#apparent-steel-use-2020-to-
16 
2024, see apparent steel use table. The grouping of countries/regions is done by the data supplier, in this case, 
Worldsteel, e.g. EU(27) + United Kingdom, or Russia+other CIS+Ukraine. 
17 See OECD Steel Outlook, p. 48. 

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2. Steel demand expectations, 2024 – 30 (in million metric tons and % change)18

Source: OECD Steel Outlook (2025) 

The outlook for the EU steel market does not look any better. While in 2023 and 2024 it saw 
very low levels of consumption, in 2025 it is expected to recover only marginally19. The OECD 
also projects a rather stable level of consumption through 203020. These projections from the 
OECD  and  World  Steel  are  in  line  with  EUROFER’s  (EU  steelmakers’  association)  own 
assessment. In its latest outlook, EUROFER noted that the outlook for 2025 and 2026 remains 
overshadowed  by  a  worsening  combination  of  very  high  tariff-related  uncertainty,  weak 
conditions  in  manufacturing  sectors  –  and  consequently  lacklustre  steel  demand  -  severe 
geopolitical tensions, and broader economic challenges. Although repeated monetary easing 
in the euro area, its effects on the economic cycle will not be visible in the short-term21. 

These outlooks also show clearly that the modest demand increases projected for the next years 
will be outpaced by the increase in capacity. In fact, and despite the consistent outlooks for 
steel demand, significant net capacity increases continue steadily, with new capacities being 
projected across different regions22. As highlighted by the OECD in its 2025 Steel Outlook, 
substantial increases in capacity are planned worldwide over the next three years […] despite 
only modest global steel demand growth23.  

This shows the stark contradiction between market evolution and decisions in many countries 
to continue increasing capacities, thus exacerbating an already acute problem in the global steel 
market.  

18 The grouping of countries/regions is done by the data supplier, in this case the OECD e.g. EU(27) + United 
Kingdom, or United States, Mexico and Canada. 
19 See Worldsteel short-range outlook for 2025:  
https://worldsteel.org/wp-content/uploads/SRO_T_Oct24_ver2025_02_05_corrr.pdf 
20 See OECD Steel Outlook, Table 4.3, p. 55. 
21 See EUROFER’s Economic and steel market outlook 2025-2026: 
 https://www.eurofer.eu/assets/publications/economic-market-outlook/economic-and-steel-market-outlook-
2025-2026-second-quarter/EUROFER-Economic-Report-Q2-2025.pdf  
22  See  Annex  A of  OECD  Steel  Committee’s  Latest  developments  in  steelmaking  capacity  and  outlook  until 
2027, STI/SC (2025); see also Tables 2.1, 2.2. and 2.3. in OECD 2025 Steel Outlook, pp. 25-28. 
23 See OECD Steel Outlook, p. 16. 

7 

 
 
 
 
 
 
 
 
 
2.2.  Overcapacity 

In  2015  China  flooded  international  steel  markets,  particularly  the  EU,  amidst  a  breakout 
caused by its severe overcapacity, once its domestic consumption could not keep up with the 
high  level  of  production.  Already  in  2014  Chinese  exports  to  the  EU  were  growing 
significantly. In 2016, in an international recognition of the magnitude of the mostly Chinese 
state-driven overcapacities, and the negative effects it was causing across steel markets, the 
Global Forum on Steel Excess Capacity (GFSEC) was created under the auspices of the G20.24 
Its  goal  was  tackling  effectively  the  root  causes  of  overcapacity.  In  the  same  period,  the 
Commission also issued a Communication acknowledging the challenges faced by the sector, 
including the effects of overcapacity25. 

Overcapacity  is  often  driven  by  systematic,  state-induced  over-investments  and  subsidies 
concentrated  along  supply  chains  in  critical  and  strategic  industrial  sectors.  Structural 
overcapacities  in  third  countries  translate  into  aggressive  export  strategies  which  increase 
pressure on EU producers adding to an already unlevel playing field.  

As the OECD has recently concluded, the steel industry is one of the most subsidised industrial 
sectors […]. The People’s Republic of China’s (“China”) subsidisation rate is ten times that of 
OECD countries. Government support for the steel sector has become increasingly prominent 
in regions where steelmaking capacity is rapidly expanding, such as in the Middle East and 
North Africa, the Association of Southeast Asian Nations, and China. In addition to government 
grants  and  below-market  borrowings,  measures  include  subsidised  energy  prices  and 
preferential tax treatment26. 

The OECD highlights Government support becoming increasingly prominent in certain regions 
where  capacity  is  growing  fast.  It  gives  examples  of  such  support  in  countries  such  Egypt, 
Algeria  in  the  MENA  region  and  Indonesia,  Malaysia  and Vietnam  in ASEAN27. All  these 
countries have rapidly increased their exports to the EU in recent years, despite a safeguard 
measure in place28.   

The GFSEC elaborated on the effects of steel overcapacity, acknowledging that overcapacity 
is associated with surges in steel exports from countries that are the source of global excess 
capacity. This leads to over-supply of steel on international markets and depressed steel prices, 
as well as lower market shares and capacity utilisation rates for domestic steel producers in 
third  countries  that  operate  under  market  conditions.  Moreover,  the  recent  excess  capacity 
crisis  that  emerged  in  2015  also  led  to  bankruptcies  and  localised  job  losses  across  the 
GFSEC’s membership. Typically, no matter where the excess capacity sits, it always leads to 
lower profitability for steel producers everywhere29. 

24 https://ec.europa.eu/commission/presscorner/detail/en/ip_16_4435  
25https://www.europarl.europa.eu/RegData/docs_autres_institutions/commission_europeenne/com/2016/0155/
COM_COM(2016)0155_EN.pdf  
26 See OECD Steel Outlook 2025, section 3, p. 32.  
27 See OECD Steel Outlook 2025, pp. 37-40. 
28 See Figure 5 in Section 3.3 below. 
29 Global Forum on Steel Excess Capacity (GFSEC): Impacts of global excess capacity on the health of GFSEC 
steel 
industries,  March  2024:  https://www.steelforum.org/content/dam/steel-forum/en/publications/gfsec-
impacts-of-global-excess-capacity_0325.pdf  

8 

 
 
 
 
 
 
 
 
A  recent  GFSEC  study30  further  concluded  that  excess  capacity  drives  the  negative 
performance of firms through multiple channels, starting with higher distortions in competition 
when  steel  products  are  sold  at  artificially  lower  prices.  This  directly  influences  the  profit 
margins  of  steel  firms  in  the  GFSEC  member  countries.  The  decline  in  operating  turnover 
demonstrates weaker demand for steel firms’ products and smaller revenues from their sales. 
Turnover  is  directly  linked  to  the  firm’s  financial  health,  as  it  determines  the  profitability 
performance. Among the outcomes of this process is an inability to finance new investments. 
The decline in assets points to smaller capital investments or devaluation of assets that steel 
firms in GFSEC member countries have experienced in the years leading up to 2020. These 
can reduce operational capacity, and lead to a loss of competitiveness and an inability to invest 
in the necessary technological advancements for the industry. 

Despite  the  well-documented  negative  impacts  on  the  steel  sector,  overcapacity  has  grown 
steadily in recent years, and it is expected to continue rising, becoming a challenge of structural 
nature31. In fact, recent OECD data shows that 165 million tons of new capacity additions are 
projected for the period 2025-27.32 These increases are also partially the result of cross-border 
investments by Chinese steel companies. Of the projected 165 million tons in new capacity, 
Asian  economies  are  expected  to  account  for  60%  of  the  new  capacity,  led  by  substantial 
increases in China, India and ASEAN.  

As a result, global excess capacity is expected to increase to 721 million tons by 2027, from 
an  estimated  602  million  tons  in  2024,  putting  enormous  pressure  on  the  viability  of  even 
highly  competitive  steelmakers33.  To  put  these  figures  into  perspective,  the  expected 
overcapacity represents around five times the EU’s steel consumption.  

The  below  table  from  the  OECD  shows  the  growing  gap  between  installed  capacity  and 
demand, set to continue in the coming years34. 

March 

activities, 

30  Global  Forum  on  Steel  Excess  Capacity  (GFSEC):  Global  excess  capacity  and  employment  in  steel  and 
https://www.steelforum.org/content/dam/steel-
2025: 
downstream 
forum/en/publications/GFSEC-Employment_and-excess-capacity_31_jan_2025-(002)_250305_1015.pdf  
31 See Annex A of OECD’s Update-Latest developments in steelmaking capacity and outlook until 2027, TI/SC 
(2025)4  |  1.  See  also:  https://mepsinternational.com/gb/en/news/overcapacity-will-continue-to-weigh-on-steel-
industry 
32 OECD Steel Outlook, p.16.  
33 OECD Steel Outlook, p. 16. 
34 OECD Steel Outlook, p.16, figure 1.3. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  2.  Recent  (2019-24)  and  forecasted  (2025-27)  global  excess  capacity  (in  million 
tons) 

Some non-exhaustive examples of significant capacity increases across steelmaking countries 
after the China overcapacity crisis outbreak in 2015 until 2024, include35: Vietnam (>100%), 
Algeria (>200%), India (>50%), Türkiye (>15%), Egypt (>20%), Malaysia (>40%), Indonesia 
(>40%), amongst others.  

Thus,  the  trend  of  growing  capacities  across  regions  continues  today  and  the  most  recent 
available projections clearly show that the problem of overcapacity is not on track to be solved 
– rather, the contrary. This trend is further widening the gap between demand and capacity, 
exacerbating the pressure on global steel market, and on the EU steel market as the  world’s 
main  steel  importing  market36. As  will  be  described  in  Section  3.2.  below,  such  capacity 
increases  disconnected  from  demand  evolution  are  having  a  very  detrimental  effect  on  the 
global steel sector and on the EU steel industry.  

Furthermore,  it  is  worth  recalling  that  the  European  Union  was  virtually  the  only  major 
steelmaking  region  where  installed  capacity  had  decreased  since  2018  and  thus  did  not 
contribute to the current trends in global overcapacity37. 

China 

Given the sheer size of its steel industry, the situation of China and its impact on global steel 
market developments, deserves particular attention. In the period 2006-2016, boosted mainly 

35 Source: Boston Consulting Group https://plantfacts.bcg.com   
36 OECD Steel Outlook, table 5.2. 
37 OECD, Latest developments in steelmaking capacity, Table 1. 

10 

 
 
 
 
 
 
 
 
 
 
by real estate and large infrastructure projects (and by stimulus packages by the Government 
to  overcome the financial  crisis,  where growth and demand weakened),  China increased its 
steel  production  capacity  by  over  675  million  tons.  This  amounts  to  around  73%  of  the 
worldwide capacity increase in the same period38. 

In 2024 China accounted for 53% of global steel production39 and around 46% of global steel 
capacity40.  In  overall  terms,  Chinese  installed  capacity  peaked  in  2015,  when  the  ‘China 
overcapacity crisis’ broke out in the form of record-level exports.  

In the subsequent years and following the creation of the GFSEC of which China was originally 
a member, net capacity decreases took place. However, since 2019 when China left the GFSEC, 
that trend has reversed, and China has seen a net increase in installed capacity41.  

Evolution of estimated installed capacity in China 
(in million tons)

 1.400

 1.200

 1.000

 800

 600

 400

 200

 -

2016

2017

2018

2019

2020

2021

2022

2023

2024

Furthermore, China is further increasing its steelmaking  presence in third countries through 
foreign  direct  investment  in  new  capacities,  including  through  State  Owned  Enterprises 
(SOEs), mostly in Asia42 but also in Africa. It is estimated that China accounts for half of the 
cross-border total [foreign investments], either as a sole investor or through joint ventures.43  

38 See Commission Staff Working Document on significant distortions in the economy of the People’s Republic 
of China for the purposes of trade defence investigations, SWD(2024) 91 final (‘the China Distortions Report’): 
https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2024)91&lang=en 
of 
Commission Documents - SWD(2024)91), Section 14.6. 
39https://worldsteel.org/wp-content/uploads/World-Steel-in-Figures-2025-3.pdf  (World-Steel-in-Figures-2025-
3.pdf) 
40 OECD Steel Outlook, p.25, table 2.1.  
41 Source: Boston Consulting Group https://plantfacts.bcg.com  
42 OECD Steel Outlook, table 2.4. (listing Indonesia, Malaysia and the Philippines, amongst others, as recipients 
of Chinese investments for new capacities). 
43 OECD Steel Outlook 2025, p.29. 

(Register 

11 

 
 
 
 
 
 
 
 
 
 
The  Commission's  Staff Working  Document  on  Significant  Distortions  in  the  People’s 
Republic of China (‘China Distortions Report’)44 identified the deployment of a wide array of 
non-market policies and practices (NMPPs) in China’s steel sector45. The report noted that the 
government directs and controls virtually every aspect in the development and functioning of 
the  sector.  For  the  last  several  decades  Chinese  policies  have  been  to  support  the  rise  of 
‘national champions’ in  the steel  industry. To accomplish this, the  Chinese authorities have 
employed  an  elaborate  set  of  financial  and  other  subsidies  for  the  sector  and  engineered 
strategic mergers that consolidated the industry players.  

The Distortions Report concluded that the overarching control of the government prevents free 
market  forces  from  prevailing  in  the  steel  sector  in  China.  The  problem  of  overcapacity  is 
arguably  the  clearest  illustration  of  the  implications  of  the  government's  policies  and  the 
distortions resulting therefrom. Overcapacity built up by China over years triggered a surge of 
low-priced Chinese exports causing a depression of steel prices globally and having a negative 
impact on, inter alia, the financial situation of steel producers worldwide.46 

Along the same lines, the OECD has established significant levels of subsidisation to Chinese 
steelmakers. The OECD 2025 Steel Outlook stated that China’s subsidisation rate is five times 
higher than the average for other partner economies, which, in turn, are double the rate of 
subsidisation in OECD countries47. 

The Commission has established in  numerous trade defence investigations, the existence of 
persistent and widely spread significant distortions on the Chinese steel sector. In addition, the 
Commission  has  also  established  the  existence  of  transnational  subsidies  in  Chinese 
investments  in  steelmaking  facilities in  third countries, e.g. Indonesia.  Overall, there are no 
signs  that  China’s  policy  regarding  the  steel  sector  is  going  to  undergo  any  fundamental 
changes48, and hence, the existing distortions, with their ensuing effect on global steel trade49, 
will remain.  

2.3.  Third country measures 

Growing overcapacity, and its negative trade-related effects, in the form of aggressive export 
behaviour,  depressing  domestic  prices,  have  triggered  numerous  trade  actions  across 
steelmaking  countries  to  protect  their  domestic  industries.  These  measures  included  both 
traditional trade defence instruments (‘TDIs’) as well as broader types of measures.  

In the framework of the EU’s steel safeguard proceeding, the Commission analysed regularly 
the evolution of trade defence measures in the steel sector50. As shown in the below table51, the 
number of TDI actions in the steel sector has progressively increased year-on-year, reaching 

44 Commission Staff Working Document on significant distortions in the economy of the People’s Republic of 
China  for  the  purposes  of  trade  defence  investigations,  SWD(2024)  91  final  (‘the  China  Distortions  Report’): 
https://ec.europa.eu/transparency/documents-register/detail?ref=SWD(2024)91&lang=en 
of 
Commission Documents - SWD(2024)91), see Chapter 14, focussing on the steel sector. 
45 The Distortions Report is primarily used by the European Commission in the framework of its trade defence 
investigations. Nevertheless, it contains a wide array of relevant and detailed factual information pertinent for the 
purpose of describing the situation on the Chinese steel market in this Staff Working Document.  
46 See China Distortions Report, p.416. 
47 OECD Steel Outlook, p.36. For more details on Chinese subsidies, see pp. 40-41 
48 See China Distortions Report, pp. 411-415 on past unsuccessful attempts to curb overcapacity in China. 
49 See Sections 3.2 and 3.3. of this Staff Working Document. 
50 See recitals 63-71 of Regulation (EU) 2024/1782 and recitals 26-28 of Regulation (EU) 2025/612. 
51 Source: WTO Trade Remedy Portal - https://trade-remedies.wto.org/en  

(Register 

12 

 
 
 
 
 
 
 
 
high numbers. The table also shows that a large share of those measures has been taken against 
the main steel exporters to the EU52. This means that such exporters have consistently followed 
aggressive export behaviours to enter third markets. Because of the increased barriers in the 
form of TDIs they are facing, thus shrinking their export opportunities, it will only exacerbate 
their need to find alternative markets to sell their production. Therefore, countries are deploying 
trade defence instruments to counter the increase in low-priced imports, stemming directly or 
indirectly from overcapacity.  

Figure 3. Evolution of TDI measures from third countries 

Evolution of TDI measures from third countries

500
450
400
350
300
250
200
150
100
50
0

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022  2023
- june

Cummulated all measures

Cummulated main steel exporters to the Union

The EU has implemented many trade defence measures, in particular following the relevant 
increase in imports starting in 201453. Despite these increased efforts, import penetration from 
an  ever-growing  number  of  countries  is  at  historically  high  levels,  undermining  the  Union 
industry’s  economic  performance.  This  is  partially  linked  to  the  fact  that  traditional  trade 
defence instruments, while being effective in targeting unfair trading practices as explained in 
Section 1.2., were not designed to tackle global overcapacity. 

