EU Ferroalloy Safeguards: New TRQs and Price Thresholds to Reshape Supply Chains

The European Commission has introduced new safeguard measures on imports of five ferroalloy categories, effective November 19, 2025, and running until November 17, 2028.

The rules establish a combined system of tariff-rate quotas and price thresholds that will govern the import of manganese- and silicon-based alloys into the EU over the next three years. Procurement teams, traders, and steel producers should expect tighter availability, more time-sensitive imports and greater sensitivity to price levels relative to EU thresholds.

This article summarises the scope of the regulation, how it works in practice and what operators in ferroalloys and steel should monitor as the system beds in.

The measure is defined in Commission Implementing Regulation (EU) 2025/2351, published on 19 November 2025. It responds to an investigation launched in December 2024 after several Member States raised concerns about rising import volumes and price undercutting. The Commission has framed the measure as a global safeguard under the World Trade Organisation (WTO) rules to address serious injury to EU producers.

Safeguards differ from anti-dumping or anti-subsidy action. They are emergency instruments that apply to imports from all third countries and are temporary by design. The EU has notified the WTO Committee on Safeguards accordingly. The measure covers three calendar years and must follow the WTO requirement for periodic review and potential liberalisation.

The product scope focuses on manganese- and silicon-based alloys commonly used in steelmaking and other industrial processes. The covered CN codes include:

• Ferro-manganese
  • 7202 11 (high-carbon FeMn)
  • 7202 19 (other FeMn)
• Ferro-silicon
  • 7202 21 (and related CN codes for FeSi, including those referenced under 7202 29)
• Ferro-silico-manganese
  • 7202 30
• Ferro-silico-magnesium
  • 7202 99 30

The Commission classifies the covered alloys as strategic for EU industrial resilience because of their role in steel, aluminium, chemical and solar value chains. Silicon metal and calcium-silicon, however, are not included in the final safeguard.

This exclusion followed strong resistance from the EU chemical industry, which relies heavily on silicon metal as a feedstock and argued that restrictions would heighten supply risk. Silicon metal is also a functional substitute for ferrosilicon in certain steelmaking processes, and some mills are already assessing whether a shift toward silicon metal could reduce exposure to the new ferrosilicon constraints.

Quarterly Tariff-Rate Quotas

The core mechanism is a set of country-specific TRQs for each product category. The system works as follows:

• Each exporting country receives an annual duty-free quota for each alloy, published in Annex III of Commission Implementing Regulation (EU) 2025/2351.
• These annual allocations are split into four equal quarterly tranches, which define the available duty-free volumes per period. For example, Annex III lists Brazil’s ferro-silicon TRQs at 6,316 tonnes in the first quarter of Year 1, and India’s ferro-silico-manganese TRQs at 31,959 tonnes in the same period.
• Imports that fall within a country’s quarterly quota enter the EU duty-free, regardless of price.

The quota levels are intentionally restrictive. The Commission has set volumes that reduce duty-free imports to roughly 75% of average import levels from 2022 to 2024. This aligns with industry analyses indicating a 25% decline in duty-free access.

Furthermore, two important operational constraints apply:

• No quarterly rollover: Unused TRQ volume at the end of a quarter does not transfer to the next.
• No annual carryover: Unused annual quota is lost and cannot be transferred into the next year.

This structure incentivises steady shipping patterns. It reduces the ability to compress shipments into late-quarter or late-year windows.

Once a country’s quarterly TRQ is exhausted, any further imports must pass a price test.

There are two possible outcomes:

1. If the declared customs price is at or above the EU price threshold, the shipment can still enter duty-free.
2. If the declared price is below the threshold, the importer must pay a “top-up” duty equal to the difference between the declared price and the threshold.

The official threshold levels are published in Annex II. They define the minimum prices for out-of-quota imports.

For example:

• If FeSi arrives at 2,000 €/mt, and the threshold is 2,408 €/mt, the duty payable would be ~408 €/mt.
• If FeSi arrives at 2,500 €/mt, no duty applies.

This structure functions as a variable price floor for out-of-quota shipments, while allowing higher-priced or specialty materials to continue flowing.

The safeguard is global in formal terms, although the practical impact varies across origins. The most visible effects will fall on suppliers with significant, commercially relevant flows into the EU.

For some products, such as ferro-silicon, imports from China are already very limited due to existing anti-dumping duties, so the safeguard changes little in practice for Chinese-origin FeSi. For ferro-manganese, silico-manganese and silico-magnesium, however, the Commission identifies India, Kazakhstan and several other exporters as key contributors to the price pressure faced by EU producers.

