Full Text
2085 GI/202 6 (1)
EXTRAORDINARY
PART I —Section 1
PUBLISHED BY AUTHORITY
No. 90] NEW DELHI SATURDAY , MARCH 21, 2026/PHALGUNA 30, 1947
CG-DL-E-25032026-271266
2. कोई अन्य *** *** *** *** 45-55
10-20
10-20
20-30
10-20
जलजमटेड *** *** *** *** 0-10
7 कोई अन्य *** *** *** *** 20-30
2. कोई अन्य *** *** *** *** 20-30
कुल मांग एमटी 6,10,344 7,72,898 8,03,441 8,63,953
अन्य देि एमटी 27,035 35,193 38,311 39,080
कुल आयात एमटी 41,642 62,734 56,561 80,799
खपत % 2% 4% 2% 5%
मांग एमटी 6,10,344 7,72,898 8,03,441 8,63,953
पहुंच कीमत रु./एमटी 1,47,411 1,44,150 1,24,911 1,22,910
उत्पादि एमटी 3,36,103 3,86,596 4,26,713 4,04,405
ददि 934 1,074 1,185 1,123
संख्या 180 175 188 188
लाभ/हाजि % - -326% -65% 61%
िकद लाभ % - -206% -114% 78%
जलजमटेड *** *** *** *** 10-20
2. कोई अन्य *** *** *** *** 25-35
15-25
30-40
0-10
7. कोई अन्य *** *** *** *** 30-40
जलजमटेड *** *** *** *** 25-35
2. कोई अन्य *** *** *** *** 40-50
1 2 3 4 5 6 7 8 9
1 3920 6210,
3920 6220,
3920 6290,
3920 6919
MINISTRY OF COMMERCE AND INDUS TRY
(Department of Commerce )
(DIRECTORATE GENERAL OF TRADE REMEDIES )
NOTIFICATION
New Delhi , the 21st March , 2026
PRELIMINARY FINDINGS
Case No. AD (OI) – 48/2025
Subject: Anti -dumping investigation concerning imports of “Polyethylene Terephthalate Film” (“PET
Films”) originating in or exported from Bangladesh, China PR and Thailand
F. No. 6/55/2025 -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 and for Determination of Injury) Rules, 1995 thereof, as amended from time to
time (hereinafter referred as the “Rules” or “Anti -Dumping Rules” ):
A. BACKGROUND OF THE CASE
1. Chiripal Poly Films Limited, Ester Industries Limited and Vacmet India Limited (hereinafter referred to as the
“applicants”) filed an application, before the Designated Authority (hereinafter also referred to as the
“Authority”) in accordance with the Act and Anti -Dumping Rules for initiation of an anti -dumping
investigation concerning imports of the Polyethylene Terephthalate Film (hereinafter also referred to as the
“product under consideration” or the “subject goods” or “PET Film”) originating in or exported from
Bangladesh, China PR, Thailand, and the United States of America (hereinafter also referred to as the “subject
countries”). Pursuant to the application, two other domestic producers, namely Uflex Limited and Sparsh
Industries Private Limited, submitted complete injury and costing information and requested to be considered
as part of the domestic industry.
2. The applicants alleged that the domestic industry has suffered injury due to dumped imports, originating in or
exported from Bangladesh, China PR, Taiwan, Thailand and United States of America and requested for the
imposition of anti -dumping duties on imports of subject goods from such countries. However, on prima facie
examination, Authority noted that the volume of injurious imports from Taiwan was negligible and did not find
it appropriate to initiate an investigation into imports from Taiwan.
3. Accordingly, in view of the duly substantiated application filed by the applicants, the Authority issued a public
notice vide Notification No. 6/55/2025 -DGTR, dated 30th September 2025, published in the Gazette of India
Extraordinary, initiating an anti -dumping investigation into imports of the product under consideration from
Bangladesh, China PR, Thailand, and the United States of America in accordance with Section 9A of the Act
read with Rule 5 of the Rules to determine the existence, degree and effect of the alleged dumping of the
subject goods and to recommend the amount of anti -dumping duty, which if levied, would be adequate to
remove the alleged injury to the domestic industry.
4. Further, during the course of the investigation, the domestic industry submitted that the imports of the subject
goods from USA were priced significantly lower as they comprised of imports of stock -lots or leftover stocks.
The domestic industry submitted that such imports were not competing with the domestic product and other
imports. Accordingly, the domestic industry withdrew its application with respect to imports from USA.
5. The Authority cross -verified the submission made by the domestic industry based on the DG Systems import
data. It was noted that the almost 99% of the imports from USA comprised of stock lot or leftover stock, which
were priced significantly lower than all other imports. Further, it was also noted that while stock lot or leftover
stock was imported from other subject countries, the volume of such imports was negligible and insignificant.
Accordingly, in view of Rule 14 (a) of the Anti -dumping Rules, the Authority terminates the investigation with
respect to imports of the product under consideration from United States of America, based on request for
withdrawal made by the domestic industry.
B. PROCEDURE
6. The procedure described below has been followed with regard to the investigation:
6.1 Initiation
a. The Authority notified the embassies of the subject countries in India about the receipt of the present anti -
dumping application before proceeding to initiate the investigation in accordance with Rule 5(5) of the Rules.
b. The Authority issued a public notice dated 30th September 2025, published in the Gazette of India,
Extraordinary, initiating an anti -dumping investigation concerning the import of the subject goods from
the subject countries.
c. The Authority sent a copy of the initiation notification along with the questionnaires to the Governments
of the subject countries, through their embassies in India, known producers and exporters from the
subject countries, known importers/users and the domestic industry as well as other interested parties, as
per the addresses made available by the applicants and requested them to make their views known in
writing within the prescribed time limit.
6.2 Circulation of non -confidential version of the application
The Authority provided a copy of the non -confidential version of the application to the known producers/exporters and to
the Governments of the subject countries, through their embassies in India, in accordance with Rule 6(3) of the Rules. A
copy of the non -confidential version of the application was provided to other interested parties, wherever requested.
6.3 Participation by Exporters of Subject Country
a. The Authority sent questionnaires to the following known producers/exporters in the subject
countries in accordance with Rule 6(4) of the Rules:
i. AKIJ Biax Films Limited (Bangladesh)
ii. Hengli Group (China)
iii. Hefei Lekai Technology Industry Co. Limited (China)
iv. Jiangsu Yuxing Film Technology Company Co. Limited (China)
v. Jiangsu Shuangxing Color Plastic New Materials Co. Limited (China)
vi. Ningbo Changyang Technology Co. Limited (China)
vii. Sanfangxiang Group Co. Limited (China)
viii. Sichuan Dongcai Technology Group Co. Limited (China)
ix. Qingdao Kingchuan Yuanrong International Trading Co. Limited (China)
x. Polyplex Thailand Public Company (Thailand)
xi. AJ Plast Public Co. Limited (Thailand)
xii. Polyplex (USA) LLC (United States of America)
b. The embassies of the subject countries in India were requested to advise the exporters/producers from their
country to respond to the questionnaire within the prescribed time limit.
c. The following producers/exporters from the subject countries have filed a response to the questionnaire
issued by the Authority:
i. AKIJ Biax Films Limited (Bangladesh)
ii. Fujian Billion High -Tech Materials Ind. Co., Ltd. (China)
iii. Hangzhou Great Southeast Science and Technology New Material Co., Ltd. (China)
iv. Jiangsu Kanghui New Material Technology Co., Ltd. (China)
v. Jiangsu Shuangxing Color Plastic New Materials Co., Ltd. (China)
vi. Kanghui Nantong New Material Technology Co., Ltd. (China)
vii. Kanghui New Material Technology Co., Ltd. (China)
viii. Kanghui International Trade (Juangsu) Co., Ltd. (China)
ix. Sunrise Asia Ltd. (Hong Kong)
x. United Raw Material PTE Ltd.
xi. A.J. Plast Public Co. Limited (Thailand)
6.4 Participation by Importers/Users
a. The Authority sent questionnaires to the following known importers/users of the subject goods in
India in accordance with Rule 6(4) of the Rules.
i. A D M Equipments Private Limited
ii. Aarnav Fashions Limited
iii. Alcon Electronics
iv. Commit Industries Private limited
v. Desai Electronics Private limited
vi. G J Impex
vii. Gopal Printpack Solutions
viii. Gsnsubh Merchandise Private limited
ix. H P Packaging
x. Hindustan Metallics
xi. HKC International
xii. Life Bonds
xiii. Mahavir Metallic
xiv. Mandagini seals
xv. Manu Creation
xvi. Maruti Narrow Fab
xvii. Narsingh Das and Co. Private Limited
xviii. Neotroniks Private limited
xix. P M Trading Co.
xx. Packajing craft
xxi. Polyplex Corporation Ltd.
xxii. Pratham International
xxiii. Quality Paper Mart
xxiv. S A Enterprise
xxv. Sagar Metallics Private limited
xxvi. Sapru machines Private limited
xxvii. Saptam Polyfilms Private limited
xxviii. Shree Ganesh Jari Covering Private limited
xxix. Shree Ram Resin Private limited
xxx. Sriram Mehar Polymers Private limited
xxxi. TBC Copier Sales and Services
xxxii. TDK India Private limited
xxxiii. Triveni Poly Films
xxxiv. Vairam Enterprises
b. The following importer/ user has filed the questionnaire response. The Authority has also considered
their submissions accordingly.
i. M/s- Ram Kishore Nagarmal Marketing Pvt. Ltd.
6.5 Period of Investigation and Injury Period
a. The period of investigation (POI) for the purpose of the present investigation is 1st April 2024 to 31st
March 2025 (12 months). The injury investigation period has been considered as 2021 -22, 2022 -23,
2023 -24 and the period of investigation.
