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CBSA INVESTIGATING CERTAIN STEEL WIRE

DUMPING OF CERTAIN CARBON AND ALLOY STEEL WIRE

On April 22, 2025, the Canada Border Services Agency (“CBSA”) issued a Notice of Initiation of Investigation under the Special Import Measures Act (“SIMA”) in respect of the alleged dumping of certain carbon and alloy steel wire originating in or exported from China, Taiwan, India, Italy, Malaysia, Portugal, Spain, Thailand, Turkiye and Vietnam.  This investigation was prompted by a joint complaint filed by two manufacturers headquartered in Quebec. 

The goods under investigation are more specifically described as: 

Carbon or alloy steel wire, of round or other solid cross section, in nominal sizes up to and including 24.13 mm (0.950 inches) in diameter, whether or not coated or plated with zinc, zinc-aluminum alloy, or any other coating, including other base metals or polyvinyl chloride or other plastics (the “Subject Goods”).

The following are excluded from Subject Goods:

stainless steel wire (i.e., alloy steel wire containing, by weight, 1.2 percent or less carbon and 10.5 percent or more chromium, with or without other elements); wire of high-speed steel and; welding wire of any type.

Further details on the Subject Goods and exclusions can be found in the notice itself.

Parallel CITT Investigation

On April 23, 2025 the Canadian International Trade Tribunal (the “CITT”) issued a notice initiating a preliminary injury inquiry in respect of the same Subject Goods, a parallel process to determine whether the alleged dumping has caused or is threatening to cause injury to the Canadian industry.

Why Do I Care?

If the CBSA and CITT ultimately conclude that dumping of the Subject Goods has caused injury or is threatening to cause injury to the Canadian industry, Anti-Dumping Duties (“ADDs”) will be imposed, effectively increasing the costs of the Subject Goods. 

Anti-dumping investigations offer Canadian importers and foreign exporters and producers the opportunity to participate in the CBSA investigation and obtain their own specific Normal Values, which are preferable to the ADDs payable on imports from producers who do not have Normal Values. 

It may  also be possible to request a product exclusion from the CITT on the basis that certain goods are unique and the Canadian industry is incapable of manufacturing a substitutable product.

What Is the Timeline for Next Steps? 

Under SIMA the matter will proceed along two parallel tracks:

• The CBSA will send out Requests for Information: Importers must respond by May 13^th, and exporters by May 29^th;
• The CITT requires any interested participants and their counsel to file Forms with the CITT by May 5^th, and any opposing submissions must be filed by noon on May 29^th.

The CITT’s preliminary determination is expected by June 19, 2025, and CBSA’s preliminary determination is expected by July 21, 2025, each followed by a Statement of Reasons 15 days later. 

How Do I Get Involved?

Specialized legal advice is generally required. Given the strict timelines, and amount of work involved in responding to CBSA and CITT questionnaires, any parties potentially impacted should contact their lawyers immediately to discuss next steps – regardless of whether you have received a questionnaire!  

For help with a Dumping Investigation, click here.

Download a PDF copy of this Blog here.