Beyond traditional trade defence measures, the steel sector is observing a spike in broader trade 
measures across countries, often in the form of tariffs. A non-exhaustive overview is provided 
below: 

In March 2018, the United States, one of the world’s largest steel importing markets, imposed 
a 25% duty under Section 232. While in the subsequent years some countries were eventually 
exempted or subject to TRQ or quota regimes, and some product types were benefitting from 
exclusions, most steelmaking countries were subject to the duty for nearly seven years on their 
exports to the US. As outlined in the EU’s steel safeguard measure, this measure posed a serious 

52  See  recitals  (16)  and  (17)  of  Commission  Implementing  Regulation  (EU)  2023/104  of  12  January  2023 
amending Implementing Regulation (EU) 2019/159 imposing a definitive safeguard measure on imports of certain 
steel products following a report adopted by the World Trade Organization’s Dispute Settlement Body; OJ L 12, 
13.1.2023, p.7; see also recitals (69) and (70) of Commission Implementing Regulation (EU)  2024/1782; OJ L 
25.6.2.2024.  
53  These  instrument  concern  mostly  anti-dumping  measures,  but  also  anti-subsidy  (including  transnational 
subsidies) as well as anti-circumvention measures, and a safeguard measure.  

13 

 
 
 
 
 
 
 
 
 
risk of trade diversion of steel into the EU market, some signs of which were already observed 
in 2018. 

A series of significant updates to Section 232 measure in the first months of 2025 have taken 
place. First, effective 12 March 2025, the US made imports from all origins subject to a 25% 
duty54, including the termination of the existing General Approved Exclusions (GAEs) regime. 
A few months later, effective from 4 June 2025, the US doubled the duty rate to 50%55. This 
duty remains in place, covering imports from all origins. This resulted in a much stricter US 
Section 232 measure.  

Imports into the US market from third countries, excluding the EU, had substantially decreased 
compared to the period prior to the imposition of Section 232 measures, i.e. pre March 2018, 
which exceeded 21 million tons56.  

US  Imports  of  products  categories  covered  by  the  EU  steel  safeguard  from  third 
countries [excl. EU] 

(in ‘000 tons) 

Year 

2021 

2022 

2023 

2024 

Imports in thousand tonnes 

18,239 

19,718 

16,633 

17,152 

Considering that the updated measure is  significantly tighter, both  in  terms of geographical 
scope as well as its level, it is very likely that the level of imports into the US will progressively 
go down further in relevant amounts. 

Canada has imposed a series of measures aiming at substantially limit imports of steel into its 
territory. On 27 June 2025, Canada introduced a system of TRQs for non-FTA partners with an 
out-of-quota  duty  of  50%  under  ‘Section  53’57.  The  level  of  TRQs  was  equivalent  to  the 
volumes exported to Canada in the year 2024. On 1 August 2025, Canada updated this measure 
by reducing the TRQs  for non-FTA partners  to  half of their  exports to  Canada in  2024 and 
introducing TRQs for FTA partners58. In addition, Canada had already introduced in 2024 a 
‘surtax’ of 25% on Chinese steel imports59. 

These  two  examples  show  clearly  that  third  countries  are  resorting  to  measures  to  restrict 
imports that go well beyond the standard trade defence instruments toolbox, with a very broad 
geographical and product scope. 

Furthermore, in recent years, other countries have also imposed broad trade measures, and an 
increasing  number  of  steel  industries  in  third  countries  are  calling  on  their  national 

54 https://www.govinfo.gov/content/pkg/FR-2025-02-18/pdf/2025-02833.pdf  
55  https://www.whitehouse.gov/fact-sheets/2025/06/fact-sheet-president-donald-j-trump-increases-section-232-
tariffs-on-steel-and-aluminum/  
56  See  table  11  of  Commission  Implementing  Regulation  (EU)  2021/1029,  https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32021R1029&from=EN [scope of the data mirroring that of the EU’s steel 
safeguard] 
57  Section  53  of  Canada’s  Customs  Tariff:  https://laws-lois.justice.gc.ca/eng/acts/C-54.011/page-14.html#h-
144680  
58 https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-24-eng.html  
59 https://gazette.gc.ca/rp-pr/p2/2025/2025-08-13/html/sor-dors154-eng.html  

14 

 
 
 
 
 
 
 
 
 
 
governments to take effective actions. Below a non-exhaustive list of measures that have been 
taken, as well as of potential measures being discussed.  

Increased applied tariffs under WTO 

In recent years, in a context of growing overcapacity and import pressure, several countries 
have increased their applied tariffs under their respective WTO commitments. These countries 
include Mexico60, Brazil61, Türkiye62 and Colombia63. The geographical and product scope, 
as well as the applied rates vary from country to country. However, the fact that these countries 
introduce higher tariff rates, contributes to fuelling further the already significant risk of trade 
diversion into the EU market. 

Tariffs under safeguard instrument 

Other countries such as India64, Türkiye65, South Africa66 and Egypt67, have also introduced 
safeguard measures in recent times. While the EU’s safeguard measure took the form of TRQs 
to  preserve  traditional  trade  flows,  these  measures  have  taken  the  form  of  tariffs,  therefore 
posing a higher risk to trade flows.  

Trade measures currently being considered by other countries 

Furthermore, other countries are in the process of assessing the introduction of trade measures 
beyond  trade  defence  instruments.  For  instance,  the  United  Kingdom  launched  a  call  for 
evidence68  as  part  of  an  ongoing  process  to  replace  its  existing  safeguard  measure,  which 
expires end-June 2026. 

This  shows  that  the  number  and  scope  of  trade  measures,  beyond  traditional  trade  defence 
instruments,  is  growing  and  will  likely  continue  this  trend  in  view  of  the  overcapacity 
developments. The analysis has also shown that many of these measures take the form of tariffs, 
thus making them more restrictive and fragmenting even further the global steel market.  

The  combination  of  these  measures  creates  substantial  pressure  in  the  global  steel  market, 
notably in view of the current evolution of overcapacity and demand outlook. These measures 
also have an additional very negative effect for the EU steel industry: a reduction in the export 
levels of EU companies. In the last decade, the EU has turned into a net steel importer, therefore 
seeing an erosion of its  performance in both its  domestic and export markets. In fact, since 
2019 alone, the EU has lost around 14 million tons in exports (almost -40%), by far, the sharpest 
drop  in  exports  in  any  steelmaking  region69.  Thus,  further  adding  to  the  negative  effects 

https://news.bloomberglaw.com/international-trade/colombia-follows-peers-and-hikes-tariffs-on-chinas-

https://www.steelorbis.com/steel-news/latest-news/mexico-sets-tariffs-up-to-50-percent-on-certain-steel-

60 
imports-1337249.htm ;  
61 https://www.reuters.com/markets/commodities/brazil-government-renews-tariffs-quotas-steel-products-2025-
05-27/  
62  https://www.resmigazete.gov.tr/eskiler/2024/12/20241231M3-1.pdf;  https://www.steelradar.com/en/import-
taxes-on-various-steel-products-determined-by-turkiye/  
63 
cheap-steel  
64 https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/SG/N7IND12S1.pdf&Open=True 
65 https://www.resmigazete.gov.tr/eskiler/2024/06/20240630-7.pdf  
66 https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/SG/N8ZAF10.pdf&Open=True  
67 https://www.steelradar.com/en/haber/egypt-imposes-temporary-safeguard-duties-on-steel-imports/ 
68https://www.gov.uk/government/news/uk-seeks-views-on-further-trade-protections-for-steel - UK seeks views 
on further trade protections for steel - GOV.UK 
69  See  OECD  Steel  Outlook,  table  5.1,  p.61;  also:    https://www.eurofer.eu/assets/publications/brochures-
booklets-and-factsheets/european-steel-in-figures-2024/EUROFER-2024-Version-June14.pdf  

15 

 
 
 
 
 
 
 
 
resulting from increased import pressure that the EU steel industry is subject to in its domestic 
market. 

Against  this  backdrop,  it  should  be  flagged  that  a  new  EU  measure  may  be  used  by  third 
countries as part of the justification for introducing new or further restrictive measures, as it 
has happened already with regards to the EU’s safeguard measure. However, while this scenario 
cannot be discarded, in a global market that is subject to multiple restrictions and disequilibria, 
it  is  not  possible  to  anticipate  the  likelihood  or  quantify  the  possible  effects  of  such  future 
measures, some of which may in any event be adopted, regardless of the EU’s adopting its own 
measure, or not. 

3.  Effects of the international situation on the EU market and EU industry 

3.1.  Attractiveness of EU market (size and price) 

The Commission has consistently established in the framework of its safeguard proceeding that 
the EU steel market is very attractive.70 

In terms of volumes, the Union is by far the largest steel importing market in the world71. It is 
thus not surprising that the EU market is the main or one of the main export destinations for 
several steelmaking countries.  

In terms of price levels, the prices that the main steel suppliers achieve when exporting into the 
EU market are, for most of their steel products, consistently higher than the price levels they 
achieve when exporting such products  to  other third country markets. The Commission  has 
confirmed  this  price  differential  consistently  across  the  last  years,  in  the  framework  of  the 
safeguard review investigations. A price assessment done during the steel safeguard review of 
2024, comparing, product by product the unit values of exports of third countries to the EU 
with  exports  of  third  countries  elsewhere,  showed  that  exporters  to  the  EU  charged  higher 
export prices to  the Union than to  other third markets in  57% to  93% of the product  codes 
depending on the exporter.72  

This indicates that exporters have a very strong interest in entering the Union market, leading 
in  some  cases  to  unfair  trading  practices  such  as  dumping.  In  fact,  in  recent  years  the 
Commission  has  imposed  several  anti-dumping  and  countervailing  measures  on  imports  of 
steel, including on product categories covered by the safeguard. The Commission has also acted 
against  increased  circumvention  of  trade  defence  measures,  another  clear  sign  of  the  very 
strong interest that third-country steelmakers show in accessing the EU market.  

The attractiveness in both prices and size makes the EU market a key target destination for 
production  resulting  from  global  overcapacity,  which  in  turn  results  in  increased  import 
penetration into the EU market.  

70 See for example recitals 49-52 of Regulation (EU) 2021/1029, recitals 83-84 of Regulation (EU) 2023/1301 
and recitals 72-74 of Regulation (EU) 2024/1782. 
71 See OECD Steel Outlook, table 5.2, pp. 62-63. 
72 See recital (72) of the Regulation (EU) 2024/1782. 

16 

 
 
 
 
 
 
 
 
 
 
 
 
3.2. 

Import pressure  

Imports into the EU have substantially increased in the last 10 years and earlier, both in absolute 
and  in  relative  terms73.  In  absolute  numbers,  in  2014  imports  already  started  increasing  in 
relevant terms compared to 2013 (+14%) with Chinese imports increasing at a much faster pace 
(+40%). In 2015, imports grew even more, reaching 28.5 million tons, up from 20.5 million 
tons  in  2013,  resulting  mostly  from  a  surge  in  imports  from  China  in  the  context  of  an 
overcapacity outbreak (+115% increase of Chinese imports from 2013).  

The next peak in imports took place in 2018, when imports reached 34,7 million tons. Such 
steep increase since 2013 was one of the reasons for the EU to impose a provisional safeguard 
measure in July 2018, and a definitive measure in February 2019. Since the imposition of the 
steel safeguard, import volumes have fluctuated  between 28.5 million tons and 34.2 million 
tons. 

In relative terms, however, the level of import pressure started to be noticeable as of 2014 and 
it has continued growing, remaining at high levels since. Before Chinese overcapacity effects 
started to be felt on the EU market in 2014, import market share stood at around 12.7%. In 
2014 it already increased by almost two percentage points and in 2015 it climbed up to 19%. 
Since then, it stood at around or slightly above 20% and exceeding 21% in 2024. This consistent 
higher level of import pressure is having a negative impact on the economic performance of 
the EU industry, supressing its efforts. Neither a high number of TDIs in place, nor a safeguard, 
have  deterred  imports  from  entering  the  Union  market  in  growing  volumes  relative  to 
consumption.  

The increased import penetration during the safeguard measure is particularly acute in certain 
product categories, notably in product categories category 1 (hot-rolled flats), 2 (cold rolled 
flats),  category  6  (tin  plate),  category  8  (stainless  hot  rolled),  category  14  (stainless  bars), 
category  22 (seamless  stainless  pipes and tubes)  and category 28 (non-alloy wire). In these 
categories, the market share of imports in 2024 has increased significantly compared to the 
average  import  market  shares  pre-safeguard  (between  2015  and  2017).  These  categories 
represent around 14 million tonnes, or 45 % of total imports in 2024.  

73The specific figures provided in this analysis refer to import volumes of product categories subject to the EU 
steel safeguard measure. 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3. Changes in the market share of imports in certain categories [comparison 2024 
v. 2017] 

Therefore, the overall increase in imports’ market share is even more acute when zooming in 
into some categories across product families.  

The  steel  safeguard  measure  has  also  shown  an  aggressive  export  behaviour  by  certain 
suppliers  in  several  product  categories,  whereby  some  quotas  (either  country-specific  or 
residual)  were  exhausted  on  the  first  day  or  very  early  into  a  given  period.  In  some  cases, 
exceeding the free-of-duty volume available by large amounts. These exporting countries have 
demonstrated during the lifetime of the safeguard their capacity to supply large volumes within 
a short period of time, creating significant disturbances on the market, but also demonstrated 
that they are ready to  increase their presence on  the Union market  further when there is  an 
opening (for example when country-specific quota holders still had additional access to duty-
free volumes in the residual quota during the fourth quarter of safeguard year). 

The example of hot-rolled flat products, ‘HRF’ serves to illustrate this issue. In overall terms, 
it is a very important product category for various reasons.74 It consistently represents, by far, 
the largest share of imports of all products subject to the safeguard (roughly 9 million tonnes 
in 2024) accounting for 30 % of total imports under the measure. HRF can be used as a final 
product in construction or automotive amongst others, but it is also used as input for producing 
further downstream products, notably product category 2 (cold-rolled flats), which then can be 
further processed into, for instance, category 4 (metallic coated sheets) which in turn can be 
processed  into  category  5  (organic  coated  steel).  Because  its  weight  over  the  total  Union 
production  and  its  interrelation  with  several  other  product  categories,  this  category  is  thus 
particularly relevant for the effectiveness of a measure. 

Between January 2023 and April 2024 (during five consecutive quarters), the residual quota75 
had been consistently exhausted, and significantly exceeded. In three quarters this happened 
on  the  first  day  of  the  quarter.76  Several  countries  (Egypt,  Vietnam,  Taiwan,  and  Japan) 

74 Recital (183) of Regulation (EU) 2024/1782, OJ L, 2024/1782, 25.6.2024. 
75 The residual quota in category 1 which is the largest individual TRQ under the safeguard measure with around 
1 million tonnes initially available each quarter. 
76 Recital (186) of Regulation (EU) 2014/1782. 

18 

 
 
 
 
 
 
 
 
 
significantly contributed to it. The Commission effectively took action to limit the effects of 
this behaviour.77 

This very aggressive export behaviour, exerted simultaneously by several exporting countries, 
resulted in very large amounts of this product entering the Union market in a very short period. 
as a result, it undermined the effectiveness of the measure as volumes well above the TRQ level 
entered the EU market, and hence the import stabilisation objective that the safeguard sought 
to achieve was being weakened. 

Therefore,  despite  increasing  trade  defence  measures  and  a  safeguard  measure  in  place, 
significant import pressure on the EU steel market remained, and continued to grow. Due to 
the  attractiveness  of  the  EU  market  and  the  growing  risk  of  trade  diversion,  such  import 
pressure would certainly increase further in the absence of an effective measure. 

3.3.  Evolution of exports from third countries - links to overcapacity and pushing 

out effects  

The  Commission  has  confirmed  in  several  reviews  of  its  steel  safeguard  that,  generally, 
steelmakers that lost market access due to trade measures in third countries were not able to 
compensate for the volumes lost by increasing their domestic sales sufficiently78, as overall 
steel consumption has shown very limited increases79. In addition, as explained in Section 2.1., 
significant net capacity increases continued to be added onto the market year-on-year, creating 
additional pressure by widening the gap between capacity and demand. 

Faced  with  shrinking  export  market  opportunities,  steelmakers  affected  by  trade  measures 
sought to increase their presence in those markets which were either not protected or whose 
level  of  protection  was  comparatively  lower.  To  keep  as  high  production  and  capacity 
utilisation levels as possible they pursued a very aggressive export behaviour, lowering prices 
to capture market share. The EU steel safeguard has confirmed it on several occasions80. 

In the regulation imposing a definitive safeguard measure81, the Commission had established 
the risk of trade diversion of steel into the EU market. Such risk stemmed, at the time, primarily 
from US Section 232 measure. The EU market remains very attractive, both in terms of size 
and prices as shown in Section 3.1. Third country measures, not limited to trade defence, have 
continued expanding in recent years and there is no sign that this trend is going to be reversed, 
rather the contrary82.  

