Full Text
REGD. No. D. L.-33004/99
The Gazette of India
CG-DL-E-07102025-266734
EXTRAORDINARY
PART I-Section 1
PUBLISHED BY AUTHORITY
NEW DELHI, TUESDAY, SEPTEMBER 30, 2025/ASVINA 8, 1947
MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce)
(DIRECTORATE GENERAL OF TRADE REMEDIES)
INITIATION NOTIFICATION
New Delhi, the 30th September, 2025
Case No. (SG) – 01/2025
Subject: Initiation of Bilateral Safeguard Investigation concerning imports of "Non-Phthalate Plasticizers in
the form of Dioctyl Terephthalate (DOTP) and Diethylhexyl Cyclohexane (DEHCH)" under the
India-Korea Comprehensive Economic Partnership Agreement.
F. No. 22/01/2025-DGTR.--An application has been filed under the Comprehensive Economic Partnership
Agreement (“CEPA") signed between India and Korea RP, and India-Korea Comprehensive Economic Partnership
Agreement (Bilateral Safeguard Measures) Rules, 2017 (hereinafter also referred to as the "Bilateral Safeguard Rules"
or the "Rules") by KLJ Plasticizers Limited (hereinafter also referred to as the "applicant") seeking complete
withdrawal of the concessions given with regard to Customs duty applicable on imports of Non-phthalate Plasticizers
in the form of Dioctyl Terephthalate (DOTP) and Diethylhexyl Cyclohexane (DEHCH) (hereinafter also referred to as
the "product under consideration" or the "subject goods") from Korea RP (hereinafter referred to as the "subject
country").
A. Product under Consideration and like article
1. The product under consideration is Non-Phthalate Plasticisers in the form of Dioctyl Terephthalate (DOTP) and
Diethylhexyl cyclohexane (DEHCH). Dioctyl Terephthalate is also known as Di-(2-ethylhexyl) 1,4 benzene di
carboxylate or DOTP. Diethylhexyl cyclohexane is also known as Bis(2-ethylhexyl) cyclohexane-1,4-
dicarboxylate or DEHCH. DOTP is an organic compound with the chemical formula C24H38O4. The product
can be identified by the CAS No. 6422-86-2. It is a diester of terephthalic acid and the branched-chain 2-
ethylhexanol. DEHCH, having the chemical formula of C24H44O4, can be identified by the CAS No. 84731-70-
4. It is a hydrogenated form of DOTP.
2. Non-phthalate plasticisers are of several types such as Dioctyl Terephthalate, Diethylhexyl cyclohexane,
Diisononyl cyclohexane-1,2-dicarboxylate (DINCH), Dibenzoates and Isosorbide diesters etc., However, only
two types of non-phthalate plasticizers are included in the product scope, namely Dioctyl Terephthalate
(DOTP) and Diethylhexyl cyclohexane (DEHCH).
3. The product under consideration is a colourless viscous liquid which possesses good plasticizing properties and
is used as alternative to phthalate-based plasticizers, such as, diethylhexyl phthalate and diisononyl phthalate.
The product under consideration is used as a plasticizer for PVC, and as a replacement for ortho-phthalates in a
wide range of applications. With the addition of plasticizers, PVC compounds become flexible and become
suitable for use as wire and cable insulation, roofing membranes, toys, medical devices, as well as for products
used in food packaging and processing. The product under consideration is also used in the paints and
varnishes industry and for production of high-temperature cables, automotive plastic parts and leatherette. It is
also used in paper finishing in the calendaring process and in extrusion, moulding, coatings and several ink
applications as well as being patented for use in latex compositions for hair care products.
