Commerce Department Issues Final Subsidy Findings in Hot-Rolled Steel Review for South Korea

On October 9, 2026, the U.S. Department of Commerce announced its final findings in the countervailing duty administrative review concerning certain hot-rolled steel flat products imported from the Republic of Korea. The determination confirms that two of South Korea's leading steel producers, Hyundai Steel Company and POSCO, received impermissible government subsidies during the 2023 review period. This decision reinforces existing U.S. trade protections aimed at leveling the playing field for domestic steel manufacturers against foreign governments' financial assistance to their industries.

Background of the Review

The administrative review, initiated under the Tariff Act of 1930, scrutinized the period from January 1, 2023, through December 31, 2023. This review is part of an ongoing order established in October 2016 against subsidized hot-rolled steel from Korea. The Commerce Department's Enforcement and Compliance unit is responsible for assessing whether foreign governments provide financial contributions that benefit specific industries or enterprises, thereby distorting international trade.

Key Findings on Subsidies

• Hyundai Steel Company: The Commerce Department determined a final net countervailable subsidy rate of 1.28 percent ad valorem for Hyundai Steel Company. This finding includes consideration of entities cross-owned with Hyundai Steel, such as Hyundai Green Power Co. Ltd.
• POSCO: For POSCO, the final net countervailable subsidy rate was set at 3.68 percent ad valorem. The review accounted for several cross-owned entities, including POSCO Future M, POSCO Holdings, POSCO M-Tech, POSCO Nippon Steel RHF Joint Venture Co., Ltd., and POSCO Mobility Solutions. Additionally, subsidies related to POSCO International Corporation, an affiliated trading company, were factored into POSCO's overall rate.

Methodology and Program Analysis

Commerce conducted its review by examining whether government-provided financial contributions conferred a benefit that was specific to the steel producers. The Issues and Decision Memorandum accompanying the final results delves into specific subsidy programs and methodologies. Key issues analyzed included:

• The provision of electricity by the Government of Korea (GOK) and whether it constituted a subsidy.
• The countervailability of permits issued under the Korea Emissions Trading System (K-ETS).
• Questions regarding the attribution of electricity benefits to POSCO International and the appropriateness of the benchmark used for electricity.
• Analysis of loans from the Korea Export-Import Bank (KEXIM), including the Overseas Investment Credit Program (OICP) and Export Growth Loan Program, examining whether these loans were tied to non-subject merchandise or if their benchmarks needed modification.
• The countervailability of the "Constructing and Operation of Workplace Nursery Program."

These detailed analyses often involve complex calculations and interpretations of benefit and specificity under U.S. trade law.

Implications for U.S. Imports

As a direct consequence of these final determinations, U.S. Customs and Border Protection (CBP) will assess countervailing duties on all appropriate entries of hot-rolled steel from Hyundai Steel and POSCO at the newly determined rates. Furthermore, Commerce will instruct CBP to collect cash deposits for estimated countervailing duties on future shipments at these updated rates. These measures are designed to offset the unfair competitive advantage that subsidized foreign producers might otherwise have in the U.S. market, thereby protecting domestic industries from injurious trade practices. The cash deposit requirements will remain in effect until subsequent administrative reviews or other official actions alter them.