Full Text
REGD. No. D. L.-33004/99
The Gazette of India
CG-DL-E-30062026-273948
EXTRAORDINARY
PART I-Section 1
PUBLISHED BY AUTHORITY
No. 175] | NEW DELHI, WEDNESDAY, JUNE 24, 2026/ASHADHA 3, 1948
MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce)
(DIRECTORATE GENERAL OF TRADE REMEDIES)
FINAL FINDINGS
New Delhi, the 24th June, 2026
Case No. AD (MTR)-03/2025
Subject: Final Findings in the Mid-Term Review limited to the product scope of anti-dumping duty
imposed on Stainless-Steel Seamless Tubes and Pipes originating in or exported from China
PR.
F. No. 7/13/2025-DGTR.— Having regard to the Customs Tariff Act, 1975 as amended from time to
time 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 (“AD Rules,
1995" or the "AD Rules" or the "Rules").
(1)
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1995 (hereinafter referred to as the "Rules") for clarification of the scope of product under
consideration as defined by Notification No. 6/13/2021-DGTR dated 23.09.2022, limited to
examining whether Casting & Tubing with premium threading (known as OCTG in market
parlance) manufactured by using "Seal-Lock XD" process patented by HESPL (Hunting Energy
Services Pte. Ltd.) originating in or exported from China PR (hereinafter also referred to as the
“subject country") is not covered within the scope of the product under consideration.
2. And whereas vide Notification No. 6/13/2021-DGTR dated 23.09.2022 recommended imposition of
definitive anti-dumping duty on imports of "Stainless-Steel Seamless Tubes and Pipes with diameter
up to and including 6 NPS, or comparable thereof in other unit of measurement, whether
manufactured using hot extrusion process or hot piercing process and whether sold as hot finished or
cold finished pipes and tubes, including subject goods imported in the form of defectives, non-prime
or secondary grades" (hereinafter also referred to as the “subject goods") originating in or exported
from China PR (hereinafter also referred to as the “subject country") and the definitive anti-dumping
duty was imposed by the Central Government vide Notification No. 31/2022-customs (ADD) dated
20.12.2022.
3. The Authority, on the basis of sufficient prima facie evidence submitted by the applicant, issued a
public notice vide Notification No. 7/13/2025-DGTR dated 26th June 2025, published in the Gazette
of India, initiating a mid-term review of anti-dumping duty imposed on imports of Stainless-Steel
Seamless Tubes and Pipes originating in or exported from the subject country, limited to re-
determination / clarification on product scope, in accordance with Section 9A of the Customs Tariff
Act read with Rule 23 of the AD Rules, 1995.
B PROCEDURE
4. The following procedure has been followed with regard to this investigation:
a. The Authority issued a public notice dated 26th June, 2025, published in the Gazette of India
Extraordinary, initiating the anti-dumping investigation concerning imports of the subject
goods from the subject country.
b. The Authority informed the Embassy of China PR in India about the initiation of the subject
investigation requesting them to inform concerned exporters/producers about the same.
c. The Authority made available copies of the non-confidential petition to the domestic industry
in the original investigation.
d. The Authority also circulated copy of the non-confidential version of the application filed by
the applicant with the known producers/exporters, known importers/users and to the Embassy
of the subject country in India in accordance with Rule 6(3) of the AD Rules, 1995.
e. Since the petition is for a limited purpose of exclusion of a certain type of product under
consideration, the Authority is not required to evaluate the quantum of dumping and injury,
therefore, stipulation of POI is not required.
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f. The Authority examined the information furnished by the applicant and the domestic industry
to the extent possible to verify the claims made by the applicant. Further information was
sought from the applicant and the domestic industry to the extent deemed necessary.
Verification of the data and claims of the applicant was conducted to the extent considered
necessary for the purpose of the investigation.
g. Verification of data and claims of the domestic industry was also carried out to the extent
considered necessary for the purpose of the investigation.
h. In accordance with Rule 6(6) of the Rules, the Authority also provided opportunity to the
interested parties to present their views orally in an oral hearing held on 11th August, 2025.
