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REGD. No. D. L.-33004/99
The Gazette of India
CG-DL-E-21032026-271107
EXTRAORDINARY
PART I-Section 1
PUBLISHED BY AUTHORITY
No. 66]
NEW DELHI, THURSDAY, MARCH 19, 2026/PHALGUNA 28, 1947
1966 GI/2026
(1)
MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce)
(DIRECTORATE GENERAL OF TRADE REMEDIES)
INITIATION NOTIFICATION
New Delhi, the 19th March, 2026
Case No. AD(OI) - 08/2026
SETU Case ID No. - AD/OI/009/2026
Subject: Initiation of an anti-dumping investigation concerning imports of “Methyl Chloroformates (MCF) in
any concentration” originating in or exported from China PR.
1. F. No. 6/08/2026 -DGTR.—Having regard to the Customs Tariff Act, 1975 as amended from time to time
(hereinafter referred to as the "Act") and the Customs Tariff (Identification, Assessment and Collection of Anti-
dumping duty on Dumped Articles for Determination of Injury) Rules, 1995 as amended from time to time
(hereinafter referred to as the “Rules" or the "Anti-dumping Rules"), M/s. Paushak Limited, M/s Superform
Chemistries Limited and UPL Limited (hereinafter also referred to as the “applicants") has filed an application
before the Designated Authority (hereinafter referred to as the “Authority”), for initiation of an anti-dumping
investigation concerning imports of "Methyl Chloroformate” (hereinafter referred to as “subject goods" or
"product under consideration” or “PUC”), originating in or exported from China PR (hereinafter referred to as
"subject country")
2. The applicants have alleged that dumped imports of the subject goods from the subject country are causing
material injury and has requested the imposition of anti-dumping duty on the imports of the subject goods from
the subject country.
A. PRODUCT UNDER CONSIDERATION
3. The product under consideration in the present application is "Methyl Chloroformate (MCF) in any
concentration."
4. MCF is an organic chemical compound. It is a colourless, volatile liquid with a pungent odour. Methyl
Chloroformate is widely used as an intermediate in organic chemical intermediates and widely finds its usage
in the pharmaceutical and agrochemical industries. It belongs to the class of chloroformates and contains both
an ester and a chloro functional group, making it highly reactive. Due to its corrosive and toxic nature, methyl
chloroformate is classified as hazardous, posing risks through inhalation, ingestion, and skin contact.
B. Unit of measurement
5. The prescribed unit of measurement for the product under consideration is Metric Tons (MT) or Kilogram
(Kg).
C. Tariff classification
6. The applicants have informed that the product under consideration (PUC) does not have a dedicated HS code.
The product is presently imported under various tariff headings under Chapter 29 of the Customs Tariff Act
specially under the sub-headings 2915 12 90. The applicants have also alleged that the product under
consideration is also imported under the code 2915 13 00, 2915 90 99 and 2933 39 90. However, the customs
classification is indicative only and not binding on the scope of the product under consideration.
7. The applicants have not proposed any product control numbers (PCN) methodology in its application. The
parties to the present investigation may provide their comments on the scope of PUC and propose product
control numbers (PCN) methodology, if any, within 15 days of circulation of the receipt of intimation of
initiation of the investigation.
B. LIKE ARTICLE
8. The applicants have stated that there are no significant differences in the article produced by the applicants and
exported from the subject country. The article produced by the applicants and that imported from the subject
country is comparable in terms of physical and chemical characteristics, manufacturing process and technology,
functions and uses, product specifications, pricing, distribution and marketing, and tariff classification of the
subject goods. The subject goods and the article manufactured by the applicants are technically and
commercially substitutable. The applicants have claimed that the consumers of the product under consideration
are using the subject goods and the article manufactured by the applicants interchangeably. Thus, for the
purposes of initiation of the present investigation, the article produced by the applicants have been prima facie
considered as like article to the product being imported from the subject country.
C. SUBJECT COUNTRY
9. The subject country in the present investigation is China PR.
D. PERIOD OF INVESTIGATION (POI)
10. The Authority has considered the period from 1st October 2024 to 30th September 2025 (12 months) as the
period of investigation (POI) for the present investigation (hereinafter referred to as “POI"). The injury
investigation period shall cover the period 1st April 2022 to 31st March 2023, 1st April 2023 to 31st March 2024,
1st April 2024 to 31st March 2025 and the period of investigation.
E. DOMESTIC INDUSTRY AND STANDING
11. The application has been filed by M/s. Paushak Limited, UPL Limited and Superform Chemistries Limited. The
applicants have submitted that they have not imported the subject goods from the subject county and is not
related to producers and exporters from the subject country. The applicants have submitted that they are the only
domestic producer and accounts for 100% of the total production of the subject goods in India.