In recent reviews to the steel safeguard, the Commission continued to assess the risk of trade 
diversion  posed  by  the  US  Section  232  measure.  In  the  2024  review,  the  Commission 

77  See  section  7.3  of  Regulation  (EU)  2024/1782,  in  which  a  15  %  limitation  (‘cap’)  was  introduced  to  the 
maximum volume that one single country can export under the residual TRQ on a quarterly basis. 
78 See, inter alia, recitals (31) to (49) in Commission Implementing Regulation (EU) 2024/1782 of 24 June 2024 
amending Implementing Regulation (EU) 2019/159. 
79 With regards to demand evolution, see Table 4.1. of the OECD 2025 Steel Outlook, showing that from 2019 
to 2023 world steel demand had contracted by -0.2%: 
 https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/05/oecd-steel-outlook-
2025_bf2b6109/28b61a5e-en.pdf  
80 See for example recitals 48, 54 and 62 of Commission Implementing Regulation (EU) 2021/1029 and recital 
46 of Commission Implementing Regulation (EU) 2024/1782. 
81 See Commission Implementing Regulation (EU) 2019/159 of 31 January 2019 imposing definitive safeguard 
measures against imports of certain steel products; OJ L 31, 1.2.2019, p.27, recitals 57 to 62 and tables 12-14. 
82 See Section 2.2. 

19 

 
 
 
 
 
 
 
 
concluded that the level of imports into the US market had remained substantially lower than 
in the period prior to the imposition of Section 232, and that the largest steel suppliers to the 
EU  have  generally  not  found  other  markets  that  would  replace  the  volumes  they  formerly 
exported, inter alia, to the US market83. The Commission thus confirmed the existence of a 
serious risk of trade diversion, as additional trade measures in other third countries were being 
progressively adopted84. This risk was a combination of third country measures limiting trade 
and the attractiveness of the EU market85. 

In view of the recent updates tightening the US Section 232, coupled with growing trade actions 
by other third countries, in a context of weak demand, the Commission has concluded that the 
risk of trade diversion into the EU market has substantially increased.  

The increase in trade defence actions as well and the tightening of the safeguard measure is a 
clear indication that the level of growing import pressure was becoming untenable. Figure 5 
below86 illustrates well a phenomenon which has developed in recent years. Countries develop 
extensive  new  capacities,  which  are  often  disconnected  from  the  market  evolution,  notably 
from domestic consumption. In the case at hand, these countries saw a significant increase in 
their installed capacities. When the new capacity is in place, producers need to maximize the 
capacity utilization to ensure the economic viability of the plant. This was done by relying on 
export markets.  

As depicted in the table below, several countries whose capacity had grown (in some cases 
substantially) increased their exports to the EU in large amounts in a rather short period of time, 
despite  a  TRQ  system  being  in  place.  Therefore,  showing  how  countries  with  increased 
capacities installed immediately look for market outlets to absorb the additional capacity, as in 
most cases it cannot be absorbed by domestic consumption. Considering the attractiveness of 
the  EU  market,  the  increasing  closure  of  other  third  country  markets  and  the  growing 
overcapacity, this trend would only exacerbate if the EU did not take further action after the 
lapse of the safeguard measure. 

83 Recital 64 of Regulation (EU) 2024/1782. 
84  See  Commission  Implementing  Regulation  (EU)  2023/1301  of  26  June  2023  amending  Commission 
Implementing  Regulation  (EU)  2019/159  imposing  a  definitive  safeguard  measure on  imports  of  certain  steel 
products; OJ L 161, 27.6.2023, p.44, recitals 18-23, and 88-89. 
85 See for example recitals 49–52 of Regulation (EU) 2021/1029, recitals 83, 84 of Regulation (EU) 2023/1301 
and recitals 63-74 of Regulation (EU) 2024/1782 and recitals 26-28 of Regulation (EU) 2025/612. 
86 Taken from Regulation (EU) 2024/1782. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 5. Imports from Algeria, Egypt, Indonesia, Malaysia and Viet Nam 

A  GFSEC  paper87  also  described  this  phenomenon  by  noting  that  “in  recent  years,  risks  of 
overinvestment have become increasingly apparent in Southeast Asia, parts of the Middle East 
and Africa, where such capacity increases exceed local demand for steel by a very wide margin. 
Ultimately, these trends  may also  contribute to  an increase of  steel  exports  to  international 
markets,  creating  new  trade  disturbances,  trade-action  responses  by  trading  partners,  and 
eventually difficult trade relations between countries. To the extent that the capacity growth in 
these regions is supported by subsidies and other non-market interventions, then they can be 
considered as sources of non-market excess capacity. […] Viet Nam, Indonesia and Malaysia 
have experienced capacity growth rates in excess of 35% to 95%, while steel demand has either 
declined or increased marginally […] and that certain other economies in the Middle East, 
South Asia and Northern Africa are also registering imbalanced growth (e.g., Iran, Pakistan 
and  Algeria).  This  raises  concerns  about  the  non-market  nature  of  this  growth,  including 
inward investments by Chinese SOEs”. 

China’s export evolution and ‘push out’ effects 

The  Commission  has  documented  extensively  the  significant  distortions  that  prevail  in  the 
Chinese domestic steel market, including a variety of NMPPs which grant Chinese steelmakers 
an unfair advantage vis-à-vis other steelmakers, including the EU steel industry.88  

Chinese surge of exports, which peaked in 2015, created a massive disruption in the world’s 
steel market, with a particular negative impact on the EU. In a period of less than two years, 
EU steel imports from China increased by more than 115%, reaching more than 6.5 million 
tons in 201589. As a result, the EU adopted a series of trade defence measures to counter the 
unfair trading  practices  from Chinese steel  imports, which included dumped and subsidised 
exports  as  well  as  several  circumvention  practices,  in  addition  to  transnational  subsidies  to 
producers in third countries. 

87 GFSEC: Steel exports, trade remedy actions and sources of excess capacity, May 2024, paragraphs 12 and 13. 
88 The Commission has established such distortions both in its Distortions Report (of 2017, as updated in 2024) 
as well as in the numerous trade defence investigations involving imports of steel products from China.  
89 Products subject to the scope of the safeguard measure.  

21 

 
 
 
 
 
 
 
 
 
Since 2022, amidst a slowdown in domestic consumption, China has turned again to export 
markets aggressively as its excess production could not be absorbed domestically. While in the 
period 2018-2022 Chinese exports remained stable between 63 to 68 million tons, in 2023 they 
saw a very large increase, reaching 95 million tons. In 2024, however, exports boomed even 
further,  exceeding  118  million  tons90.  This  surge,  nearly  doubling  its  exports  compared  to 
recent years, created again an immense disruption in the global steel sector.  

The negative effects of China’s surge of exports have also been acknowledged by the OECD, 
which noted in its 2025 Steel Outlook that the surge in exports of low-priced steel from China 
has  disrupted  international  markets,  resulting  in  growing  trade  tensions  that  seem  likely  to 
persist in the near term in light of sluggish market growth and increased capacity91. 

Chinese  exports  have  had  major  impact  across  regions.  The  main  importing  countries  are 
located in Asia, but also in Latin America, Middle East and North Africa. Already before the 
Chinese export peak in 2024, the Commission had established that imports from some of the 
origins  where  China  had  increased  substantially  its  export  presence  in  2023  (including 
Vietnam, Indonesia, and Malaysia) as well as other countries usually competing in such Asian 
markets with China (Japan) had surged in the Union market in 2023. Such increases were even 
more acute if compared to the period prior to the imposition of the safeguard measure. Hence, 
the  data  analysed  strongly  suggests  that,  in  an  overall  context  of  weaker  consumption,  this 
strong and increasing import pressure from China in certain third markets pushed producers 
in some countries into finding other export markets for part of their production, amongst which, 
the Union market92. 

This  ‘pushing  out’  or  displacement  effect  was  also  developed  by  a  GFSEC  paper93,  which 
concluded that excess capacity in China could have different effects on the steel exports of other 
countries. On the one hand, as steel imports from China rise to meet local demand, domestic 
steel producers may export the steel that is no longer needed domestically, in order to keep 
production  running  at  desired  levels.  On  the  other  hand,  those  steel  producers  may  also 
compete with Chinese exporters in third markets. China’s excess capacity may crowd out the 
exports of those competing companies, and hence a negative effect might also be expected in 
these cases. 

Considering  the  substantial  further  increase  in  Chinese  exports  in  2024  (almost  +25% 
compared  to  2023)  this  phenomenon  has  exacerbated. The  two  examples  below  illustrate  it 
clearly94:  

First, Chinese exports to Thailand increased by around +40% since 2022, and its exports to 
UAE increased by +180%. In the same period, exports from Vietnam to Thailand decreased 
by around -40% and its exports to the UAE decreased by more than half. At the same time, 
Chinese exports to Vietnam surged (+125%). In turn, Vietnam’s exports to the EU increased 
by almost +70%, becoming the fourth largest steel supplier to the EU in a very short period, 

90 OECD, Half-Yearly Statistical Report, 2025, DSTI/SC (2025)5. 
91 OECD Steel Outlook, p.12. 
92 Commission Implementing Regulation (EU) 2024/1782 of 24 June 2024 amending Implementing Regulation 
(EU) 2019/159, including the prolongation of the safeguard measure on imports of certain steel products; OJ L, 
25.6.2024, recitals (46). 
93 Global Forum on Steel Excess Capacity (GFSEC): Impacts of global excess capacity on the health of GFSEC 
steel industries, March 2024, Section 4.3. 
94 Underlying data for both examples based on Global Trade Atlas (GTA) extraction. 

22 

 
 
 
 
 
 
 
 
while it had supplied much more limited volumes of steel in the preceding years. These trade 
flows took place in a context where Vietnam had substantially increased its installed capacity 
well  above  domestic  demand  evolution,  as  shown  above.  This  example  illustrates  well  the 
knock-on [negative] effects in the form of strong import pressure that global overcapacities and 
the resulting impact on trade flows across regions create.  

Another example relates to Chinese increased exports capturing market share away from other 
traditional  suppliers  in  third  countries.  While  China  increased  its  exports  significantly  in 
markets such as Thailand, South Korea, Indonesia, Taiwan and Türkiye, Japan lost relevant 
export volumes in all these markets. Almost simultaneously, Japan found an alternative market 
for some of the lost exports to these regions by increasing sharply its exports to the EU, which 
had been negligible in the previous years95. Thus, contributing to the increased import pressure 
on the EU market.  

These two non-exhaustive examples illustrate clearly the so-called ‘push-out’ effect which is 
taking  place  amidst  growing  overcapacity,  and  which  is  having  a  negative  impact  on  EU 
producers  and  undermined  to  some  extent  the  effectiveness  of  the  EU’s  steel  safeguard 

95 Japanese steel exports to the EU increased by 105% in 2023 compared to 2021.  

23 

 
 
 
 
 
 
 
 
 
 
 
measure96. Such an effect is not limited to Chinese exports97, but given the size of its exports, 
it serves as the most visible example to illustrate this phenomenon.  

Looking  at  the  most  recent  developments,  data  covering  the  first  half  of  2025  shows  that 
Chinese exports continued an upwards trend and would be on track to exceed the 2024 record 
levels98. This development, was sustained during the second half of the year, will worsen the 
existing situation even further99.  

Furthermore,  there  is  consistent  anecdotal  evidence  indicating  that  Chinese  steelmakers  are 
increasing significantly their exports of semi-finished steel products100. This could be the result 
of the increasing pressure that exports of finished steel goods face because of a larger number 
of trade measures in place. This situation would lead to further pressure from imports of steel 
finished goods incorporating Chinese-originating input. Therefore, it is a relevant development 
to consider by the Commission regarding the effectiveness of its trade measure. 

3.4. 

Impact on the economic performance of the EU steel industry  

Capacity utilisation, production, sales, market share and profitability 

The  high  level  of  import  pressure  due  to  growing  global  overcapacity  and  protectionism 
worldwide is impacting negatively the economic performance of the EU industry, jeopardising 
its competitiveness in the long-term and the effectiveness of its decarbonisation efforts. 

Key economic performance indicators, such as capacity utilisation, production, sales, market 
share  and  profitability,  developed  negatively  in  2024,  from  an  already  deteriorating 
performance in 2023. In 2024 the EU industry was operating at a very low capacity utilization 
rate, 67%101, whereas healthy levels for the steel industry are usually considered to be around 
80%.  

While the EU steel industry saw positive developments in 2021 and 2022 (largely driven by 
high prices and a strong recovery in demand after COVID-19), as from the second half of 2022, 
the Union industry started to show signs of deterioration. Capacity utilisation dropped sharply 
in 2023 and given the economies of scale in steel production102, such low utilisation rates raise 
unit production costs. Combined with downwards price pressure stemming from the growing 
excess  capacity  levels,  it  further  depressed  the  industry’s  profitability,  to  the  point  that  the 
industry became loss-making (-0.4 %)103 in 2024. In the same year, EU production reached a 

96  See  Commission  Implementing  Regulation  (EU)  2024/1782  of  24  June  2024  amending  Implementing 
Regulation  (EU)  2019/159,  including  the  prolongation  of  the  safeguard  measure  on  imports  of  certain  steel 
products, recital (59); OJ L 25.6.2024. 
97 Other steelmaking countries which added substantial capacity compared to domestic demand evolution, and 
turned to increasing their exports, have also contributed to this effect across regions.  
98  https://www.reuters.com/markets/commodities/china-steel-exports-rise-july-despite-protectionist-backlash-
2025-08-07/ ; https://gmk.center/en/news/china-increased-steel-exports-by-9-2-y-y-in-1h2025/  
99  https://www.reuters.com/world/china/china-steel-exports-poised-record-high-risking-further-tariff-backlash-
2025-09-16/  
100 See reporting on the issue from different sources: https://www.seaisi.org/details/26920?type=news-rooms ; 
https://www.spglobal.com/commodity-insights/en/news-research/latest-news/metals/022525-chinas-steel-
https://www.reuters.com/world/china/chinese-
exports-face-rising-trade-barriers-as-antidumping-cases-surge; 
steel-companies-find-new-tariff-workaround-steel-billet-2025-07-17/ 
https://gmk.center/en/news/china-
quadrupled-its-exports-of-semi-finished-steel-products-in-january-may/;  https://www.steelradar.com/en/chinas-
semi-finished-steel-trade-undergoes-transformation-in-2024/.  
101 See Table 1 of Regulation (EU) 2025/612. 
102 See OECD Steel Outlook, p. 30. 
103 See Table 3 of Regulation (EU) 2025/612. 

; 

24 

 
 
 
 
 
 
 
 
record low. As explained in Section 3.1, import penetration continued at high levels, and even 
managed to gain some market share at the expense of EU producers, whose market share went 
down by 10 % between 2023 and 2024104. 

Along the same lines, a GFSEC study105 concluded that non-market excess capacity is causing 
significant harm on the profitability and even the viability of GFSEC steel industries. So long 
as the root causes of this excess capacity are not addressed (market-distorting subsidies, other 
government  interventions,  and  weak  market-based  conditions),  GFSEC  steel  industries  will 
suffer  from  lower  profitability  than  would  otherwise  be  the  case.  This  will  lead  to  fewer 
resources to invest in R&D and sustainability for a healthier future. 

Considering the steel market outlook for 2025 both in the EU and globally, as well as the trends 
in  overcapacity  and  third  country  measures,  it  is  not  expected  that  the  EU  steel  industry’s 
economic  performance  would substantially improve, if at  all, in  the absence of an effective 
measure. This would seriously compromise the industry’s ability to invest in decarbonisation 
and put at risk the long-term sustainability and competitiveness of a key industry for the EU. 

Employment and social dimension 

The SMAP acknowledged that the steel sector, as well as other metals,  is vital for the EU’s 
economic  security  and  social  stability.  It  also  recognized  that  Europe  has  a  longstanding 
tradition of steel production, with steelworkers playing a key role in the foundation of European 
manufacturing. Upholding these high-skill quality jobs that provide decent pay, strong labour 
protections,  and  high  health  and  safety  standards  is  essential  to  sustaining  the  sector’s 
competitiveness and high social value.  

However, as noted in Section 1, the EU steel industry has seen a consistent decimation of its 
workforce over the last years. According to the EU steel industry figures, about 30 000 direct 
jobs have been lost since 2018 alone106. This negative trend continues. In fact, last year the EU 
steel industry has seen announcements of significant number of layoffs and capacity reductions 
across the EU, including in the largest producers such as ThyssenKrupp (up to 11,000 jobs at 
stake)  and Arcelor  Mittal  (600  jobs  lost  in  Dunkirk,  France).  The  situation  is  deteriorating 
further quickly across Member States and steel plants, including Ilva (Italy)107, Liberty Steel 
(Romania, Luxembourg and Belgium)108, Dunaferr (Hungary), to name a few109. The negative 
effects on employment are thus not limited to one specific country or geographical area with 
the Union, they have an EU-wide impact. 