The parties, which presented their views in the oral hearing, were requested to file written
submissions of their views expressed orally, followed by rejoinder submissions.
i. In accordance with the Rules, the Authority disclosed the essential facts of the case that would
form the basis of its findings in the form of a disclosure statement on 14th November 2025 and
the interested parties were allowed time up to 21st November 2025 to comment on the same.
The comments of the interested parties, to the extent relevant, have been considered by the
Authority and have been addressed in this finding.
j. Due to change in the Designated Authority, a fresh oral hearing was conducted on 10th March
2026. The parties, which presented their views in the oral hearing were requested to file
written submissions of their views expressed orally, followed by rejoinder submissions.
k. The essential facts of the investigation gathered by the Authority during the present
investigation and analysed by the Authority were disclosed to the interested parties in order to
enable them to offer their comments on these facts.
l. '***' in the final findings represents information furnished by an interested party on
confidential basis and so considered by the Authority under Rule 7 of AD Rules, 1995.
C PRODUCT UNDER CONSIDERATION AND LIKE ARTICLE
C.1. Submissions made by the applicant
5. The submissions made by the Applicant are as follows:
i. The original investigation covered only seamless stainless pipes and tubes made by hot
extrusion or piercing and not OCTG pipes made with the SEAL Lock XD (SLXD) process.
ii. Threading is a critical process as it increases the sealing ability and resistance to high pressure
and corrosion faced in drilling. Due to this, the product concerned is imported as per specific
requirement for cut size and dimensions etc.
iii. The product concerned differ from products covered by the original investigation in terms of
price, physical characteristics, manufacturing process and technology, functions, end-uses and
technical specifications, and are neither technically nor commercially substitutable from the
consumer's perspective.
iv. Commercial orders to Jindal SAW Limited (JSL) were placed post the period of investigation
in 2022. During the period of investigation of the original anti-dumping investigation, there
was no domestic manufacturer of the product concerned.
v. The inclusion of OCTG, which was not produced domestically during the period of
investigation, to the product scope would create a monopoly for Jindal SAW Limited which is
the only local producer.
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vi. Jindal SAW Limited did not have the license or API Certification during the period of
investigation of the original investigation to produce OCTG with SLXD. The responses from
Chandan Steel and Tubacex Prakash show that OCTG was not offered domestically until 2022
and differs from stainless steel seamless pipes and tubes.
vii. There is no proven commercial availability of the product during 2017 to 2021. The only
domestic licence for the Seal-Lock threading process was obtained in March-April 2022, that
is, after the period of investigation of the original investigation. Thus, the product could not
have formed part of the original product scope. This shows that the domestic producers
received license post POI which shows changed circumstance.
viii. Commercial records submitted by JSW only show indexed values and lack proof of production
for the period before 2022. Further, the production data filed by JSW pertains to casing and
tubing of steel tubes and pipes, not specifically to casing and tubing with premium-threading
OCTG using Seal-Lock XD process.
ix. Domestic production and sales of premium-threaded products by Jindal was 100 MT in 2020-
21, 85 MT in 2021-22 and 29 MT in 2022-23. Further, the findings in the original
investigation shows that there is no data for the previous years, 2017–2020. Thus, the segment
was commercially nascent and absent from the original investigation. The product concerned
was not commercially ready or technically interchangeable with the imported product, and
under the CESTAT decision in Oxo Alcohols Industries' Association v. Designated Authority,
the non-interchangeable product cannot be treated as dumped product.
x. There are scale constraints and only limited supply of the product concerned by Jindal Saw
Limited. There is a need for commercial supply of the product in order for inclusion of the
same in the scope of the product under consideration.
xi. Jindal Saw Limited has not applied for the global tender floated by Vedanta in 2022 which
shows supply constraints.
xii. Paragraph 128 of the Final Findings in the original investigation records the landing value of
the subject goods at ₹ 2.3 lakh per MT to ₹ 2.84 lakh per MT, whereas the domestic industry
stated that the product concerned is priced at ₹ 8 lakh per MT to ₹ 9 lakh per MT. Imports at
high price shows product is not dumped and duty cannot be imposed on them.
