Full Text
REGD. No. D. L.-33004/99
The Gazette of India
CG-DL-E-04102025-266664
EXTRAORDINARY
PART I—Section 1
PUBLISHED BY AUTHORITY
No. 282]
NEW DELHI, MONDAY, SEPTEMBER 29, 2025/ASVINA 7, 1947
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[PART I-SEC.1]
MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce)
(DIRECTORATE GENERAL OF TRADE REMEDIES)
INITIATION NOTIFICATION
New Delhi, the 29th September, 2025
Case No. AD (OI)-36/2025
Subject: Initiation of an anti-dumping investigation concerning imports of Sublimation Paper
originating in or exported from China PR and Korea RP.
F. No. 6/41/2025 -DGTR.—1. Having regards to the Customs Tariff Act, 1975 as amended from
time to time (hereinafter also referred as the “Act") and the Customs Tariff (Identification,
Assessment, and Collection of Anti-Dumping Duty on Dumped Articles and for Determination of
Injury) Rules, 1995 thereof, as amended from time to time (hereinafter also referred to as the
"Rules"), an application has been filed by M/s GT Papers, M/s Hi Tech Papers and M/s Zibo Paper
Industries before the Designated Authority (hereinafter also referred to as the “Authority") for
initiation of an anti-dumping investigation concerning imports of Sublimation Paper (hereinafter also
referred to as the “subject goods" or the "product under consideration"), originating in or exported
from China PR and Korea RP (hereinafter also referred to as the “subject countries").
2. The applicants have alleged that material injury is being caused to the domestic industry due to the
alleged dumping of imports of the product under consideration originating in or exported from the
subject countries. Accordingly, the applicants have requested for the imposition of anti-dumping duty
on imports of the subject goods originating in or exported from the subject countries.
A. Product under consideration
3. The product under consideration in the present investigation is Sublimation Paper. It is also known as
sublimation transfer paper, heat transfer paper, paper for digital textile printing, wood grain transfer
paper, and thermal transfer paper in the market parlance.
4. In order to manufacture the subject goods, high quality paper with low porosity and high dimensional
stability, is coated in a solution made of inorganic pigments, binders, surfactants and other materials
evenly on both sides of the paper. The coated paper passes through drying ovens that cure the coating
and the dried paper is then pressed through rollers to achieve desired smoothness, finish and
thickness.
5. Sublimation Paper is majorly used as a specialty printing material in textile and garment printing,
personalized products, promotional merchandize, ceramic tiles, phone covers, mugs and tumblers,
puzzles, mouse pads, photo gifts and signage. It is used to transfer ink to polyester or its blends. It is
a coated transfer paper engineered to temporarily retain sublimation dye-based inks in printed form
and facilitate their efficient release onto a compatible substrate via a thermal transfer process. The
product under consideration can be either made of hardwood pulp or recycled paper.
6. For the purpose of the present investigation, the Authority has considered square meters as the unit of
measurement.
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7. The subject goods are classified under Chapter 48 of the Customs Tariff Act under the tariff code
4809 9000, 4810 2200 and 4810 2900. However, as per information on record, the subject goods
have been imported under a number of codes, including 4802 1010, 4807 0090, 4808 9000, 4810
1390, 4810 1490, 4810 1990, 4810 99 00, 4811 4900, 4811 9099, 4816 9090, 4821 9090, 4823 6900,
4823 7090 and 4823 9090. The Customs classification is only indicative and is not binding on the
scope of the product under consideration.
8. The following product control numbers (PCNs) have been proposed by the applicants for the purpose
of the present investigation, considering the difference in terms of cost and price.
| S.No. | PCN Parameter | Code |
| :---- | :------------------------------------------------------- | :--- |
| 1. | GSM upto 34 | A |
| 2. | GSM including and more than 34 but upto and including 40 | B |
| 3. | GSM more than 40 | C |
B. Like Article
9. The applicants have claimed that the subject goods produced by the domestic industry are identical to
the subject goods exported from the subject countries. The subject goods produced by the domestic
industry have comparable characteristics to the subject goods imported from the subject countries in
terms of technical specifications, physical and chemical characteristics, manufacturing process and
technology, functions and uses, pricing, distribution and marketing and tariff classification. The two
are technically and commercially substitutable. Therefore, for the purpose of initiation of the present
investigation, the subject goods produced by the applicants are being treated as ‘like article' to the
subject goods originating in or exported from the subject countries.
C. Domestic Industry and Standing
10. The application has been filed by M/s GT Papers, M/s Hi Tech Papers and M/s Zibo Paper
Industries. The application has been supported by three (3) other producers of the subject goods,
namely, Elysium Industries Private Limited, Shrinathji Marketing Company and Silver Papercoats
Private Limited. Further, Elysium Industries India Private Limited and Silver Papercoat Private
Limited are related to the importers of dumped article in India.
