Analysis of the Impact of Implementing Export License Management for Seamless Pipe Products and Enterprises’ Response Strategies

Introduction: On December 12, 2025, the Ministry of Commerce and the General Administration of Customs jointly issued Announcement No. 79, deciding to adjust the "Catalog of Goods Subject to Export License Management (2025)." As a result, certain steel products have been brought under the scope of export license management, effective January 1, 2026. The list of steel products subject to export license management includes 13 major categories of seamless pipes, covering 37 commodity codes (from No. 234 to No. 270). These latest changes to seamless pipe export licenses aim to standardize seamless pipe export practices, optimize the export structure, and curb disorderly competition in low-end products. At the same time, these changes could significantly impact domestic trading enterprises involved in seamless pipe exports. Therefore, all exporting companies should adapt to these changing circumstances and make preparations well in advance.

I. Interpretation of Policy Content

According to the annex to the announcement, a total of 37 customs commodity codes cover seamless pipe products that are now subject to export license management—effectively encompassing virtually all seamless pipe products. Although no specific quota has been set for the export of seamless pipes, the addition of mandatory quality and procedural review steps will help standardize export practices from the very outset.

When exporting seamless pipe products, foreign trade operators must apply for an export license by presenting the goods export contract and the product quality inspection certificate issued by the manufacturer.

Table 1: Seamless Pipes Included in the Export License Management List

Data source: Compiled from publicly available data

II. Current Status of Seamless Pipe Exports Under the Policy

1. Increased volume, falling prices—profits flowing out of the country.

According to data from the General Administration of Customs, China's total exports of seamless pipes have been on a steady upward trend year after year. In 2023, China exported a total of 5.6645 million tons of seamless steel pipes, and this figure rose to 5.7226 million tons in 2024. From January to October 2025, exports reached 5.0817 million tons. Based on the current trend, it is expected that China’s total exports for 2025 will surpass 6 million tons. Meanwhile, from January to October, the average export price of seamless pipes was 8,547.67 yuan per ton, down 5.4% year-on-year. In contrast, the average import price of seamless pipes stood at 56,077.05 yuan per ton, highlighting a significant price gap. Although the total volume of seamless pipe exports has increased, the unit price has declined, indicating that the added value of domestically exported seamless pipe products remains relatively low. This “volume-for-price” strategy directly results in an outflow of industrial profits, further driving up seamless pipe production capacity and hindering the industry’s transition toward high-quality development.

Figure 1: Changes in Total Seamless Pipe Exports from 2023 to 2025

Data source: SteelLink Data

2. Increased risk of international trade friction

With high export volumes, the risk of trade friction is also on the rise. In July 2025, Brazil’s Foreign Trade Commission issued its final ruling in the second sunset review of the anti-dumping measures, deciding to continue imposing an anti-dumping duty of US$778.99 to US$835.47 per ton on seamless carbon steel pipes with outer diameters ranging from 5 to 14 inches originating from China, for a period of five years. This product, primarily used in oil and gas pipelines, is a category that frequently triggers trade disputes. If seamless pipe exports continue to maintain high volumes while prices decline rather than rise, such products will easily become targets of “low-price dumping” investigations.

III. Analysis of Potential Impacts on the Seamless Pipe Market

1. Short-term impact

Before the policy is officially implemented, it cannot be ruled out that some trading companies might rush to export goods. Starting December 15, 2025, companies can already apply for licenses for the 2026 fiscal year. The typical approval period for license applications is 15 days, and these 15 days will serve as a “buffer period” for the policy. As a result, there is a possibility of another surge in exports in mid-to-late December.

2. Medium- and Long-term Impacts

A significant portion of seamless pipe exports is currently conducted via “re-export trade.” After the formal implementation of the export licensing system, the quality requirements for exported seamless pipe products will become even stricter, and compliance reviews for enterprises will be more thorough. As a result, seamless pipe exports may experience a certain decline. For products that fail to meet the new requirements, exporters will shift their focus toward domestic sales. Meanwhile, once domestic demand can no longer absorb these products, some lower-quality items will be forced to withdraw from the market.

From the current structure of seamless pipe exports, seamless pipes for oil and gas applications (tariff heading 730419) and seamless casing and tubing for oil or gas drilling (tariff heading 730429) account for a significant share and serve as the “mainstay” of export business. Following the implementation of the new policy, companies will need to focus on centralized license applications. Cold-drawn or cold-rolled stainless steel seamless pipes (730441) and cold-drawn or cold-rolled alloy seamless pipes (730451), with their higher unit prices and greater added value, are better positioned to meet export requirements. As for other non-depth-processed products, the compliance costs brought about by the new regulations may weaken the competitiveness of some low-margin orders, potentially intensifying the competitive environment. Overall, the mandatory requirement for export licenses will compel seamless pipe enterprises to step up their technological R&D efforts and optimize their product offerings, thereby enhancing the quality of seamless pipe products. Meanwhile, trading companies should adopt a forward-looking approach in their product planning and adjust their export product mix accordingly.

Table 2: Export Performance of Various Domestic Seamless Pipe Categories from January to October 2025

Data source: SteelLink Data

IV. Guide to Applying for Export Licenses

December 15, 2025, to January 1, 2026, will be a critical window period for enterprises to apply for export licenses. Export-oriented businesses are advised to apply as soon as possible to respond to changes in the export situation.

The required documents mainly include the export contract for the goods and the certificate of product quality inspection issued by the manufacturer.

The issuing institutions fall primarily into the following three categories:

1. The Ministry of Commerce and its Licensing Bureau.

2. Provincial-level local commerce authorities (including all provinces, autonomous regions, municipalities directly under the central government, cities under separate planning, and the Xinjiang Production and Construction Corps).

3. The commerce authorities of certain sub-provincial-level cities designated (Shenyang, Changchun, Harbin, Nanjing, Wuhan, Guangzhou, Chengdu, and Xi'an, as listed in the document)