6.6 Others
a. A copy of the initiation notification and non -confidential version of the application was sent to the
Department of Chemical and Petrochemicals, Ministry of Chemicals and Fertilizers.
b. The Authority invited all the interested parties to give their comments on the scope of the product
under consideration and PCN methodology vide Initiation Notification dated 30th September 2025.
c. The Authority received submissions from the domestic industry and various interested parties with
regards to the scope of the product under consideration and the PCN methodology for the present
investigation. Based on the submissions made, the Authority finalized the scope of the product under
consideration and the PCN methodology vide notification dated 6th November 2025.
d. The Authority made available the non -confidential version of the submissions made by the various
interested parties. A list of all the interested parties was uploaded on the DGTR website along with
the request to all of them to email the non -confidential version of their submissions to all the other
interested parties.
e. A request was made to DG Systems to provide the transaction -wise details of imports of the subject
goods for the injury period and also the period of investigation. The Authority has relied upon the DG
Systems data for computation of the volume of imports and required analysis after due examination of
the transactions.
f. The non -injurious price (NIP) based on the optimum cost of production and cost to make & sell the
subject goods in India as per the information furnished by the domestic industry on the basis of
Generally Accepted Accounting Principles (GAAP) and Annexure III to the Rules has been worked
out so as to ascertain whether anti -dumping duty lower than the dumping margin would be sufficient
to remove injury to the domestic industry.
g. The submissions made by the interested parties during the course of this investigation, to the extent
supported with evidence and considered relevant to the present investigation, have been appropriately
considered by the Authority, in these preliminary findings.
h. Information provided by the interested parties on a confidential basis was examined with regard to the
sufficiency of the confidentiality claim. On being satisfied, the Authority has accepted the
confidentiality claims wherever warranted and such information has been considered confidential and
not disclosed to other interested parties. Wherever possible, parties providing information on a
confidential basis were directed to provide sufficient non -confidential version of the information filed
on a confidential basis.
i. Wherever an interested party has refused access to, or has otherwise not provided necessary
information during the course of the present investigation, or has significantly impeded the
investigation, the Authority has considered such parties as non -cooperative and recorded the
views/observations on the basis of the facts available.
j. The Authority has considered all the arguments raised and information provided by all the interested
parties at this stage, to the extent the same are supported with evidence and considered relevant to the
present investigation. The Authority will further examine the evidentiary documents submitted by the
interested parties subsequent to preliminary findings, which will form the basis for conclusions at the
time of final findings.
k. ‘***’ in this notification represents information furnished by an interested party on a confidential
basis and so considered by the Authority under the Rules.
l. The exchange rate adopted by the Authority for the subject investigation is 1 US$ = ₹ 85.43. (Source;
Petition)
C. PRODUCT UNDER CONSIDERATION AND LIKE ARTICLE
7. The Authority, at the stage of the initiation notification, defined the product under consideration as follows:
“1. The product under consideration is “Polyethylene Terephthalate Film” or Biaxially Oriented
Terephthalate Film of 8 -100 microns. It is commonly known as PET Film or Polyester Film. PET Film
is a clear, flexible, transparent or translucent film and is available in a wide range of variants
depending on its use. PET Film may be plain, chemical coated, acrylic coated, metalized films on one
side or both sides. All such PET Films are biaxially oriented and are produced from the same raw
material and using the same technology and therefore, such variants have similar physical and
technical characteristics.
2. PET Film for use in solar panels is excluded from the scope of the product under consideration.
3. The product under consideration is widely used as a packaging material in fast moving consumer
goods such as food packaging, cosmetic packaging and other flexible packaging. It is also used for
industrial application as electrical insulation, electrical material packaging and magnetic tapes and
other applications where durability is required. It can be used for printing and is used in labels, posters,
other printed materials and as adhesive tapes and silicon films. It is also used to provide a base and
shine for manufacturing gold and silver yarns.
4. The subject goods are classified under Chapter 39 of the Customs Tariff Act, 1975 under headings
3920 and 3921. The subject goods are imported under tariff codes 3920 6210, 3920 6220, 39206290,
3920 6919 and 3921 9094. The customs classification is only indicative and is not binding on the scope
of the product under consideration.”
C.1. Submissions made on behalf of the other interested parties.
8. The following submissions have been made by the other interested parties with regard to the product under
consideration and like article.
i. PETG Shrink Film must be excluded from the scope of the product under consideration as it is a
specialty product with specific application and is not manufactured in India for commercial sale.
ii. Thermal Lamination Films must be excluded from the scope of product under consideration since they
are a downstream product, which is not manufactured by Chiripal, Ester and Vacmet.
iii. Thermal Lamination Film is produced by layering base BOPET film with thermally activable resins
such as Ethylene Vinyl Acetate, Low Density Polyethylene, or other similar adhesive layers. Thermal
Lamination Films have different product process, end -use spectrum and technical properties.
iv. Letters from distributors and customers in India clearly show that they prefer Thermal Lamination Films
from Polyplex.
v. If Thermal Lamination Films are not excluded, then following PCN methodology must be considered –
Parameter Basis Suggested classification
A Thickness (Micron) Range between [Confidential] microns
B Surface treatment / coating One side of PET films:
a) Plain
(b) Chemically Coated
(c) Acrylic Coated
(d)Metalized
Thermal Lamination Films:
Thermally Activable Resin Coated (EVA and/or LDPE)
C Intended use / functionality Lamination of Printed substrates Like Paper, Photo Album, Books,
Carton Board, School/College Degree/ Certificates, Maps, Posters,
Leaflets, Menu Cards and Brochures
D Transparency Mostly Glossy, few laminates require Matte and Soft Touch finish
vi. A PCN methodology based only on the thickness of the film should be considered since it is the main
determinant of cost and price, while other factors such as kind of film or surface treatment do not have
significant impact on the cost or price. Accordingly, the following PCN methodology should be
adopted –
Sl. No. Parameter Value PCN Code
1. Thickness 8 microns (inclusive) up to 20 microns 01
Above 20 microns up to 30 microns 02
Above 30 microns up to 40 microns 03
Above 40 microns up to 50 microns 04
Above 50 microns up to 100 microns 05
C.2. Submissions made by the domestic industry
9. The following submissions have been made by the domestic industry with regard to the product under
consideration and like article.
i. The product under consideration is available in a wide range of variants, wherein the product may have
differences in the type of film used, surface treatment of the film and thickness of the film. Such
variants result in material differences in the cost of production and the consequent selling price.
ii. The following PCN methodology should be adopted for the present investigation –
SN Parameter Product Type
1. Kind of film A – Plain
B – Metallized
C – Others
2. Surface Treatment 01 – Uncoated
02 – Online Chemically coated (i.e., chemical coating applied before the base
film is fully stretched)
03 – Offline Chemically coated (i.e., chemical coating applied after the base
film is fully stretched)
3. Thickness Range 01 – Upto 20 microns
02 – Above 20, upto 30 microns
03 – Above 30, upto 40 microns
04 – Above 40, upto 50 microns
05 – Above 50, upto 100 microns
iii. The domestic industry does not have objection to the exclusion of Thermal Lamination Films from the
scope of product under consideration.
iv. PETG Shrink films should not be excluded from the product scope.
v. While the demand for PETG Shrink film is very limited, the domestic industry has produced and sold
such films, as evident from the production records and invoices of sale. However, due to limited
demand and lack of orders, the production of PETG Shrink film has not been viable.
vi. Other Indian producers such as Garware Hi -tech Films and Cosmo First Limited are also engaged in
production and sale of PETG Shrink films.
C.3 Examination by the Authority
10. The product under consideration in the present investigation is Polyethylene Terephthalate (PET) Film or
Biaxially Oriented Polyethylene Terephthalate Film of 8 -100 microns.
11. The other interested parties have requested for exclusion of certain products from the scope of the product
under consideration, which have been examined hereinbelow.
12. Certain interested parties have contended that PETG Shrink Film must be excluded from the scope of product
under consideration as it is a specialty product with specific application and is not manufactured in India for
commercial sale. The Authority notes that the domestic industry has submitted evidence establishing that they
have produced and sold like article in the form of PETG Shrink Films in the market. Further, the domestic
industry has also submitted that other Indian producers are also producing and selling PETG Shrink Film.
Since the like article has been produced and sold by the domestic industry, exclusion of PETG Shrink Films
from the scope of product under consideration is not warranted. Further, since PETG shrink film is a specialty
polymer —Polyethylene Terephthalate Glycol -modified, a separate PCN was adopted for PETG Shrink Film.
Accordingly, the Authority has considered PETG Shrink Film as a parameter in the PCN methodology
explained hereinbelow.
13. With regards to the request for exclusion of Thermal Lamination Films, the domestic industry has submitted
that it has no objection to such exclusion. Therefore, Thermal Lamination Films are excluded from the scope of
product under consideration.
14. Accordingly, the Authority has determined the following product scope for the purpose of the present
investigation, as also notified vide notification F. No. 6/55/2025 -DGTR, dated 6th November 2024. The
Authority notified a clarification in the scope of the product under consideration as defined in the initiation
notification.
“The product under consideration is “Polyethylene Terephthalate Film” or Biaxially Oriented
Polyethylene Terephthalate Film of 8 -100 microns. It is commonly known as PET Film or Polyester
Film. It is a clear, flexible, transparent or translucent film and is available in a wide range of variants
depending on its use. PET Film may be plain, chemical coated, acrylic coated, metalized films on one
side or both sides. All such PET Films are biaxially oriented as they are produced from the same raw
material and using the same technology and therefore, such variants have similar physical and
technical characteristics.
PET Film for use in solar panels and Thermal Lamination Film are excluded from the scope of the
product under consideration.”
15. The subject goods are classified under Chapter 39 of the Customs Tariff Act, 1975 under headings 3920 and
3921. The subject goods are imported under tariff codes 3920 6210, 3920 6220, 39206290, 3920 6919 and
3921 9094. The customs classification is only indicative and is not binding on the scope of the product under
consideration.
16. In absence of any further submissions thereafter, the Authority has provisionally adopted the scope of product
under consideration as notified under the notice dated 6th November 2025.
17. The Authority notes that there are no significant differences in the product produced by the domestic industry
and the goods imported from the subject countries. The product produced by the domestic industry and
imported from the subject countries are comparable in terms of physical & chemical properties, functions &
uses, product specifications, pricing, distribution & marketing and tariff classification of the goods. The
Authority notes that the two are technically and commercially substitutable. Therefore, the Authority
provisionally concludes that the subject goods produced by the domestic industry in India are “like article” to
the subject goods being imported from the subject countries, as defined under Rule 2(d) of the Rules.
18. Various interested parties as well as the domestic industry submitted their comments regarding determination
of PCN methodology.
19. Certain interested parties argued that in case Thermal Lamination Films are included in the product scope, it
should be considered as a parameter in the PCN methodology. However, since Thermal Lamination Film has
already been excluded from the product scope, the same has not been considered as a PCN parameter.
20. Certain other interested parties also requested for consideration of intended use and transparency as parameters
for PCN methodology. However, no evidence was provided showing differences in cost of production to justify
the methodology proposed. Further, intended application of the product does not lead to difference in cost of
production of the product produced. Thus, no PCN methodology is required to be adopted considering these
parameters.
21. The domestic industry requested that the PCN methodology should be determined based on kind of film,
surface treatment and thickness of the film. On the contrary, certain interested parties argued that the PCN
methodology should be based only on thickness of the film. The Authority notes that thickness of the film
indeed results in significant differences in cost. However, the kind of film used, and additional surface
treatment of the film also result in significant differences in the costs of the PET film. Accordingly, the
Authority has determined a PCN methodology considering factors including kind of film, surface treatment of
the film and thickness of the film.
22. In view of the above, the Authority has determined the following PCN methodology for the present
investigation -
S.N. Parameter Product Type
1. Kind of Film A – Plain
B – Metallized
C – PETG Shrink Films
D – Others
2. Surface Treatment 01 – Uncoated
02 – Online Chemically coated (i.e., chemical coating applied before the
base film is fully stretched)
03 – Offline Chemically coated (i.e., chemical coating applied after the
base film is fully stretched)
3. Thickness Range 01 – Upto 20 microns
02 – Above 20, upto 30 microns
03 – Above 30, upto 50 microns
04 – Above 40, upto 50 microns
05 – Above 50, upto 100 microns
For instance, the PCN for Plain BOPET uncoated film of 12 microns will be A 01 01 and the PCN for
Metalized BOPET film offline coated of 22 microns will be B 03 02.
D. SCOPE OF THE DOMESTIC INDUSTRY & STANDING
D.1. Submissions made on behalf of the other interested parties.
23. The other interested parties have not made any submissions with regard to the scope of domestic industry and
standing.
D.2. Submissions made on behalf of the domestic industry.