A GFSEC study110 elaborated in detail on the direct link between global overcapacity and the 
impact on employment. The study concluded that total employment in GFSEC steel industries 
could have been 1.2% higher annually between 2012 and 2021 in the absence of weak market 

104 See Table 2 of Regulation (EU) 2025/612. 
105 Global Forum on Steel Excess Capacity (GFSEC): Impacts of global excess capacity on the health of GFSEC 
steel industries, March 2024.  
106 https://www.eurofer.eu/publications/brochures-booklets-and-factsheets/steel-flooded  
107  https://www.reuters.com/markets/commodities/italy-begin-exclusive-talks-with-azeri-consortium-over-sale-
ilva-steelworks-2025-03-20/  
108 https://gmk.center/en/news/liberty-steel-prepares-for-final-exit-from-belgium-and-luxembourg/  
109  Other  examples  can  be  found  in  the  following  links:  https://news.industriall-europe.eu/Article/1169  ; 
https://www.industriall-union.org/liberty-steel-crisis-worsens  
110  Global  Forum  on  Steel  Excess  Capacity  (GFSEC):  Global  excess  capacity  and  employment  in  steel  and 
downstream 
https://www.steelforum.org/content/dam/steel-
2025: 
forum/en/publications/GFSEC-Employment_and-excess-capacity_31_jan_2025-(002)_250305_1015.pdf  

activities, 

March 

25 

 
 
 
 
 
 
 
 
conditions  that  resulted  from  global  steel  excess  capacity.  By  2021,  this  translates  to  an 
estimated 113,000 additional jobs, or 10% more than the actual 2021 employment levels, would 
have been possible absent the impacts of global excess capacity. 

4.  Existing protection expiring - steel safeguard measure 

Background  

Safeguard  measures  are  intended  to  provide  temporary  relief  from  imports  to  allow  the 
domestic industry to adapt to new market conditions and regain competitiveness. Because it is 
meant as a temporary relief measure, the maximum possible duration of a safeguard measure 
is eight years and is supposed to progressively allow more import competition into the market 
while the domestic industry is adjusting.111 A safeguard may not be applied again to a product 
until a period equal to the duration of the original safeguard measure has elapsed.112   

In July 2018, the Commission introduced a provisional safeguard measure on imports of certain 
steel products due to a significant increase in imports into the Union (by 71% over the previous 
five years).113 Additionally, in  March 2018 the United States implemented import measures 
under Section 232 of the Trade Expansion Act of 1962114, creating a high risk of further import 
increases caused by trade diversion. These factors, combined with global overcapacity, unfair 
trade  practices  and  numerous  trade  defence  measures  on  steel  products  worldwide,  posed  a 
serious threat to the EU steel industry. The measure became definitive on 1 February 2019115 
and was originally set to be in place for a period of three years.  

The safeguard measure was extended twice, following the prolongation review investigations 
in 2021 and 2024 respectively. The Commission has revised the functioning of the measure 
regularly and has adjusted the measure in line with market developments116. The measure will 
expire  on  30  June  2026,  when  its  duration  will  have  reached  the  maximum  of  eight  years 
allowed under EU law and WTO rules.  

The current safeguard measure 

The safeguard measure covers 26 steel product categories including sheets, bars, plates, tubes, 
wire,  stainless  steel,  and  takes  the  form  of  Tariff-Rate-Quotas  (‘TRQs’).  For  each  product 
category, there are quotas in place allowing a certain level of imports free-of-duty into the EU 
market. A 25% duty applies when imports exceed the quota in a certain category.  

The safeguard contains two kinds of quotas: country-specific quotas (assigned to the trading 
partners whose share in the total imports in a certain category in the 2015-2017 reference period 
was at least 5 %) and residual quotas (consisting of the traditional import volumes of all the 
smaller trading partners combined). In a few categories, the TRQ administered globally, i.e. 
with no specific country allocation due to different Union interest considerations. The TRQs 

https://www.federalregister.gov/documents/2018/03/15/2018-05478/adjusting-imports-of-steel-into-the-

111 Article 7(3) and (4) WTO Agreement on Safeguards 
112 Article 7(5) WTO Agreement on Safeguards 
113 See recital (33) of the Definitive Regulation (EU) 2019/159. 
114 
united-states 
115 Commission Implementing Regulation (EU) 2019/159, OJ L 31, 1.2.2019, p.27. 
116 In addition to regular reviews of the measure, the Commission also adjusted the measure to reflect Brexit and 
the sanctions on Russia and Belarus. 

26 

 
 
 
 
 
 
 
 
are  administrated  on  a  quarterly  basis  and  in  certain  categories,  unused  volumes  can  be 
transferred to the next quarter within the same year. 

The safeguard measure is erga omnes117, although WTO developing country members below a 
certain threshold of import shares are excluded.118 The Commission has regularly updated the 
list of developing countries subject to and excluded from the measure to ensure that it reflected 
the situation in the market as accurately as possible.  

Market developments and adjustments 

In June 2021, the Commission prolonged the safeguard measure for three additional years. The 
Commission assessed the situation and established that the structural challenges faced by the 
EU industry remained in place and were unlikely to improve or disappear in the short-term.119 
Such  challenges  included  persistent  import  pressure,  high  levels  of  overcapacity  and  its 
negative trade-related effects and a risk of trade diversion stemming from third country trade 
measures.  This  was  the  case  despite  a  situation  of  exceptionally  high  prices  and  tensions 
regarding delivery times, which were deemed to be of a temporary nature in a post-COVID 
market situation and not driven by the measure itself. This assessment was confirmed by the 
evolution  of  the  market  in  the  subsequent  months,  as  prices  went  down  considerably,  and 
delivery times adjusted120.  

However, demand significantly deteriorated from the second half of 2022 onwards reaching 
nearly historic low levels in 2023 and 2024. As a result of liberalisation, TRQs continued to 
increase in a shrinking market121. In this regard, since the imposition of the definitive safeguard 
measure,  the TRQs  have  been  gradually  increased  year-on-year  because  of  the  requirement 
under WTO rules and EU law to progressively liberalise the measure. The safeguard measure 
was  imposed  based  on  a  threat  of  serious  injury  and  in  a  context  of  rather  positive  market 
outlook. The TRQ volumes established during the first years of the measure still represented 
an overall free-of-duty volume below the peak imports prior to the imposition of the safeguard 
measure,  which  had  not  caused  injury  to  the  EU  steel  industry.  However,  the  consumption 
trend, in particular during 2023 and 2024, has followed an opposite trend. 

In  a  series  of  review  investigations,  the  Commission  has  adjusted  the  functioning  of  the 
measure,  including  the  liberalisation  pace,  which  now  stands  at  0,1  %,  to  improve  its 
effectiveness122 in line with market developments within the limits allowed by the safeguard 
instrument.  

5.  Steel measure - description of options analysed 

In the SMAP, the Commission committed to  proposing a trade measure replacing the steel 
safeguards as of 1 July 2026, providing a highly effective level of protection against negative 

117 Only members of the European Economic Area have  been unconditionally excluded from its application. 
Since 2022, also Ukraine is exempted. 
118 A WTO developing country member whose import share remains below 3 % of the total imports in a given 
product category needs to be excluded according to EU law and WTO rules, unless the share of imports of all 
WTO developing country Members below the 3 % threshold account for more than 9 % of total imports in a given 
category. 
119 See section 3.1.3 of Regulation (EU) 2021/1029. 
120 Recital 64 of Regulation (EU) 2022/978. 
121 As confirmed in recitals 86-89 of Regulation (EU) 2025/612.  
122 Recital 91 of Regulation (EU) 2025/612. 

27 

 
 
 
 
 
 
 
 
trade-related  effects  caused  by  global  overcapacities.  In  devising  such  measure,  the 
Commission  has  assessed  different  options,  as  outlined  in  the  targeted  consultation 
launched on 18 July 2025. The responses to the different options are presented in Section 6. 
The economic impact analysis of each option is presented in Section 7.  

The Commission sought feedback concerning the form of the measure, of either an upfront 
tariff, i.e. payable on the first tonne imported, or a TRQ system. The form is the first essential 
feature  of  a  trade  measure. The  current  steel  safeguard  takes  the  form  of  a TRQ,  but  other 
measures in third countries take different forms, e.g. some countries impose tariffs, like the US 
under  its  Section  232  measure  (50%),  as  well  as  other  countries  because  of  their  increased 
applied tariffs or under safeguard measures. Other countries, like Canada and the UK have a 
system of TRQs.  

Concerning the level of the measure, if it took the form of a duty, for those preferring an upfront 
duty the Commission sought views on their specific level, providing different duty ranges of 
ten percentage points intervals, with a range of 0%-10% being the lowest, and above 50% being 
the highest.  

In  the  questions  related  to  TRQs,  the  consultation  provided  different  levels:  i)  the  level 
currently  available  under  the  steel  safeguard  measure,  ii)  a  level  that  would  set  TRQs  to 
volumes  comparable  to  the  level  of  import  penetration  in  the  period  2013-2014  (pre-2015 
overcapacity breakout), and iii) a level of TRQs that would reduce imports by around half, iv) 
while  a  last  option  sought  views  on  potential  differentiation  of  TRQ  levels  depending  on 
product family. 

Another key question concerned geographical scope. The current steel safeguard measure is 
an erga omnes measure, with certain caveats (under EU and WTO rules, developing countries 
are temporarily exempted if they are below certain threshold of imports)123. The Commission 
sought specific views on this key question because steel is a product supplied into the EU from 
numerous countries across all world regions. Another important aspect linked to geographical 
scope has to do with overcapacity, a phenomenon of global nature which has expanded and 
continues to expand across third countries.  

The consultation also sought views on specific features of a TRQ system, notably the level of 
out-of-quota duty.  

In case of a TRQ system the consultation presented different options regarding key features. 
First, the appropriate level of out-of-quota duty that would kick in when a quota is exhausted. 
The Commission outlined two concrete options (25% or 50%). 25% is the current out-of-quota 
duty  level  under  the  safeguard  measure,  while  50%  is  the  level  of  upfront  duty  of  the  US 
Section 232 measure and the level of out-of-quota tariffs imposed by Canada (also 50%) as 
well as the upfront tariffs it imposed on Chinese-origin imports. Considering the role that the 
US Section 232 measure played in the analysis of risk of trade diversion of the current steel 
safeguard, and in view of its tightening in 2025, the Commission considered it relevant to have 
concrete views on these two options. 

The consultation  inquired about  the preferred TRQ allocation method, i.e. the feature that 
defines how much a country is allowed to export free-of-duty in a certain category. The steel 

123 In addition, EEA countries have been excluded from the measure since its imposition, and Ukraine since 
March 2022. 

28 

 
 
 
 
 
 
 
 
safeguard  measure  has  a  system,  for  most  product  categories,  of  country-specific  TRQs 
allocated to the main historical suppliers and a residual quota for the rest. Thus, it was one of 
the options presented. The Commission also sought views on other possibilities which certain 
stakeholders had been advocating for, such as global TRQs with a maximum level of imports 
that any country can reach (a cap), like it is the case in several residual or global quotas under 
the current steel safeguard, and a global TRQs with no kind of cap (as it was the case under the 
provisional stage of the steel safeguard measure).  

The TRQ volumes are usually calculated on an annual basis. However, it is important to define 
how  the  TRQ  will  be  administered,  i.e.  how  often  the  volumes  will  be  made  available. A 
system where the yearly volumes are split proportionally into four and made available at the 
beginning of each of the four quarters comprising a year is the status quo under the safeguard 
(quarterly  administration).  However,  other  options  were  presented,  such  as  annual 
administration  (like  it  was  the  case  at  the  beginning  of  the  steel  safeguard)  or  monthly 
administration.  

Unless TRQs are administered annually, the question of how to treat unused quota volumes 
from one period to another becomes relevant, i.e. carryover mechanism. In essence, in case 
of quarterly or monthly allocation, the Commission presented the option of allowing (in full or 
partially) or not, the carryover of unused quotas from period to period (quarter/month) within 
a  year.  Under  the  current  safeguard  the  system  allows  carryover  only  in  certain  categories, 
while it does not allow it in others.  

In addition, the Commission also asked stakeholders’ views on the possibility of introducing a 
‘melted & poured’ regime, which would have an impact on the application of rules of origin 
for steel imports under the measure but would ensure transparency, and it is being implemented 
by other countries such as the USA and Canada.  

Lastly, the Commission asked for views concerning the  duration of the measure proposing 
different  scenarios  to  ascertain  whether  stakeholders  favour  an  initially  longer  or  shorter 
measure. In addition, the Commission inquired about the possibility and desirability of having 
a review mechanism in place that would allow for adjustments to the measure in case of market 
developments.  

The Commission gave stakeholders the possibility to elaborate on each of their choices as well 
as to develop views more broadly in a narrative section of the questionnaire.  

6.  Targeted consultation and call for evidence 

As  part  of  the  process  for  a  legislative  proposal  of  a  highly  effective  trade  measure,  the 
Commission  launched  a  targeted  consultation124.  Its  objective  was  to  gather  views  from 
sectoral  stakeholders  with  a  view  to  finding  an  effective  replacement  for  the  current  EU 
safeguard on steel, due to expire on 30 June 2026. The consultation ran until 18 August 2025 
and  stakeholders  had  the  opportunity  to  express  their  views  on  several  potential  scenarios 
prepared by the Commission. Through this consultation, the Commission aimed to gather input 

124https://policy.trade.ec.europa.eu/news/commission-launches-consultation-future-measures-safeguard-eu-
steel-sector-unfair-trade-practices-2025-07-18_en  

29 

 
 
 
 
 
 
 
 
from across the steel value chain. In parallel to the targeted consultation, the Commission also 
published a Call for Evidence.125 

6.1. 

Summary of the responses to the targeted consultation 

The targeted consultation and call for evidence triggered a strong interest from stakeholders, 
receiving 516 individual responses (373 replies to questionnaire + 143 submissions to Call 
for Evidence). 

Geographical data 

Most respondents (86%) were based in the EU, with Germany, France, Italy, and Spain (the 
EU’s  four  largest  steelmaking  Member  States)  representing  50%  of  total  responses. 
Conversely, the largest third country suppliers, save for Korea (15) and to a lesser extent 
Ukraine (5), accounted for very few responses, e.g. China (1), Türkiye (2), Japan (2), Vietnam 
(2), India (2), Taiwan (1) and in  most  cases  their respective governments did  not provide a 
response.  

Role of respondents 

Respondents labelled their core activity as ‘producers’ (127), ‘users’ (142), and ‘other’ (101), 
while  3  did  not  choose  any  role.  Of  note,  some  of  the  users  are  companies  related  to  EU 
producers, and a few respondents (8) labelling themselves as ‘users’ are non-EU based (thus, 
not EU users). Likewise, under ‘other’ category, there are a few (5) third country governments 
and  (2)  EU  Member  States,  in  addition  to  large user  associations,  as  well  as  some  relevant 
national steel producers’ associations. 

125  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14781-Trade-measure-addressing-
the-negative-trade-related-effects-of-global-excess-capacity-on-the-EU-steel-sector_en  

30 

 
 
 
 
 
 
 
 
 
 
6.1.1.  Necessity for a measure 

Most respondents (75.1%) supported the introduction of a measure. The support stemmed from 
many kinds of stakeholders, well beyond steel producers, and included large EU  processors 
and  users’  associations.  Also,  most  respondents  labelled  as  ‘users’  (and  based  in  the  EU) 
support  the  adoption  of  a  measure.  Furthermore,  multiple  associations  in  other  sectors126 
strongly supported the need for an effective measure, highlighting the importance of the steel 
sector. Only 69 respondents expressed opposition to a measure (18.5% of responses), while 
6.5% of respondents either did not reply or did not express a view. 

Amongst  those  opposing,  mostly  individual  EU  users  (including  20  SMEs),  EU-based 
subsidiaries of third country steelmakers or with business links with foreign steelmakers and 
some third country governments and their steelmakers’ associations. 

126 EU associations in the following sectors expressed support for a measure: foundry, mining, aluminium, certain 
chemicals, lime, amongst others.  

31 

 
 
 
 
 
 
 
 
 
 
Some  individual  EU  users  have  also  acknowledged  the  necessity  of  the  measure,  and  even 
some  subsidiaries  of  third  country  steelmakers  have  recognized  that  in  the  absence  of  a 
measure, the EU market would be flooded. 

Overall, the consultation reflected ample recognition of the need for a measure in view of the 
risks and challenges faced by EU steelmakers as well as their relevance in preserving a strong 
supply chain in the EU.  

6.1.2.  Geographical scope 

A large majority of respondents advocated for an erga omnes application, with no exclusions 
of any third country, arguing that this approach was essential to ensure effectiveness of the 
measure given the global nature and widespread effects of overcapacity. 

Some stakeholders suggested to apply the measure in a discriminatory fashion against those 
countries that would be contributors to overcapacity, however without providing any concrete 
or substantiated claim as to who these countries would be and how far the discrimination should 
go.  

There were also requests from  some stakeholders to  exclude Ukraine due to  the war, and a 
handful requests from stakeholders to exclude some third countries arguing that they are trusted 
partners which do not contribute to overcapacity. 

6.1.3.  Form of the measure 

84%  of  respondents  that  chose  a  form  of  measure  (188  out  of  223),  supported  TRQs  over 
upfront tariffs. Amongst the 150 respondents who did not select an answer, 69 had previously 
indicated opposition to a measure. 56 respondents supported the need of a measure but chose 
not to express a view on its form.  

