Pakistan Extends Anti-Dumping Duties on Chinese Steel Billets: NTC Confirms 24.04% Rate for Five Years Under ADC36
Pakistan's National Tariff Commission finalised the second sunset review of anti-dumping case ADC36 on 10 April 2026, confirming a 24.04% anti-dumping duty on continuous casting steel billets imported from China for a further five-year period effective from 22 June 2025.
Effective date and legal basis
Timeline and review process
The National Tariff Commission of Pakistan issued its final determination on 10 April 2026. The anti-dumping duty under case ADC36 applies for five years from 22 June 2025. Initial duties were first imposed in 2017. A first sunset review followed in 2022. The current second sunset review relied on trade data covering the period from 1 January 2022 to 31 December 2024.
| Issuing authority | National Tariff Commission (NTC) of Pakistan |
| Case reference | ADC36 — Second Sunset Review |
| Determination date | 10 April 2026 |
| Duty effective from | 22 June 2025 |
| Duration | Five years |
| Investigation data period | 1 January 2022 — 31 December 2024 |
Products covered and HS code classification
Scope of the measures
The anti-dumping duty covers semi-finished products of iron, alloy steel, and non-alloy steel in continuous cast form. These billets are used as inputs for manufacturing steel bars, wire rods, beams, channels, T-iron, and other downstream long products. The product scope is defined by reference to 12 HS sub-headings under Chapters 72 of Pakistan's customs tariff schedule.
Importers must verify the exact HS classification of each product line at Pakistani customs. Sub-heading misclassification can result in incorrect duty assessment. Confirm the applicable code with a licensed Pakistani customs agent before shipment.
HS 7207.xx — semi-finished products of iron or non-alloy steel. HS 7224.xx — semi-finished products of other alloy steel. All sub-headings refer to Pakistan's customs tariff schedule. Confirm classification with a licensed Pakistani customs agent before shipment.
Duty rate and exemption structure
The 24.04% rate and its duration
The NTC determined that a 24.04% ad valorem anti-dumping duty remains necessary to offset the margin of dumping established for Chinese continuous casting billets. This rate applies to all imports of the covered products originating from China. The five-year duration is consistent with WTO Anti-Dumping Agreement Article 11.3 provisions governing sunset review determinations.
A 24.04% ad valorem duty on semi-finished steel is commercially significant. At current billet price levels, this adds a meaningful cost layer to any shipment from China destined for Pakistani use. It effectively prices Chinese billet out of competitive range against domestically produced material or imports from non-subject origins.
Export and grant-in-aid exemptions
Imports of subject billets escape the duty if the material serves as an input for goods destined solely for export. The exemption also applies to inputs used in foreign grant-in-aid projects. In both cases, the material must qualify for customs duty relief under Pakistan's Customs Act, 1969.
This exemption structure is commercially important. Pakistani manufacturers who process Chinese billets into finished long products for export markets — rather than for domestic sale — can in principle source Chinese billet without incurring the 24.04% duty. The qualification requirements and documentation obligations under the Customs Act, 1969 apply. Buyers intending to rely on this exemption should obtain a formal legal opinion from a Pakistani trade counsel before concluding purchase agreements.
| Category | Rate | Condition |
|---|---|---|
| Standard import (domestic use) | 24.04% | All subject HS codes from China |
| Input for export-destined goods | Exempt | Must qualify under Customs Act, 1969 |
| Foreign grant-in-aid project inputs | Exempt | Must qualify under Customs Act, 1969 |
Impact on Chinese exporters and overseas buyers
Commercial consequences for Chinese billet exporters
A 24.04% duty effectively closes the Pakistani market for competitively priced Chinese billets intended for domestic consumption. At current market prices, a duty of this magnitude adds a cost layer that eliminates the price advantage that Chinese semi-finished steel typically holds over locally produced material or imports from non-subject origins.
Chinese producers that cooperated with the original 2017 investigation and subsequent reviews will have individual dumping margin records on file with the NTC. Those without cooperation history default to the residual rate. Any Chinese exporter seeking to challenge the current determination has the right to participate in future review proceedings.
Priorities for Pakistani importers and buyers
Pakistani steel mills and fabricators that have been sourcing Chinese billets for domestic downstream production must now operate under the 24.04% duty structure. Key actions are immediate.
First, confirm whether any current or planned Chinese billet purchases qualify for the export-destined or grant-in-aid exemption. This requires a legal assessment under the Customs Act, 1969. Second, reassess landed cost models for all Chinese billet programmes. The duty applies from 22 June 2025, which means any shipments cleared after that date under the prior review framework are now subject to the new determination. Third, evaluate alternative supply origins. Non-subject countries are not affected by ADC36. Billet from Turkey, Ukraine, Russia, or regional producers may offer competitive landed costs without the AD duty exposure.
Broader trade context
Pakistan's ADC36 decision is part of a broader global pattern. South Korea, Mexico, Vietnam, the United Kingdom, and the United States have all tightened their steel import frameworks for Chinese products in the current cycle. Each individual measure adds to the cumulative narrowing of market access for Chinese steel exports. For multi-market procurement teams, tracking the overlap of these measures across destinations is now an active supply chain risk management requirement, not a compliance afterthought.
Alternative sourcing considerations
Non-subject origins and domestic supply
For Pakistani buyers needing continuous casting billets for domestic downstream use, non-subject origins are the most straightforward alternative. Countries not named in ADC36 are not subject to the 24.04% duty. Confirm origin certification and Mill Test Certificate standards with each potential alternative source before committing to volume.
Domestic Pakistani billet production — from integrated steelmakers and electric arc furnace operators — also provides a duty-free sourcing option. Capacity and lead time availability should be verified against project timelines before relying on domestic supply as a substitute for previously Chinese-sourced material.
Stainless flat products: a separate supply chain
It is important to note that ADC36 covers carbon and alloy steel billets only. Stainless steel flat products — including austenitic grades such as 304 stainless steel coil and 316L stainless steel coil — are classified under a different chapter and are not subject to this determination. Procurement teams sourcing stainless grades for Pakistani projects or for export to Pakistan can proceed on their normal supply chain basis.
| Response option | Best suited for | Key consideration |
|---|---|---|
| Verify export / grant-in-aid exemption | Processors exporting finished goods | Legal opinion under Customs Act, 1969 required |
| Switch to non-subject billet origin | Domestic-use downstream manufacturers | Confirm MTC standards and origin certification |
| Source from domestic Pakistani producers | Buyers needing short lead times | Verify capacity availability and delivery schedule |
| Source stainless flat products separately | Corrosion-critical applications | 304 and 316L are outside ADC36 scope |
Related products and further reading
For procurement teams reviewing their steel supply strategy in South Asian and global markets, the following TISCO resources provide grade specifications and application references:
Official references (external)
National Tariff Commission of Pakistan | WTO — Anti-Dumping Agreement | World Steel Association | ISSF — International Stainless Steel Forum
Sourcing stainless steel coils — outside the scope of ADC36
ADC36 covers carbon and alloy steel billets only. Stainless flat products remain unaffected. TISCO supplies 304 stainless steel coil, 304L, and 316L stainless steel coil with full Mill Test Certificates, compliant origin documentation, and consistent export execution for buyers in South Asia and global markets. View the full stainless coil range or request a quote for your current requirements.
© tiscoco.com | Stainless steel market insights and procurement guidance. Duty rates and HS codes referenced in this article are sourced from the NTC of Pakistan final determination for ADC36 dated 10 April 2026. Importers should verify applicable rates with a licensed Pakistani customs agent before making procurement decisions. This article does not constitute legal or customs advisory.