xiii. Even after first domestic production ONGC, other buyers sought exemptions for procuring the
product concerned due to performance, technical and patent licensing issues. This highlights
the supply constraints in India.
xiv. The United States of America separately define and impose duties on OCTG pipes and
standard seamless pipes.
xv. The SLXD process fundamentally alters the functional capability of the tube. OCTG pipes
were not produced during the original period of investigation.
xvi. Jindal SAW Limited secured a contract to manufacture OCTG pipes post the period of
investigation.
xvii. The claim that ONGC has been a regular and consistent buyer from Indian producers is false.
ONGC and OIL procurement records before and during the period of investigation show
imports citing non-availability of the required product from domestic sources.
xviii. The DGTR recommends anti-dumping duties if there exists dumping and injury to the
domestic industry. Since the product concerned was not produced in India during the period of
investigation no duty should be imposed on the same.
xix. The inclusion of OCTG within the scope would allow for monopoly by the single domestic
producer, this is not the intent of trade remedial measures.
xx. The HS classification for both products is different. The HS Code for subject goods covered
by the original investigation is HS 7304 11, pipe of a kind used for oil and gas pipelines",
while the product concerned falls under HS 7304 22, “casing, tubing and drill pipe, of a kind
used in drilling for oil or gas”.
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xxi. Contrary to the submissions of the domestic industry, commercial importers of the product
concerned include oil field operators which are large and regulated entities and there are only
remote possibility of wrongful declaration and circumvention of duties by them.
C.2. Submissions made by the domestic industry and Indian Stainless Seamless Pipes
Manufacturers Association
6. The submissions made by the domestic industry and Indian Stainless Seamless Pipes Manufacturers
Association are as follows:
i. The product concerned is a stainless-steel pipe and tube and hence, covered under the scope of
the product under consideration.
ii. The definition of the product under consideration does not distinguish between threaded and
non-threaded product. Thus, the scope of the product under consideration is clear and includes
both threaded and no threaded products.
iii. The definition of the product under consideration as per the initiation notification in the
original investigation shows that the product is used to transfer liquids and gases, thus, the
product concerned is included within the scope of the product under consideration.
iv. Jindal Saw Limited is producing and selling the product concerned since 2020-21, that is, the
period of investigation of the original investigation. Further, Jindal Saw Limited has produced
and sold the subject goods continuously till 2025-26.
v. Jindal Saw Limited received license from Hunting PLC to undertake Seal Lock XD threading
process in 2019, that is prior to the period of investigation of the original investigation.
vi. The product concerned is not mass produced and inventories of the same are not maintained.
The product has been produced by Jindal Saw Limited based on the orders received.
vii. The applicant has failed to demonstrate that the demand of the product concerned was higher
in the past as compared to the supply by the domestic industry.
viii. ONGC is the largest consumer of the product concerned and has continuously bought the
product concerned from the Indian industry. ONGC has not imported the product concerned at
all.
ix. The Indian industry has also sold to Oil India Limited.
x. The brochure issued by the domestic industry shows that the product is being offered in India.
xi. The domestic industry has offered the product concerned to the applicant as well. However,
the applicant has not replied to the offer made by Jindal Saw Limited and instead opted to
import the said product from the subject country.
xii. Even in the present period, Jindal Saw Limited holds purchase order for the product
concerned.
xiii. During the oral hearing, Vedanta had relied upon certain minutes of the meeting but failed to
share the same with the domestic industry.
xiv. Seal Lock XD is not a production process for manufacturing of pipes and is merely a threading
process. Even OCTG pipes are manufactured using hot extrusion or hot piercing process; and
hence, there is no difference in the basic production process of the product concerned and the
product under consideration.
xv. Threading is being done by the Indian industry also using the same process as stated by the
applicant.