32 

 
 
 
 
 
 
 
 
 
In connection to the form of the measure, 90% of respondents did not choose any option under 
the question pertaining to the right level in case of upfront tariffs. 

6.1.4.  TRQ level 

Most respondents (187) did not choose any specific TRQ level, including the 69 stakeholders 
that had previously indicated opposition to a measure. 134 respondents supported the option of 
a TRQ of around16-18 million tons. To be noted however that several respondents who chose 
the option of differentiated TRQs, were in fact supporting the strictest option of 16-18 million 
tons TRQ. Very few (12) supported either the status quo (around 34 million tons). Lastly, few 
respondents (10) selected the option of around 21-23 million tons. Amongst those that did not 
choose any option, 94 stakeholders had indicated that they supported the need for a measure, 
but did not take position on the level, while 24 responded ‘don’t know’ or did not respond. 

33 

 
 
 
 
 
 
 
 
 
 
127 

Amongst  those  supporting  a  volume  of  TRQs  of  around  16-18  million  tons.  The  main 
arguments in favour included the need to significantly increase producers’ capacity utilization 
to healthy levels, which was not possible with the current level of import penetration allowed 
under the steel safeguard TRQs. Such level of TRQs would reflect the level of imports that 
prevailed before the 2015 overcapacity crisis broke out, which resulted in a surge of imports 
and consistent higher level of import penetration since then. Therefore, restoring a situation 
regarding the level of imports would allow for  tackling  overcapacity’s  negative effects that 
have been present in the market since 2015 notably.  

Many respondents supporting this option however emphasized that the  reference period to 
calculate TRQs should be different for each product family (carbon flats, carbon longs and 
stainless).  As  such,  the  level  of  import  penetration  under  a  TRQ  in  each  of  these  market 
segments would be different (15% for carbon flats and stainless, and 5% for carbon longs). 
Furthermore,  supporters  of  this  option  emphasized  that  such  level  of  a  measure  would 
strengthen domestic production, prevent de-industrialization, ensuring investments needed to 
decarbonize, increasing strategic autonomy (including military capabilities), while protecting 
and preserving thousands of industrial jobs, and overall, ensuring that the measure is  highly 
effective, as set out by SMAP. 

Amongst those advocating for a higher level  of TRQs the main arguments  suggested that a 
strict TRQ system would impact negatively the cost competitiveness of downstream sector. 

127 Option 1 - level of Tariff-Rate Quotas (TRQs) maintaining the volumes as set out in the safeguard currently in 
place; [around 33-35 million tons of TRQ volume]; Option 2 - level of TRQ volumes reflecting the imports’ market 
share of the period before 2015 (average 2013-2014) [around 21-23 million tons of TRQ volume]; Option 3 - 
level of TRQ volumes around half the size of 2024 import levels. [around 16-17 million tons of TRQ volume]; 
Option 4 - Level of TRQ volumes differentiated per product (flat, stainless, long, tubes and pipes). 

34 

 
 
 
 
 
 
 
 
 
 
 
6.1.5.  Out-of-quota duty level 

215 respondents (57.6%) favored an out-of-quota duty set at 50% while 72 (19.3%) supported 
a 25% duty. 64 (17.2%) selected a different level of duty and 22 (5.9%) did not reply.  

Amongst the reasons behind 50% out-of-quota duty many respondents made a direct link with 
the US Section 232, which currently impose a 50% (upfront) duty. Arguments included that 
having a lower level of out-of-quota duty, compared to the one prevailing in the US market, 
would undermine the effectiveness of a TRQ system, as a lower duty (e.g. 25%) would create 
significant risk of trade diversion, in a context of growing third country measures and high 
levels of overcapacity.  

In  addition,  stakeholders  presented  several  arguments  in  support  of  different  duty  levels, 
including a 25% duty. Some highlighted that having high duties would severely damage the 
competitiveness of downstream industries, risking de-localization into third countries. Others 
proposed to set a differentiated duty level by exporting country and product types. This would 
be linked for instance to the level of overcapacity in a country, the strategic importance of a 
product, the risk of import surges. Others proposed to have higher duties for certain countries. 
Conversely,  others  proposed  no  (or  low)  duties  in  certain  products  for  which  no  sufficient 
production may exist in the EU, for low-CO2 steel products, to promote sustainability and avoid 
supply gaps. Others pointed to a flexible level of duties that would adapt to industry’s capacity 
utilization levels per category to avoid supply gaps, and others supported adjustments to the 
level based on market conditions, level of imports and geopolitical changes.  

6.1.6.  TRQ Allocation 

Most respondents (211) supported a global TRQ with a cap, while many (117) also supported 
keeping a system of country-specific quotas and residual quotas, like the safeguard.  

35 

 
 
 
 
 
 
 
 
Regarding country-specific quotas, generally not very detailed information was provided by 
respondents on a preferred methodology to allocate volumes, e.g. minimum threshold to define 
who would receive a country-specific quotas (in the safeguard the threshold was 5%). Some 
respondents referred to an allocation period based on recent performance as the  appropriate 
basis. 

The responses to this question revealed that a vast majority of stakeholders did not favour an 
option of having a global TRQ per category, administered on a first-come, first-served, without 
any kind of limitation by origin. Therefore, the responses showed that most stakeholders (88%) 
support a TRQ system whereby there is a certain kind of limitation to the share of a specific 
TRQ that a single country can use, either via a country-specific quota or via a cap.  

6.1.7.  TRQ Administration  

Quarterly administration was widely supported, noting that this feature currently in place 
under the steel safeguard measure ensures a balance between limiting a flood of imports in a 
short  timeframe  while  not  creating  a  disproportionate  burden  for  trading,  as  opposed  what 
monthly administration could have caused. Annual or monthly administration gathered limited 
support respectively. 

36 

 
 
 
 
 
 
 
 
In  support  of  the  quarterly  administration,  stakeholders  noted  that  it  strikes  a  good  balance 
between avoiding surges of imports in a short period of time (which would be a risk associated 
to  yearly  administration)  while  not  unduly  disrupting  trade  flows  and  creating  additional 
administrative burdens (which may take place under a monthly administration). Stakeholders 
also  noted  that  quarterly  administration  has  been  in  place  for  many  years  under  the  steel 
safeguard so market operators are used to its functioning, and it would be easier for them to 
continue operating under such regime.  

Some  calls  for  annual  administration  (mostly  EU  users)  sought  to  have  less  constraints  to 
source steel throughout a year, allowing for easier planning and reducing the risks of paying a 
duty due to unforeseen transportation or production delays from third country suppliers, while 
reducing the administrative burden.   

On the other hand, those stakeholders calling for monthly administration argued that it would 
reduce more effectively the damage that larger import volumes may cause, as imports will be 
more spaced out, offering some users a higher level of predictability. Stakeholders also pointed 
that this kind of administration would increase the opportunities for suppliers to export free-
of-duty (at least once every month) while under a quarterly administration, they would only 
have  four  chances  a  year,  i.e.  one  at  the  beginning  of  each  quarter.  In  the  same  line,  some 
argued that this would avoid having to wait almost three months to source free-of-duty material 
if the quota gets quickly exhausted early into a quarter. Lastly, some stakeholders flagged that 
it would reduce the amount of steel stockpiled in warehouses at EU ports. 

On whether carryover of unused quotas should be allowed or not, or limited, stakeholders’ 
views supported not allowing for such mechanism (53%). Many stakeholders (105), primarily 
producers, considered that it was important not to allow this feature altogether, and that the 
latest  adjustment  to  the  steel  safeguard  measure  already  went  in  that  direction.  Those 
stakeholders opposing (more than half, 62, ‘users’) indicated that this would artificially reduce 
the availability of TRQs, by not catering for seasonality in consumption and that unused quotas 
should be allowed to be consumed throughout a whole year, as it was the case during most of 
the lifespan of the steel safeguard measure.  

37 

 
 
 
 
 
 
 
 
6.1.8.  Duration 

More  than  210  respondents  (57%),  mostly  EU  producers,  supported  either  a  permanent 
measure (189) or a measure longer than 5 years (26), while 117 respondents, including most of 
those who oppose a measure, supported a measure for an initial period of 3 years. All options 
on duration included a review for possible extension [see ‘review’ section below]. 

The main arguments given for implementing a  permanent measure, or a measure longer 
than  5  years,  are  to  address  the  growing  and  structural  global  steel  overcapacity,  which 
requires long-term policies; to support the European steel industry’s decarbonization efforts by 
providing regulatory and investment stability that encourages new investments; and to protect 
and  maintain  the  competitiveness  of  EU  steel  producers  amid  global  challenges.  Mainly 
producers,  as  well  as  other  associations,  including  several  processors,  support  an  initial 
duration  of  more  than  5  years,  on  grounds  that  it  provides  increased  legal  and  commercial 
certainty to stakeholders, including to make long-term decarbonisation investments. 

The main arguments given for a three-year measure are that, while protecting the EU steel 
industry,  the  Commission  must  also  consider  the  competitiveness  of  downstream  sectors. 
Additionally, a three-year balances protection without causing unnecessary rigidity, and avoids 
reducing incentives for the industry to adjust to market shifts. This finite timeframe helps keep 

38 

 
 
 
 
 
 
 
 
 
trade fair and open while minimizing disruption. Around half of the users (70) support a 3-year 
measure.  

The questionnaire also contained the option of a five-year period, argued by 27 respondents 
to be a balanced choice since shorter periods might be too brief, while longer ones could lead 
to lasting market distortions. This timeframe allows sufficient opportunity to assess the impact 
of the measures, with the option to extend if necessary to meet long-term strategic goals and 
adapt to changing market conditions. Some respondents argue that they do not have a strong 
preference between three or five years but insist that reviews should occur no less frequently 
than every five years. 

6.1.9.  Review mechanism 

There is a broad consensus (306 stakeholders in favour) that a review mechanism needs to be 
a  core  element  of  the  measure.  Some  participants  (mostly  producers)  wanted  to  ensure  the 
possibility that the measure be adapted to market downturns (unlike the safeguard) while others 
wanted  to  make  sure  that  TRQs  can  be  increased  if  market  improvements  or  shortages  are 
identified (mostly users). Overall, the call for a strong and fair review mechanism that can 
be deployed swiftly in line with market developments, was echoed across the board.  

6.1.10. Entry into force 

The  steel  safeguard  expires  after  30  June  2026,  and  108  respondents  preferred  the  trade 
measure to enter into force on 1 July 2026. However, most respondents (203 responses, mostly 
EU steel producers) indicated that the measure should already enter into force on Q1 2026. 

39 

 
 
 
 
 
 
 
 
Regarding this aspect, the entry into force of the measure will fundamentally depend on the 
pace of the ordinary legislative procedure that will be triggered once the Commission adopts 
the legislative proposal.  

6.1.11. Melted and Poured 

Most responses (77,5%) are in favour of a Melted and Poured regime. This included 118 
producers and 169 users and ‘others’, including some users and traders’ associations, as well 
as some third country suppliers and some EU users.  

Supporters of introducing such regime argued it would be expected to close loopholes (i.e. limit 
risk of circumvention), which would otherwise exist and be exploited by minimal processing 
to disguise the true origin of steel. Introducing a melted & poured regime, they argued, would 
enhance supply chain integrity and supporting fair competition. 

Those that do not support introducing such regime expressed concerns that it might increase 
the administrative burden, and could disrupt supply chains, while disproportionately impacting 
processors dependent on semi-finished inputs from multiple origins. Amongst those opposing, 
mostly individual EU users, including EU users and processors associations.  

6.1.12. Narrative section – free-format submissions 

EU steel producers stressed that if no measures are adopted, in the short term, the EU steel 
industry  is  expected  to  face  worsening  trends,  including  a  decline  in  investment, 

40 

 
 
 
 
 
 
 
 
 
competitiveness,  and production. Medium-term  effects  could  involve plant closures and job 
losses. Over the long term, there may be an increased reliance on imports, posing significant 
risks during periods of geopolitical uncertainty. Additionally, these challenges could result in 
reduced investments in new technologies, undermining efforts towards decarbonization. 

Other stakeholders acknowledged the problems posed by overcapacity and the potential of 
these measures to support the long-term competitiveness of the steel industry. However, some 
users raised concerns that strict quotas could disrupt trade flows, significantly increase costs, 
and impede the competitiveness of EU businesses in the EU and in third-country markets.  

Overall,  there  is  a  strong  call  for  an  effective  trade  measure,  that  would  allow  the  EU 
steelmakers to improve its capacity utilisation and their overall economic performance so that 
they  can  undertake  decarbonisation  investments.  There  are  nevertheless  requests  from 
stakeholders to consider in the design of the measure the competitiveness of the downstream 
industries, in particular, warning against the most radical requests from steelmakers. 

Lastly, few stakeholders (11), have made broader calls for extending protection to other steel-
made  or  steel-intensive  products  further  down  the  steel  supply  chain,  referred  by  several 
stakeholders as ‘steel derivatives. 

6.2. 

Summary of submissions to the Call for Evidence 

143  stakeholders  made  submissions  in  response  to  the  Call  for  Evidence.  In  some  cases, 
stakeholders responding to the Call for Evidence had also replied to the targeted consultation. 
The Call for Evidence allowed submissions in a free-format text; therefore, the responses did 
not necessarily follow a comparable structure that would allow for the same degree of statistical 
assessment as the replies to the targeted consultation. Below a summary of the most common 
views presented: 

Many respondents showed support for a measure, with most advocating for a TRQ-system 
applicable  to  all  origins. Amongst  the  reasons,  many  echoed  the  arguments  received  by 
producers  in  the  targeted  consultation,  seeking  to  preserve  a  strong  domestic  steelmaking 
industry in the EU, noting that the current  steel safeguard measure would be insufficient to 
achieve the SMAP objectives. Several stakeholders called for extending protection to the entire 
steel  value  chain  and  some  proposed  specific  CN  codes  to  be  added  to  the  scope  of  the 
measure. Also, a noticeable number of submissions focused on the importance of designing a 
measure  that  would  avoid  circumvention  through  loopholes,  with  strict  rules  of  origin, 
including melted & poured regime. Some respondents also flagged that the challenges faced 
by the EU steel industry are not unique and that other sectors should be protected, including a 
mention to an across the board overcapacity instrument.  

On  the  other  end,  some  respondents  called  for  a  balanced  measure  which  does  not 
disproportionally  limit  the  availability  of  steel  supply  in  the  EU,  with  some  (non-EU 
stakeholders  mostly)  recalling  that  WTO  obligations  need  to  be  observed.  Several 
stakeholders made country-specific requests to either exclude or grant better treatment under 
the measure to suppliers in some third countries. 

41 

 
 
 
 
 
 
 
 
 
7.  Economic model of the impact of the measures 

As  a  critical  part  of  the  analysis,  the  Commission  carried  out  an  analysis  of  the  potential 
economic impact of the different options, including TRQs set at different levels and across the 
board tariffs. The economic model took into account the impact of the different options on the 
following  elements  which  were  assessed  for  both  the  iron  and  steel  industry,  other  key  EU 
industries: output, prices, export performance and imports (by sector). 

The  potential  impact  of  a  measure  on  the  EU  economy  was  assessed  based  on  economic 
modelling for several scenarios. It considers the impact of different levels of in-quota volumes 
compared to the evolution of the “baseline” that reflect the import pressure and energy –price 
dynamics currently in place in the steel sector (including overcapacities).  

7.1.  Modelling methodology 

7.1.1.  Computable  General  Equilibrium  models  and  the  Global  Trade  Analysis 

Project  

The  simulations  are  based  on  Computable  General  Equilibrium  (CGE)  models. These  have 
been  the  workhorse  models  used  for  assessing  the  economy-wide  impact  of  trade  policy 
changes for more than three decades. The main advantage of CGE models is that they analyse 
the effects of trade policy taking into account the main links between sectors and between the 
domestic and international production of goods and services. They also include consumption 
and investment decisions of firms across sectors as well as of consumers and governments; 
they also account for the fact that different sectors compete for capital, labour and land.  

These types of models help to answer 'what if…' questions by simulating the price, income and 
substitution effects of different policy changes and comparing them to a so-called baseline (i.e., 
what would happen without a policy change). The baseline is key as it is the counterfactual 
element against which the economic outcome of the initiative is assessed. Hence, CGE models 
allow to simulate, at the same time, how all sectors and actors adjust to the changes to costs, 
prices  and/or incentives  that a trade  policy change would  cause. This  allows for an  ex-ante 
assessment of all the direct and indirect effects of changes to trade policy in terms of a wide 
range of indicators among which gross domestic product, sectoral trade, production and value 
added,  reflecting  inter-sectoral  input-output  links,  including  sourcing  of  inputs  (goods  and 
services) from abroad.  

