Adjustment of Anti-Dumping Duty in Presence of Safeguard Duty on Steel Imports from Vietnam
Introduction
The Ministry of Finance has modified the anti-dumping duty structure applicable to imports of hot rolled flat products of alloy or non-alloy steel from Vietnam. This change, notified through Notification No. 40/2025–Customs (ADD) dated 30 December 2025, introduces a mechanism to offset anti-dumping duty by the amount of safeguard duty imposed on the same products.
The amendment stems from the recommendations of the designated authority under the Customs Tariff Act, 1975, and is intended to prevent overlapping trade remedial duties on the same imports. In effect, where both safeguard duty and anti-dumping duty are simultaneously attracted on these steel products, the anti-dumping duty will be reduced by the quantum of safeguard duty payable.
Background of the Anti-Dumping Proceedings
Subject Goods and Country of Origin
The products covered are ‘Hot rolled flat products of alloy or non-alloy steel’, which fall under the following tariff headings of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975):
- 7208
- 7211
- 7225
- 7226
These goods:
- Originate in, or are exported from, Vietnam, and
- Are imported into India as the subject goods from the subject country.
Findings of the Designated Authority
The designated authority, after conducting a detailed investigation, issued its final findings vide notification No. 06/15/2024-DGTR dated 13th August, 2025, as published in the Gazette of India, Extraordinary, Part I, Section 1, on the same date. The authority concluded, inter alia, that:
- The subject goods exported from Vietnam to India were priced below the normal value, thereby constituting dumping.
- The domestic industry suffered material injury because of these dumped imports.
- There existed a threat of further aggravation of injury to the domestic industry if anti-dumping duties were not levied on imports of the subject goods from Vietnam.
On the basis of the above, the authority recommended the imposition of anti-dumping duty on imports of the subject goods from Vietnam to neutralise the injurious effects of dumping and to protect the domestic industry.
Initial Imposition of Anti-Dumping Duty
Acting upon the final findings of the designated authority, the Central Government introduced anti-dumping duty through Notification No. 32/2025-Customs (ADD) dated 12th November, 2025, issued by the Ministry of Finance (Department of Revenue). This notification was:
- Published in the Gazette of India, Extraordinary, Part II, Section 3, sub-section (i),
- Bearing number G.S.R. 836(E), dated 12th November, 2025.
This principal notification prescribed specific anti-dumping duty rates applicable to imports of hot rolled flat products of alloy or non-alloy steel from Vietnam, based on the designated authority’s detailed assessment.
Recommendation for Coordination with Safeguard Duty
Designated Authority’s Specific Recommendation
In the same final findings notification No. 06/15/2024-DGTR dated 13th August, 2025, the designated authority went a step further to address the potential overlap between anti-dumping duty and safeguard duty. The authority recommended that:
The anti-dumping duty payable would be the anti-dumping duty (mentioned in column (7) of the Table in para 122 of the aforementioned Final Findings) minus the safeguard duty payable, if any.
This explicit recommendation recognised that, if both anti-dumping and safeguard duties become applicable on the same consignments, there should be a mechanism to avoid double burden on the same imports.