In brief
Earlier this year, Australia’s Productivity Commission (PC) initiated an investigation into whether safeguard measures for imports of certain fabricated structural steel are warranted on the basis of there being a surge of imports that causes, or threatens to cause, serious injury to domestic injury. If the recommended outcome of the PC’s report is that such that the safeguard measures should apply, it will sit with the Australian Government to ultimately impose any measures (including imposition of customs duties, import quotas etc.) on the subject imports.
In detail
On 23 January 2026, the Treasurer referred to the PC an inquiry into whether safeguard measures are warranted on imports of fabricated structural steel, on the basis that a surge in imports is causing, or threatening to cause, serious injury to the domestic industry. The PC is Australia's competent authority for safeguard inquiries under World Trade Organization (WTO) rules, and Australia has formally notified the WTO Committee on Safeguards of the initiation.
The investigation follows concerns raised by the Australian Steel Institute (ASI) and local fabricators, who have warned of a “crisis of import penetration” in fabricated structural steel. This ultimately culminated in ASI lodging a formal application for safeguard action in late 2025. If the PC ultimately recommends that safeguard action is warranted, it will be for the Australian Government to decide whether to impose any measures (such as additional customs duties, tariff-rate quotas, or a combination of price- and volume-based remedies).
The scope of the PC’s investigation is summarised as follows.
Products under investigation
The inquiry covers a range of fabricated structural steel products falling within tariff subheadings 7308.10 and 7308.90 of the Australian Customs Tariff. The PC's terms of reference list specific steel commodities that include, among other things:
- bridges and bridge sections of iron or steel;
- columns, pillars, posts, beams, girders, bracing, gantries, brackets, struts, ties and similar structural units (hot rolled, roll formed, and plated/coated variants);
- steel grating, stairways and treads;
- handrails and stanchions;
- guard rails and road barriers prepared for use on bridges and roads;
- sectional components for towers and lattice masts;
- lintels prepared for use with doors and windows; and
- structures and parts of structures (and plates, rods, angles, shapes, sections and tubes) prepared for use in structures.
Importers should review their tariff classifications carefully. The breadth of the scope means that goods which sit at the periphery (for example, semi-fabricated sections, pre-assembled modules, or composite products containing structural steel) may be drawn into any final measure.
What is safeguarding?
Under Article XIX of the General Agreement on Tariffs and Trade (GATT) 1994 and the WTO Agreement on Safeguards, a safeguard measure may only be imposed where the investigating authority finds, on the basis of objective evidence, that:
- imports of the product have increased, in absolute terms or relative to domestic production;
- the increase has occurred under such conditions as to cause, or threaten to cause, serious injury (a significant overall impairment) to the domestic industry producing the like or directly competitive product; and
- there is a causal link between the increased imports and the serious injury, with injury caused by other factors not being attributed to imports.
Importantly, safeguards differ from anti-dumping and countervailing measures: they are predicated on the volume and suddenness of the import surge rather than on unfair pricing practices, and they generally apply on a most-favoured-nation basis to all sources, not just to a specific exporting country. They are intended as temporary, emergency measures, typically of up to four years' duration, extendable to a maximum of eight years subject to ongoing review.
Inquiry process and timeline
The accelerated inquiry timeline is set out below.
| Milestone | Status / commentary |
| 23 January 2026 - Terms of Reference issued | The inquiry was formally launched on this date and notified to the WTO Committee on Safeguards (G/SG/N/6/AUS/5). |
| February 2026 - Call for submissions paper | The PC released its call for submissions paper, outlining the matters under examination and the legal requirements for safeguard measures. |
| 20 April 2026 - Initial submissions due | The initial submissions period closed with 25 submissions received from industry stakeholders, importers, unions and other affected parties. |
| By September 2026 - Interim report | The PC will release an interim report setting out preliminary findings on whether the import surge has caused serious injury and any indicative position on safeguard measures, including whether provisional measures should apply. The interim report will be open to further public comment. |
| Late 2026 (TBA) - Public hearings and final submissions | The PC may hold public hearings and invite a second round of submissions on the interim findings, allowing stakeholders to scrutinise and respond to draft recommendations. |
| November 2026 - Final report due | The PC is expected to deliver its final report to Government in November 2026 (release date to be advised). The Government will then decide whether to accept the recommendation and, if so, the form and duration of any safeguard measure. |
Potential outcomes and implications
If the PC finds that the legal thresholds are met, the measures it could recommend include:
- additional customs duties on imported fabricated structural steel (potentially as a flat ad valorem rate or a graduated rate depending on volume thresholds);
- quantitative restrictions (quotas) on import volumes, with allocations potentially by country of origin; or
- a combination of price- and volume-based measures, such as a tariff-rate quota under which a base volume enters at the existing rate and out-of-quota volumes attract a higher rate.