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xvi. While the applicant submitted in the oral hearing that threading is being undertaken by Jindal
Saw Limited in a joint venture with Chinese entity, the same is incorrect. Jindal Saw Limited
has a joint venture with Hunting PLC which is an American company.
xvii. Contrary to the submissions of the applicant, there are a number of products for which there is
only a single producer in the country and the DGTR has recommended and MOF has imposed
anti-dumping duty. Further, product concerned is only one of the grades of the product under
consideration. There are multiple producers of the product under consideration in India.
xviii. Imposition of anti-dumping duty does not lead to monopoly and does not restrict imports into
India, the users are free to import the product at fair prices.
xix. As opposed to the submissions of the other interested parties, there is no obligation on each
Indian producer to supply each grade of the product under consideration.
xx. The applicant itself has submitted documents showing that the request filed by ONGC for
exemption for procuring the product concerned was withdrawn during the meeting of the
standing committee under DMI&SP Policy due to availability of domestic capacity in India.
xxi. Certain minutes submitted by the applicant are for the products not made out of stainless steel
but for products of carbon steel.
xxii. Contrary to the submissions by the applicant, the decision of the US investigating authority
does not impact the decision of the Authority in the Indian anti-dumping investigation. There
is no fixed definition of the product under consideration and the same is decided in each
investigation separately.
xxiii. Since the product concerned is available in India, there is no justification to exclude the same
from the scope of the product under consideration based on incremental process.
xxiv. The present is a review under Rule 23 and the Authority is not re-examining the correctness of
the decision taken at the time of original investigation as the Authority has become functus
officio at this stage and cannot revisit its own final findings. Since the present review is under
rule 23, the Designated Authority can only examine the request on the basis of changed
circumstances and whether the product is being produced in India during the present period.
xxv. Request for clarification of product scope under Rule 23 is not maintainable and a product
grade cannot be excluded based on clarification request under Rule 23. By filing an
application under Rule 23, the applicant itself admits that the product concerned is included in
the scope of the product under consideration.
xxvi. The applicant has failed to show that there are any changed circumstances of lasting nature
due to which there is a need for exclusion of the product concerned.
xxvii. Vedanta has filed the present application primarily to seek clearance for a shipment already at
port. The Ministry of Steel has questioned on the necessity of imports when such product was
available and being produced by the domestic producers. The Authority may seek inputs from
Ministry of Steel.
xxviii. Merely because the price of the product concerned is higher, the same does not establish
absence of dumping.
xxix. The incidence of anti-dumping duty on the product concerned is only 1.1%.
xxx. Any exclusion in the name of product concerned is likely to lead to widespread abuse and
avoidance of anti-dumping duty in force. The importers are likely to import the product under
consideration under the name of product concerned.
xxxi. Contrary to the submissions of the applicant, the Authority had considered HS Code at 4-digit
level, that is, 7304 for imposition of anti-dumping duty. Hence, the product concerned is not
excluded from the scope of the product under consideration.
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C.3. Examination by the Authority
7. The Authority considered the following scope of the product under consideration at the time of
issuance of the final findings in the original investigation.
“3. The product under consideration is stainless-steel seamless tubes and pipes with diameter up to
and including 6 inches, whether manufactured using hot extrusion process or hot piercing process
and whether sold as hot finished or cold finished pipes and tubes, including subject goods imported
in the form of defectives, non-prime or secondary grades.
4. Stainless-steel seamless tubes and pipes are used for structural purposes and to transfer liquids
and gases. The product under consideration is used in application relating to oil and gas;
petrochemicals and refineries; atomic energy; power generators including nuclear and thermal
power; and aerospace and defence applications.
5. The product under consideration can be manufactured using either hot extrusion process or hot
piercing process, which is also known as cross roll piercer process. The scope of product under
consideration includes product manufactured using both processes.
6. The product under consideration is classified under Chapter 73 under tariff headings 7304. The
customs classification is only indicative and is not binding on the scope of the present
investigation."