CGE  models  contain  more  variables  than  equations;  hence  some  variables  have  to  be 
determined  exogenously  (outside  the  model).  The  choice  of  variables  which  are  to  be 
exogenous  is  defined  as  the  model  closure.  In  this  analysis  the  closure  is  the  “fixed 
employment”, one of the most common closure rules. The labour supply of the whole economy 
is given, and the model restores equilibrium by adjusting the nominal wage rate, which is a 
standard specification in  such modelling exercises. In the model, the market  prices are  also 
computed  endogenously  so  that  results  can  show  the  real  wage  changes.  Furthermore,  this 
'fixed  employment  closure'  provides  information  on  shifts  between  sectors  thus  indicating 
which sectors employment is likely to increase and decrease as a result of the new trade policy 
measure.  

42 

 
 
 
 
 
 
 
Among  the  CGE  models  available,  for  this  analysis,  the  recursive  dynamic  Global  Trade 
Analysis Project (GTAP)128 CGE model, GTAP -RD and the comparative static GTAP Hybrid 
CGE model (GTAP-HS-TRQ) have been considered as best suited to quantify the impacts of 
protection of the steel sector on the trade and on the output of all sectors of the economy. Both 
these GTAP models are built upon Social Accounting Matrices (SAMs) of individual countries 
and regions129.  

The recursive dynamic model that will be used for the baseline, extends the comparative static 
framework of the standard GTAP model developed by Hertel (1997)130 to a dynamic framework 
by incorporating international capital mobility and capital accumulation, while preserving all 
the features of the standard GTAP model, such as constant returns to production technology, 
perfectly competitive markets and product differentiation by countries of origin - the so-called 
Armington assumption.  

The static GTAP Hybrid CGE model (GTAP-HS) is a version of the standard GTAP model that 
allows  splitting  the  standard  aggregate  GTAP  sectors  at  6-digit  level  of  the  harmonized 
system.131 The product detail needed for this analysis will be added by splitting the available 
standard  GTAP  aggregates  “iron  and  steel”  into  the  groups  of  products,  used  in  the  2018 
safeguards. The 216 HS6 sub-headings that are generally aggregated in the GTAP sector “iron 
and  steel”  have  been  mapped  into  the  26  groups  of  Table A1  plus  a  residual  group.  The 
simulations  with  the  GTAP-HS  model  will  estimate  the  impact  of  different  trade  policy 
measures on steel imports, broken down by detailed product groups, relative to the projected 
baseline.  

The data used to run these models is the GTAP database. The Version 11c, used in this analysis, 
includes data on 160 regions and countries, 65 industries and 8 endowments. It uses 2017 as 
the base year but underlying basic trade and economic data have been updated to reflect the 
most  recent  information  available. As  far  as  trade  data  is  concerned,  the  underlying  GTAP 
database  is  based  on  COMTRADE  data,  supplied  by  the  United  Nations  Statistical  Office, 
through an ad-hoc reconciliation procedure based on a reliability indicator of the information 
supplied by each importing and exporting country. Protection data comes from the MacMap 
database132. Elasticities are sourced from Fontagné et al (2022).133  

7.1.2.  Aggregation (sectors and countries) 

For the simulations, the 65 industries and 160 countries covered by the GTAP database134  have 
been aggregated (or disaggregated) to best fit the nature of the issue.  

128  
129  

https://www.gtap.agecon.purdue.edu/about/project.asp 
Social Accounting Matrices (SAMs) provide a comprehensive representation of the economic structure 
of individual countries or regions, capturing transactions between sectors, households, government, and with 
the rest of the world through trade. They enable consistent analysis of production, income distribution, and 
trade linkages, offering a solid basis for assessing economy-wide impacts. 

130  

Hertel, T.W. et al (1997), Global Trade Analysis: Modelling and Applications, Cambridge University 

Press. 

131  

Corong et al., (2021), Detailed Trade Policy Simulations Using a Global General Equilibrium Model, 

GTAP Working Paper No. 89. 
https://www.macmap.org/ 
Fontagné  L.,  Guimbard  H.  and  G.  Orefice  G  (2022),  Product-Level  Trade  Elasticities.  Journal  of 

132  
133  

International Economics, Vol 137, https://doi.org/10.1016/j.jinteco.2022.103593. 

134  

https://www.gtap.agecon.purdue.edu/databases/default.asp 

43 

 
 
 
 
 
 
 
 
First, to better model the impact of the new steel measure, the “iron and steel” aggregate sector 
of the GTAP database has been disaggregated in the groups of products135 shown in Table A1 
using the corresponding HS6 codes. The GTAP sectoral details have been maintained for all 
the other sectors except for the agricultural sectors that have been aggregated into one sector. 
Table A2 shows the sectoral aggregation used.  

The purpose of this analysis is to focus on the impact of the EU imposing trade restrictions to 
the exports of the main steel producers, for this reason the geographical breakdown in Table 
A3 separates the main EU steel import sources (top 25) from all the other countries in the world 
that are then grouped according to some general criteria. 

7.2.  Baseline and scenarios  

7.2.1.  Baseline 

The  projected  baseline  is  an  integral  part  of  the  analysis  because  it  shows  expected 
developments in terms of output and trade for both the steel sector and for the downstream 
sectors in case no new measure is introduced.  

The latest  release of the GTAP database, with  2017 as the base year, includes all EU FTAs 
implemented by that year. The first step is therefore the update of the macroeconomic baseline 
to 2024 incorporating key trade policy changes implemented between 2017 and 2024. These 
are the EU agreements which have been concluded since 2017. FTAs for which negotiations 
are not  yet  concluded are not  incorporated. The  baseline also  incorporates  the first  wave of 
bilateral tariffs introduced in 2018 between the US and China (i.e. the first phase of the US-
China ‘trade war’), as well as the set of restrictive trade measures imposed by the EU and its 
allies on Russia following its invasion of Ukraine.  

After 2024, the baseline is built with GDP and population projections from the IMF. Projections 
for changes to the labour force are derived from the ILO and CEPII136  

For  the  steel  sector  the  baseline  includes  all  the Anti-Dumping  and  Countervailing  duties 
imposed  by  third  countries  and  the  additional  duties  imposed  to  steel  products  by  third 
countries  starting  from  2025  such  as  US,  Canada,  Mexico,  Türkiye,  Brazil,  Colombia  and 
India.137  

The expected competitive pressure on the EU industry coming from the overcapacity that has 
built up in third countries has been added in the baseline with shocks calibrated from data on 
capacity,  imports  and  demand  of  steel  and  steel  products.138Such  shocks  generate 
(exogenously) exports from third countries to the EU and to the rest-of-the-world at low prices 

The same groups of steel products identified for the 2018 steel safeguards. 
Centre d’études prospectives et d’informations internationales (CEPII, http://www.cepii.fr) 

135  
136  
137   US Section 232, Canada Section 52. Mexico, Türkiye, Brazil, Colombia increased applied WTO tariffs 
(different  scopes)  (  Mexico  sets  tariffs  up  to  50  percent  on  certain  steel  imports  /  Brazil  government 
renews tariffs, quotas on steel products | Reuters / TR Communiqué No:2023/6-Wire Rod-All Countries 
/  Colombia  Raises  Tariffs  on  Steel  Imports  Amid  Rising  Chinese  Competition.  India:  double-digit 
safeguard measure on flat-steel products - India slaps 12% safeguard duty on steel imports from China, 
others - Industry News | The Financial Express. 
Source:  Boston  Consulting  capacity  database  and  World  Steel  Short  Range  Outlook  April  2025.  The 
following third countries have been identified as able to increase significantly their exports to the EU by 
2030: Algeria, Australia, Brazil, Canada and Mexico, China, Egypt, GCC, India, Indonesia, Japan, South 
Korea, Malaysia, Saudi Arabia, South Africa, Taiwan, Thailand, Turkey, UAE, UK and Vietnam. 

138  

44 

 
 
 
 
 
 
 
 
and  mimic  the  impact  of  overcapacity  on  the  steel  sector.  Consequently, the  EU  faces  both 
import competition and competition in export markets. 

In  addition,  given  the  importance  of  energy-price  dynamics  and  differentials  for  energy-
intensive industries such as steel, the higher costs of energy in the EU and the expected price 
developments have also been included in the baseline. Using the International Energy Agency’s 
(IEA) Electricity 2025 and quarterly Gas Market Reports139 as market benchmarks. Using a 
conservative hypothesis, EU energy costs (electricity and gas) have been set 10% higher than 
the Rest-of-World average over the 2025–2030 period.140 

Finally, for the baseline two options are explored, in the first the 2018 EU safeguards are set to 
expire in 2026, in the second option, such safeguards are prolonged beyond their expiry date, 
to 2030, keeping the quotas at the level of the April 2025 revision. 

7.2.2.  Scenarios  

The scenarios will show the impact (relative to the baseline) on the steel sector and on the 
downstream sectors (output, exports and imports) of various degrees of restrictiveness of the 
new TRQs or of an upfront tariff. 

1)  In-quota volumes that would correspond to the 2013-2014 (hence, before the surge in 
global overcapacity) import penetration levels of all the codes affected (total), allocated 
to  each  group  (Table A1)  according  to  the  2024  weight  of  the  group.  The  import 
penetration level was at around 15% market share. The reduction of total steel imports 
would be of about 30% (28%). The out-of-quota tariff is prohibitive. 

2)  In-quota volumes that would correspond to 50% of the 2024 imports of all the codes 
affected (total) allocated to each group (Table A1) according to the 2024 weight of the 
group. The out-of-quota tariff is prohibitive. 

3)  An upfront 25% tariff.  

The quotas are calculated on the imports in tonnes (2024 and 2013-14) but implemented in 
value (not in tonnes) because GTAP model needs to account for all sectors of the economy and 
for this can only use USD because it cannot mix tonnes of steel and units of cars. 

7.3. 

Simulation’s results 

7.3.1.  Output and trade effects in the EU – 2030 without new measures  

The CGE model-based baseline projections in Table 7.1 show that, the import pressure on the 
European steel sector, mainly deriving from third countries overcapacity and from the trade 
diversion  towards  the  EU  generated  by  third  countries  measures,  is  expected  to  result  in  a 
reduction of the sector’s output of 18% in the next five years (by 2030) that is coupled with an 
increase of imports of 18.7%. The reduction in output is also driven by the reduction in EU 
exports to third markets (due to the competition in third markets faced by EU producers) and 
at the same time a lower domestic output (due to import pressure) corresponds to lower exports. 
In net terms, EU exports of steel are expected to decline by 45.6%. 

139  
140  

https://www.iea.org/analysis?type=report 
These price gaps are mapped into sectoral energy-cost shares 

45 

 
 
 
 
 
 
 
 
The high decline in output in the baseline is mainly generated by the import pressure coming 
from overcapacity and from the energy price differentials. Their impact is exponential relative 
to EU output. In fact, the more EU output starts decreasing, the more external pressure becomes 
stronger in relative terms.  

The contraction of the EU domestic steel production will affect negatively the sectors more 
heavily dependent on steel, like metal products, machineries, construction and motor vehicles. 
These sectors depend on domestic EU steel production141 rather than on imported steel. 

The  sectors  that  are  less  reliant  on  steel  (and  therefore  on  domestic  steel)  like  for  example 
electrical equipment, electronics or chemicals and pharmaceuticals will see their output (and 
in most cases exports) increase thanks to cheaper imported steel because for the relatively lower 
quantities they demand they can more easily substitute with imports.  

Energy prices dynamics and differentials between the EU and the Rest of the world expected 
in the next five years are contributing to the negative dynamics of all energy intensive industries 
in a similar way, and do not affect only the steel sector. 

Overall,  total  output  is  expected  to  decrease  by  1.1%,  imports  expected  to  decrease  by  a 
negligible 0.2% and exports expected to increase by another negligible 0.3%. 

Output 

Exports 

Imports 

Table 7.1 – Baseline (projections to 2030, percentage change relative to 2025) 
Sectors 
Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total 
Source: DG Trade simulations (GTAP RD) 
Notes: “Total” refers to all sectors of the economy including the ones not shown in this table (see Table B1 
for the full results). 

-18.0 
-1.4 
0.1 
0.4 
0.8 
0.8 
0.6 
-3.3 
-0.8 
-0.5 
0.9 
3.5 
-1.4 
0.5 
-2.0 
-1.1 

18.7 
-3.2 
8.4 
1.0 
-1.7 
-3.6 
-2.5 
0.5 
-2.1 
-2.7 
-3.8 
-2.2 
-3.1 
-3.6 
-2.3 
-0.2 

-45.6 
-0.8 
-11.7 
-0.2 
1.3 
3.4 
1.6 
-6.8 
-0.3 
0.2 
3.0 
5.5 
-0.4 
3.1 
0.4 
0.3 

The projections in Table 7.1 foresee the expiry in 2026 of the 2018 EU Steel safeguards while 
in table 7.2, these are prolonged beyond their expiry date (keeping the quotas, for each group 

141 The Input-Output tables in the GTAP database allows tracing the domestic and the foreign sourcing of steel. 

46 

 
 
 
 
 
 
 
 
 
of steel product and partner country, at the level foreseen in the April 2025 revision). The codes 
covered by the EU safeguards (Table A1) correspond to about 85% of the value of imports of 
the iron and steel sector in Table 7.1 and 7.2. The impact of such quotas is however presented 
for the whole sector, so for both the codes covered and those not covered.  

Relative to Table 7.1, the prolongation of the current steel safeguards would lead by 2030 to a 
lower  increase  of  steel  imports  (+16%  rather  than  +18.7%),  a  lower  decrease  of  domestic 
production of steel (-15% rather than -18%) but also a higher decrease in exports (-46.5% rather 
than -45.6%).  

In this second set of projections, the output decrease of the sectors that were already losing is 
marginally higher (e.g. machinery’s output decreases by -1.5% rather than -1.4%) than in the 
projections without the prolongation of the safeguards currently in place. The only exceptions 
are  metal  products  and  construction  for  which  things  do  not  change  significantly.  For  the 
sectors  that  were  projected  to  increase,  such  increases  are  lower  (e.g  electrical  equipment’s 
output increases by 0.7% instead of 0.9%).  

However given the lower losses of the steel sector, the overall output decreases marginally less 
(1% instead of 1.1%), total imports are unaffected, and total exports increase by 0.2% instead 
of 0.3%. 

Output 

Exports 

Imports 

Table  7.2  –  Prolonging  ‘status  quo’  in  terms  of  TRQ  volumes  (projections  to  2030, 
percentage change relative to 2025) – with 2025 revision of steel safeguards prolonged 
to 2030 
Sectors 
Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total  
Source: DG Trade simulations (GTAP RD and GTAP HS) 
Notes: “Total” refers to all sectors of the economy including the ones not shown in this table  

-14.8 
-1.3 
0.1 
0.3 
0.8 
0.8 
0.5 
-3.3 
-0.8 
-0.6 
0.7 
3.4 
-1.5 
0.4 
-2.0 
-1.0 

-46.5 
-0.8 
-11.7 
-0.2 
1.3 
3.3 
1.4 
-7.2 
-0.4 
0.0 
2.8 
5.4 
-0.7 
3.0 
0.3 
0.2 

16.0 
-3.0 
8.4 
1.0 
-1.7 
-3.5 
-2.3 
1.1 
-2.0 
-2.5 
-3.6 
-2.1 
-2.7 
-3.4 
-2.2 
-0.2 

7.3.2.  Output and trade effects in the EU – 2030 with new measures 

Table 7.3, 7.4, 7.5 and 7.6 presents, for each sector, the impacts on output, prices, import and 
exports of the 3 scenarios described above. The tables include the baseline so to confront the 
impact of the new measures compared to the “do nothing” option.  

47 

 
 
 
 
 
 
 
 
These  simulations  have  been  done  with  GTAP-HS.  Hence,  the  quotas  or  tariff  have  been 
applied  to  each  group  of  products  (as  defined  in  Table A1)  and,  for  each  group,  uniformly 
across partners.  The results have then been re-aggregated for the iron and steel sector.  

The results in Table 7.3 indicate that the projected decline of the steel sector by 2030 shown in 
Table 7.1 (also reported in the column “baseline”) is reduced when introducing various forms 
of import restrictions but is not neutralised except in the case of 50% reduction of the import 
volumes (Scenario  2). In this scenario, the output of the steel  sector is  actually expected to 
increase by 2030 (+1.4%). Scenario 2 is the only scenario that allows the EU steel industry to 
slightly increase the manufacturing input. 

Table B2 in the Annex shows the same scenarios as a percentage change relative to the baseline. 