The PC may also recommend that any measure be paired with adjustment requirements on the domestic industry (for example, investment, productivity or capacity commitments) and a sunset review to test whether continued protection remains necessary. It is ultimately at the Government's discretion whether and how to give effect to any recommendation.
The implications by stakeholder group are summarised below.
- Domestic fabricators are likely beneficiaries of reduced import competition, with potential for increased local orders and improved pricing power. Any relief is likely to come with expectations to invest in productivity, capacity and workforce capability during the period of the measure.
- Importers, EPC contractors and major project owners face exposure to higher landed costs and potentially tighter supply, with consequences for project budgets, program delivery and contractual risk allocation. Long-dated, fixed-price construction contracts (where steel pricing is not subject to a rise-and-fall mechanism) are particularly exposed.
- Downstream manufacturers and infrastructure clients (including state government infrastructure pipelines, energy and resources project sponsors, and major commercial property developers) may face flow-through cost pressures and lead-time impacts even where they are not direct importers.
- Overseas exporters face reduced access to the Australian market and closer scrutiny of trade flows, with the residual risk of follow-on anti-circumvention or anti-dumping action if trade patterns shift in response to the measure.
What businesses should be doing now
The window between now and the PC's interim report in September 2026 is a critical period for affected businesses to position themselves. Practical steps include:
- Quantify exposure across the project pipeline. Map current and forecast imports of fabricated structural steel by HS subheading, country of origin, value and volume. Model the impact of indicative duty rates and quota outcomes on landed cost, gross margin and project economics.
- Review tariff classifications and origin documentation. Confirm whether goods are correctly classified within HS 7308.10 / 7308.90 or whether they sit outside scope. Ensure Certificates of Origin and supporting documentation are sufficient to defend any Free Trade Agreement (FTA) preference claim that has been (or will be) made.
- Engage with the inquiry. Although initial submissions have closed, there will be further opportunities to make post-interim report submissions and to participate in any public hearings. Importers, project owners and end-users should ensure their evidence and commercial perspective are reflected in the PC's deliberations - not just the petitioners'.
- Plan for sourcing diversification. Given the concentration of supply from China, identify alternative suppliers in FTA partner countries that may be less exposed to a final measure, taking into account product specification, certification, lead time and total landed cost.
- Monitor developments. Track the interim report, any provisional measures, and the final report. Provisional safeguard measures can be imposed in critical circumstances and may take effect with limited notice.
How PwC can help
PwC Global Trade team works with importers, fabricators, EPC contractors, infrastructure owners and overseas exporters across the full lifecycle of a safeguard inquiry. The areas where we are typically engaged include:
- Exposure quantification and scenario modelling. We use trade data and client-supplied procurement data to quantify exposure by HS subheading, supplier and project, and model the financial impact of alternative measure designs (ad valorem duty, specific duty, tariff-rate quota) across the in-scope portfolio.
- Trade remedy submissions. We assist clients to prepare evidence-based submissions to the PC, both in the initial round and post-interim report, drawing on commercial, technical and economic data and aligning the submission to the WTO legal tests.
- FTA and rules-of-origin strategy. We assess whether the structure of an FTA (and its safeguard chapter) preserves or limits exposure to any final measure for goods originating in particular countries, and we review origin documentation to ensure it can support both ongoing tariff preference claims and any safeguard exemption argument.
- Contract and procurement risk review. Working with our legal and deals teams, we review contractual pass-through, change-in-law and force majeure provisions, and advise on the drafting of new contracts entered into during the inquiry period to ensure customs duty and safeguard risk is appropriately allocated.
- Stakeholder engagement. We support clients in their engagement with the PC, the Department of Industry, the Anti-Dumping Commission and Treasury, including coordinated industry responses where appropriate.
- Post-measure compliance and review. If a safeguard measure is imposed, we assist with implementation, including system and broker readiness, mid-term review submissions, and any application for an exemption or amendment.
The safeguard investigation is a meaningful indicator of the Government's willingness to use trade policy to protect domestic industrial capacity, and it follows the broader policy trend reflected in the recent Australian Carbon Leakage Review and other industrial policy initiatives. Companies in the steel and construction supply chain should treat the period through to the interim report as a structured planning window, rather than waiting for the final report to crystallise.
If you would like to discuss how this inquiry may affect your business, please contact your usual PwC adviser.
Contact us
For further information on how these measures may affect you or your business, please contact your PwC adviser or one of the contacts listed below.
Paul Cornick
Partner, National FTC and Excise Leader, PwC Australia
Gary Dutton
Partner, National Global Trade Leader, PwC Australia
Frances Ryan
Director, Global Trade and Excise, PwC Australia
Sarah Macchiavelli
Director, Global Trade and Excise, PwC Australia
Melissa Camilleri
Director, Global Trade and Excise, PwC Australia
Lara Jobling
Director, Global Trade and Excise, PwC Australia
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