8. The applicant has filed an application for mid-term review of the scope of the product under
consideration and has requested clarification that “Casing & Tubing with premium threading (known
as OCTG in market parlance) manufactured by using Seal-Lock XD process patented by HESPL” is
not included in the scope of the product under consideration. The applicant has further claimed that
such product is not being manufactured by the domestic industry in India and the manufacturing
process and end use of the product concerned is different form the product under consideration in the
original investigation. The Authority has noted the arguments and counter arguments by all parties in
the present investigation and accordingly examined the following.
9. The Authority notes that SEAL Lock XD which a process patented by Hunting PLC, is a process for
undertaking threading on the product under consideration during the manufacturing process.
Stainless steel tubes and pipes are not manufactured using the said process. All stainless-steel tubes
and pipes are manufactured using either hot extrusion process or hot piercing process. Further, this is
the primary production process for making product under consideration. Thereafter, threading
process is undertaken, which may be done using SEAL Lock XD process or any other process. Thus,
the submission that the product concerned is itself manufactured using SEAL Lock XD process is not
appropriate.
10. The Authority further notes that the scope of product under consideration as defined in the original
investigation does not distinguish between threaded and non-threaded product. Further, the product
concerned is a stainless-steel tubes and pipes manufactured using either hot extrusion process or hot
piercing process and squarely falls within the definition of the product under consideration. The
applicant has not provided any evidence with regard to the fact that the definition of the product
under consideration does not include the product concerned. It has not been shown by the applicant
that this product was imported in the period of investigation of the original investigation. Nor it has
been shown that like article has not been supplied by Indian industry. On the contrary, the domestic
industry has submitted that there were no imports of this type during the POI of the original
investigations.
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11. The applicant has submitted that the domestic industry does not manufacture the said product in
India and had no manufacturing of the product concerned in the period of investigation of the
original investigation. However, the data on record shows that Jindal Saw Limited has produced and
sold the product concerned in India continuously since 2020-21, that is the period of investigation of
the original investigation.
Year | Unit | Production | Domestic Sales
2020-21 | MT | *** | ***
2020-21 | Indexed | 100 | 100
2021-22 | MT | *** | ***
2021-22 | Indexed | 85 | 85
2022-23 | MT | *** | ***
2022-23 | Indexed | 29 | 29
2023-24 | MT | *** | ***
2023-24 | Indexed | 664 | 664
2024-25 | MT | *** | ***
2024-25 | Indexed | 1043 | 1043
(Source: Submissions made by the Domestic Industry)
12. The domestic industry has established that it is holding technical qualifications and capabilities, as
required by the applicant, to produce the product. The company also holds the license to do threading
from the very same company as has been referred by the applicant, and does threading using the
same process as stated by the applicant. The Authority also notes that threading is not the primary
production process and is merely an incremental production process after production of pipes.
13. As regard the submission that there are supply constraints of the product concerned in India and only
limited quantities are being supplied by Jindal Saw Limited, the Authority notes that the domestic
industry has submitted that the product concerned is manufactured based on orders in hand and not
manufactured and stored as inventory.
14. The domestic industry has submitted that there are two other consumers of the product concerned
namely, Oil and Natural Gas Corporation (ONGC) and Oil India Limited (OIL). ONGC is the largest
buyer of the product concerned in India. And only one consumer, that is, Vedanta has filed the
present application.
15. The applicant has submitted that the end application for the product concerned is different from the
product under consideration in the original investigation as the same is used for oil and gas purposes.
In this regard, the Authority notes that para 4 of the initiation notification of the original investigation
states that the product under consideration is used for structural purposes as well as for applications
relating to oil and gas. Thus, there is no difference between the applications considered for product
under consideration at the time of the original investigation and the applications listed by the
applicant for the product concerned.
“4. Stainless-Steel seamless tubes and pipes are used for structural purposes and to transfer
liquids and gases. The product under consideration is used in applications relating to oil and
gases; petrochemicals and refineries; atomic energy; power generators including nuclear and
thermal power; and aerospace and defence applications.”