Table  7.3.  Sectoral  Output  of  the  EU  (2030,  %  change  relative  to  2025)  -  main  sectors 
affected 

Baseline 

Scenario 1 
Quotas with 
2013-14 total 
volumes (-
30%) 

Scenario 2 
Quotas with 
reduction by 50% 
of 2024 total 
volumes  

Scenario 
3 
25% 
tariff 

-6.2 
-1 
0.1 
0.3 
0.8 
0.7 
0.4 
-3.1 
-1 
-1 
0.5 

-8.1 
-1.1 
0.1 
0.3 
0.8 
0.7 
0.5 
-3.2 
-0.9 
-0.9 
0.5 

1.4 
-0.7 
0.2 
0.3 
0.8 
0.6 
0.4 
-3 
-1.1 
-1.3 
0.3 

-18.0 
-1.4 
0.1 
0.4 
0.8 
0.8 
0.6 
-3.3 
-0.8 
-0.5 
0.9 
3.5 

Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & 
optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total 
Source: DG Trade simulations. (GTAP HS) 
Notes: “Iron and steel” Simulations have been done disaggregating the groups as per Table A1 but the results have 
then beer re-aggregated; “Total” refers to all sectors of the economy including the ones not shown in this table. 
Baseline = as in Table 7.1; Scenario 1= (TRQs with 2013-14 aggregated volumes allocated to groups with 2024 
weights); Scenario 2= (TRQs with reduction by 50% of 2024 aggregated volumes allocated to groups with 2024 
weights); Scenario 3= (25% tariff) 

-1.7 
0.3 
-1.9 
-0.9 

-1.9 
0.3 
-1.9 
-0.8 

-1.7 
0.4 
-2 
-0.9 

-1.4 
0.5 
-2.0 
-1.1 

3.3 

3.3 

3.1 

Metal products, that is strongly related to the steel sector, will see its decline in output reduced 
but never eliminated. Other sectors that use steel as inputs but marginally less dependent than 
metal products like motor vehicles and machinery will see higher declines in output when the 
steel sector is protected (e.g., -1.1% in motor vehicles and -1.9% in machineries in scenario 2 
relative to -0.8% and –1.4% respectively in the baseline), between 70% and more than 100% 

48 

 
 
 
 
 
 
 
  
 
 
larger  declines.  The  sectors  that  were  projected  to  increase  their  output  by  2030  (e.g. 
electronics) will see slightly lower output growth if steel imports are reduced, between 6% and 
16% less.  

The various scenario of protection of the steel sectors are expected to reduce the decline of the 
total output of the EU by a very small amount going from -1.1% to a range between -0.8% and 
–0.9%. Scenario 2 results in the most positive outcome of -0.8%. 

In synthesis, focusing on the sectors that are most dependent on steel (the selection in Table 2), 
Figure 7.1 shows the variation in USD billion of the total gains and losses of output of the 
sectors  that  gain  and  lose  respectively  (excluding  steel). The  different  scenarios  need  to  be 
added to the baseline. The gaining sectors, relative to the baseline are metal products, mining 
and marginally construction. All the other sectors lose relative to the baseline. 

Figure 7.1 Variations in output relative to the baseline – main sectors affected (BN $) 

100

0

-100

-200

-55

-7

-13

-8

Baseline

Scenario 1

Scenario 2

Scenario 3

Change in output  – Sum of growing sectors
Steel sector

Change in output  – Sum of declining sectors
IMPACT (difference positive - negative)

Source: DG Trade simulations. (GTAP HS) 
Notes: manufacturing sectors excluding steel and including construction (as per Table 7.3). 
Baseline = as in Table 7.1; Scenario 1= (TRQs with 2013-14 aggregated volumes allocated to groups with 2024 
weights); Scenario 2= (TRQs  with reduction by 50% of 2024 aggregated volumes allocated to groups with 
2024 weights); Scenario 3= (25% tariff) 

The three scenarios, by reducing imports are expected to have an upwards impact on prices. 
Table 7.4 shows that the more restrictive the measure is, the higher the percentage increase in 
the  domestic  price  of  steel  and  in  the  overall  level  of  prices.  Scenario  2  is  expected  to  be 
accompanied by an increase of the price of steel of 3.25% which would propagate to the whole 
economy where prices are expected to increase by 0.42%. 

Table 7.4 Impact on prices (2030, % change relative to the baseline) 

Scenario 1 
Quotas with 2013-14 
total volumes (-30%) 

Scenario 2 
Quotas with 
reduction by 50% of 
2024 total volumes  

Scenario 3 
25% tariff 

1.72% 

3.25% 

2.04% 

Price  of  Iron  and  Steel  as 
input to other sectors 

Price  impact  on  household 
consumption 
Source: DG Trade simulations. (GTAP HS) 
Notes: Baseline = as in Table 7.1; Scenario 1= (TRQs with 2013-14 aggregated volumes allocated to groups 
with 2024 weights) ; Scenario 2= (TRQs with reduction by 50% of 2024 aggregated volumes allocated to groups 
with 2024 weights); Scenario 3= (25% tariff) 

0.42% 

0.27% 

0.23% 

49 

 
 
 
 
 
 
 
 
 
 
 
Table 7.5 shows the results of the projections of the 3 scenarios on EU export by sector. By 
adding  quantitative  restrictions  (or  tariffs  as  in  Scenario  3)  to  steel  imports,  the  expected 
decrease,  by  2030,  in  the  value  of  steel  exports  shown  in Table  7.1  (column  “baseline”)  is 
increased. Instead of -45.6%, EU exports of steel are expected to decline in a range that goes 
from -47.7% to -50.7%. The same applies to exports of metal products, motor vehicles, other 
transport equipment and machinery (higher decreases in all scenarios). 

For sectors that were projected to increase their exports (e.g. electronics, +5.5% in Table 1) 
such increases are expected to be lower. 

In all scenarios, the increase in EU total exports projected by 2030 is either annulled (scenario 
1) or is expected to turn into a decrease (Table 7.1). 

Table 7.5. Sectoral EU exports (2030, % change relative to 2025) - main sectors affected 

Baseline 

Scenario 1 
Quotas with 
2013-14 total 
volumes (-
30%) 

Scenario 2 
Quotas with 
reduction by 50% 
of 2024 total 
volumes  

Scenario 
3 
25% 
tariff 

-48.9 
-1.0 
-11.9 
-0.3 
1.2 
3.2 
1.1 
-8.4 
-0.6 
-0.5 
2.3 

-48.4 
-1.0 
-11.9 
-0.3 
1.2 
3.2 
1.2 
-8.1 
-0.5 
-0.4 
2.4 

-45.6 
-0.8 
-11.7 
-0.2 
1.3 
3.4 
1.6 
-6.8 
-0.3 
0.2 
3.0 

-50.7 
-1.2 
-12.1 
-0.3 
1.2 
3.1 
0.8 
-9.2 
-0.7 
-0.9 
1.9 

Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & 
optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total 
Source: DG Trade simulations. (GTAP HS) 
Notes: “Iron and steel” Simulations have been done disaggregating the groups as per Table A1 but the results have 
then beer re-aggregated; “Total” refers to all sectors of the economy including the ones not shown in this table. 
Baseline  =  as  in  Table  7.1;  Scenario  1=  (TRQs  with  2013-14  aggregated  volumes  allocated  to  groups  with  2024 
weights);  Scenario  2=  (TRQs  with  reduction  by  50%  of  2024  aggregated  volumes  allocated  to  groups  with  2024 
weights); Scenario 3= (25% tariff) 

5.2 
-1.4 
2.6 
0.2 
-0.1 

5.5 
-0.4 
3.1 
0.4 
0.3 

5.3 
-1.3 
2.7 
0.2 
0 

5.1 
-2.0 
2.4 
0.0 
-0.3 

Table 7.6 shows the results of the projections of the 3 scenarios on  EU imports. By adding 
quantitative restrictions (or tariffs as in Scenario 3) to steel imports, the expected increase, by 
2030, in the value of steel imports shown in Table 7.1 (and column “baseline”) is lower but still 
positive. Only in Scenario 2, imports are decreasing in value (relative to the 2025 levels).  

50 

 
 
 
 
 
 
 
  
 
 
In all scenarios, imports of metal products are increasing even more than in Table 7.1 (+3.9% 
in scenario 2 compared to 0.5% in the baseline) while imports of other sectors are decreasing 
less. 

Lower imports of steel are also reflected in an higher decline of the EU total imports 
projected by 2030 in the baseline (Table 7.1). 

Table 7.6. Sectoral EU Imports (2030, % change relative to 2025) - main sectors affected 

Baseline 

Scenario 1 
Quotas with 
2013-14 total 
volumes (-
30%) 

Scenario 2 
Quotas with 
reduction by 50% 
of 2024 total 
volumes  

Scenario 
3 
25% 
tariff 

2.9 
-2.4 
8.5 
1.1 
-1.6 
-3.4 
-1.8 
2.7 
-1.6 
-2.1 
-3.0 

5.8 
-2.5 
8.5 
1.1 
-1.6 
-3.4 
-1.9 
2.3 
-1.7 
-2.2 
-3.2 

-7.8 
-1.9 
8.6 
1.2 
-1.5 
-3.3 
-1.5 
3.9 
-1.3 
-1.9 
-2.6 

18.7 
-3.2 
8.4 
1.0 
-1.7 
-3.6 
-2.5 
0.5 
-2.1 
-2.7 
-3.8 

Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & 
optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total 
Source: DG Trade simulations. (GTAP HS) 
Notes: “Iron and steel” Simulations have been done disaggregating the groups as per Table A1 but the results have 
then beer re-aggregated; “Total” refers to all sectors of the economy including the ones not shown in this table. 
Baseline = as in Table 7.1; Scenario 1= (TRQs with 2013-14 aggregated volumes allocated to groups with 2024 
weights); Scenario 2= (TRQs with reduction by 50% of 2024 aggregated volumes allocated to groups with 2024 
weights); Scenario 3= (25% tariff) 

-2.1 
-1.7 
-3.2 
-2.1 
-0.3 

-2.1 
-0.9 
-3.0 
-2.0 
-0.4 

-2.2 
-3.1 
-3.6 
-2.3 
-0.2 

-2.1 
-1.9 
-3.2 
-2.1 
-0.3 

Conclusions 

The in-house economic modelling shows that in the next five years, in the absence of any policy 
action, the import pressure resulting from the effects of global overcapacity (coupled with third 
countries measures and energy price differentials) will result in a sharp decline of the output of 
the EU steel sector (-18%) and of EU steel exports (-45%). The downstream sectors that can 
switch  to  cheap  imported  steel  (e.g.  electrical  machineries  and  electronics)  would  gain 
competitiveness while those that cannot switch so easily to imported steel (e.g. machineries 
and motor vehicles) would lose. The sectors that have steel as a very big share of their inputs 
(e.g. metal products and construction) lose as well. 

51 

 
 
 
 
 
 
 
  
 
 
Protective  measures  for  the  steel  sector  (quotas  or  tariffs)  would  benefit  the  steel  sector. 
Scenario  2  (set  TRQs  to  half  of  2024  imports  with  prohibitive  out  of  quota  tariff)  would 
represent the best outcome for the iron and steel sector with a projected increase of output of 
1.4% (relative to current levels) despite the import pressure deriving from overcapacity and 
energy  prices  differentials.  The  baseline,  scenario  1  and  scenario  3  would  result  in  the 
significant reduction of the manufacturing output by the steel industry. 

Thanks to the lower decreases (or small increases) in output of the steel sector, all scenarios 
project a positive impact on the aggregated manufacturing output of all sectors relative to the 
baseline scenario (do nothing). Scenario 2 would result in the most positive outcome of all of 
the scenarios.  

At the sectors level, few sectors (metal products, mining and, marginally, construction) would 
see  an  improvement  compared  to  the  baseline  although  these  sectors  would  not  manage  to 
maintain the current level of production in any of the three scenarios. All other sectors would 
lose relative to the baseline. In fact, the sectors that were losing in the do-nothing option would 
lose more and the sectors that were gaining would gain less.  

Import protection under all scenarios, would also increase the price of steel and derivatives. 

Exports of steel to third countries is expected to decrease in the baseline due to the increasing 
global overcapacity and protectionist measures introduced by third countries. In the scenarios 
such decrease is higher. Overall, in all scenarios, total EU exports will decrease.    

52 

 
 
 
 
 
 
 
 
 
Annex 1 – additional background on the economic model 

Table A1. Product categories subject to the scope of the safeguard measure 
1A 
and 
1B 

Non Alloy and Other Alloy Hot 
Rolled Sheets and Strips 

72081000,72082500,72082600,72082700,72083600,72083700,72083800,72083900,720840
00,72085299,72085390,72085400,72111400,72111900,72126000,72251910,72253010,722
53030,72253090,72254015,72254090,72261910,72269120,72269191,72269199 
72091500,72091690,72091790,72091891,72092500,72092690,72092790,72092890,720990
20,72099080,72112320,72112330,72112380,72112900,72119020,72119080,72255020,722
55080,72262000,72269200 

2 

3.A 

3.B 

Non Alloy and Other Alloy Cold 
Rolled Sheets 

Electrical  Sheets  (other  than 
GOES) 

4 

5 

6 

7 

8 

9 

10 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

Metallic Coated Sheets 

Organic Coated Sheets 

Tin Mill products 

Non  Alloy  and  Other  Alloy 
Quarto Plates 
Stainless  Hot  Rolled  Sheets 
and Strips 

Stainless  Cold  Rolled  Sheets 
and Strips 

Stainless  Hot  Rolled  Quarto 
Plates 

Non  Alloy  and  Other  Alloy 
Merchant  Bars  and  Light 
Sections 

Rebars 

Stainless  Bars  and  Light 
Sections 

Stainless Wire Rod 
Non Alloy and Other Alloy Wire 
Rod 
Angles,  Shapes  and  Sections 
of Iron or Non Alloy Steel 
Sheet Piling 

Railway Material 

Gas pipes 

Hollow sections 
Seamless Stainless Tubes and 
Pipes 

24 

Other Seamless Tubes 

25.A 

25.B 

Large welded tubes 

26 

Other Welded Pipes 

27 

28 

Non-alloy and other alloy cold 
finished bars 

Non Alloy Wire 

72091610,72091710,72091810,72092610,72092710,72092810 

72251990,72261980 
72102000,72103000,72104100, 
72109080, 
72122000,72123000,72125020,72125030,72125040,72125061,72125069,72125090,722591
00, 72259200, 72259900, 72269910, 72269930,72269970 

72106100, 

72104900, 

72106900, 

72107080, 72124080, 
72091899,72101100,72101220,72101280,72105000,72107010,72109040,72121010,721210
90,72124020 
72085120,72085191,72085198,72085291,72089020,72089080,72109030,72254012,722540
40,72254060,72259900 
72191100,72191210,72191290,72191310,72191390,72191410,72191490,72192210,721922
90,72192300,72192400,72201100,72201200 
72193100,72193210,72193290,72193310,72193390,72193410,72193490,72193510,721935
90,72199020,72199080,72202021,72202029,72202041,72202049,72202081,72202089,722
09020,72209080 

72192110,7219219 
72143000,72149110,72149190,72149931,72149939,72149950,72149971,72149979,721499
95,72159000,72161000,72162100,72162200,72164010,72164090,72165010,72165091,721
65099,72169900,72281020,72282010,72282091,72283020,72283041,72283049,72283061,
72283069,72283070,72283089,72286020,72286080,72287010,72287090,72288000+C203 

72142000,7214991 
72221111,72221119,72221181,72221189,72221910,72221990,72222011,72222019,722220
21,72222029,72222031,72222039,72222081,72222089,72223051,72223091,72223097,722
24010,72224050,72224090 

72210010,7221009 
72131000,72132000,72139110,72139120,72139141,72139149,72139170,72139190,721399
10,72139990,72271000,72272000,72279010,72279050,72279095 

72163110,72163190,72163211,72163219,72163291,72163299,72163310,72163390 

73011000 

73021022,73021028,73021040,73021050,73024000 

73063041,73063049,73063072,73063077 

73066110,73066192,73066199 

73041100,73042200,73042400,73044100,73044910,73044993,73044995,73044999 
73041910,73041930,73041990,73042300,73042910,73042930,73042990,73043120,730431
80,73043910,73043952,73043958,73043992,73043993,73043998,73045181,73045189,730
45910,73045992,73045993,73045999,73049000 
73051100,73051200,73051900,73052000,73053100,73053900,73059000 
73051100,73051200 

73051900,73052000,73053100,73053900,73059000 
73061110,73061190,73061910,73061990,73062100,73062900,73063011, 
73063019,73063080,73064020,73064080,73065020,73065080,73066910,73066990, 
73069000 
72151000,72155011,72155019,  72155080,  72281090,  72282099,  72285020,  72285040, 
72285061, 72285069, 72285080 
72171010,72171031,72171039,72171050,72171090,72172010,72172030,72172050,721720
90,72173041,72173049,72173050,72173090,72179020,72179050,72179090 

53 

 
 
 
 
 
 
 
Table A2. Sectoral aggregation used for CGE simulations 
Aggregation 

GTAP Sector Name 
Rice;  Wheat;  Cereals; 
Fruit and vegetables; Oil 
seeds;  Sugar;  Fibres; 
Other  crops;  Vegetable 
oils; Live and fresh fish; 
Animal  products;  Dairy; 
Ruminant  meat;  Other 
and 
meat;  Beverage 
tobacco;  Processed  fish 
and agricultural products 

Agriculture  and  agricultural 
products 

Wood and paper 

Textile, Apparel and Leather 

Minerals and glass 

Energy sector 

Chemicals 

Pharmaceutical sector 

Rubber and Plastic 
Split  in  groups  as  shown  in 
Table A1  
Residual metals 

Metal Products  

Motor Vehicles 
Transport Equipment 
Electrical equipment 
Computers 

Machinery and equipment 

Other manufacturing 
Utility 
Construction 
Trade 
Accommodation 
Other Transport 
Water Transport 
Air Transport 
Communication sector 
Warehousing 
Business 
Finance 
Insurance 
Real estate 