12. The applicants have submitted that UPL Limited commenced the production of PUC in the month of June 2024
at Dahej Plant and from June 2024 to November 2024, UPL produced the subject goods. December 2024
onwards PUC was produced by Superform Chemistries Limited pursuant to its transfer of speciality chemicals
business by UPL Limited to Superform Chemistries Limited. Paushak Limited produced the PUC throughout
the injury period and POI.
13. The applicants constitute domestic industry within the meaning of Rule 2(b) of the ADD Rules, 1995 and the
application satisfies the requirements of standing under Rule 5(3) of the AD Rules, 1995
F. BASIS OF ALLEGED DUMPING
a) Normal Value for China
14. The applicants have claimed that China PR should be treated as a non-market economy and the normal value
should be determined in terms of Rule- 7 of Annexure I of the Rules. The applicants have cited Para 8(2) of
Annexure I of the Rules and has stated that the Chinese producers should be directed to demonstrate that market
economy conditions prevail in the industry producing the subject goods in terms of Para 8(3) of Annexure I of
the Rules. The applicants have claimed that for China PR, normal value should be determined in accordance
with Para 7 and 8 of Annexure I of the Rules.
15. The applicants have submitted that efforts were made to determine normal value on the basis of price or
constructed value in a market economy third country. However, the applicants could not get reliable information
regarding the information on price or cost in market economy in a third country. Therefore, the normal value
has been constructed based on cost of production of the applicant, duly adjusted for selling, general and
administrative expenses, with reasonable profit. The same has been considered for the purpose of initiation of
the investigation.
b) Export Price
16. The export price of the product under consideration has been determined by considering the CIF price of the
product under consideration as reported in DG System data. Adjustments have been made for ocean freight,
inland freight, marine insurance, handling charges, port expenses, dealers commission and bank charges.
c) Dumping Margin
17. The normal value and the export price have been compared at ex-factory level, which prima facie shows that
the dumping margin is above the de-minimis level and is significant with respect to the product under
consideration exported from the subject country. Thus, there is prima facie evidence that the product under
consideration from the subject country is being dumped in the Indian market by the exporters from the subject
country.
G. EVIDENCE OF INJURY AND CAUSAL LINK
18. The applicants have provided prima facie evidence with respect to the injury suffered by the domestic industry
due to the dumped imports. The volume of the subject imports from the subject country has increased during
the injury period. There is evidence of price suppression and price depression due to imports. The subject imports
have had an adverse impact on the profitability parameters of the domestic industry.
19. From the foregoing, the Authority prima facie finds sufficient evidence of dumping of the subject goods
originating in or exported from the subject country, injury to the domestic industry and causal link between the
alleged dumping and injury exist to justify initiation of an anti-dumping investigation in terms of Rule 5 of the
Rules, to determine the existence, degree, and effect of alleged dumping and to recommend the amount of anti-
dumping duty, which if levied, would be adequate to remove injury to the domestic industry.
H. INITIATION OF ANTI-DUMPING INVESTIGATION
20. On the basis of the duly substantiated written application submitted by the applicants and having reached
satisfaction based on the prima facie evidence submitted by the applicants concerning the dumping of the
product under consideration originating in or exported from the subject country, the consequential injury to the
domestic industry as a result of the alleged dumping of the product under consideration and the causal link
between such injury and the dumped imports, and in accordance with Section 9A of the Act read with Rule 5 of
the AD Rules, the Authority, hereby, initiates an anti-dumping 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 country 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
21. The provisions stipulated in Rule 6 of the Anti-Dumping Rules shall be followed in this investigation.
J. SUBMISSION OF INFORMATION
22. All the interested parties are required to register themselves on SETU Portal (https://setu.dgtr.gov.in). All
communications and submissions from the interested parties shall be uploaded on the SETU portal under their
registered name and corresponding SETU Case ID – AD/OI/009/2026. 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.
23. The known producers/exporters in the subject country, the government of subject country through its Embassy
in India, and the importers and users in India who are known to be associated with the product under
consideration are being informed separately to enable them to file all the relevant information within the time
limits mentioned in this initiation notification. All such information must be filed in the form and manner as
prescribed by this initiation notification, the Rules, and the applicable trade notices issued by the Authority.
24. Any other interested party may also make a submission relevant to the present investigation in the form and
manner as prescribed by this initiation notification, the Rules, and the applicable trade notices issued by the
Authority within the time limits mentioned in this initiation notification.