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16. With regard to the submissions that inclusion of product concerned within the scope of the product
under consideration will lead to monopoly in India as there is only one producer of the product
concerned in India, the Authority notes that imposition of anti-dumping duty does not lead to
monopoly as it does not restrict imports into India. Anti-dumping duty only ensures that the product
is being imported into India at fair prices. Further, product concerned is merely a grade of the
product under consideration and there are multiple producers of the product under consideration in
India. In any case, if Jindal Saw Limited engages in monopolistic practices, the applicant may reach
to appropriate authorities under the relevant laws and rules.
17. As regard the submissions that ONGC and other buyers of the product concerned sought exemption
for procuring the product concerned due to supply constraints in India, the Authority notes that the
documents submitted by the applicant shows that such request was withdrawn by ONGC during the
meeting of standing committee under DMI&SP Policy. Further, the evidence on record shows that
ONGC has actually procured the product concerned from Jindal Saw Limited.
18. With regard to the minutes of meeting of standing committee under DMI&SP Policy dated 15th April
2024, submitted by Vedanta, the Authority notes that the discussion was held on 11-3/4" OD Size,
N-80, 60 PPF Flush Joint; 7" P-110, 35 PPF for HPHT application; and 7" OD Size Q 125 35 PPF
for HPHT application. The domestic industry has submitted that such products are not stainless-steel
tubes and pipes but tubes and pipes which are made out of carbon steel.
19. As regard the fact that the product concerned is a higher priced product than the product under
consideration, the Authority notes that there are multiple grades of the product under consideration
which entail a different cost and price. The Authority had formulated a PCN methodology for this
purpose in the original investigation. Merely because one product grade is priced higher than average
price of imports in India, does not mean that the same is not being dumped in India.
20. The applicant has submitted that the HS code for the product concerned at 6-digit level is different
from the HS code of the product under consideration at 6-digit level. The Authority notes that the
product under consideration is imported under various HS codes and for this purpose, the anti-
dumping duty has been imposed at 4-digit level. The HS code for the product concerned is covered
with the HS Code which entails the anti-dumping duty.
21. DI has also annexed licences with their written submissions which show that the licence was with
them during the period of investigation. The identical product to the product being imported by
Vedanta Limited is being manufactured and supplied in India as Jindal SAW Limited holds licences
from Hunting PLC for threading process. A copy of this licence has also been submitted. In such a
case, the product produced by Jindal SAW Limited is identical to the product being imported from
the subject country.
22. In light of the examination made above and the evidence placed on record, the Authority holds that
there is no need to change the scope of the product under consideration as determined in the original
investigation and the product concerned is included within the definition of the product under
consideration.
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D. POST DISCLOSURE COMMENTS
D.1 SUBMISSIONS BY THE APPLICANT
23. The applicant has reiterated its submissions regarding scope of product under consideration in the
original investigation, end use of product concerned, manufacturing process, higher landed price of
the product concerned, lack of manufacturing of product concerned during the original period of
investigation, lack of technology and licenses to manufacture product concerned and difference in
HS Codes. In addition, the other applicant has made the following submissions post issuance of the
disclosure statement:
i. Seal Lock XD is a critical process to manufacture the product concerned as threading enhances
the sealing performance of the product under consideration which makes it capable to
withstand high pressure in drilling operations.
ii. The product concerned cannot be replaced by regular stainless steel tubes and pipes and entire
oil and gas industry relies upon product concerned for extraction.
iii. While the product under consideration is used for transporting oil and gas, the product
concerned is used for extraction of the same. Hence, there is difference in usage of the product
concerned.
iv. The product concerned is technically non substitutable by the product under consideration due
to threading process which changes the identity and characteristics of the final product.
v. The manufacturing facility for the product concerned was started by Jindal Saw Limited post
September 2023.
vi. The US Authority imposed anti-dumping duty on imports of product under consideration and
product concerned separately.
vii. Negligible quantity of the product concerned was imported into India during the period of
investigation of the original investigation and such quantities cannot be considered to cause any
injury to the domestic industry.
viii. The observation of the Authority that the said product was not imported during the period of
investigation of the original investigation shows that no injury can be inflicted by such product
type on the domestic industry.
