Yesterday, the European Union adopted safeguard measures (C/2025/7842) to curb imports of manganese- and silicon-based ferro-alloys, key alloying inputs for the European steel industry. The decision follows a surge in imports and forms part of a broader policy response to global overcapacity and shifting trade flows in the steel sector. The measures take effect on 18 November 2025 and will be in force for an initial period of three years.

 The safeguard measures conclude an investigation initiated by the European Commission on 19 December 2024 (C/2024/7541) into manganese- and silicon-based ferro-alloys. In launching the probe, the Commission pointed to overcapacity on the global market and an increasing number of trade defence actions by third countries affecting these products, factors that can divert trade towards the EU and lead to injurious import surges. While safeguard investigations are ordinarily concluded within nine months, the Commission found exceptional grounds to extend the inquiry by two months (C/2025/5015), citing the structure of the EU industry and the nature of the products at issue, which require complex economic and legal assessment. The vote on the definitive measures was repeatedly postponed due to the difficulty of securing a majority, particularly because the inclusion of imports from Norway and Iceland under the measures was contentious among member states. The measures, as published yesterday, apply to imports originating in all countries, including those with which the EU has bilateral or regional trade agreements. With the exception of countries that are specifically set out in the published measures, the Commission has determined, consistent with the EU’s World Trade Organization (WTO) obligations, that imports of the product concerned originating in developing country WTO Members and in Algeria are excluded from the measures.

The measures apply to manganese- and silicon-based ferro-alloys entering the EU market – specifically, ferro-manganese, ferro-silicon, ferro-silico-manganese, and ferro-silico-magnesium. Silicon and calcium‑silicon, which were initially within the scope of the investigation, have been excluded from the measures due to declining imports or the absence of EU production. Because safeguard measures are designed to address sudden, sharp, and unforeseen surges in imports that threaten serious injury to a domestic industry, the instrument adopted seeks to moderate the pace of inflows and stabilise market conditions for EU producers of these essential steel inputs. This is achieved through the imposition of safeguard measures combining tariff-rate quotas (TRQ) with an out-of-quota variable duty. Imports of products subject to these measures that enter the EU within the allocated TRQ volume will not incur safeguard duty. Imports that exceed the TRQ volume will be subject to a variable duty calculated as the difference between the cost, insurance, and freight (CIF) import price and the price threshold established for the relevant product category (if the former price is lower than the threshold).

The annual TRQ is apportioned into four consecutive three-month periods, beginning on 18 November each year. Similar to the steel safeguard measures, countries with a share of more than 5% of imports over the last three years for the relevant product type (e.g., Norway, Brazil, and India) are allocated country-specific quotas, while imports originating from other countries may claim the residual quota on a first-come, first-served basis, i.e., in the chronological order in which declarations of release for free circulation are accepted. By way of illustration, the price threshold set for ferro-silicon (HS codes 7202 21 and 7202 29) is €2,408 per metric ton (CIF). If the TRQ volume per country and per product category is exceeded and the CIF price of the import is €1,500 per metric ton, the variable safeguard duty due would be €908 per metric ton, reflecting the difference between the minimum sales price and the CIF import price.

Importers, traders, and downstream users should assess the impact of the new measures on sourcing strategies and supply continuity. EU importers of in-scope products must carefully determine the non-preferential origin of the goods they source and assess how the safeguard tariff affects their purchase price. Contract terms, delivery schedules, and customs planning may need to be reviewed in light of the new measures.