Recreational services 

Public services 

Wood and paper 
Textile,  Apparel 
Leather 
Minerals and glass 
Energy sector 

and 

Chemicals 
Pharmaceutical sector 

Rubber and Plastic 

Ferrous metals 

Metal Products 

and 

Motor Vehicles 
Transport Equipment 
Electrical equipment 
Computers 
Machinery 
equipment 
Other manufacturing 
Utility 
Construction 
Trade 
Accommodation 
Other Transport 
Water Transport 
Air Transport 
Communication sector 
Warehousing 
Business 
Finance 
Insurance 
Real estate 
Recreation  &  Other 
Services: 
Public services 

Description 
Paddy  and  processed  rice;  Wheat;  Cereal  grains  nec.  (e.g.  corn,  barley,  rye); 
Vegetables, fruit and nuts, edible roots and tubers, pulses; Oil seeds and oleaginous 
fruit; Sugar crops and sugar and molasses; Fibres crops; Spice and aromatic crops; 
forage products; plants and parts of plants used primarily in perfumery, pharmacy, 
beet seeds (excluding sugar beet seeds) and seeds of forage plants; cut flowers and 
flower  buds;  flower  seeds;  Margarine  and  similar  preparations;  cotton  linters; 
flours  and  meals  of  oil  seeds  or  oleaginous  fruits;  Hunting,  fishing,  fish  farms; 
Swine;  poultry;  other  live  animals;  eggs  of  hens  or  other  birds  in  shell,  fresh; 
reproductive  materials  of  animals;  natural  honey;  bovine  animals,  live,  other 
ruminants, horses and other equines; Milk and dairy products; Bovine meat (incl. 
of  sheep,  goats,  horses);  Pig  meat  and  offal,  poultry;  Beverages  and  tobacco 
products;  Prepared  and  preserved  fish;  prepared  and  preserved  fruit  and 
vegetables; wheat and meslin flour; other cereal grain products; 
Forestry, Wood products and Paper products, publishing 
Textiles, Wearing apparel and Leather products 

Mining Extraction 
Coal, Oil, Gas (extraction and distribution) and manufacture of coke and refined 
petroleum products 
Manufacture of chemicals and chemical products 
Manufacture of pharmaceuticals, medicinal chemical and botanical products 

Manufacture of rubber and plastics products 
Ferrous metals (Iron and steel) 

Metals from the GTAP sector not included in the SFG groups 
Production and casting of copper, aluminium, zinc, lead, gold, and silver and Non-
Ferrous Metals and Fabricated Metal Products 
Motor vehicles and parts  
Transport equipment nec 
Manufacture of electrical equipment 
Manufacture of computer, electronic and optical products 
Machinery and equipment nec (including medical, precision and optical instr.) 

Manufactures nec 
Water supply and electricity 
Construction: building houses factories offices and roads 
Wholesale and retail trade  
Accommodation, food and service 
Road and Rail Transport 
Water transport (pipelines, water, auxiliary transport activities;) 
Air Transport 
Information and communication 
Warehousing and support activities 
Other Business Services nec 
Other Financial Intermediation 
Insurance 
Real estate activities 
Recreational, cultural and sporting activities, other service activities; 

Government,  public  administration  and  defense;  Education;  Human  health  and 
social work; Dwellings 

54 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table A3: Geographical aggregation used in CGE simulations 
Regions/groups  Countries 

EU 

EU 

Algeria 
Australia 
Brazil 
China 
Egypt 
India 
Indonesia 
Japan 
South Korea 
Malaysia 
Saudi Arabia 
Serbia 
South Africa 
Switzerland 
Taiwan 
Tunisia 
Turkiye 
Ukraine 
United Arab Emirates 
UK 
USA 
Vietnam 
Russia 
Moldova 
Rest  of  Europe 
Herzegovina, North Macedonia) 
Thailand 
Canada & Mexico 
Argentina, Paraguay, Uruguay, Chile,  
Andean Community, Singapore, Ecuador, New 
Zealand 
Norway and Iceland 
Gulf Cooperation Council 

(including  Bosnia  and 

Least Developed Countries 

Generalized System of Preferences 
Rest of the World 

Steel producers 

Canada & Mexico 

Rest of EU FTAs  

Rest of EFTA 
Gulf 
Council 

Cooperation 

LDC 

GSP 

Rest of the World 

Comprising* 
aut bel bgr hrv cyp cze dnk est fin fra deu grc hun irl ita lva ltu lux mlt 
nld pol prt rou svk svn esp swe  
dza 
aus  
bra  
chn hkg  
egy 
ind  
idn  
jpn  
kor 
mys 
sau 
srb 
zaf 
che 
twn 
tun 
tur  
ukr 
are 
gbr  
usa  
vnm  
rus  
xee  
xer 

tha 
can mex 
nzl sgp arg chl col ecu pry per ury 

nor xef 
bhr kwt omn qat 

khm lao xse afg npl xsa ben bfa gin mli ner sen tgo xwf caf tcd cod 
gnq xac com eth mdg mwi rwa sdn tza uga zmb xec 
xoc mng bgd pak lka bol nic kgz tjk uzb nga cog ken moz 
xea brn phl xna ven xsm cri gtm hnd pan slv xca dom hti jam pri tto 
xcb alb blr kaz xsu arm aze geo irn irq isr jor lbn pse syr xws mar xnf 
cmr civ gha gab mus zwe bwa swz nam xsc xtw 

Notes: * ISO abbreviations; all abbreviations starting with "x" are countries aggregation in the GTAP database, 
details are available here: https://www.gtap.agecon.purdue.edu/databases/regions.aspx?version=10. 

55 

 
 
 
 
 
 
 
 
 
 
Additional results 

Table B1 – Baseline (projections to 2030, percentage change relative to 2025) 
Sectors 
Exports 
Output 
-45.6 
-18.0 
Iron and steel 
2.1 
-0.3 
Agriculture 
2.8 
-0.1 
Wood products 
6.2 
3.8 
Textiles 
-0.8 
-1.4 
Mining 
-11.7 
0.1 
Energy 
-0.2 
0.4 
Chemicals 
1.3 
0.8 
Pharmaceuticals 
3.4 
0.8 
Rubber and plastics 
1.6 
0.6 
Non-ferrous metals 
-6.8 
-3.3 
Metal products 
-0.3 
-0.8 
Motor vehicles 
0.2 
-0.5 
Other transport equipment 
3.0 
0.9 
Electrical equipment 
5.5 
3.5 
Electronics (computers & optics) 
-0.4 
-1.4 
Machinery and equipment 
3.1 
0.5 
Other manufactures 
-1.0 
-1.0 
Utilities (power, gas, water) 
0.4 
-2.0 
Construction 
1.4 
-1.3 
Trade 
1.2 
-0.8 
Accommodation & food services 
0.2 
-0.1 
Land transport 
-0.6 
0.7 
Water transport 
-1.3 
0.6 
Air transport 
1.0 
-1.1 
Communications 
1.1 
-1.6 
Warehousing & support 
1.2 
-1.0 
Business services 
1.1 
-1.0 
Financial services 
1.0 
-1.1 
Insurance 
1.0 
-1.4 
Real estate 
1.5 
-1.6 
Recreation & other services 
0.3 
-1.1 
Total 
Source: DG Trade simulations (GTAP RD) 

Imports 
18.7 
-2.4 
-3.1 
-2.9 
-3.2 
8.4 
1.0 
-1.7 
-3.6 
-2.5 
0.5 
-2.1 
-2.7 
-3.8 
-2.2 
-3.1 
-3.6 
-1.1 
-2.3 
-1.9 
-1.9 
-0.1 
0.5 
2.5 
-2.1 
-2.8 
-1.8 
-1.7 
-1.9 
-2.6 
-2.8 
-0.2 

56 

 
 
 
 
 
 
 
 
 
 
 
Table B2. Sectoral output of the EU (% change relative to the baseline) - main sectors 
affected 

Scenario 1 
Quotas with 2013-
14 total volumes  
(-30%) 

Scenario 2 
Quotas with 
reduction by 
50% of 2024 
total volumes  

Scenario 3 
25% tariff 

9.9 
0.3 
0 
-0.1 
0 
-0.1 
-0.1 
0.1 
-0.1 
-0.4 
-0.4 
-0.2 
-0.3 
-0.1 
0 

Iron and steel 
Mining 
Energy 
Chemicals 
Pharmaceuticals 
Rubber and plastics 
Non-ferrous metals 
Metal products 
Motor vehicles 
Other transport equipment 
Electrical equipment 
Electronics (computers & optics) 
Machinery and equipment 
Other manufactures 
Construction 
Total 
Source: DG Trade simulations. (GTAP HS) 
Notes: “Iron and steel” Simulations have been done disaggregating the groups as per Table A1 but the results have 
then beer re-aggregated; “Total” refers to all sectors of the economy including the ones not shown in this table. 
Baseline = as in Table 7.1; Scenario 1= (TRQs with 2013-14 aggregated volumes allocated to groups with 2024 
weights); Scenario 2= (TRQs with reduction by 50% of 2024 aggregated volumes allocated to groups with 2024 
weights); Scenario 3= (25% tariff) 

19.4 
0.7 
0.1 
-0.1 
0 
-0.2 
-0.2 
0.3 
-0.3 
-0.8 
-0.6 
-0.4 
-0.5 
-0.2 
0.1 

11.8 
0.4 
0 
-0.1 
0 
-0.1 
-0.2 
0.2 
-0.2 
-0.5 
-0.4 
-0.2 
-0.3 
-0.2 
0.1 

0.3 

0.2 

0.2 

57 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
Annex 2 – targeted consultation questions 

Section 1 - FREE TEXT QUESTIONS 

-  Please elaborate on the estimated impact that the different options outlined in Section 
2 below may have on your business, your suppliers and clients, in the EU and in third 
countries. 

-  Please  elaborate  on  the  estimated  impact  of  these  options  on  the  competitiveness  of 

your business both in the EU market and on third country markets. 

-  To ensure that the measure remains suitable in view of potential market developments, 
the Commission would foresee the possibility to review it, including the TRQ volumes 
and/or tariff levels,  as appropriate. Please share  your views on which indicators and 
sources should be taken into account to adjust the measure during its lifespan, should it 
be necessary. 

Section 2 - MULTIPLE CHOICE QUESTIONS 

Question 1: The EU steel sector is currently protected by a safeguard measure (last adjusted 
by  Commission  Implementing  Regulation  (EU)  2025/612142)  which  will  expire  on  30  June 
2026. As set  out  in  the European Commission’s Steel  and Metals  Action Plan of  19 March 
2025143, the European Commission has committed to, “no later than Q3 2025, the Commission 
(propose) a trade measure replacing the steel safeguards as of 1 July 2026, providing a highly 
effective  level  of  protection  against  negative  trade-related  effects  caused  by  global 
overcapacities.” Do you agree with the necessity of such a measure? 

-  Yes 
-  No 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 2: If you consider such a measure necessary, do you consider it should be applicable 
to all 3rd countries alike? 

-  Yes 
-  No 

If no, could you please specify whether you consider any specific countries should be excluded 
from the scope of such measure, or should be treated differently, and why? 

142  Commission  Implementing  Regulation  (EU)  2025/612  of  24 March  2025  amending  Commission 
Implementing  Regulation  (EU) 2019/159  imposing  a  definitive  safeguard  measure  on  imports  of  certain  steel 
products; corrected by Corrigendum to Commission Implementing Regulation (EU) 2025/612 of 24 March 2025 
amending  Commission  Implementing  Regulation  (EU) 2019/159  imposing  a  definitive  safeguard  measure  on 
imports of certain steel products (OJ L, 2025/612, 25.3.2025) 
143https://single-market-economy.ec.europa.eu/document/download/7807ca8b-10ce-4ee2-9c11-
357afe163190_en?filename=Communication%20-%20Steel%20and%20Metals%20Action%20Plan.pdf   

58 

 
 
 
 
 
 
 
 
 
 
Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 3. If you consider a measure necessary, which type of measure would you consider 
as the most appropriate and effective form of measure to achieve the necessary protection of 
the European steel sector against the negative effects of global excess capacities as set out in 
the Steels and Metals Action Plan?  

a.  level of Tariff-Rate Quotas (TRQs) maintaining the volumes as set out in the safeguard 

currently in place; [around 33-35 million tons of TRQ volume] 

b.  level of TRQ volumes reflecting the imports’ market share of the period before 2015 

(average 2013-2014) [around 21-23 million tons of TRQ volume] 

c.  level of TRQ volumes around half the size of 2024 import levels. [around 16-17 million 

tons of TRQ volume] 

d.  Level of TRQ volumes differentiated per product (flat, stainless, long, tubes and pipes) 
e.  Upfront tariff 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries  and  their  businesses.  If  you  chose  option  e,  please  explain  what  the  level  per 
product should be 

Question 4. If the measure takes the form of a TRQ, what would be the appropriate level of 
out-of-quota tariffs; or of the upfront tariff for the measure? 

1.  25% (like the current safeguard) 

2.  50% (like US Section 232 current levels) 

3.  Other (specify) 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question  5.  If  the  measure  takes  the  form  of  TRQs,  what  should  be  the  preferred  quota 
allocation method: 

1.  Combination of country-specific and residual quotas 

2.  Global quotas with a maximum cap per origin 

3.  Global quotas without a maximum cap per origin  

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

59 

 
 
 
 
 
 
 
 
 
Question 6: As regards the administration of TRQs which kind of approach would you consider 
most adequate. 

1.  Annual administration 
2.  Quarterly administration 
3.  Monthly administration 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 7: If answered 2 or 3, should the measure include a mechanism allowing carry over 
of unused TRQs from one quarter/month respectively to the next (within a year)? 

-  Yes 
-  No 

Please explain the reasons for your answer and what impacts you think  your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 8: To ensure the effectiveness of its trade defence measures, as one of the priority 
actions,  the  Commission  will  assess  whether  it  should  adapt  its  practice  by  introducing  a 
“melted and poured rule”, which would allow the Commission to trace where the metal was 
originally melted, regardless of the place of subsequent transformation and the origin of the 
good as determined by the traditional non-preferential rules of origin. Applying this rule would 
eliminate  the  possibility  to  change  the  origin  of  the  metal  product  by  performing  minimal 
transformation and give more certainty in tracing the origin of the product. 

Do you consider it necessary for the effectiveness of this measure to introduce a wider “melted 
and poured” requirement for importers to report the country of melt and pour for all applicable 
steel goods beyond the application of trade defence measures? 

-  Yes 
-  No 
If yes, do you consider it necessary to apply this to all applicable steel goods  

-  Yes 
-  No 

If No, or should there be provisions for an exemption below a certain quantitative threshold? 

-  Yes 
-  No  

If Yes, below which threshold should a requirement to report the country of melt and pour be 
waived, if any? 

1.  Below 1 000 tons 
2.  Below 2 500 tons 

60 

 
 
 
 
 
 
 
 
 
 
3.  Below 5 000 tons 
4.  Below 7 500 tons 
5.  Below 10 000 tons 
6.  No waiver 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 9. For how long should this measure be initially applicable? 

1)  3 years with an option for renewal 
2)  5 years with an option for renewal 
3)  More than 5 years with an option for renewal 
4)  Permanent application subject to adjustments and review 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 10: Do you consider the measure should provide a review clause allowing to adapt 
the TRQs, the out-of-quota rates or the tariff levels (if it is an upfront tariff) based on changing 
circumstances,  including  decreasing  demand,  increasing  import  share  and/or  decreasing 
utilisation rates of the EU industry.  

-  Yes 
-  No 

Question 10.1. Should this review allow for the possibility of downward adjustments in the 
case of TRQs (or upwards adjustment in the case of upfront tariffs)? 

-  Yes 
-  No 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 11: Please indicate the type(s) of steel produced/processed/traded: Please tick the 
box(es) regarding the steel product categories (currently under safeguard measure) that you use 
in your business.  

•  [Internal] A scroll-down option to choose from all the relevant product categories 

(name as per sfg and product category number for ease of reference). 

•  Based on the annex in Commission Implementing Regulation (EU) 2019/ 159 - of 
31  January  2019  -  imposing  definitive  safeguard  measures  against  imports  of 
certain steel products [removing categories 11 and 23] 

61 

 
 
 
 
 
 
 
 
 
 
 
Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Question 12. Pending the outcome of the legislative process, and subject to this being legally 
feasible, when do you consider that the measure should enter into force?  

1)  Q1 2026 

2)  Q2 2026 

3)  On 1 July 2026 (following the expiry of the steel safeguard) 

Please explain the reasons for your answer and what impacts you think your answer will 
have  on  you/your  business,  the  downstream  and  upstream  markets  as  well  as  on  third 
countries and their businesses 

Section 3 - FIGURES  

-  Volume of steel purchased domestically v. imported [to assess how reliant they would 

be on imports] in the year 2024 

-  Share of steel in the total cost of production (in %) [to assess the relevance of steel and 

of potential price increases in their business] in the year 2024 

-  Substitutes  to  steel  for  making  their  products  [to  assess  future  claims  on  potential 

shortage; lower if they have other alternative inputs] 

62