ix. Jindal Saw Limited did not participate in the global tender floated by the applicant in 2022 as it
did not have capacity to manufacture the same.
x. Information submitted by Jindal Saw Limited regarding supply of the said product prior to
September 2023 is factually incorrect and does not correlate to the product concerned.
xi. The data provided in the disclosure statement is indexed and does not provide an idea of the
quantities produced and supplied by Jindal Saw Limited and whether such quantities pertain to
Seal Lock XD threading or casing and tubing in general. The trend shows declining production
and sales post the period of investigation.
xii. The Authority has not analysed the production and sales of the product concerned during 2017-
19 which is the actual injury period.
xiii. The Authority did not establish a causal link between the injury to the domestic industry and
imports of product concerned during the original anti-dumping investigation. Accordingly, no
duties can be imposed on the product concerned.
xiv. It is a consistent practice of the Authority to exclude the product not manufactured by the
domestic industry from the scope of the domestic industry.
xv. The Authority may provide actual user based exemption for imports of the product concerned
as done in previous investigations.
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xvi. The present case is similar to the anti-dumping investigation into imports of low ash
metallurgical coke where the Authority has provided exemption for imports of product type on
actual user conditions.
D.2 SUBMISSIONS BY THE DOMESTIC INDUSTRY AND INDIAN STAINLESS
SEAMLESS PIPES MANUFACTURERS ASSOCIATION
24. The domestic industry and Indian Stainless Seamless Pipes Manufacturers Association have made
the following new submissions post issuance of the disclosure statement:
a. The present is not a case for imposition of anti-dumping duty. The anti-dumping duty is
already in force and the applicant has not been able to demonstrate any monopoly created by
Jindal Saw Limited.
b. The Indian industry holds license from Hunting PLC for threading and has produced and
supplied the identical product in the domestic market.
c. There is no mandatory requirement for use of the product with threading done by SEAL Lock
XD process patented by Hunting PLC. There are number of different brands offering threading
process and the product with such threading can also be used to meet the requirements of the
applicant.
d. The present application appears to have been filed by Vedanta primarily to seek clearance for a
shipment of the product concerned currently held at the port as the Ministry of Steel has
questioned such imports.
e. The incidence of anti-dumping duty on the product concerned is negligible which shows that
the application has been filed only due to a Customs issue.
f. Any exclusion in the name of product concerned is likely to lead to widespread circumvention
of the anti-dumping duty in force.
D.3 EXAMINATION BY THE AUTHORITY
25. The Authority has examined the post disclosure submissions made by the applicant and the domestic
industry and notes that a number of submissions are reiterations which have already been examined
suitably and addressed adequately in the relevant paras of the final findings. The issues raised in the
post-disclosure comments/submissions by the interested parties and considered relevant by the
Authority are examined below.
26. With regard to the submissions that Seal Lock XD is an essential process to manufacture the product
concerned, the Authority has already noted that the product is manufactured using hot piercing or hot
extrusion process. Threading process is only an incremental process. Further, as per the evidence on
record, the Indian industry holds licenses and has been consistently supplying the product concerned
(with Seal Lock XD threading) in the domestic market. Thus, identical article is being supplied in the
domestic market by the Indian industry.
27. With regard to the submission that threading process changes the identity as well as use of the
product, the Authority notes that since the said product is being produced and supplied by the Indian
industry and the same falls within the definition of the product under consideration defined in the
original investigation, change in usage based on incremental process does not justify exclusion from
the scope of the product under consideration.
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28. The applicant has submitted that manufacturing facility for the product concerned was started by
Jindal Saw Limited in September 2023, that is, post the period of investigation in the original
investigation. The Authority notes that Jindal Saw Limited held license from Hunting PLC for
manufacturing of the product concerned during the period of investigation of the original
investigation. Jindal Saw Limited manufactured and supplied the product concerned even during the
period of investigation of the original investigation.