24. The following submissions have been made by the domestic industry with regards to the scope of domestic
industry and standing.
i. The application has been filed by three Indian producers, namely Chiripal Poly Films Limited, Ester
Industries Limited and Vacmet India Limited.
ii. Post filing of application, two other producers namely Uflex Limited and Sparsh Industries Private
Limited, have filed complete cost and injury data and have requested to be considered as part of the
domestic industry.
iii. The application has been supported by ten other domestic producers of the product.
iv. There are four other known domestic producers namely, SRF Limited, Polyplex Corporation Ltd.,
Tapadia Polysters Pvt. Ltd. and Garware Hi -Tech Films Ltd. of the product, who have not supported or
opposed the present application.
v. Two producers, namely SRF Limited and Polyplex Corporation Limited, are related to the exporters of
the subject goods in the subject countries. Accordingly, SRF Limited and Polyplex Corporation
Limited should be considered ineligible to constitute domestic industry.
vi. The applicants account for a major proportion in the total eligible Indian production for the subject
goods and constitute domestic industry under the Rules.
vii. There are no known differences in the goods produced by the domestic industry and the goods
imported from the subject countries.
viii. The applicants have not imported the subject goods from the subject countries and are not related to
any exporter of the subject goods in the subject countries or importer of the subject goods in India.
D.3 Examination by the Authority
25. Rule 2(b) of the Anti -Dumping Rules defines the domestic industry as under:
“(b) “domestic industry” means the domestic producers as a whole engaged in the manufacture of the
like article and any activity connected therewith or those whose collective output of the said article
constitutes a major proportion of the total domestic production of that article except when such
producers are related to the exporters or importers of the alleged dumped article or are themselves
importers thereof in such case the term ‘domestic industry’ may be construed as referring to the rest of
the producers.”
26. The application for initiation of the present investigation was filed by Chiripal Poly Films Limited, Ester
Industries Limited and Vacmet India Limited. The applicants have claimed that they have not imported the
product under consideration into India from the subject countries. The applicants have also confirmed that they
are not related to exporters of the subject goods in the subject countries, or any importer in India.
27. Further, two producers, namely Uflex Limited and Sparsh Industries Private Limited separately submitted
costing and injury information and requested to be considered as part of domestic industry. After the Initiation,
Authority examined the costing and injury information provided by the producers and decided to consider
Uflex Limited and Sparsh Industries Private Limited as part of the domestic industry in the present
investigation. Both producers have claimed that they have not imported the subject goods from the subject
countries and are not related to any exporter of subject goods in the subject countries or any importer in India.
28. Apart from the aforesaid producers, there are fourteen other domestic producers engaged in the production of
like article in India. Ten domestic producers, namely, Aakash Polyfilms Limited, Aegios Polyfilms Private
Limited, Cosmo First Limited, Dhunseri Poly Films Private Limited, General Polyfilms Private Limited, GLS
Polyfilms Private Limited, Jindal Polyfilms Private Limited, Saj Industries Private Limited, SML Films
Limited and Surya Global Flexifilms Private Limited filed letters supporting the application and the present
investigation. It is noted that General Polyfilms Private Limited was not engaged in production of the like
article during the period of investigation and commenced production in the post -POI period.
29. The applicants have submitted that two domestic producers, namely SRF Limited and Polyplex Corporation
Limited are related to the exporters of subject goods from the subject countries, that have exported the product
under consideration to India during the period of investigation. Accordingly, the applicants claimed that their
production should not be treated as part of total production.
30. The Authority has examined the information provided and the DG Systems data, it is noted that SRF Limited is
related to SRF Industries (Thailand) Co., Limited which is an exporter from Thailand, and Polyplex
Corporation Limited is related to Polyplex (Thailand) Public Company Limited, which is an exporter from
Thailand respectively. Such related exporters have exported significant quantities of the subject goods to India
during the period of investigation.
31. Export volumes of SRF Industries Thailand Limited has been checked from DG Systems data and found that
they have exported *** MT of PUC in India during POI. Similarly, Polyplex (Thailand) Public Company
Limited has exported *** MT of PUC in India in the POI. Applicant has submitted evidence showing that SRF
India Ltd. is a related entity of SRF Industries Thailand Limited. Similarly, Polyplex (Thailand) Public
Company Limited is a related entity of the Polyplex Corporation Ltd.
32. Further, both the producers have not cooperated before the Authority during this investigation, and have not
furnished any information regarding their performance or such imports. Accordingly, based on the established
practice of the Authority, SRF Limited and Polyplex Corporation Limited are treated ineligible from being
considered as part of domestic industry under Rule 2 (b) of the Rules. As a result, the production of subject
goods by SRF Limited and Polyplex Corporation Limited has not been considered while determining the total
Indian production of the subject goods, for the purpose of Rule 2(b) and Rule 5(3).
33. In view of the above, it is noted that the production of like article by the domestic producers being considered
as part of the domestic industry in the present investigation account for a major proportion (45%) of the total
eligible domestic production in India. Further, the domestic producers being considered as part of the domestic
industry along with the supporters account for 96% of the total eligible production in India. Thus, the Authority
provisionally finds that Chiripal Poly Films Limited, Ester Industries Limited, Vacmet India Limited, Ulfex
Limited and Sparsh Industries Private Limited constitute domestic industry as defined under Rule 2(b) of the
Anti-Dumping Rules, and the application satisfies the requirement of Rule 5(3) of the Rules.
Particulars Unit Production Share
Eligible domestic production
Domestic industry MT 4,04,405 45%
Supporting producers MT 4,61,464 51%
Domestic Industry + Supporters MT 8,65,869 96%
Other eligible Indian producers MT 37,920 4%
Total eligible domestic production MT 9,03,789 100%
Ineligible domestic production
SRF Limited MT ***
Polyplex Corporation Limited MT ***
Total Indian Production MT 10,45,341
E. CONFIDENTIALITY AND MISCELLANEOUS ISSUES
E.1. Submissions made on behalf of the other interested parties.
34. The other interested parties have not made any submissions with regard to the confidentiality claims of the
domestic industry. However, in response to the submissions made by the domestic industry regarding excessive
confidentiality claimed by the exporter, the Kanghui group has claimed that such information constitutes
business proprietary information, which would cause commercial harm, if disclosed.
E.2. Submissions made on behalf of the domestic industry.
35. The domestic industry has submitted that Kanghui group has claimed excessive confidentiality with respect to
its shareholders and related parties, even when such information is available in the public domain. Further, the
exporter group has claimed excessive confidentiality regarding adjustments claimed with respect to export
price.
E.3 Examination by Authority
36. With regard to confidentiality of information, Rule 7 of Anti -dumping Rules provides as follows:
“Confidential information: (1) Notwithstanding anything contained in sub -rules (2), (3) and (7)of rule
6, sub -rule(2) of rule12,sub -rule(4) of rule 15 and sub -rule (4) of rule 17, the copies of applications
received under sub -rule (1) of rule 5, or any other information provided to the designated authority on a
confidential basis by any party in the course of investigation, shall, upon the designated authority being
satisfied as to its confidentiality, be treated as such by it and no such information shall be disclosed to
any other party without specific authorization of the party providing such information.
(2) The designated authority may require the parties providing information on a confidential basis to
furnish a non -confidential summary thereof and if, in the opinion of a party providing such information,
such information is not susceptible to summary, such party may submit to the designated authority a
statement of reasons why summarization is not possible.
(3) Notwithstanding anything contained in sub -rule (2), if the designated authority is satisfied that the
request for confidentiality is not warranted or the supplier of the information is either unwilling to make
the information public or to authorize its disclosure in a generalized or summary form, it may disregard
such information.”
37. The information provided by the interested parties on a confidential basis was examined with regard to the
sufficiency of such claims. On being satisfied, the Authority has accepted the confidentiality claims, wherever
warranted, and such information has been considered confidential and not disclosed to the other interested
parties. Wherever possible, the parties providing information on a confidential basis were directed to provide a
sufficient non -confidential version of the information filed on a confidential basis.
F. NORMAL VALUE, EXPORT PRICE AND DUMPING MARGIN
F.1. Submissions made on behalf of the other interested parties.
38. The other interested parties have not made any submissions with regard to normal value, export price and
dumping margin.
F.2. Submissions made on behalf of the domestic industry.
39. The following submissions have been made by the domestic industry with regard to the normal value, export
price and dumping margin.
i. China PR should be treated as a non -market economy in accordance with Article 15(a)(i) of China’s
Accession Protocol and the normal value should be determined in terms of Annexure I, Rule 7 of the
Rules.
ii. The domestic industry has provided information with regard to determination of normal value for
exporter from China PR based on price payable in India, having regards to its own cost of production
duly adjusted for selling, general and administrative expenses, with a reasonable profit.
iii. With respect to determination of normal value for other subject countries, the domestic industry has
submitted best available information with regard to cost of production, plus selling, general and
administrative expenses and profits.
iv. The dumping margin for the subject countries is not only above de minimis levels, but also significant.
v. The Authority should determine individual margins only for the two sampled exporters from China PR
and should not accept requests for margins from any other exporters.
F.3. Examination by the Authority
40. The Authority notes that the following producers/exporters of the subject goods have filed their responses to
the exporter’s questionnaire:
i. AKIJ Biax Films Limited (Bangladesh)
ii. Fujian Billion High -Tech Materials Ind. Co., Ltd. (China)
iii. Hangzhou Great Southeast Science and Technology New Material Co., Ltd. (China)
iv. Jiangsu Kanghui New Material Technology Co., Ltd. (China)
v. Jiangsu Shuangxing Color Plastic New Materials Co., Ltd. (China)
vi. Kanghui Nantong New Material Technology Co., Ltd. (China)
vii. Kanghui New Material Technology Co., Ltd. (China)
viii. Kanghui International Trade (Juangsu) Co., Ltd. (China)
ix. Sunrise Asia Ltd. (Hong Kong)
x. United Raw Material PTE Ltd.
xi. A.J. Plast Public Co. Limited (Thailand)
41. As per the provisions of Rule 17, while the Authority is required to determine individual dumping margin in
respect of all those producers/exporters who have filed questionnaire responses, in a situation where a large
number of producers/ exporters have filed questionnaire responses, the Authority may resort to sampling by
limiting the response to a limited number of producers. The Rules provides as follows in this regard.
“17(3) The designated authority shall determine an individual margin of dumping for each known
exporter or producer concerned of the article under investigation:
Provided that in cases where the number of exporters, producers, importers or types of articles involved
are so large as to make such determination impracticable, it may limit its findings either to a
reasonable number of interested parties or articles by using statistically valid samples based on
information available at the time of selection, or to the largest percentage of the volume of the exports
from the country in question which can reasonably be investigated, and any selection, of exporters,
producers, or types of articles, made under this proviso shall preferably be made in consultation with
and with the consent of the exporters, producers or importers concerned :
Provided further that the designated authority shall, determine an individual margin of dumping for any
exporter or producer, though not selected initially, who submit necessary information in time, except
where the number of exporters or producers are so large that individual examination would be unduly
burdensome and prevent the timely completion of the investigation.”
42. In view of the large number of responses received from China PR, the Authority considered sampling of
producers from China PR. The same was proposed vide notification dated 23rd December 2025. After receiving
comments from various parties, the sampled producers were notified vide notification dated 9th January 2025.
The sample considered was based on the volume of exports to India, with the producers / producer groups
having the largest volume of exports, being considered as a part of the sample. Exports by such sampled
producers accounted for 66% of the total volume of exports by the cooperative exporters.
