Commerce Department Concludes Year-Long Turkish Steel Investigation

The International Trade Administration (ITA), an agency within the U.S. Department of Commerce, has completed its comprehensive administrative review of steel concrete reinforcing bar (rebar) imports from the Republic of Türkiye. The investigation, which examined the period from July 1, 2022, through June 30, 2023, was conducted to determine whether Turkish manufacturers were selling rebar in the American market at less than fair value, a practice known as dumping. After collecting extensive data and analyzing market conditions, Commerce found evidence that some Turkish producers indeed sold their products below normal value during the review period. This determination follows preliminary findings published in August 2024, with the final results released on May 19, 2025, after several deadline extensions. The investigation was conducted under section 751 of the Tariff Act of 1930, which authorizes the Commerce Department to periodically review antidumping duty orders to ensure they remain appropriate based on current market conditions. This particular review represents the latest chapter in ongoing trade tensions between the U.S. and Türkiye regarding steel products, which have been subject to various trade remedies over recent years.

Differential Duties Applied Based on Individual Company Assessments

The Commerce Department's final determination established varying antidumping duties for the Turkish rebar producers under review, reflecting different pricing behaviors discovered during the investigation. Colakoglu Metalurji A.S. and its affiliated company Colakoglu Dis Ticaret A.S. received a weighted-average dumping margin of 1.13%, meaning the Department found this producer group was selling rebar in the U.S. market at prices 1.13% below fair value. In contrast, Icdas Celik Enerju Tersane ve Ulasim Sanayi A.S. received a zero percent margin, indicating that this producer was found to be selling at fair market prices during the review period. Additionally, Kaptan Demir Celik Endustrisi Ve Ticaret A.S. and its affiliate Kaptan Metal Dis Ticaret Ve Nakliyat A.S., which were not individually examined, received the 1.13% rate based on Colakoglu's calculation. These differentiated rates demonstrate the Department's company-specific approach to antidumping investigations, which aims to impose remedial duties proportionate to each producer's actual pricing behavior rather than applying blanket penalties across an entire industry or country. The modest duty rate of 1.13% suggests the Department found relatively minor pricing discrepancies compared to previous steel-related investigations that have sometimes resulted in double-digit tariff rates.

Methodology Behind Commerce's Determination

The Commerce Department employed a rigorous analytical framework to determine whether dumping occurred and to calculate appropriate duty rates. Following standard procedures for administrative reviews, the Department compared the export prices of Turkish rebar sold in the United States with the normal value of comparable products in Türkiye's domestic market. This price comparison methodology involved numerous technical adjustments to ensure an "apples-to-apples" comparison, accounting for differences in physical characteristics, sales terms, shipping costs, and other factors that might affect price comparability. For companies not individually examined, Commerce typically looks to section 735(c)(5) of the Tariff Act, which provides guidance for calculating rates based on the weighted-average margins determined for individually examined respondents, excluding zero or de minimis rates. Since one mandatory respondent received a zero rate while another received a positive margin, Commerce assigned the non-examined company the positive rate of 1.13%. The Department's detailed analysis of all factors affecting price comparability was documented in an Issues and Decision Memorandum made available to the public through its online Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS).

Revisions From Preliminary to Final Determination

The final results published on May 19, 2025, contain several modifications from the preliminary findings announced in August 2024. These changes resulted from Commerce's consideration of arguments presented by interested parties during the comment period following the preliminary determination. Both mandatory respondents, Colakoglu and Icdas, submitted case briefs challenging various aspects of the Department's preliminary calculations, while U.S. producers likely provided rebuttals defending or seeking to strengthen the initial findings. While the notice does not detail the specific changes made, it acknowledges that Commerce revised its margin calculations for both individually examined companies based on comments received. Such revisions typically involve technical adjustments to cost allocations, price adjustments, or the treatment of particular sales transactions that may affect the final dumping margin. The Department's willingness to modify its calculations based on stakeholder input reflects the administrative review process's iterative nature, designed to ensure that final determinations accurately reflect market realities and comply with U.S. trade laws. These adjustments demonstrate the complex, data-intensive nature of antidumping proceedings, which require sophisticated economic analysis and careful consideration of factual and legal arguments from multiple parties.

