《World Metals》Published a Signed Article by Chen Leiming

On December 12, 2025, the Ministry of Commerce (MOFCOM) and the General Administration of Customs (GAC) of the People’s Republic of China jointly issued Announcement No. 79, announcing the implementation of export license administration for selected steel products commencing January 1, 2026. This marks the resumption of such a system 16 years after its cancellation in 2009, signifying that China’s steel export governance has entered a new phase.

I. Policy Background: Addressing Challenges and Optimizing Industrial Structure

This policy adjustment constitutes a necessary measure to tackle the multiple challenges confronting the steel industry.

From January to November 2025, China’s steel export volume reached 107.7 million metric tons, registering a year-on-year growth of 6.7%. The full-year export volume is projected to hit 115 million metric tons, exceeding the historical peak of 112 million metric tons recorded in 2015.

Beneath the seemingly robust export data lies a structural imbalance. According to GAC statistics, in the first half of 2025, China’s steel exports amounted to 58.15 million metric tons (a 9.2% year-on-year increase), while the average export price stood at US$ 699.3 per metric ton (a 10.3% year-on-year decline) and the total export value reached US $40.66 billion (a 2.0% year-on-year decrease).

A more pressing issue is the significant surge in trade friction cases targeting the steel industry. Since 2024, the Chinese steel sector has been subjected to over 50 anti-dumping investigations, reaching an all-time high.

Countries including Vietnam, India, South Korea, and Indonesia have successively imposed anti-dumping duties on Chinese products such as hot-rolled coils and medium-to-heavy plates, with the maximum duty rate reaching 38.02%.

Concurrently, exports of low-value-added primary steel products have skyrocketed. In the first half of 2025, China’s cumulative steel billet exports totaled 5.89 million metric tons—triple the volume in the corresponding period of the previous year—while the average export price dropped by 15.3%.

This "volume-driven price compensation" export model not only elevates energy consumption and carbon emissions but also tends to trigger more international trade frictions. It is incompatible with the long-term objective of high-quality development for China’s steel industry.

II. Policy Content: Precision Governance and Categorized Implementation

Pursuant to Announcement No. 79, a total of 300 customs commodity codes for steel products are incorporated into the scope of export license administration, covering the entire industrial chain from raw materials to finished goods.

The regulated products are specifically categorized as follows:

Raw materials and primary products:  Unalloyed Pig Iron, recycled steel raw materials, iron and steel powder, etc.

Intermediate products: Rectangular Billet, continuous casting slabs, etc.

Finished steel products: Hot-rolled coils, cold-rolled coils, coated and plated products, etc.

Notably, the annex to the announcement explicitly mandates that Products No. 7, 14, and 16 (i.e., recycled steel raw materials) must comply with the national standard GB/T 39733-2020 Recycled Steel Raw Materials. This detail underscores the policy’s emphasis on resource recycling and environmental protection standards.

The license application procedure clearly stipulates that foreign trade operators shall submit applications with the goods export contract and the product quality inspection certificate issued by the manufacturer. This provision designates product quality inspection as a pre-export prerequisite, which helps to enhance the quality reputation of China’s steel products at the source.

The licensing authorities are structured into three tiers:

The License Bureau of the Ministry of Commerce (MOFCOM) is responsible for enterprises  which based in Beijing supervised by the State-owned Assets Supervision and Administration Commission of the State Council (SASAC).

Provincial-level local commerce authorities and commerce authorities of some sub-provincial cities are responsible for other enterprises within their respective jurisdictions.

III. Policy Coordination: Integrated System and Clear Objectives

Announcement No. 79 is not an isolated policy adjustment, but rather a component of a systematically coordinated framework aligned with China’s recent national-level steel industry policies.

In September 2025, the Ministry of Industry and Information Technology (MIIT) collaborated with the Ministry of Natural Resources (MNR), the Ministry of Ecology and Environment (MEE), the Ministry of Commerce (MOFCOM), and the State Administration for Market Regulation (SAMR) to jointly issue the Steel Industry Growth Stabilization Work Plan (2025–2026). This plan explicitly proposes to strengthen steel product export governance, safeguard the order of export competition, and optimize the structure of steel export products. Announcement No. 79 serves as a concrete measure to operationalize this requirement.

Announcement No. 79 further clarifies that "other matters not addressed herein shall be implemented in accordance with Announcement No. 65 of 2024 issued by MOFCOM and the General Administration of Customs (GAC)." This coordinated arrangement ensures policy continuity and stability, enabling enterprises to adapt to new regulatory requirements within the existing management framework.

IV. Industry Implications: Guiding Transformation and Enhancing Value

This policy carries multiple positive implications for the long-term development of the steel industry.

First, it helps curb the unregulated export of low-value-added products. The surge in steel billet exports alongside declining prices in the first half of 2025 reflects that some enterprises remain trapped in the primary stage of price competition. Export license administration will increase the compliance costs associated with exporting low-value-added products, thereby forcing enterprises to adjust their product mix.

Second, it facilitates enterprises’ response to international trade barriers. Through license-based governance, enterprises can be guided to optimize their export market layout, reduce dependence on traditional markets that have imposed high anti-dumping duties, and expand into emerging markets such as Africa and Latin America.

Third, export license administration can also promote the green transformation of enterprises. The year 2025 marks the first year that the steel industry has been incorporated into China’s national carbon emission trading market, and it also coincides with the transitional period before the European Union’s Carbon Border Adjustment Mechanism (CBAM) officially imposes carbon tariffs starting in 2026.

V. Recommendations for Enterprises: Proactive Adaptation and Strategic Transformation

It is recommended that enterprises adopt a proactive stance to adapt to the new policy, convert challenges into opportunities, and accelerate the pace of transformation and upgrading.

Enterprises should promptly familiarize themselves with the specific product catalogues included in the regulatory scope and prepare application materials—such as export contracts and product quality inspection certificates—in advance. Starting from December 15, 2025, enterprises are eligible to apply for 2026 annual licenses and are advised to make early arrangements.

Steel enterprises should increase R&D investment to develop high-end products, including high-performance bearing steel, gear steel, and high-temperature alloys. Some leading domestic enterprises have already started exporting "green steel" products, obtaining Environmental Product Declarations (EPDs) through full-process carbon verification, which achieves a 50% carbon emission reduction per ton of steel. This transformation path is worthy of reference.

Enterprises need to establish a robust quality management system. The requirement to provide product quality inspection certificates for export license applications is not only a compliance obligation but also the foundation for enhancing product competitiveness and brand value.

Considering the regional variation in licensing authorities, enterprises should proactively understand the specific procedures and requirements of the commerce authorities in their respective jurisdictions to ensure the smooth operation of export businesses.

The regulation that export license applications require product quality inspection certificates issued by manufacturers will drive enterprises to establish sound quality management systems, enabling Chinese steel products to enter the global market with higher standards.