43. In view of the foregoing, the Authority has selected the following producers from China PR along with their
associated exporters for determining individual dumping margin –
S. No. Producer / exporter group
1 Kanghui New Material Technology Co., Ltd., China
Kanghui Nantong New Material Technology Co., Ltd., China
Kanghui International Trade (Jiangsu) Co. Ltd., China
Jiangsu Kanghui New Material Technology Co., Ltd., China (Trader)
2 Jiangsu Shuangxing Color Plastic New Materials Co., Ltd., China
F.3.1. Determination of Normal Value and Export Price for Bangladesh
Normal Value for Bangladesh
Normal value for AKIJ Biax Films Limited (AKIJ)
44. During the period of investigation, AKIJ Biax Films Limited (AKIJ) has exported [ ***] MT of the product
under consideration to India, while selling [ ***] MT of the subject goods in the domestic market. The
Authority notes that the domestic sales are sufficient in volumes when compared with exports to India, to
determine the normal value based on domestic selling price.
45. For determining the Normal value, the Authority has examined the domestic sales transactions carried out by
AKIJ in their home market. Ordinary course of trade test to determine profit making domestic sales
transactions with reference to the cost of production of the subject goods, on a PCN -wise basis was carried out.
In case of PCNs, where more than 80% of sales were made at profits, the normal value has been determined
based on the ex -factory selling price of all sales transactions. Where less than 80% of sales were made at
profits, the normal value has been determined based on the ex -factory selling price of profitable sales only.
46. AKIJ has claimed price adjustments on account of inland freight, credit cost, packing cost, and indirect selling
expense. The adjustments claimed have been provisionally allowed except for indirect selling expense , pending
verification . Thus, the normal value at ex -factory level has been provisionally calculated as mentioned in the
dumping margin table below.
Normal value for all other producers / exporters from Bangladesh
47. The normal value for all other non -cooperating producers and exporters from Bangladesh has been determined
based on facts available and the same is mentioned in the dumping margin table below.
Export Price for Bangladesh
Export Price for AKIJ Biax Films Limited
48. AKIJ has exported [ ***] MT of the product under consideration to India. All sales have been made directly to
unrelated customers.
AKIJ → Unrelated customers in India
49. The export price has been determined on the provisional basis subject to detailed verification to be carried out
post issuance of preliminary findings, based on the price charged by AKIJ from the unrelated customers. The
producer has claimed adjustments for ocean freight, insurance, inland transportation, port and other related
expenses, credit cost, bank charges, packing cost, export incentives and indirect selling expenses. The
adjustments claimed, barring indirect selling expenses and export incentives has been provisionally allowed by
the Authority, pending detailed verification. Net export price provisionally determined is mentioned in the table
below.
Export Price for all other producers / exporters from Bangladesh
50. The export price for all other non -cooperating producers and exporters from Bangladesh has been determined
based on facts available and the same is mentioned in the dumping margin table below.
F.3.2. Determination of Normal Value and Export Price for China PR
Normal Value for China PR
51. Article 15 of China's Accession Protocol in WTO provides as follows:
“Article VI of the GATT 1994, the Agreement on Implementation of Article VI of the General Agreement
on Tariffs and Trade 1994 (“Anti -Dumping Agreement”) and the SCM Agreement shall apply in
proceedings involving imports of Chinese origin into a WTO Member consistent with the following.
(a) In determining price comparability under Article VI of the GATT 1994 and the Anti -Dumping
Agreement, the importing WTO Member shall use either Chinese prices or costs for the industry under
investigation or a methodology that is not based on a strict comparison with domestic prices or costs in
China based on the following rules:
(i) If the producers under investigation can clearly show that market economy conditions prevail in the
industry producing the like product with regard to the manufacture, production and sale of that product,
the importing WTO Member shall use Chinese prices or costs for the industry under investigation in
determining price comparability;
(ii) The importing WTO Member may use a methodology that is not based on a strict comparison with
domestic prices or costs in China if the producers under investigation cannot clearly show that market
economy conditions prevail in the industry producing the like product with regard to manufacture,
production and sale of that product.
(b) In proceedings under Parts II, III and V of the SCM Agreement, when addressing subsidies
described in Articles 14(a), 14(b), l4(c) and l4(d), relevant provisions of the SCM Agreement shall
apply; however, if there are special difficulties in that application, the importing WTO Member may
then use methodologies for identifying and measuring the subsidy benefit which take into account the
possibility that prevailing terms and conditions in China may not always be available as appropriate
benchmarks. In applying such methodologies, where practicable, the importing WTO Member should
adjust such prevailing terms and conditions before considering the use of terms and conditions
prevailing outside China.
(c) The importing WTO Member shall notify methodologies used in accordance with subparagraph (a)
to the Committee on Anti -Dumping Practices and shall notify methodologies used in accordance with
subparagraph (b) to the Committee on Subsidies and Countervailing Measures.
(d) Once China has established, under the national law of the importing WTO Member, that it is a
market economy, the provisions of subparagraph (a) shall be terminated provided that the importing
Member's national law contains market economy criteria as of the date of accession. In any event, the
provisions of subparagraph (a)(ii) shall expire 15 years after the date of accession. In addition, should
China establish, pursuant to the national law of the importing WTO Member, that market economy
conditions prevail in a particular industry or sector, the non -market economy provisions of
subparagraph (a) shall no longer apply to that industry or sector.”
52. The applicants have cited and relied upon Article 15(a)( i) of China's Accession Protocol. The applicants have
claimed that producers in China PR must be asked to demonstrate that market economy conditions prevail in
their industry producing the like product with regard to the manufacturing, the production and the sale of the
product under consideration. It has been stated by the applicants that in case the responding Chinese producers
are not able to demonstrate that their costs and price information are market driven, the normal value should be
calculated in terms of provisions of Para 7 and 8 of Annexure - I to the Rules.
53. It is noted that while the provision contained in Section 15 (a)(ii) has expired on 11.12.2016, the provision
under Article 2.2.1.1 of WTO Anti -dumping Agreement read with the obligation under Section 15(a)(i) of the
Accession Protocol require criterion stipulated in paragraph 8 of Annexure I of the AD Rules to be satisfied
through the information/data to be provided in the supplementary questionnaire on claiming market economy
treatment. It is noted that since the responding producers/exporters from China PR have not submitted response
to the supplementary questionnaire the normal value computation is required to be done as per the provisions
of paragraph 7 of Annexure I of the AD Rules, 1995.
54. The Authority notes that none of the sampled producers have claimed market economy treatment in the present
case. Accordingly, the normal value has been determined in accordance with Paragraph 7 of Annexure I to the
Rules, which states as follows.
“7. In case of imports from non -market economy countries, normal value shall be determined on the
basis of the price or constructed value in a market economy third country, or the price from such a third
country to other countries, including India, or where it is not possible, on any other reasonable basis,
including the price actually paid or payable in India for the like product, duly adjusted, if necessary, to
include a reasonable profit margin. An appropriate market economy third country shall be selected by
the designated authority in a reasonable manner keeping in view the level of development of the country
concerned and the product in question and due account shall be taken of any reliable information made
available at the time of the selection. Account shall also be taken within time limits; where appropriate,
of the investigation if any made in a similar matter in respect of any other market economy third
country. The parties to the investigation shall be informed without unreasonable delay of the aforesaid
selection of the market economy third country and shall be given a reasonable period of time to offer
their comments.
55. As noted above, Paragraph 7 lays down a hierarchy for determination of normal value with respect to non -
market economy and provides that normal value shall be determined on the basis of the price or constructed
value in a market economy third country or the price from such a third country to other countries, including
India or where it is not possible, on any other reasonable basis, including the price actually paid or payable in
India for the like product, duly adjusted, if necessary, to include a reasonable profit margin. In the present case,
there is no evidence of price or constructed value prevailing in a market economy third country brought
forward by any interested party. Apart from the subject countries in the present investigation, imports into
India from other countries are low in volume. Thus, imports into India from the market economy third country
could not be considered for determination of normal value.
56. Therefore, the Authority has provisionally determined normal value for China PR as “price payable in India” as
stipulated in Paragraph 7. It has been computed based on the
the cost of production of the domestic industry duly adjusted for selling, general and administrative expenses
and reasonable profits. The normal value provisionally determined is given below in the dumping margin table.
Export price for China PR
Export price for Jiangsu Kanghui New Material Technology Co., Ltd., Kanghui Nantong New Material
Technology Co., Ltd. and Kanghui New Material Technology Co., Ltd., and (collectively referred to as
“Kanghui Group”)
57. Jiangsu Kanghui New Material Technology Co., Ltd. (Jiangsu Kanghui), Kanghui New Material Technology
Co., Ltd. (Kanghui New Material) and Kanghui Nantong New Material Technology Co., Ltd. (Kanghui
Nantong) are related companies engaged in manufacturing of the subject goods in China PR. During the period
of investigation, all three companies have exported the subject goods through related trader, namely Kanghui
International Trade Jiangsu Co., Ltd. (Kanghui International). Kanghui International further sold subject goods
directly to unrelated customers in India and through unrelated traders.
58. Jiangsu Kanghui has sold a total of [ ***] MT during the period of investigation, of which [ ***] MT has been
exported through related trader Kanghui International who has directly exported this volume to unrelated
customers in India, and [ ***] MT was exported through related trader Kanghui International, who further sold
the product under consideration to unrelated traders Sunrise and United for further export to India. Out of total
[***] MT, [ ***] MT was exported through related trader Kanghui International, who further sold the product
under consideration to unrelated traders for further export to India. However, such unrelated traders have not
participated in the present investigation.
59. Kanghui Nantong has exported a total of [ ***] MT quantity during the period of investigation through related
trader Kanghui International who has directly exported this volume to unrelated customers in India.
60. Kanghui New Material has exported a total of [ ***] MT during the period of investigation through related
trader Kanghui International. Kanghui International has, in turn, sold the same quantity to unrelated trader for
further export to India. However, such unrelated traders have not participated in the present investigation.
Jiangsu Kanghui → Kanghui International → Unrelated customers in India [ *** MT]
Jiangsu Kanghui → Kanghui International → Sunrise → Unrelated customers in India [ *** MT]
Jiangsu Kanghui → Kanghui International → United → Unrelated customers in India [ *** MT]
Jiangsu Kanghui → Kanghui International → non-co-operative traders → Unrelated customers in India
[***MT]
Kanghui Nantong →Kanghui International → Unrelated customers in India [ ***MT]
Kanghui New Material → Kanghui International → non-co-operative traders → Unrelated customers in India
[***MT]
61. It is noted that the Kanghui Group has exported a total quantity of [ ***] MT to India through related and
unrelated traders. Out of such total exports, a small quantity of exports have been made indirectly through
unrelated traders who have not participated in the present investigation. Since the volume of exports through
non-participating unrelated traders is low, the Authority has determined the net export price with respect to
such exports based on facts available.
62. The export price has been provisionally determined based on the price charged by the exporter from the
unrelated customers. The producers have claimed adjustments for ocean freight, insurance, inland
transportation, credit cost, bank charges and commission. The adjustments claimed have been allowed by the
Authority provisionally pending detailed verification.
63. In accordance with the above, weighted average export price for Kanghui group which consists of Jiangsu
Kanghui and Kanghui Nantong has been determined provisionally pending detailed verification at this stage.