Impact on U.S.-Türkiye Steel Trade Relations

The modest duty rates established in this review may signal a relative easing of trade tensions between the U.S. and Türkiye in the steel sector. With one company receiving a zero margin and others facing only a 1.13% duty, the outcome represents a significantly less restrictive approach compared to previous trade actions targeting Turkish steel products, which have sometimes imposed duties exceeding 20%. This more measured result could reflect improved pricing practices by Turkish producers, changes in market conditions, or shifts in U.S. trade enforcement priorities. The determination comes amid broader discussions about global steel overcapacity and various countries' efforts to protect domestic industries while maintaining commitments to rules-based international trade. For Turkish producers, even the modest 1.13% duty represents an additional cost when exporting to the U.S. market, potentially affecting their competitiveness against domestic producers and other foreign suppliers not subject to similar duties. However, the relatively low rate suggests that Turkish rebar may continue to maintain a significant presence in the U.S. market despite the trade remedy measures. This outcome balances providing some protection to domestic producers against allegedly unfair trade practices while avoiding excessive disruption to established supply chains and customer relationships.

Procedural Timeline and Transparency Measures

The administrative review followed a structured timeline with multiple opportunities for stakeholder participation, reflecting Commerce's commitment to procedural transparency. The process began with the publication of preliminary results in August 2024, followed by a comment period during which interested parties could submit case briefs and rebuttal arguments. The Department initially extended the deadline for final results in November 2024, and subsequently implemented an additional 90-day tolling of deadlines in December 2024, pushing the final determination to May 2025. These extensions are common in complex trade cases, allowing Commerce sufficient time to thoroughly analyze submissions and prepare well-reasoned determinations. Throughout the process, Commerce maintained transparency by publishing relevant documents in the Federal Register and making detailed analysis available through its online ACCESS system. The Issues and Decision Memorandum, which addresses all arguments raised by interested parties, was made publicly available, allowing stakeholders to understand the reasoning behind Commerce's final determination. This procedural transparency is essential for maintaining the credibility of U.S. trade remedy enforcement and providing predictability for businesses operating in international markets affected by such determinations.

Market Implications and Next Steps for Affected Parties

The final determination has immediate commercial implications for both Turkish exporters and U.S. importers of rebar. Customs and Border Protection will now collect cash deposits at the rates established in the review for future shipments from the named Turkish producers. For Icdas, which received a zero margin, no cash deposits will be required, potentially giving this producer a competitive advantage in the U.S. market compared to its Turkish counterparts subject to the 1.13% duty. Importers who have been paying cash deposits at potentially different rates during the review period may be entitled to refunds or could face additional duty liability, depending on how the final rates compare to the deposit rates previously in effect. The relatively low duty rates suggest that Turkish rebar will likely remain competitive in the U.S. market, though producers subject to the 1.13% duty will face a modest cost disadvantage compared to domestic suppliers and imports from countries not subject to antidumping duties. Affected parties have the option to challenge Commerce's determination through appeals to the U.S. Court of International Trade, though the modest nature of the duties may reduce the likelihood of costly litigation. Additionally, as this was an administrative review of an existing order rather than a new investigation, the antidumping duty order itself remains in place and will be subject to potential future reviews unless revoked through a sunset review process.

Broader Context of U.S. Steel Trade Enforcement

This determination fits within a broader pattern of U.S. trade enforcement actions targeting steel imports, which have been a particular focus of American trade policy across multiple administrations. Steel products, including rebar, have been subject to various trade remedies, including antidumping duties, countervailing duties addressing government subsidies, and Section 232 national security tariffs. The relatively modest outcome of this particular review contrasts with more aggressive enforcement actions in other steel product categories or against other countries, potentially reflecting the specific circumstances of the Turkish rebar market rather than a general shift in U.S. trade policy. The case demonstrates the case-by-case approach of U.S. trade remedy laws, which aim to address specific instances of unfair trade rather than imposing blanket restrictions. For the U.S. domestic steel industry, which has long advocated for strong enforcement against allegedly unfair foreign competition, the outcome provides some continued protection, though at levels that may be lower than domestic producers had sought. The determination illustrates the delicate balance Commerce must strike between addressing unfair trade practices and avoiding excessive trade restrictions that could harm downstream industries and consumers who rely on competitively priced steel inputs.

Key Takeaways:

• The U.S. Department of Commerce has imposed a 1.13% antidumping duty on certain Turkish rebar producers while exempting Icdas with a zero margin following its administrative review covering July 2022 through June 2023

• The modest duty rates represent a relatively measured trade enforcement action compared to previous steel-related cases, potentially signaling improved pricing practices by Turkish producers or changing market conditions

• The determination followed a transparent process with multiple opportunities for stakeholder input, resulting in revisions to the preliminary calculations based on arguments presented by interested parties