Norway and Iceland, despite being EEA members, are also subject to the safeguard because ferroalloys are not covered by EEA free-movement provisions. Both countries supply large volumes to the EU, especially Norway, for FeSi and SiMn. The Commission has committed to quarterly consultations with them, and there is a possibility that Norway will challenge the measure on the grounds that it is incompatible with its EEA relationship.

For EU steelmakers, foundries, aluminium producers and chemical users, the impact will materialise through higher alloy input costs, particularly in quarters where TRQs tighten, and out-of-quota shipments fall below the EU’s price thresholds. Supply is still available, but the cost of discounted imports is likely to rise, which increases the importance of timing, supplier diversification and closer monitoring of price dynamics.

The Commission’s investigation highlighted many aspects, summarised in these five reasons:

1. Import surge: Imports of the covered ferroalloys into the EU rose by about 17% between 2019 and 2024.
2. Market share loss: EU producers’ market share fell from around 38% to 24% over the same period.
3. Price undercutting: EU producers are consistently undercut by significantly cheaper imports, particularly from China, India and Kazakhstan.
4. Global overcapacity & trade diversion: The global overcapacity and import restrictions in other regions are redirecting ferroalloy flows into the EU, exacerbating the injury.
5. Strategic importance: Ferro-manganese and silicon-based alloys are considered critical for EU industrial resilience, highlighting their role in the construction, automotive, aerospace, defence, aluminium, and solar/chemical industries.

The Commission concluded that EU producers were experiencing serious injury and that safeguard action served the broader Union interest, even with acknowledged cost impacts for downstream industries.

EU Ferroalloy Producers

EU producers stand to benefit most directly from the safeguard. Reduced duty-free import volumes and the introduction of minimum price thresholds are expected to lift market prices and improve producer profitability, particularly for plants operating with higher European energy and carbon costs. The measure provides breathing room for utilisation, reinvestment and operational stability.

The group most negatively affected on the supply side will be EU-based traders who import ferroalloys from non-EU origins and resell into the European market. Their business model depends on access to competitively priced imports, which becomes more constrained once quarterly TRQs tighten and lower-priced out-of-quota shipments face additional duties.
Safeguards remain temporary under WTO rules, and the Commission is required to review and potentially liberalise them over time, so the measure should be viewed as a transitional intervention rather than a permanent restructuring of the market.

Importers, Traders and Foreign Producers

The safeguard introduces a set of commercial risks for non-EU ferroalloy producers, EU-based importers and trading houses, particularly those supplying the bulk grades covered by the measure. Their exposure centres on three operational areas:

1. Quota availability: Quarterly quotas create sensitivity to timing. Early-quarter front loading is likely, and securing quota allocation becomes commercially important.
2. Price risk relative to thresholds: Sales priced below the threshold can quickly become unviable once a quota closes. Margins will increasingly depend on positioning against these thresholds.
3. Destination management: Suppliers may divert shipments to other regions when EU margins narrow. Traders may explore alternative routing, product switching or blending, although these raise compliance considerations under customs and classification rules.

EU Steelmakers and Downstream Users

Downstream users should prepare for:

• Higher input costs once TRQs are filled
• More active procurement planning around quarterly quota cycles
• Increased use of price transparency tools to assess the viability of out-of-quota imports

The measure is designed to avoid cutting off the supply entirely. High-priced or urgent deliveries can continue without additional duty, but discounted flows will face barriers.

As a global safeguard, the measure is subject to WTO oversight. Exporting countries may challenge the EU’s analysis on causation or proportionality.

The EU has already signalled that it will conduct periodic reviews and may adjust quotas or thresholds if market conditions shift. Consultations with Norway and Iceland will be held quarterly due to their EEA relationship.

The coming months will show how the safeguard plays out in practice. Market participants should monitor:

• Quarterly TRQ usage: How quickly quotas fill for each country and alloy category. TRQ trackers from Argus, S&P Global and specialist services will be important sources.
• Price levels relative to thresholds: The balance between duty-free and duty-paid flows will depend on where spot and contract prices sit against the EU’s official thresholds. Early data already shows FeSi and FeMn prices on Metalshub’s indices moving higher, reflecting tighter expectations for landed cost and quota availability.
• Adjustments under pressure from downstream users: Steel, chemicals and automotive manufacturers may push for quota or threshold adjustments if supply becomes tight.
• WTO consultations and potential disputes: Outcomes could influence the structure or duration of the measure.

The safeguard is likely to influence seasonal shipment cycles and increase the need for transparent data on quota utilisation and price dynamics.

Digital procurement tools, structured bidding, and real-time visibility, such as those available on the Metalshub platform, will become increasingly important as ferroalloy flows adjust to the new rules.