4. Dioctyl terephthalate is manufactured from an esterification reaction wherein purified terephthalic acid and 2-
Ethyl Hexanol, in presence of a catalyst are heated in a reactor while stirring. Water is generated and separated
during the production process, which neutralises the mass. The reaction mass is neutralized after the removal of
the excess water. After such neutralisation, the soap is removed from the resultant compound, and the
compound is stripped resulting in the removal of all excess alcohol. Thereafter, the compound is dried for the
removal of moisture. Next, the compound is carbon treated in order to improve the glossiness of the same and
finally, the compound is filtered. Once the filtered cake is removed from the compound, the result of the
process is Dioctyl Terephthalate.
5. DEHCH is manufactured through a high-pressure hydrogenation process wherein pure Dioctyl Terephthalate,
in the presence of a catalyst, is stirred and hydrogenated in a reactor. The resultant reaction mass is filtered to
separate the catalyst, which is then collected for reuse in the next batch. The filtered material is known as
Diethylhexyl cyclohexane.
6. The product under consideration in Non-Phthalate Plasticisers in form of DOTP and DEHCH. Non-Phthalate
Plasticizers in form of DOTP and DEHCH have been produced by the domestic industry and imported from the
subject country during the period of investigation. DOTP and DEHCH have comparable characteristics, and
directly compete with each other. DOTP and DEHCH are easily substitutable in different applications, and are
used interchangeably by the same users in India.
7. There are no known differences in products manufactured by the domestic industry and that imported from the
subject country. The goods are comparable in terms of physical & chemical characteristics, functions & uses,
pricing, distribution & marketing, and tariff classification of the goods. The two are technically and
commercially substitutable. The subject goods produced by the domestic industry is a like article to the goods
that is imported from subject country.
8. The product under consideration falls under the category of organic chemicals under Chapter 29 and is
classifiable under tariff code 2917 20 00 and 2917 39 20. However, the goods are also imported under 2917 13
90, 2917 32 00, 2917 33 00, 2917 39 30, 2917 39 50 and 2917 39 90. The Customs classification is indicative
and is not binding on the scope of the product under consideration.
B. Domestic industry and standing
9. The application has been filed by KLJ Plasticizers Limited. In addition to the applicant, there are other
domestic producers of the like article in India, namely, Payal Polyplast Limited, Payal Plastichem Private
Limited and Rachna Plasticizers. The applicant has submitted that there are two other entities, namely, Marvel
Vinyls Limited and Vinyl Products Private Limited which are major importers of the product but may be
engaged in production of small quantities of like articles in India.
10. The application has been supported by Payal Polyplast Private Limited and Payal Plastichem Private Limited.
Based on the information provided, the applicant constitutes a major proportion of the total domestic
production of the like or directly competitive goods in India. Accordingly, the applicant constitutes domestic
industry under the provisions of Rule 2(1)(b) of the Bilateral Safeguard Rules.
C. Period of investigation
11. The period considered for the purpose of the present investigation is 1st April 2021 to 31st March 2025. The
Authority has considered 1st April 2024 to 31st March 2025 as the most recent period.
D. Subject country
12. The country involved in the present investigation is Republic of Korea ("Korea RP").
E. Increase in Subject Imports
13. The applicant has claimed that imports originating from Korea RP have increased in both absolute terms and
relative to domestic production, due to the phased reduction and elimination of custom duty on imports of the
product under consideration. The imports from the subject country have increased under such conditions that
the said imports have caused serious injury to the domestic industry. The rate of increase in imports of subject
goods is higher than the increase in rate of demand for the subject goods.
F. Serious Injury to the domestic industry
14. The applicant has claimed that the increase in imports from subject country has caused serious injury to the
domestic industry. The imports from Korea RP have increased in absolute terms and in relation to Indian
production. Such increase in imports is more than the increase in demand. The subject imports are undercutting
the prices of the domestic industry and have entered India at prices below the cost of sales of the domestic
industry. The subject imports have depressed the prices of the domestic industry. The performance of the
domestic industry has deteriorated during the period considered. In the most recent period, the domestic
industry has incurred losses, cash losses and negative return on capital employed.
15. The Authority finds that there is prima facie evidence that the imports of the product under consideration from
the subject country have increased in absolute and relative terms, causing serious injury to the domestic
industry, and there is causal link between increased imports and serious injury caused to the domestic industry.
