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CBSA INVESTIGATING STEEL STRAPPING

DUMPING OF STEEL STRAPPING FROM CHINA, KOREA, TÜRKIYE & VIETNAM

On May 12, 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 steel strapping originating in or exported from China, Korea, Türkiye and Vietnam.  This investigation was prompted by a complaint filed by JEM Strapping Systems Inc., a manufacturer located in Ontario.

This investigation continues a broader trend of increased scrutiny on foreign steel products.  Just last month, the CBSA and the Canadian International Trade Tribunal (the “CITT”) launched investigations into potential dumping of steel wire, which we wrote about here.

The Subject Goods

The goods under investigation are more specifically described as: 

Steel strapping, of carbon or alloy steel, with or without seals, whether or not in coils, whether or not punched, whether or not waxed, regardless of surface finish (including whether or not coated, painted, galvanized or “blued”), with a nominal width of 9.5 mm (3/8”) to 50.8 mm (2”) inclusive, and a nominal thickness of 0.38 mm (0.015”) to 1.12 mm (0.044") inclusive (with all dimensions being plus or minus allowable tolerances), originating in or exported from the People’s Republic of China, the Republic of Türkiye, the Republic of Korea, and the Socialist Republic of Vietnam (the “Subject Goods”).          

Parallel CITT Investigation

On May 13, 2025 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 June 2^nd, and exporters by June 18^th; and
• The CITT requires any interested participants and their counsel to file Forms with the CITT by May 26^th, and any opposing submissions must be filed by noon on June 10^th.

The CITT’s preliminary determination is expected by July 10, 2025, and CBSA’s preliminary determination is expected by August 11, 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.