The net export price so provisionally determined has been mentioned in the table below.
Export price for Jiangsu Shuangxing Color Plastic New Materials Co., Ltd.
64. Jiangsu Shuangxing Color Plastic New Materials Co., Ltd. (Jiangsu Shuangxing) has exported [ ***] MT of the
product under consideration to India. All sales have been made directly to unrelated customers.
Jiangsu Shuangxing → Unrelated customers in India
65. The export price has been determined provisionally for the producer/exporter at this stage which is based on
the price charged by the exporter from the unrelated customers. The producer has claimed adjustments for
ocean freight, insurance, inland freight and port related expenses, credit cost and bank charges. The
adjustments claimed have been allowed by the Authority provisionally subject to detailed verification. The net
export price provisionally determined is mentioned in the table below.
Export price for all other producers / exporters from China PR
66. The dumping margin for all other cooperative non -sampled producers has been determined based on the
weighted average dumping margin for the cooperative sampled producers. The export price for all other
producers and exporters, that have not participated in the present investigation, has been determined as per
facts available. The same has been mentioned in the dumping margin table.
F.3.3. Determination of Normal Value and Export Price for Thailand
Normal Value for Thailand
Normal value for A.J. Plast Public Co. Limited
67. During the period of investigation, A.J. Plast Public Co. Limited (A.J. Plast) has exported [ ***] MT of the
product under consideration to India, while selling [ ***] MT of the subject goods in the domestic market. The
Authority notes that the domestic sales are sufficient in volumes when compared with exports to India, to
determine the normal value based on domestic selling price.
68. For determining the Normal value, the Authority has examined the domestic sales transactions carried out by
A.J.Plast in their home market.
69. Ordinary course of trade test to determine profit making domestic sales transactions with reference to the cost
of production of the subject goods, on a PCN -wise basis was carried out. In case of PCNs, where more than
80% of sales were made at profits, the normal value has been determined based on the ex -factory selling price
of all sales transactions. Where less than 80% of sales were made at profits, the normal value has been
determined based on the ex -factory selling price of profitable sales only.
70. A.J. Plast has claimed price adjustments on account of inland transportation, credit cost, packing cost and
marketing cost. The adjustments claimed have been provisionally allowed , pending detailed verification . Thus,
the normal value at ex -factory level has been provisionally calculated as mentioned in the dumping margin
table below.
Normal value for all other producers / exporters from Thailand
71. The normal value for all other non -cooperating producers and exporters from Thailand has been determined
based on facts available and the same is mentioned in the dumping margin table below.
Export Price for Thailand
Export Price for A.J. Plast Public Co. Limited
72. A.J. Plast has exported [ ***] MT of the product under consideration to India. All sales have been made directly
to unrelated customers.
A. J. Plast → Unrelated customers in India
73. The export price has been determined based on the price charged by the exporter from the unrelated customers.
The producer has claimed adjustments for ocean freight, insurance, packing cost, commission and duty
drawback. The adjustments claimed, have been provisionally allowed by the Authority, pending verification.
The net export price provisionally determined is mentioned in the table below.
Export Price for all other producers / exporters from Thailand
74. The export price for all other non -cooperating producers and exporters from Thailand has been determined
based on facts available and the same is mentioned in the dumping margin table below.
F.3.5. Dumping Margin
75. Considering the normal value and export price determined as above, the dumping margin determined for the
subject countries is as follows.
Dumping Margin Table
S.N. Producer Normal
Value
(USD/MT) Export Price
(USD/MT) Dumping
Margin
(USD/MT) Dumping
Margin
(%) Dumping
Margin
(Range)
A. Bangladesh
1. AKIJ Biax Films Limited *** *** *** *** 30-40
2. Any other *** *** *** *** 45-55
B. China PR
1. Jiangsu Kanghui New
Material Technology Co.,
Ltd
*** *** *** *** 10-20
2. Kanghui Nantong New
Material Technology Co.,
Ltd
*** *** *** *** 10-20
3 Kanghui New Material
Technology Co., Ltd.
(collectively "Kanghui
Group") *** *** *** *** 20-30
4 Weighted Average
(Kanghui Group) *** *** *** *** 10-20
5 Jiangsu Shuangxing Color
Plastic New Materials Co.,
Ltd. *** *** *** *** 0-10
6 Other non -sampled
cooperating producers *** *** *** *** 10-20
7 Any other *** *** *** *** 20-30
C. Thailand
1. A.J. Plast Public Co.
Limited *** *** *** *** 10-20
2. Any other *** *** *** *** 20-30
G. ASSESSMENT OF INJURY AND CAUSAL LINK
G.1. Submissions made on behalf of the other interested parties.
76. The other interested parties have not made any submissions with regard to injury and causal link.
G.2. Submissions made on behalf of the domestic industry.
77. The following submissions have been made by the domestic industry to demonstrate that the domestic industry
has suffered injury and that there is causal link between dumping and injury.
i. Cumulative assessment of the effects of imports is appropriate in the present case as all conditions of
cumulation have been met.
ii. The volume of imports from the subject countries increased throughout the injury period and was the
highest during the period of investigation.
iii. The volume of subject imports has also increased in relation to Indian production and consumption over
the injury period.
iv. The rate of increase in volume of imports was higher than the rate of increase in demand in the country,
despite no demand -supply gap in the country.
v. The subject imports are entirely unnecessary as the Indian industry has sufficient capacity to meet the
entire demand.
vi. The subject imports have displaced imports from all other countries, and accounted for majority of the
total imports into the country.
vii. As a result, the market share of the subject imports has increased while that of the domestic industry has
declined.
viii. The subject imports were undercutting the prices of the domestic industry during the period of
investigation.
ix. The domestic industry was forced to reduce its prices at rate higher than changes in its cost, in order to
maintain its place in the market as the landed price of the subject imports was very low.
x. The subject imports suppressed and depressed the domestic prices.
xi. The installed capacities, production and domestic sales of the domestic industry increased over the
period due to capacity expansion. However, production and sales volume declined during the period of
investigation when compared to 2023 -24.
xii. The capacity utilization of the domestic industry has declined over the period.
xiii. Despite reducing its prices and selling at losses, the domestic industry was unable to sell its product,
resulting in significant accumulation of inventories.
xiv. The profitability of the domestic has declined significantly over the injury period. While the profitability
of the industry improved slightly during the period of investigation due to slight decline in costs, the
domestic industry continued to face significant losses.
xv. The domestic industry faced significant losses and cash losses during the period of investigation, and
earned negative return on its investments.
xvi. The subject imports are threatening to cause further injury to the domestic industry.
xvii. The volume of exports has increased at significant rate.
xviii. The exporters in the subject countries hold significant capacities, which are underutilized to low
production, resulting in availability of large idle capacities.
xix. The demand for the subject goods in the subject countries is lower than available capacities, indicating
that the capacities are intended for exports.
xx. There is a global oversupply situation where the global installed capacities are double the demand.
xxi. Despite limited demand, the exporters in subject countries have planned significant capacity expansions,
which can be used for diverting exports to India.
xxii. The exporters in the subject countries are dumping the subject goods in third countries as well and are
facing trade remedial measures in such third countries, further limiting markets for the exporters.
xxiii. USA has also imposed other tariff measures on imports of various products, including subject goods.
xxiv. Injury to the domestic industry is caused due to dumping of subject imports into India and is not caused
by any other factors.
G.3. Examination by the Authority
78. The Authority has examined the arguments made by domestic industry with regard to injury to the domestic
industry. The injury analysis made by the Authority hereunder addresses the various submissions made.
However, no submissions have been made yet by other interested parties.
79. For the purpose of injury analysis in the present investigation, the Authority has considered the costing and
injury information submitted by Chiripal Poly Films Limited, Ester Industries Limited, Vacmet India Limited,
Ulfex Limited and Sparsh Industries Private Limited, which have been determined as constituting domestic
industry within the meaning of Rule 2(b) of the Rules.
G.3.1. Cumulative assessment of injury
80. Article 3.3 of the WTO agreement and Paragraph (iii) of Annexure II to the Rules provide that in case where
imports of a product from more than one country are being simultaneously subjected to anti -dumping
investigation, the Authority will cumulatively assess the effect of such imports, in case it determines that:
a. The margin of dumping established in relation to the imports from each country is more than two per cent
expressed as a percentage of export price and the volume of the imports from each country is three per cent
(or more) of the import of like article or where the export of individual countries is less than three per cent,
the imports collectively account for more than seven per cent of the import of like article, and
b. Cumulative assessment of the effect of imports is appropriate in light of the conditions of competition
between the imported article and that between imported like domestic articles.
81. The Authority notes that:
a. The subject goods are being dumped into India from the subject countries. The margin of dumping from
each of the subject countries is more than de minimis limits prescribed under the Rules.
b. The volume of imports from each of the subject countries is individually more than 3% of the total
volume of imports.
c. Cumulative assessment of the effects of import is appropriate in light of the conditions of competition
between the imported article and the like domestic articles.
82. In view of the above, the Authority considers that it is appropriate to assess the effect of dumped imports of the
subject goods from Bangladesh, China PR and Thailand on the domestic industry.
G.3.2. Volume effect of the dumped imports
a) Assessment of demand / apparent consumption
83. For the purpose of the present investigation, demand or apparent consumption of the product in India has been
defined as the sum of the domestic sales of the domestic industry, domestic sales of other Indian producers and
imports from all sources. The demand so assessed is given below.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Domestic industry MT 2,80,485 3,30,353 3,54,311 3,29,656
Other Indian producers MT 2,88,217 3,79,812 3,92,570 4,53,498
Subject imports MT 14,607 27,541 18,249 41,719
Other imports MT 27,035 35,193 38,311 39,080
Total demand MT 6,10,344 7,72,898 8,03,441 8,63,953
84. It is seen that the demand for the subject goods has increased throughout the injury period and was the highest
during the period of investigation.
b) Import volumes from the subject countries
85. With regard to the volume of the dumped imports, the Authority is required to consider whether there has been a
significant increase in dumped imports, either in absolute terms or relative to production or consumption in India.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Subject imports MT 14,607 27,541 18,249 41,719
Bangladesh MT 12 2790 1281 2763
China PR MT 1785 6955 6483 26086
Thailand MT 12810 17796 10486 12870
Other Countries MT 27,035 35,193 38,311 39,080
Total imports MT 41,642 62,734 56,561 80,799
Subject import in relation to:
Indian production % 2% 4% 2% 5%
Trend Indexed 100 153 89 189
Consumption % 2% 4% 2% 5%
Trend Indexed 100 149 95 202
Total imports % 35% 44% 32% 52%
Trend Indexed 100 125 92 147
86. It is seen that -
a. Barring 2023 -24, subject imports have increased significantly during the injury period and were the
highest during the period of investigation.
b. The volume of imports in relation to Indian production and consumption have increased over the injury period.
c. The imports from the subject countries constitute half of the total imports during the period of
investigation.