G. Initiation of Bilateral Safeguard measures
16. Having determined that there is sufficient prima facie evidence to justify initiation of the safeguard
investigation, the Authority considers it appropriate to initiate the investigation in order to determine whether
the imports of the product under consideration from Korea RP constitute increased imports due to the phased
reduction and elimination of custom duty on imports of the product under consideration and whether the
increased imports have caused or are threatening to cause serious injury to the domestic industry.
H. Submission of information
17. All communication should be sent to the Authority via email at the email addresses jd11-dgtr@gov.in,
adv13dgtr@gov.in, dir16-dgtr@gov.in and consultant-dgtr@nic.in within 30 days from the date of this
notification as per Rule 5(4) of the India-Korea Comprehensive Economic Partnership Agreement (Bilateral
Safeguard Measures) Rules. It should be ensured that the narrative part of the submission is in searchable
PDF/MS Work format and data files are in MS Excel format.
18. It may, however, be noted that in terms of explanation of the said Rules, 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 Authority or transmitted to the appropriate diplomatic representative of Korea RP. If no information is
received within the prescribed time limit or the information received is incomplete, the Authority may record
its finding on the basis of the facts available on record in accordance with the Rules.
19. Parties interested in the investigation are hereby advised to intimate their interest (including the nature of
interest) in the instant investigation and file their questionnaire response/submissions within the time limit
specified above.
20. Interested parties are further advised to keep a regular watch on the official website of the Directorate General
of Trade Remedies (http://www.dgtr.gov.in ) for any updated information with respect to this investigation as
well as further processes related to the investigation.
21. All known interested parties are being informed separately to enable them to file the relevant information in the
form and manner prescribed within the time limit specified. Any other interested party may also make its
submissions relevant to the investigation in the form and manner prescribed within the time limit specified
above.
22. Any party making any confidential submission or providing information on confidential basis before the
Authority, is required to simultaneously submit a non-confidential version of the same. Failure to adhere to the
above may lead to rejection of the response/ submissions. 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.
23. 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.
24. The confidential version shall contain all information which is by nature confidential and/or other information
which the supplier of such information claims as confidential. For information which are claimed to be
confidential by nature or the information on which confidentiality is claimed because of other reasons, the
supplier of the information is required to provide a good cause statement along with the supplied information
as to why such information cannot be disclosed.
25. 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.
26. The non-confidential summary must be in sufficient detail to permit a reasonable understanding of the
substance of the information furnished on confidential basis. However, in exceptional circumstances, the party
submitting the confidential information may indicate that such information is not susceptible to summary, and
a statement of reasons why summarization is not possible must be provided to the satisfaction of the Authority.
In case any interested party is not satisfied on the claim of confidentiality the party can raise an objection on
the claim within seven (7) days of receiving the non-confidential version of the documents.
27. The Authority may accept or reject the request for confidentiality on examination of the nature of the
information submitted. If the Authority is satisfied, 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 in summary form, it may disregard such information.
28. Any submission made without a meaningful non-confidential version thereof or without good cause statement
on the confidentiality claim shall not be taken on record by the Authority.
29. The Authority on being satisfied and accepting the need for confidentiality of the information provided, shall
not disclose it to any party without specific authorization of the party providing such information.
I. Inspection of Public File
30. A list of registered interested parties will be uploaded on the DGTR's website along with the request therein to
email the non-confidential version of their submissions/response/information to all other interested parties.
Failure to circulate non-confidential version of submissions/response/information might lead to consideration
of an interested party as non-cooperative.
J. Non-cooperation
31. In case where an interested party refuses access to, or otherwise does not provide necessary information within
a reasonable period, or significantly impedes the investigation, the Authority may record its findings on the
basis of the facts available to it and make such recommendations to the Central Government as deemed fit.
SIDDHARTH MAHAJAN, Designated Authority
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