25. Any party making any confidential submission before the Authority is required to make a non-confidential
version of the same available to the other interested parties.
26. The interested parties are further advised to keep a regular watch on the official website of the Directorate
General of Trade Remedies at www.dgtr.gov.in and SETU portal (https://setu.dgtr.gov.in) for any updated
information with respect to this investigation. Interested parties are directed to regularly visit the website of
DGTR (https://www.dgtr.gov.in/) to stay apprised with the further developments in the subject investigation
and remain informed regarding notices that may be issued from time to time regarding questionnaire formats,
PCN methodology, PCN discussion/meeting schedule, notice of oral hearing, corrigendum, amendment
notifications, and other such information.
K. TIME LIMIT
27. Any information relating to the present investigation should be uploaded on the SETU portal
(https://setu.dgtr.gov.in) under their registered name and corresponding SETU Case ID – AD/OI/ 009/2026.
28. Both versions of each submission, the confidential version (CV) and the non-confidential version (NCV) must
be uploaded in the respective designated columns within 37 days from the date on which the nonconfidential
version of the application filed by the domestic industry would be circulated by the Authority or transmitted to
the appropriate diplomatic representative of the exporting country as per Rule 6(4) of the AD Rules, 1995. If no
information is received within the stipulated time limit or the information received is incomplete, the Authority
may record its findings based on the facts available on record and in accordance with the AD Rules, 1995.
29. 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 as stipulated in this notification
through SETU portal only.
30. The 15-day period to file comments on the scope of the PUC/ PCN Methodology shall run concurrently with
the time limit mentioned in para 28 above of this Initiation Notification.
31. Extension due to Modification of PUC/PCN: An extension of time by 15 days shall be granted if the Authority,
through a subsequent notice, modifies the PUC, and PCN that was not previously proposed or is different from
the initiation notification. This extension of 15 days shall be granted from date of such notification of modified
PUC and PCN. Extension of time by 15 days stated in this paragraph is not applicable in instances where there
is no change in the PUC, and PCN methodology after initiation of investigation. Requests for a further
extension of time, beyond the 15-day extension (if granted), will ordinarily not be considered except in case of
exceptional circumstances, in line with the Rule 6(4) of the AD Rules.
32. Any request for an extension must be submitted by the concerned parties through the SETU portal at least one
day before the original deadline specified above. Requests submitted after this time will not be considered.
L. SUBMISSION OF INFORMATION ON CONFIDENTIAL BASIS
33. Where any party to the present investigation makes confidential submissions or provides information on a
confidential basis before the Authority, such party is required to simultaneously submit a non-confidential
version of such information in terms of Rule 7(2) of the Rules and in accordance with the relevant trade notices
issued by the Authority in this regard. Failure to adhere to the above may lead to rejection of the
response/submissions.
34. The parties making any submission (including Appendices/ Annexures attached thereto), before the Authority
including questionnaire responses, are required to file confidential and non-confidential versions separately.
35. Such submissions must be clearly marked as 'confidential' or 'non-confidential' at the top of each page. Any
submission that has been made to the Authority without such markings shall be treated as 'non-confidential'
information by the Authority, and the Authority shall be at liberty to allow other interested parties to inspect
such submissions.
36. 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 the information which is
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.
37. The non-confidential version of the information filed by the interested parties is required to be a replica of the
confidential version with the confidential information preferably indexed or blanked out (where indexation is
not possible) and such information must be appropriately and adequately 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 summary, and a statement of reasons containing a sufficient and adequate
explanation as to why such summarization is not possible, must be provided to the satisfaction of the Authority.
38. The interested parties can offer their comments on the issues of confidentiality within 7 days from the date of
circulation of the non-confidential version of the documents.
39. 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.
40. Any submission made without a meaningful non-confidential version thereof or a sufficient and adequate cause
statement in terms of Rule 7 of the Rules, and appropriate trade notices issued by the Authority, on the
confidentiality claim shall not be taken on record by the Authority.
M. INSPECTION OF PUBLIC FILE
41. All non-confidential versions of submissions made by any interested party will be accessible to other interested
parties through their respective login on the SETU portal.
N. NON-COOPERATION
42. In case any interested party refuses access to and otherwise does not provide necessary information within a
reasonable period or within the time stipulated by the Authority in this initiation notification, or significantly
impedes the investigation, the Authority may declare such interested party as non-cooperative and record its
findings based on the facts available and make such recommendations to the Central Government as it deems
fit.
AMITABH KUMAR, Designated Authority
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.
GORAKHA NATH
YADAVA
Digitally signed by GORAKHA
NATH YADAVA
Date: 2026.03.21 10:03:21 +05'30'
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