87. The domestic industry has also highlighted that the imports have increased at a faster rate than the increase in
demand. When compared to the base year, while the demand increased by 42%, the imports show a significant
increase of 186%.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Subject imports MT 14,607 27,541 18,249 41,719
Trend Indexed 100 189 125 286
Demand MT 6,10,344 7,72,898 8,03,441 8,63,953
Trend Indexed 100 127 132 142
G.3.3. Price effect of the dumped imports
88. With regard to the effect of the dumped imports on prices of the domestic industry, it is required to be analysed
whether there has been a significant price undercutting by the alleged dumped imports as compared to the price
of the like products in India, or whether the effect of such imports is otherwise to depress prices or prevent
price increases, which otherwise would have occurred in the normal course. The impact on the prices of the
domestic industry on account of the dumped imports from the subject countries has been examined with
reference to price undercutting, price suppression and price depression, if any.
a) Price undercutting
89. Price undercutting has been determined by comparing the net selling price of the domestic industry with the
landed price of the subject imports for the period of investigation.
Particulars Unit POI
Net sales realization ₹/MT ***
Landed Price ₹/MT ***
Price undercutting ₹/MT (***)
Price undercutting % (***)
Range Range Negative
90. The Authority notes that during the period of investigation, the landed price of the subject imports was
marginally higher than the net sales realization of the domestic industry.
b) Price suppression/depression
In order to determine whether the dumped imports are depressing the domestic prices and whether the effect of such
imports is to suppress prices to a significant degree or prevent price increases which otherwise would have occurred in
the normal course, the changes in the costs and prices over the injury period, were compared as below.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Cost of Sales ₹/MT *** *** *** ***
Trend Indexed 100 113 108 108
Net Sales Realisation ₹/MT *** *** *** ***
Trend Indexed 100 95 82 94
Landed Price ₹/MT 1,47,411 1,44,150 1,24,911 1,22,910
Trend Indexed 100 98 85 83
91. It is noted that the cost of sales of the domestic industry increased in 2022 -23. However, the net sales
realisation of the domestic industry declined as the landed price of imports declined. Thereafter, in 2023 -24,
the cost of sales of the domestic industry reduced by 5%. However, the net sales realisation of the domestic
industry declined by a larger degree, by 13%, as the landed price also declined and remained low. During the
period of investigation, the cost of sales of the domestic industry remained largely constant. During this time,
the domestic industry was able to improve its prices. However, since the landed price declined further, the
domestic industry sold its product below its cost in order to compete. It is noted that over the injury period, the
cost of sales of the domestic increased by 8%, while its net sales realisation declined by 6%. During the same
period, the landed price of imports declined by 17%. It is, therefore, noted that the imports have depressed the
prices of the domestic industry and prevented price increases, which otherwise would have occurred.
G.3.4. Economic parameters of the domestic industry
92. Annexure II to the Anti -Dumping Rules requires that the determination of injury shall involve an objective
examination of the consequent impact of dumped imports on domestic producers of such products. With regard
to the consequent impact of dumped imports on domestic producers of such products, the Rules further provide
that the examination of the impact of the dumped imports on the domestic industry should include an objective
and unbiased evaluation of all relevant economic factors and indices having a bearing on the state of the
industry, including actual and potential decline in sales, profits, output, market share, productivity, return on
investments or utilization of capacity; factors affecting domestic prices, the magnitude of the margin of
dumping; actual and potential negative effects on cash flow, inventories, employment, wages, growth, ability to
raise capital investments.
93. The impact on the economic parameters of the domestic industry is discussed as below.
a) Production, capacity, capacity utilization and sales
94. Capacity, production, sales and capacity utilization of the domestic industry over the injury period were as below.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Installed Capacity MT 3,44,950 4,55,450 5,59,020 5,59,020
Trend Indexed 100 132 162 162
Production MT 3,36,103 3,86,596 4,26,713 4,04,405
Trend Indexed 100 115 127 120
Capacity Utilization % 97% 85% 76% 72%
Trend Indexed 100 87 78 74
Domestic Sales MT 2,80,485 3,30,353 3,54,311 3,29,656
Trend Indexed 100 118 126 118
95. It is seen that –
a. The installed capacity of the domestic industry has increased over the period. The domestic industry has
submitted that it has expanded production capacities over the injury period.
b. The production of the domestic industry increased till 2023 -24 but declined during the period of
investigation.
c. Similarly, the domestic sales volume of the domestic industry increased upto 2023 -24 but declined thereafter
during the period of investigation. This is despite the fact that the demand increased over the injury period.
d. The capacity utilization of the domestic industry has significantly declined over the injury period.
b) Market share
96. The market share of the domestic industry, other domestic producers, subject imports and other imports is as
per the table below.
Market share Unit 2021 -22 2022 -23 2023 -24 POI
Domestic industry % 46% 43% 44% 38%
Other Indian producers % 47% 49% 49% 52%
Subject imports % 2% 4% 2% 5%
Other Imports % 4% 5% 5% 5%
97. It is noted that the market share of the domestic industry has declined over the injury period. Market share of
the other domestic producers has increased over the injury period. During the same time, the market share of
the subject imports has increased.
c) Inventories
98. Inventory position of the domestic industry over the injury period is given in the table below.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Opening Inventory MT *** *** *** ***
Closing Inventory MT *** *** *** ***
Average Inventory MT 6,379 7,899 9,988 9,566
Trend Indexed 100 124 157 150
99. The Authority notes that the average inventories of the domestic industry have increased over the injury period
with slight decline in the period of investigation, with decline in production. The domestic industry has claimed
that it has not been able to dispose of its production in the domestic market, resulting in accumulation of
inventories.
d) Profitability, cash profits and return on capital employed
100. Profitability, return on investment and cash profits of the domestic industry over the injury period are given in
the table below.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Cost of sales ₹/MT *** *** *** ***
Trend Indexed 100 113 108 108
Net sales realization ₹/MT *** *** *** ***
Trend Indexed 100 95 82 94
Profit/ (loss) ₹/MT *** (***) (***) (***)
Trend Indexed 100 -226 -373 -147
Profit/ (loss) ₹ Lacs *** (***) (***) (***)
Trend Indexed 100 -267 -471 -173
Cash Profit ₹ Lacs *** (***) (***) (***)
Trend Indexed 100 -106 -228 -49
Return of capital employed % *** (***) (***) (***)
Trend Indexed 100 -112 -190 -57
101. It is noted that that –
a. The domestic industry was earning profits in 2021 -22. However, the domestic industry started to face
losses in 2022 -23, which increased in 2023 -24. The losses of the domestic industry reduced during the
period of investigation. The domestic industry has claimed that the losses reduced due to its ability to
achieve cost reductions during this period. However, the domestic industry has continued to remain in
losses.
b. Over the injury period, the profitability of the domestic industry has deteriorated sharply.
c. The domestic industry has also incurred significant cash losses since 2022 -23.
d. The domestic has earned negative returns since 2022 -23. During the period of investigation also, the
domestic industry continued to earn negative returns.
e) Employment, productivity and wages
102. The Authority has examined the information relating to employment, wages and productivity, as given below.
Particulars Unit 2020 -21 2021 -22 2022 -23 POI
No. of employees Nos. 1,864 2,208 2,264 2,156
Salaries & Wages ₹ Lacs 15,326 17,560 20,052 20,850
Productivity per day MT/Days 934 1,074 1,185 1,123
Productivity per employee MT/Nos 180 175 188 188
103. It is noted that the number of employees and salaries have increased over the injury period. Further,
productivity per day and productivity per employee have increased. The domestic industry has not claimed
injury on this account.
f) Growth
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Production % - 15% 10% -5%
Domestic sales % - 18% 7% -7%
Profit / Loss % - -326% -65% 61%
Cash Profits % - -206% -114% 78%
Return on capital employed % - -212% -69% 70%
104. It is noted that the volume parameters of the domestic industry improved in 2022 -23 and 2023 -24. During the
period of investigation, the volume parameters of the domestic industry witnessed negative growth compared
to previous year. The profitability parameters of the domestic industry have, however, been adversely impacted
and deteriorated over the injury period. While the profitability has recovered slightly during the period of
investigation, the domestic industry has continued to face heavy losses and cash losses, and earned
significantly negative returns on its investments. Therefore, the domestic industry has faced deterioration in
respect of its profitability parameters.
g) Impact on the ability to raise capital investment
105. The Authority notes that the domestic industry has incurred steep losses since 2022 -23 and has faced negative
returns during this period. The domestic industry has incurred steep losses during the period of investigation as
well. The domestic industry is also facing cash losses. Therefore, it can be concluded that the ability of the
domestic industry to raise capital investment has been adversely impacted due to dumping.
h) Factors affecting prices
106. It is seen that the landed price of the subject imports remained significantly low. The imports were priced
below the non -injurious price and cost of sales of the domestic industry. This has forced the domestic industry
to sell at prices below their cost, resulting in financial and cash losses. The subject imports have depressed the
prices of the domestic industry and have prevented price increases, which otherwise would have occurred.
Thus, the imports have adversely impacted the prices of the domestic industry,
i) Magnitude of dumping
107. There is significant dumping of the subject goods from the subject countries which has adversely impacted the
conditions of fair competition in the market.
G.3.5. Threat of further injury
108. The Authority has also examined whether the imports are likely to cause further injury to the domestic
industry. The Authority notes as follows in this regard.
a) Increase in imports
109. It is noted that the volume of dumped imports has increased over the injury period. As compared to 2021 -22,
the volume of imports has increased by 186%. Further, the subject imports have more than doubled since the
previous year alone. Thus, the subject imports have increase at a sharp and alarming rate.
Particulars Unit 2021 -22 2022 -23 2023 -24 POI
Subject imports MT 14,607 27,541 18,249 41,719
Trend Indexed 100 189 125 286
b) Sufficiently freely disposable and idle capacities in the subject country
110. The domestic industry has provided information to show that the producers in the subject countries have large
production capacities, to the tune of 7,542 KT. Such capacities are significantly higher than the demand in
India. Further, the domestic industry has submitted information to demonstrate that the producers in the subject
countries are not fully utilizing their capacities, and have large freely disposable idle capacities. It is seen that
the unutilized capacities with producers in the subject countries are almost equivalent to 500% of the demand
in India. In case such idle capacities are utilized to export additional volumes to India, it is likely to result in
loss of significant market for domestic producers.
Figures in KT
Particulars Volume
Total capacity in subject countries 7,542
Total production in subject countries 3,226
Idle capacity in subject countries 4,316
Idle capacity in subject countries (%) 57%
Idle capacity in relation to Indian demand (%) 500%
Source: Report of Market Research Agency (Wood Mackenzie)
111. In fact, based on information submitted by the domestic industry, it is noted that there is a global oversupply of
the subject goods. While the total global demand in 2024 was 6,097 KT, the total global capacities were 12,179
KT. Such oversupply creates a situation conducive to aggressive pricing, including in the form of dumping.
Further, since the other markets are saturated in terms of supply themselves, it implies that the foreign
producers in the subject countries do not have access to alternative markets.
c) Significant export orientation of the subject countries
112. In addition, the domestic industry has provided evidence to show that there is limited demand for the subject
goods in the subject countries is limited and far lower than the installed capacities. The same can be seen from
the table below. The Authority notes that the producers in the subject countries have capacities which exceed
their demand, which indicates that the producers are highly export oriented and the capacities are intended for
exports. Such excess capacities are more than almost 5 times the demand in India.
Figures in KT
Particulars Volume
Total capacity in subject countries 7,542
Total demand in subject countries 3,122
Capacity in excess of demand 4,420
Excess capacity in subject countries (%) 59%
Excess capacity in relation to Indian demand (%) 512%
Source: Report of Market Research Agency (Wood Mackenzie)
d) Planned capacity expansions
113. The domestic industry has also submitted information to show that in addition to the existing underutilized
capacities in the subject countries, the producers/ exporters have planned further capacity expansions between
2025 -2029, as can be seen from below. Such capacity additions is likely to create an additional disposable
surplus, that may be used for exports to India.
