On February 12, China's Ministry of Commerce and General Administration of Customs announced the implementation of export license management for certain steel products.
Pursuant to the Foreign Trade Law of the People's Republic of China, the Regulations of the People's Republic of China on the Administration of Import and Export of Goods, the Measures for the Administration of Export Licenses for Goods, and other relevant laws, administrative regulations, and rules, the Ministry of Commerce and the General Administration of Customs have decided to adjust the Catalogue of Goods Subject to Export License Management (2025) (hereinafter referred to as the “Catalogue”). Relevant matters are hereby announced as follows:
I. Certain steel products (see Annex) shall be included in the Catalogue.
II. Foreign trade operators exporting the aforementioned goods shall apply for an export license based on the goods export contract and the product quality inspection certificate issued by the manufacturer. Export licenses shall be issued by the Ministry of Commerce and provincial-level local commerce authorities (provinces, autonomous regions, municipalities directly under the central government, cities with independent planning status, and the Xinjiang Production and Construction Corps) entrusted by the Ministry of Commerce, as well as commerce authorities of certain sub-provincial cities (Shenyang, Changchun, Harbin, Nanjing, Wuhan, Guangzhou, Chengdu, Xi'an) according to their respective responsibilities. Enterprises under the supervision of the State-owned Assets Supervision and Administration Commission of the State Council in Beijing shall apply for export licenses issued by the Licensing Bureau of the Ministry of Commerce. Other enterprises shall apply for export licenses issued by the competent local commerce authorities at the provincial level or sub-provincial city level where they are located. Other matters not specified herein shall be implemented in accordance with Announcement No. 65 of 2024 issued jointly by the Ministry of Commerce and the General Administration of Customs.
III. This Announcement shall take effect on January 1, 2026.
Viewpoint: Implementing Export License Management for Chinese Steel Products Aids in Regulating Export Practices
This marks the reintroduction of export license management for steel products in China 16 years after its abolishment in 2009, signaling a new phase in China's steel export regulation.
I. Policy Background: Addressing Challenges and Optimizing Structure
This policy adjustment is a necessary response to the multiple challenges currently facing the steel industry.
From January to November 2025, China's steel exports reached 107.7 million tons, a 6.7% year-on-year increase. Annual exports are projected to hit 115 million tons, surpassing the historical peak of 112 million tons recorded in 2015.
Yet beneath this seemingly robust data lie structural contradictions. In the first half of 2025, China's steel exports exhibited a pattern of “rising volume but falling prices,” with the average export price declining by 10.3% year-on-year.
More critically, trade friction cases against the steel sector have surged dramatically. Since 2024, China's steel industry has faced over 50 anti-dumping cases—a record high.
Countries including Vietnam, India, South Korea, and Indonesia have successively imposed anti-dumping duties on Chinese products like hot-rolled coil and medium-thick plates, with rates reaching up to 38.02%.
Concurrently, exports of low-value-added primary products surged dramatically. In the first half of 2025, China exported a cumulative 5.89 million tons of steel billets—three times the volume of the same period last year—while the average export price fell by 15.3%.
This export model of “compensating for price declines with volume” not only increases energy consumption and carbon emissions but also risks triggering more international trade frictions. It is incompatible with the long-term goal of high-quality development for China's steel industry.
II. Policy Content: Targeted Management and Categorized Implementation
According to Announcement No. 79, steel products subject to export license management encompass 300 customs commodity codes, covering the entire industrial chain from raw materials to finished products.
Specifically, these include:
Raw Materials and Primary Products: Non-alloy pig iron, recycled steel raw materials, steel powders, etc.;
Intermediate Products: Rectangular section steel billets, continuous casting slabs, etc.;
Finished Steel Products: Hot-rolled coils, cold-rolled coils, coated products, etc.
Notably, the annex to the announcement specifically requires products under items 7, 14, and 16 (recycled steel raw materials) to 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 standards.