11. The applicants have submitted that they have not imported the subject goods from the subject
countries during the period of investigation and they are not related to the exporters of the subject
goods in the subject countries or importers of the subject goods in India.
12. The applicants have claimed that even if Elysium Industries India Private Limited and Silver
Papercoat Private Limited are considered as eligible to constitute domestic industry, the applicants
account for major proportion of the total Indian production at 34%. The applicant, along with
supporters account for 55% of the total domestic production in India. Thus, the Authority prima facie
notes that the applicants constitute domestic industry under Rule 2(b), and the application satisfies
the requirement of standing in terms of Rule 5(3) of the Anti-Dumping Rules.
D. Subject Countries
13. The application has been filed in respect of dumped imports of the product under consideration from
China PR and Korea RP.
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E. Period of Investigation
14. The Authority has considered 1st April 2024 to 31st March 2025 (12 months) as the period of
investigation. The injury investigation period shall cover the period 1st April 2021–31st March 2022,
1st April 2022- 31st March 2023, 1st April 2023 – 31st March 2024 and the period of investigation.
F. Basis of alleged dumping
Normal value for China PR
15. The applicants have cited and relied upon Article 15(a)(i) of China's Accession Protocol and para 7
of the Annexure I to the AD Rules, and have claimed that China PR should be treated as a non-
market economy and that producers from China PR should be directed to demonstrate that market
economy conditions prevail in the industry with regard to the production and sales of the subject
goods. Unless the producers from China PR show that such market economy conditions prevail, their
normal value should be calculated in terms of provisions of para 7 and 8 of Annexure I to the Anti-
dumping Rules, 1995.
16. The normal value, for the purpose of initiation of the present investigation, has been constructed
based on the price payable in India, which is based on the cost of production of the domestic
industry, adjusted for selling, general and administrative expenses plus reasonable profits.
Normal value for Korea RP
17. With respect to Korea RP, the applicants have submitted that they did not have access to information
with regards to selling prices, or any other information with regard to the prevailing prices in Korea
RP. Therefore, the normal value has been determined on alternative basis. The applicants have
further stated that they did not have access to the actual cost of production of the producers in Korea
RP and thus, such information has been determined based on best available information. The
applicants have determined normal value based on cost of production with addition of general,
selling and administrative expenses and reasonable profits, as per available information. The normal
value, for the purpose of initiation of the present investigation, has been constructed based on the
cost of production of the domestic industry, adjusted for selling, general and administrative expenses
plus reasonable profits.
Export price
18. The export price of the subject goods has been determined by considering CIF price of the subject
goods, as reported in the DG Systems data. Price adjustments have been made on account of ocean
freight, marine insurance, commission, port and handling expenses, inland freight, bank charges,
credit cost and inventory carrying costs to arrive at ex-factory export price.
Dumping margin
19. The dumping margin has been determined, in accordance with Section 9A(1)(a) of the Customs
Tariff Act. The normal value and export price of the subject goods have been compared at the ex-
factory level, which prima facie shows that the dumping margin is not only above the de-minimis
level but is also significant in respect of imports of product under consideration from the subject
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countries. Thus, there is prima facie evidence that the product under consideration is being dumped
in the Indian market by the exporters from the subject countries.
G. Injury and Causal Link
20. The information furnished by the applicants has been considered for assessment of injury to the
domestic industry. The applicants have furnished prima facie evidence with respect to the injury
suffered because of the alleged dumped imports. The information concerning imports and economic
parameters of the domestic industry over the injury period show that the imports have increased
significantly in absolute terms and in relation to production and consumption in India. The subject
imports are undercutting the prices of the domestic industry and are priced below the cost of sales of
the domestic industry. The performance of the domestic industry has been adversely impacted in
respect of market share, inventories and profitability. The profits, cash profit and return on capital
have declined over the injury period. There is sufficient prima facie evidence that the injury is being
caused to the domestic industry by dumped imports from the subject countries.
H. Initiation of Anti-Dumping Investigation
21. On the basis of the duly substantiated application filed by the domestic industry, and having satisfied
itself, on the basis of the prima facie evidence submitted, substantiating dumping of the product
under consideration from the subject countries, injury to the domestic industry and a causal link
between such dumping and injury, and in accordance with Section 9A of the Act read with Rule 5 of
the Rules, the Authority, hereby, initiates an investigation to determine the existence, degree, and
effect of the dumping with respect to the product under consideration originating in or exported from
the subject countries and to recommend the appropriate amount of anti-dumping duty, which if
levied, would be adequate to remove the injury to the domestic industry.
I. Procedure
22. The provisions stipulated in Rule 6 of the Anti-Dumping Rules shall be followed in the present
investigation.
J. Submission of Information
23. All the communications should be sent to the Designated Authority via email at email address dd15-
dgtr@gov.in, dir16-dgtr@gov.in and adv13-dgtr@gov.in. It should be ensured that the narrative part
of the submission is in searchable PDF/ MS Word format and data files are in MS Excel format.