Country Producer Capacity (kt)
China Nantong Kanghui Petrochemical Co. Ltd 600
China Zhejiang Yuyue New Materials 200
China Jiangsu Xingye Polytech Co.,Ltd 197
China Zhejiang XinFengMing (Jiangsu) 125
China Jiangsu Shuangxing Color Plastic New Materials 120
China Yingkou Kanghui Petrochemical Co. Ltd 104
China Ningbo Changyang Technology 100
China Shaoxing XiangYu Green Packing 100
China Other producers 872
Total 2,419
Source: Report of Market Research Agency (Wood Mackenzie)
e) Trade remedial and tariff measures imposed by other countries
114. The exports of subject goods from subject countries are subject to trade remedial measures in various third
countries.
Country Measure Date of imposition
Indonesia Anti-dumping duty on imports of Biaxially
Oriented Polyethylene Terephthalate Films from
China and Thailand Originally imposed in December 2015 and
continued in May 2021
Brazil Anti-dumping duty on imports of Polyethylene
Terephthalate Films including BOPET Film from
China Originally imposed in May 2015 and continued
in May 2021
USA Anti-dumping duty on imports of Polyethylene
Terephthalate Film from China and UAE Originally imposed in November 2008 and
continued in September 2020
115. Additionally, USA has imposed Section 301 tariffs to the extent of 25% on imports of PET Film from China.
The domestic industry has claimed that since almost all major export destinations for the subject goods have
imposed measures on imports from the subject countries, such markets are practically closed to the exporters.
In such a situation, the exporters in the subject countries are likely to divert their exports to India.
f) India is an attractive market
116. As noted above, the exports from subject countries are facing tariff and trade remedial measures from major
consuming countries, which has resulted in loss of market. Further, the exporters in the subject countries are
already facing limited demand and idling of capacities. In such a situation, India would likely be key export
market for such producers. Thus, in case of non -imposition of duties at the earliest, the producers in the subject
countries would intensify dumping in the Indian market.
g) Subject imports are likely to further suppress or depress the prices of the industry
117. During the period of investigation, the subject imports were undercutting the prices of the domestic industry. In
the absence of duty, the lower import prices are likely to exert pressure on the prices of the domestic industry.
Thus, the imports are entering the Indian market at prices that are likely to have a further suppressing or
depressing effect on the prices of the domestic industry. This is further likely to adversely impact the
profitability of the domestic industry, pushing it into higher losses.
G.3.6 Overall assessment of injury
118. The examination of the imports of the subject product and the performance of domestic industry clearly shows
that –
i. The volume of imports from the subject countries has increased significantly in absolute terms, by
186%.
ii. The subject imports have also increased in relation to Indian production and in relation to the domestic
consumption.
iii. The subject imports were priced above the net sales realization of the domestic industry, but were priced
below the cost of sales of the domestic industry.
iv. The domestic industry reduced its prices at a rate higher than decline in cost, in order to match the
import price, which remained significantly low. As a result, the subject imports have suppressed and
depressed the costs of the domestic industry.
v. While the production and sales volume of the domestic industry increased till 2023 -24, the same
declined in the period of investigation. The sales of the domestic industry have reduced by 7% in the
period of investigation as compared to preceding year, despite an increase in demand by 8% during the
period of investigation.
vi. The capacity utilization of the domestic industry has declined over the period.
vii. The market share of the domestic industry has declined, while that of the subject imports increased.
viii. The domestic industry is unable to dispose of its production, thereby resulting in the piling up of
inventories.
ix. The domestic industry faced significant losses, cash losses and it earned a negative return on its capital
employed.
x. The imports have adversely impacted the ability of the domestic industry to raise further capital
investments.
xi. The imports have adversely affected the prices of the domestic industry.
xii. The dumping margin is positive and significant.
xiii. The dumped imports are threatening to cause further injury to the domestic industry, in view of the
significant rate of increase in imports, significant idle capacities available with foreign producers, high
export orientation of foreign producers, global oversupply situation, planned capacity expansions,
imposition of trade remedial measures by third countries as well as imposition of additional tariffs.
119. In view of the foregoing, the Authority provisionally concludes that the domestic industry has suffered material
injury and the imports are threatening to cause further injury to the domestic industry.
G.3.7. Non-attribution analysis and causal link
120. Having examined the existence of injury, volume and price effects of dumped imports on the prices of the
domestic industry, the Authority has examined whether injury to the domestic industry can be attributed to any
factor, other than the dumped imports, as listed under the Rules.
a) Volume and value of imports from third countries
121. It is noted that, barring the subject countries, there are no significant imports from any other country, barring
Taiwan and USA. The Authority notes that the volume of injurious imports from Taiwan is negligible and thus,
could not have caused injury to the domestic industry. Further, the imports from USA comprised entirely of
stock lot or leftover stocks, which were not competing with the domestic industry and could not have caused
injury. Therefore, the injury is not attributable to imports from third countries.
b) Contraction in demand
122. The Authority notes that the demand for the subject goods has increased through the injury period and the
domestic industry has not suffered injury due to a contraction in demand.
c) Pattern of consumption
123. No material change in the pattern of consumption of the product under consideration has been identified, which
could have caused injury to the domestic industry.
d) Conditions of competition and trade restrictive practices
124. It is noted that there is no evidence of conditions of competition or trade restrictive practices that are
responsible for the claimed injury to the domestic industry. It is further noted market share of Indian industry
as a whole has declined and market share of subject imports has increased. Therefore, the Authority
provisionally finds that the domestic industry has not suffered injury due to conditions of competition.
e) Developments in technology
125. It is noted that there has been no change in technology for the production of the subject goods that could have
caused injury to the domestic industry.
f) Productivity
126. The Authority notes that the productivity of the domestic industry has increased over the injury period.
Therefore, the domestic industry has not suffered injury on this account.
g) Export performance of the domestic industry
127. The injury information examined hereinabove relates only to the performance of the domestic industry in terms of its
domestic market. Thus, the injury suffered cannot be attributed to the export performance of the domestic industry.
h) Performance of other products
128. The Authority has considered data relating only to the performance of the subject goods. Therefore, the
performance of other products produced and sold is not a possible cause of injury to the domestic industry.
G.3.8. Conclusions on causal link
129. While other known factors listed under the Rules have not caused injury to the domestic industry, the Authority
notes that the following parameters show that injury to the domestic industry is caused by the dumped imports.
i. There is significant dumping of the subject goods from the subject countries.
ii. As a result, the volume of dumped imports has increased significantly over the injury period.
iii. The volume of imports has also increased in relation to Indian consumption and production.
iv. The increase in dumped imports prevented the domestic industry to sell its goods in the market at
remunerative prices.
v. As a result, the market share of the domestic industry declined while that of the imports has increased
over the period.
vi. The domestic industry faced significant accumulation of inventories as it was unable to sell its product
in the market.
vii. The capacity utilization of the domestic industry has declined.
viii. The low -priced imports prevented price increases, which otherwise would have occurred, and depressed
the prices of the domestic industry.
ix. The domestic industry has been forced to sell at losses, and it has faced cash losses as well.
130. The Authority, thus, provisionally concludes that there exists a causal link between the dumping of the subject
goods and injury to the domestic industry.
H. MAGNITUDE OF INJURY MARGIN
131. The Authority has determined non -injurious price for the domestic industry on the basis of principles laid down
in the Rules read with Annexure III. The non -injurious price of the product under consideration has been
determined by adopting the provisionally verified information/data relating to the cost of production for the
period of investigation. The non -injurious price has been considered for comparing the landed price from the
subject country for calculating the injury margin. For determining the provisional non -injurious price, the best
utilization of the raw materials by the domestic industry over the injury period has been considered. The same
treatment has been carried out with the utilities. The best utilization of production capacity over the injury
period has been considered. It is ensured that no extraordinary or non -recurring expenses are charged to the
cost of production. A reasonable return (pre -tax @ 22%) on average capital employed (i.e., average net fixed
assets plus average working capital) for the product under consideration was allowed as pre -tax profit to arrive
at the non -injurious price as prescribed in Annexure III of the Rules and being followed.
132. The landed price for the cooperative exporters has been provisionally determined on the basis of the data
furnished by the exporters pending detailed verification. For all co -operative non -sampled producers/exporters,
weighted average landed value of the sampled producers/exporters is taken. For all the non -cooperative
producers/exporters from the subject countries, the Authority has determined the landed price based on the
facts available.
133. Based on the landed price and non -injurious price determined as above, the injury margin for producers/exporters has
been provisionally determined by the Authority and the same is provided in the table below:
Injury Margin Table
Producer Non-
injurious
price
(USD/MT) Landed
Price
(USD/MT) Injury
Margin
(USD/MT) Injury
Margin
(%) Injury
Margin
(Range)
A. Bangladesh
1. AKIJ Biax Films Limited *** *** *** *** 10-20
2. Any other *** *** *** *** 25-35
B. China PR
1. Jiangsu Kanghui New
Material Technology Co.,
Ltd. *** *** *** *** 15-25
2. Kanghui Nantong New
Material Technology Co.,
Ltd.
*** *** *** *** 20-30
3 Kanghui New Material
Technology Co., Ltd.
(collectively "Kanghui
Group") *** *** *** *** 30-40
4 Weighted Average
(Kanghui Group) *** *** *** *** 15-25
5 Jiangsu Shuangxing Color
Plastic New Materials Co.,
Ltd. *** *** *** *** 0-10
6 Other non -sampled
cooperating producers *** *** *** *** 10-20
7 Any other *** *** *** *** 30-40
C. Thailand
1. A.J. Plast Public Co.
Limited *** *** *** *** 25-35
2. Any other *** *** *** *** 40-50
I. INDIAN INDUSTRY’S INTEREST & OTHER ISSUES
I.1. Submissions made on behalf of the other interested parties.
134. The other interested parties have submitted that they oppose the imposition of anti -dumping duties on the
subject goods. Further, it has been submitted that imposition of duties would adversely impact the operations of
downstream users who would not be able to survive.
I.2 Submissions made on behalf of the domestic industry.
135. The domestic industry has made the following submissions with regard to the Indian industry’s interest.
i. Imposition of duties would not have any adverse impact on the costs of the downstream users and would
be in the interests of public at large.
ii. PET Film accounts for only 25% of the weight of a packet of chips which is approximately 4 -5 grams.