29. With regard to the submissions that negligible / no imports of the product concerned in the period of
investigation of the original investigation shows that no injury was inflicted on the domestic industry,
the Authority notes that the product concerned is only a grade of the product under consideration.
The injury is examined based on the imports of the product under consideration and not grades of the
product under consideration. The Authority conducted detailed PCN wise examination in the original
anti-dumping investigation and held that the dumping of subject imports has caused injury to the
domestic industry. Accordingly, anti-dumping duty was recommended and imposed on the imports
of the product under consideration. A separate grade wise analysis of injury and causal link is not
conducted in the anti-dumping investigation. Further, it is a consistent practice of the Authority that a
product type not imported into India cannot be excluded from the scope of the product under
consideration.
30. The applicant has submitted that the data provided in the disclosure statement issued is indexed. The
Authority notes that such data is business proprietary information of the domestic industry and
disclosure of the same would cause adverse impact on the domestic producer. Accordingly, the data
has been shared on indexed basis.
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31. As regard the submission that the Authority has not examined production and sales of the product
concerned during 2017-2019 which was the injury period for the original investigation, the Authority
notes that there is no evidence of imports of such product during this period. Therefore, the question
of domestic industry having produced like article does not arise. In any case, once the Authority has
found that the domestic industry has produced like article in the present period and original period of
investigation, it is not relevant whether the industry was producing in another periods. The findings
from the investigation show that the product was included in the product scope of the original
investigation. Further, there is no justifications for exclusion of the product based on facts as existing
in the present period.
32. The applicant has requested for actual user based exemption for the product concerned and has
submitted that the present case is similar to the anti-dumping investigation into imports of low ash
metallurgical coke. The Authority notes that in the anti-dumping investigation into imports of low
ash metallurgical coke, the domestic industry had submitted that it does not manufacture a product
type used by ferroalloy industry due to commercial considerations and accordingly agreed for
exclusion of the same. However, in the present investigation, the domestic industry has manufactured
and supplied the product concerned in the Indian market. Further, the applicant itself has
acknowledged that Jindal Saw Limited has production facilities to manufacture the product
concerned and has a joint venture with Hunting Plc. In such a case, an exclusion based on actual user
condition is not justified in the present investigation.
33. With regard to the submission that exclusion of the product concerned will lead to circumvention of
anti-dumping duty in force, the Authority notes that since the product concerned has not been
excluded from the scope of the product under consideration, there can be no concerns on
circumvention of duties.
E. CONCLUSION AND RECOMMENDATIONS
34. After examining the submissions made by all the applicant and the domestic industry and issues
raised therein; and considering the facts available on record, the Authority concludes that:
i. The scope of the product under consideration defined in the original investigation does not
distinguish between threaded and non-threaded product.
ii. The product concerned is manufactured using hot piercing or hot extrusion process, and hence,
the same is included within the scope of the product under consideration.
iii. The domestic industry has produced and sold the product concerned in the domestic market in
the period of investigation of the original investigation as well as in the current period.
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iv. The domestic producer holds a license from Hunting PLC for threading and has produced
identical article to that imported into India.
v. There is no difference between the applications considered for the product under consideration
at the time of the original investigation and the applications listed by the applicant for product
concerned.
vi. Product concerned is only a product type of the product under consideration. There are
multiple producers of the product under consideration in India.
vii. Merely because one product grade is priced higher than average price of imports in India, does
not mean that the same is not being dumped in India.
viii. The HS Code pertaining to the product concerned is already included in the HS Codes on
which anti-dumping duty has been imposed.
ix. There is no need to change the scope of the product under consideration as considered in the
original investigation and product concerned is covered within the scope of the product under
consideration.
F. FURTHER PROCURE
35. An appeal against the determination/review of the Authority in this final finding shall lie before the
Customs, Excise and Service Tax Appellate Tribunal in accordance with the relevant provisions of
the Act.
AMITABH KUMAR, Designated Authority
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054. SARVESH KUMAR RUitally signed by SARVESH
SRIVASTAVA
SRIVASTAVA
Date: 2026.06.30 23:03:48
+05'30"
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