Submissions requiring special software to access the files will not be accepted
24. The known producers/exporters in the subject countries, the governments of the subject countries
through their embassies in India, and the importers and users in India known to be concerned with
the subject goods are being informed separately to enable them to file all the relevant information in
the form and manner prescribed within the time limit set out below.
25. Any other interested party may also make its submissions relevant to the investigation in the form
and manner prescribed within the time limit set out below. Any party making any confidential
submission before the Authority is required to make a non-confidential version of the same available
to the other parties.
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K. Time Limit
26. Any information relating to the present investigation should be sent to the Designated Authority via
email at the following email addresses dd15-dgtr@gov.in, dir16-dgtr@gov.in and adv13-
dgtr@gov.in within 30 days from the date on which it was sent by the Designated Authority or
transmitted to the appropriate diplomatic representative of the exporting country as per Rule 6(4) of
the AD Rules. It may, however, be noted that in terms of explanation of the said Rule, the notice
calling for information and other documents shall be deemed to have been received within one week
from the date on which it was sent by the Designated Authority or transmitted to the appropriate
diplomatic representative of the exporting countries. If no information is received within the
prescribed time limit or the information received is incomplete, the Authority may record its findings
on the basis of the facts available on record in accordance with the AD Rules.
27. All the interested parties are hereby advised to intimate their interest (including the nature of interest)
in the instant matter and file their questionnaire responses within the above time limit.
28. Where an interested party seeks additional time for filing of submissions, it must demonstrate
sufficient cause for such extension in terms of Rule 6(4) of the AD Rules 1995 and such request must
come within the time stipulated in this notification.
L. Submission of Information on a Confidential Basis
29. Any party making any confidential submission or providing information on a confidential basis
before the Authority, is required to simultaneously submit a non-confidential version of the same in
terms of Rule 7(2) of the AD Rules. Failure to adhere to the above may lead to the rejection of the
response / submissions.
30. The parties making any submission (including Appendices/Annexures attached thereto), before the
Authority including questionnaire response, are required to file Confidential and Non-Confidential
versions separately. In case, the submission is made in multiple parts, it is instructed to provide an
index table in each part outlining the contents of all parts/emails and documents enclosed. Please
ensure page numbering on all submissions.
31. Where the original documents are in a language other than Hindi and English, the interested parties
are requested to ensure that the true translated version is provided along with the original documents
32. The "confidential” or “non-confidential" submissions must be clearly marked as “confidential” or
“non-confidential" at the top of each page. Any submission made without such marking shall be
treated as non-confidential by the Authority, and the Authority shall be at liberty to allow the other
interested parties to inspect such submissions.
33. The non-confidential version is required to be a replica of the confidential version with the
confidential information preferably indexed or blanked out (in case indexation is not feasible) and
summarized depending upon the information on which confidentiality is claimed. The non-
confidential summary must be in sufficient detail to permit a reasonable understanding of the
substance of the information furnished on a confidential basis. However, in exceptional
circumstances, the party submitting the confidential information may indicate that such information
is not susceptible to a summary, and a statement of reasons why summarization is not possible must
be provided to the satisfaction of the Authority. The other interested parties may offer their
comments on the confidentiality claimed within 7 days of receiving the non-confidential version of
the documents.
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34. The Authority may accept or reject the request for confidentiality on examination of the nature of the
information submitted. If the Authority is satisfied that the request for confidentiality is not
warranted or if the supplier of the information is either unwilling to make the information public or
to authorize its disclosure in generalized or summary form, it may disregard such information
35. Any submission made without a meaningful non-confidential version thereof or a good cause
statement on the confidentiality claim shall not be taken on record by the Authority.
36. The interested parties can offer their comments on the issues of confidentiality claimed by the
domestic industry within 7 days from the date of circulation of the non-confidential version of the
documents in terms of relevant paragraphs of this initiation notification.
37. The Authority on being satisfied and accepting the need for confidentiality of the information
provided, shall not disclose it to any party without specific authorisation of the party providing such
information
M. Inspection of Public File
38. A list of registered interested parties will be uploaded on DGTR's website along with the request
therein to all of them to email the non-confidential version of their submissions to all other interested
parties. The non-confidential version of the questionnaire response or other submissions should
preferably be circulated to all other interested parties on the same day and, in no case, later than the
day following the filing of submissions on a confidential basis. Failure to circulate a non-confidential
version of submissions/responses/information might lead to the consideration of an interested party
as non-cooperative.
N. Non-cooperation
39. In case any interested party refuses access to and otherwise does not provide necessary information
within a reasonable period, or significantly impedes the investigation, the Authority may declare
such interested party as non-cooperative and record its findings based on the facts available to it and
make such recommendations to the Central Government as deemed fit
SIDDHARTH MAHAJAN, Designated Authority