Imposition of duties upto 30% will have a negligible impact of only 5 paise or 0.2% on the costs of the
end-consumers.
iii. The subject goods do not constitute a major share in the costs of the downstream users, and thus,
imposition of duties would not have any significant impact.
iv. Since 2001, the Indian industry for PET Film has increased from 6 producers to 18 domestic producers
who are employing upto 12,000 employees across 45+ production lines.
v. Imposition of duties will create a level playing field and will allow the domestic industry to recover its
costs and sell at remunerative prices.
vi. The Indian industry has sufficient capacity to cater to the entire demand in the country, and thus, subject
imports are entirely unnecessary.
vii. Imposition of duties is necessary to ensure viability operations of the Indian industry who have made
significant investments and have increased capacities to cater to the demand in the last two decades.
viii. The Indian industry is using latest technology which is at par with other global producers.
ix. The Indian industry offers full range of variants of PET Film which can be used in all applications.
x. Imposition of duties is essential to ensure a fair market situation where Indian producers can compete
and would further the goal of Aatma Nirbhar Bharat policy.
xi. If duties are not imposed, the Indian industry would continue suffering which may lead to unnecessary
loss of employment.
xii. Imposition of duties will contribute to forex savings in the country.
xiii. There is healthy inter -se competition between the Indian producers, ensuring availability of goods at
competitive prices.
xiv. The users can easily procure the subject goods from the Indian industry and other countries. Further, the
goods can be imported from subject countries at fair prices.
xv. Non-imposition of duties would make the users dependent on exports who would become vulnerable to
exploitation by exporters.
xvi. Non-imposition of duty on PET Film will only add on to the injury being suffered by MEG industry due
to dumping of MEG imports from Kuwait, Saudi Arabia and Singapore.
I.3 Examination by the Authority
136. The Authority notes that the primary objective of anti -dumping duties is to rectify the injury inflicted upon the
domestic industry by the unjust trade practices of dumping, thereby fostering an environment of open and
equitable competition in the Indian market. The imposition of anti -dumping measures is not designed to curtail
imports from the subject countries arbitrarily. Rather, it is a mechanism to ensure a level playing field. The
Authority acknowledges that the persistence of anti -dumping duties may influence the price levels of the
product in India.
137. The subject goods are majorly used in the manufacturing of flexible packaging, which is then used for packing
various consumer goods. Thus, the subject goods do not constitute a major cost in the ultimate finished
product, and the change in price of the subject goods would not impact the price of the finished consumer
product.
138. Certain interested parties have argued that imposition of duties would adversely impact the operations of the
downstream duties. On the other hand, the domestic industry has claimed that imposition of duties would not
have any significant impact on the downstream users or the end -consumers. The domestic industry has also
submitted that even if anti -dumping upto 30% is imposed, the same would not have any significant adverse
impact on the costs of the end -users.
139. It is noted that there are 19 other producers in the country, ensuring domestic availability of the subject goods.
Further, the subject goods can also be imported from various third countries, which would ensure sufficient
supply of the goods for the users.
140. The domestic industry has submitted that since 2001, when there were only 6 -8 producers of PET Film in
India, the industry has made significant investments and today, there are almost 19 producers in India. The
plants of the industry are all based on new technology and the industry is offering full range of products. The
new capacity additions have generated employment for 12,000 employees. Thus, there is a need to protect such
investments and support the industry to further the goal of Aatmanirbharta.
141. It is noted that there is no demand -supply gap in the country necessitating dumped imports into the country.
The Authority notes that the Indian industry has significant capacities as claimed by the domestic industry
which are sufficient to meet the entire present and foreseeable demand in the country.
Figures in MT
Particulars 2024 -25
Indian demand 8,63,953
Indian capacity 14,09,200
Demand -supply gap -5,45,247
J. CONCLUSION & RECOMMENDATIONS
142. After examining the submissions made by the interested parties and issues raised therein; and considering the
facts available on record, the Authority provisionally concludes that:
i. The product under consideration is Polyethylene Terephthalate Film or Biaxially Oriented Polyethylene
Terephthalate Film of 8 -100 microns. PET Film for use in solar panels and Thermal Lamination Film
are excluded from the scope of the product under consideration.
ii. The five producers i.e., Chiripal Poly Films Limited, Ester Industries Limited, Vacmet India Limited,
Uflex Limited and Sparsh Industries Private Limited account for 45% of the total eligible Indian
production, and have been considered eligible to constitute domestic industry for the purpose of the
present investigation. The application has been supported by 10 other producers. The domestic industry
long with the supporters account for 96% of the total eligible Indian production.
iii. Considering a large number of responses received from China PR, the Authority has resorted to
sampling of 2 producer groups, based on the volume exports made by such exporters.
iv. Since no producer from China PR filed a request for market economy treatment, China PR has been
considered as a non -market economy and the normal value has been determined based on the price
payable in India. For this purpose, the cost of production of the domestic industry with reasonable
adjustments has been considered. Individual export price has been determined for sampled producers
from China based on their responses. For non -sampled cooperating producers, the dumping margin has
been determined based on weighted average of margins determined for sampled producers.
v. The dumping margin for the subject goods from each of the subject countries is positive.
vi. The demand for the subject goods has increased throughout the injury period.
vii. It is provisionally concluded that domestic industry has suffered injury as a result of the import of
subject goods, as evident from the following.
a. The volume of imports increased sharply over the injury period, in absolute and relative terms, and
were the highest in the period of investigation.
b. The subject imports were priced above the net sales realization of the domestic industry, but were
priced below the cost of sales of the domestic industry.
c. The cost of sales of the domestic industry increased over the period, while the net sales realisation of
the domestic industry declined in response to the decline in the landed price of imports.
d. The market share of the domestic industry declined, while that of the imports increased.
e. The domestic industry faced significant losses and cash losses.
f. The return on capital employed of the domestic industry is negative.
g. The imports have adversely impacted the ability of the domestic industry to raise further capital
investments.
viii. The subject imports are threatening to cause further injury to the domestic industry, as evident from the
following.
a. The volume of subject imports has increased at a significant rate.
b. The producers in the subject countries have significant freely disposable and idle capacities.
c. The producers in the subject countries are highly export oriented.
d. The producers in the subject countries have planned capacity expansions, despite significant idle
capacities and low demand.
e. There is global oversupply situation, which makes India a vulnerable market.
f. The producers in subject countries are facing trade remedial measures and additional tariffs in
third countries, which has restricted their market.
g. The imports are entering at prices which are likely to further suppress or depress the domestic
prices.
ix. The injury margin for each of the subject countries is positive.
x. No other factor appears to have caused injury to the domestic industry. It is noted that domestic industry
has suffered material injury as a result of the dumped imports.
xi. The imposition of anti -dumping duty is in the interest of the public and would have no adverse impact
on the interests of public at large.
xii. Imposition of duties would not increase the cost of end -consumers significantly.
xiii. The subject goods are used producing packaging for consumer goods, and thus, do not constitute a
major cost for the end -users.
xiv. There is no demand supply gap in the country, and the Indian industry has sufficient capacities to cater
to the entire demand.
xv. The subject goods can be imported from various third countries, and from the subject countries at fair
prices.
143. The Authority notes that the investigation was initiated and notified to all interested parties and adequate
opportunity was given to the domestic industry, exporters, importers and other interested parties to provide
positive information on the aspect of dumping, injury and causal link. Having initiated and conducted the
investigation into dumping, injury and causal link in terms of the provisions laid down under the Anti -
Dumping Rules, the Authority is of the view that imposition of provisional duty is required to offset dumping
and injury, pending completion of the investigation. Therefore, the Authority considers it necessary and
recommends the imposition of provisional anti -dumping duty on imports of the subject goods from the subject
countries.
144. Having regard to the lesser duty rule followed by the Authority, the Authority recommends the imposition of
provisional anti -dumping duty equal to the lesser of the margin of dumping and the margin of injury, so as to
remove the injury to the domestic industry. Accordingly, the Authority recommends imposition of provisional
anti-dumping duty as per Rule 12 on the imports of the subject goods, originating in or exported from subject
countries, from the date of notification to be issued in this regard by the Central Government, equal to the
amount mentioned in Col. 7 of the duty table appended below.
Duty Table
S.
no. Heading Description Country of
Origin Country of
Export Producer Amount Unit Currency
1 2 3 4 5 6 7 8 9
1 3920 6210,
3920 6220,
3920 6290,
3920 6919
and 3921
9094. Polyethylene
Terephthalate
Film* Bangladesh Any
country
including
Bangladesh AKIJ Biax
Films Limited 206 MT USD
2 -do- -do- Bangladesh Any
country
including
Bangladesh Any producer
other than that
mentioned at
S.N. 1 330 MT USD
3 -do- -do- Any country
other than
Bangladesh,
China PR
and
Thailand Bangladesh Any producer 330 MT USD
4 -do- -do- China PR Any
country
including
China PR Jiangsu
Kanghui New
Material
Technology
Co., Ltd. 162 MT USD
5 -do- -do- China PR Any
country
including
China PR Kanghui
Nantong New
Material
Technology
Co., Ltd 162 MT USD
6 -do- -do- China PR Any
country
including
China PR Kanghui New
Material
Technology
Co., Ltd. 162 MT USD
7 -do- -do- China PR Any
country
including
China PR Jiangsu
Shuangxing
Color Plastic
New Materials
Co., Ltd. 56 MT USD
8 -do- -do- China PR Any
country
including
China PR Non-Sampled
Cooperative
Producers, as
per list
below** 135 MT USD
9 -do- -do- China PR Any
country
including
China PR Any, other
than those
mentioned at
S.N. 4, S.N. 5,
S.N. 6, S.N. 7
and S.N. 8 216 MT USD
10 -do- -do- Any country
other than
Bangladesh,
China PR
and
Thailand China PR Any 216 MT USD
11 -do- -do- Thailand Any
country
including
Thailand A.J. Plast
Public Co.
Limited 139 MT USD
12 -do- -do- Thailand Any
country
including
Thailand Any, other
than that
mentioned at
S.N. 11 245 MT USD
13 -do- -do- Any country
other than
Bangladesh,
China PR
and
Thailand Thailand Any 245 MT USD
* The product under consideration is Polyethylene Terephthalate Film or Biaxially Oriented Polyethylene
Terephthalate Film of 8 -100 microns. PET Film for use in solar panels and Thermal Lamination Film are excluded
from the scope of the product under consideration
** List of non -sampled cooperative producers from China PR
i. Fujian Billion High -Tech Materials Ind. Co., Ltd.
ii. M/s. Hangzhou Great Southeast Science and Technology New Material Co., Ltd.
iii. Shandong Shenghe Films New Materials
145. The application of the individual duty rates specified for the companies mentioned in the above duty table shall
be conditional upon presentation to the customs authorities of a valid commercial invoice, on which shall
appear a declaration dated and signed by an official of the entity issuing such invoice, identified by his/her
name and function, drafted as follows:
“‘I, the undersigned, certify that the (volume) of (name of PUC) sold for export to the India covered by this
invoice was manufactured by (company name and address) in [country concerned]. I declare that the
information provided in this invoice is complete and correct.”
146. If no such invoice is presented, the duty applicable to all other rates shall apply. This requirement is without
prejudice to the verification procedures independently undertaken by the Customs authorities under the
applicable customs law and regulations.
K. FURTHER PROCEDURE
147. The procedure as below would be followed subsequent to notifying the preliminary findings:
i. The Authority invites comments on these provisional findings from all interested parties within 15 days
from the publication of these findings, and the same, to the extent considered relevant by the Authority,
would be considered in the final findings.
ii. The Authority would conduct an oral hearing in terms of Rule 6(6) of the Anti -dumping Rules to
provide an opportunity to the interested parties to present their views relevant to the subject
investigation. The date of the oral hearing will be published on the website of the Authority.
(www.dgtr.gov.in ).
iii. The Authority would conduct further verification of the interested parties to the extent deemed
necessary.
iv. The Authority will disclose the essential facts as per the Anti -dumping Rules before issuing its final
findings.
AMITABH KUMAR , Designated Authority
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