The licensing application procedure explicitly requires foreign trade operators to submit export contracts and quality inspection certificates issued by manufacturers. This regulation establishes product quality inspection as a prerequisite for export, helping to enhance the quality credibility of Chinese steel products at the source.
Licensing authorities are divided into three tiers:
- The Licensing Bureau of the Ministry of Commerce handles enterprises under the supervision of the State-owned Assets Supervision and Administration Commission (SASAC) in Beijing.
- Provincial-level commerce authorities and commerce departments of certain sub-provincial cities oversee other enterprises within their jurisdictions.
III. Policy Integration: Comprehensive Framework and Clear Objectives
Announcement No. 79 is not an isolated policy adjustment but an integral part of a coherent system aligned with recent national steel industry policies.
In September 2025, the Ministry of Industry and Information Technology (MIIT), in collaboration with the Ministry of Natural Resources, the Ministry of Ecology and Environment, the Ministry of Commerce, and the State Administration for Market Regulation, jointly issued the “Steel Industry Growth Stabilization Work Plan (2025–2026).” This plan explicitly calls for strengthening the management of steel product exports, maintaining export competition order, and optimizing the export product structure of steel. Announcement No. 79 is a concrete measure to implement this requirement.
Announcement No. 79 further specifies that “all other matters not covered herein shall be implemented in accordance with Announcement No. 65 of 2024 issued jointly by the Ministry of Commerce and the General Administration of Customs.” This transitional arrangement ensures policy continuity and stability, allowing enterprises to adapt to new requirements within the existing regulatory framework.
IV. Industry Significance: Guiding Transformation and Enhancing Value
This policy holds multiple positive implications for the industry's long-term development.
First, it helps curb disorderly exports of low-value-added products. The surge in billet exports coupled with falling prices during the first half of 2025 reflects that some enterprises remain stuck in the rudimentary stage of price competition. Export license management will increase compliance costs for low-value-added exports, compelling enterprises to adjust their product portfolios.
Second, it helps companies cope with international trade barriers. Through licensing management, companies can be guided to optimize their export market strategies, reduce their reliance on traditional markets where high anti-dumping duties have been imposed, and expand into emerging markets such as Africa and Latin America.
Third, export license management can accelerate enterprises' green transformation. 2025 marks the first year the steel sector enters China's national carbon emissions trading market, while also serving as the transition period before the EU Carbon Border Adjustment Mechanism (CBAM) imposes carbon tariffs starting in 2026.
Viewpoint: Implementing Export License Management for Chinese Steel Products Aids in Regulating Export Practices
This marks the reintroduction of export license management for steel products in China 16 years after its abolishment in 2009, signaling a new phase in China's steel export regulation.
V. Recommendations for Enterprises: Proactive Adaptation and Voluntary Transformation
Enterprises are advised to adopt a proactive stance in adapting to the new policy, transforming challenges into opportunities, and accelerating their transformation and upgrading efforts.
Companies should promptly familiarize themselves with the specific product catalog subject to management, preparing in advance the required application materials such as export contracts and product quality inspection certificates. Applications for 2026 licenses will open starting December 15, 2025, necessitating early planning.
Steel enterprises should increase R&D investment to develop high-end products like high-performance bearing steel, gear steel, and high-temperature alloys. Some leading domestic companies have begun exporting “green steel” products, obtaining Environmental Product Declarations (EPDs) through full-process carbon verification, achieving 50% carbon reduction per ton of steel—a transformative approach worth emulating.
Enterprises must establish robust quality management systems. Export license applications require submission of product quality inspection certificates, which not only fulfill compliance requirements but also form the foundation for enhancing product competitiveness and brand value.
Given that licensing authorities vary by region, enterprises should proactively understand the specific procedures and requirements of their local commerce departments to ensure smooth export operations.
The requirement for manufacturers to provide product quality inspection certificates for license applications will drive enterprises to establish robust quality management systems, propelling Chinese steel products to meet higher global standards.
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