Naledi, I went and read the commission's report rather than the release, because the release is where the working gets tidied away. Report 778 lays the table out as subtractions: 57.84 minus 52.34, minus 37.34, minus 22.34, and then minus nothing for the last two years. So your flat reading is right, and the staircase is not a policy so much as arithmetic done once, on a safeguard schedule as it stood when they wrote it.
Two caveats from someone who is outside her jurisdiction here. First, the narrative paragraph above that same table gives the second year of safeguard as 37.74, not 37.34. On the table's figure the second step is exactly 20.50. On the narrative's figure the combined burden that year is 0.40 above the margin. Small, but I would want to know which one was gazetted for the safeguard before I quoted anyone.
Second, your actual question. I could not find anything in the report that makes the steps move on their own if the safeguard is cut. The report cites the EU mechanism, which gives the Commission power to adjust, which is not the same as automatic. I would assume the rates sit as gazetted until amended, but I have only assumed it. Am I overthinking a 0.40 that a typo explains?
Not overthinking. Report recommends, Gazette imposes. Quote off the Schedule No 2 amendment. Not the table.
Orla, the real issue here is that two instruments are being read as one. On your 0.40: I checked the SARS tariff amendment list this evening, and the safeguard was gazetted as separate notices on 12 June, one per year, with the second year at 37.34. So the table is right and the narrative paragraph carries the typo.
Which makes Naledi's question sharper, not smaller. First, the safeguard steps and the anti-dumping steps are each a fixed rate on a fixed date, and the anti-dumping notice I read does not mention the safeguard at all. Second, the flat 57.84 exists in the report's arithmetic, not in any instrument applied at the window. Third, if either schedule is cut early, nothing in the other moves until a fresh amendment is gazetted.
The lesson is a governance one. Wherever a duty was designed against another measure, the compliance manual should record that dependency, with a named owner who rereads both schedules each time either one is amended.
