Full Text
REGD. No. D. L.-33004/99
The Gazette of India
CG-DL-E-30092025-266545
EXTRAORDINARY
PART I-Section 1
PUBLISHED BY AUTHORITY
No. 277]
NEW DELHI, MONDAY, SEPTEMBER 29, 2025/ASVINA 7, 1947
6507 GI/2025
MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce)
(Directorate General of Trade Remedies)
INITIATION NOTIFICATION
New Delhi, 29th September, 2025
Case No.-AD (OI)–27/2025
Subject: Initiation of anti-dumping investigation concerning imports of “4-Aminodiphenylamine (also
known as 4-ADPA)” originating in or exported from China PR and European Union – reg.
1. F. No. 6/30/2025-DGTR: Having regards to the Customs Tariff Act, 1975 as amended from time to
time (hereinafter referred as the 'Act') and the Customs Tariff (Identification, Assessment, and
Collection of Anti-Dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995,
as amended from time to time (hereinafter referred to as the 'Rules'), M/s NOCIL Limited
(hereinafter referred to as “applicant” or “petitioner") has filed an application seeking imposition of
anti-dumping duty on the imports of “4-Aminodiphenylamine” (hereinafter referred to as the
"product under consideration” or “4-ADPA"), originating in and exported from China PR and
European Union (hereinafter referred to as the "subject countries").
2. The applicant has alleged that injury and threat of injury is being caused to the domestic industry due
to the dumped imports, originating in or exported from the subject countries and has requested for
the imposition of anti-dumping duty on the imports of the subject goods from the subject countries.
3. The applicant, NOCIL Limited, is the known domestic producer of 4-ADPA and has submitted that
dumped imports of this intermediate are causing significant injury to its operations.
A. PRODUCT UNDER CONSIDERATION
4. The product under consideration (PUC) in this present application is “4-Aminodiphenylamine” also
known as "4-ADPA” or “4-N-phenylbenzene-1,4-diamine".
5. 4-ADPA is a rubber chemical intermediate falling under the scope of 'Rubber Chemicals'. It is
primarily used in the production of PX-13 (N-(1,3-dimethylbutyl)-N'-phenyl-p-phenylenediamine),
also known as 6PPD, and to a minor extent in the production of IPPD.
6. The prescribed unit of measurement for the product under consideration is weight, expressed in
Metric Tonne (MT). All information in the application is presented in MT.
7. The applicant has submitted that 4-ADPA produced and sold for merchant sales and the 4-ADPA
that is captively transferred for PX-13 production are reported separately. However,this has been
treated as a single product for the purpose of present investigation.
8. The product under investigation is being imported under Custom Tariff Heading 2921 44 10 and
2921 51 90 of the First Schedule to the Customs Tariff Act, 1975. However, it is possible that the
subject goods may also be imported under other headings and therefore, the Customs tariff heading
is indicative only and is not binding on scope of the product.
9. The parties to the present investigation may provide their comments on the PUC and propose PCNs,
if any, within 15 days of the circulation of the non-confidential version of the documents filed before
the Authority.
B. LIKE ARTICLE
10. The applicant has claimed that the subject goods, which have been alleged to be dumped in India,
are identical to the goods produced by the domestic industry. There are no known differences in the
technical specifications, quality, functions and end use of the two products. The Authority notes that
the two are prima facie technically and commercially substitutable. Therefore, for the purpose of the
present investigation, the product produced by the applicant in India are being treated as 'like article'
to the subject goods being imported from the subject countries
C. SUBJECT COUNTRIES
11. The subject countries in the present petition are China PR and the European Union.
D. PERIOD OF INVESTIGATION (POI)
12. The applicant has proposed the period of investigation (POI) as 1st April 2024 to 31st March 2025.
The period proposed by the applicant and the same is found to be appropriate. The injury information
has been provided for the POI and the three preceding years, that is 2021-22, 2022-23 and 2023-24.
E. DOMESTIC INDUSTRY AND STANDING
13. The application has been filed by M/s NOCIL Limited. The applicant has claimed that it is the sole
producer of the subject goods in India constituting 100% of the Indian production and therefore, has
the requisite standing to file the present application.
14. M/s Finorchem Ltd. has produced some quantity of the product under consideration (PUC) during
the period of investigation (POI) and has supported the application. It is noted that the applicant
accounts for 99% share in the total Indian production. The applicant has also stated that it has not
imported the PUC from the subject countries. Further, it is not related to any exporter in the subject
countries nor to any importers in India.
15. In view of the same, and after examination, the Authority is satisfied that the application has been
made by the domestic industry and satisfies the requirements of standing in terms of Rule 5(3) of the
Rules and the applicant constitutes domestic industry within the meaning of Rule 2(b).
F. BASIS OF ALLEGED DUMPING
Normal Value China PR
16. The applicant has cited and relied upon Article 15(a) (i) of China's Accession Protocol and has
claimed that China PR should be treated as a non-market economy and that producers from China
PR should be directed to demonstrate that market economy conditions prevail in the industry with
regard to the production and sales of the product under consideration. Unless the producers from
China PR show that such market economy conditions prevail, their normal value should be
determined in accordance with Para 7 and 8 of Annexure-I to the Anti-Dumping Rules, 1995.
17. The applicant has submitted that data relating to cost and price in market economy third country is
not available. The applicant has determined normal value for the product under consideration based
on cost of production in India, adjusted to include a reasonable profit margin.
18. For the purpose of initiation, the normal value for the product under consideration has been
determined based on cost of production in India, duly adjusted for addition of selling, general and
administrative expenses and reasonable profits.
Normal Value for European Union
19. The applicant could not obtain verifiable domestic selling prices for 4-ADPA in the European Union.
The normal value has been, thereby, constructed based on the best estimates of the cost of the
production of the domestic industry of the subject goods as per the best information available after
duly adjusting the selling, general and administrative expenses with reasonable profits.
Export Price
20. The export price for the subject goods has been computed based on the Directorate General of
Commercial Intelligence and Statistics (DGCI & S) transaction-wise import data. Appropriate price
adjustments have been claimed to make the prices at ex-factory levels so that they become
comparable with normal value.
Dumping Margin
21. The normal value and the export price have been compared at the ex-factory level, which prima facie
shows that the dumping margin is above the de-minimis level and is significant in respect of the
product under consideration exported from the subject countries. Thus, there is sufficient prima facie
evidence that the product under consideration from the subject countries is being dumped in the
Indian market by the exporters from the subject countries.
G. INJURY AND CAUSAL LINK
22. With regards to injury, the domestic industry has furnished prima facie evidence showing injury
suffered because of alleged dumped imports. The information concerning imports and economic
parameters of the domestic industry over the injury period show that the volume of subject imports
from the subject countries has increased in absolute as well as relative terms. The price depression
caused by dumped imports has prevented the domestic industry from increasing its prices to recover
the full cost and achieve a reasonable rate of return, resulting in the domestic industry suffering
losses. The domestic industry has claimed that it is operating with low capacity utilization and low
domestic sales in the merchant market because of dumped imports. The domestic industry has
claimed that it could have produced and sold to the extent of imports, had the consumers placed
orders on the domestic industry. The sales details provided by the domestic industry shows that
though the domestic sales are limited, they are spread over the injury period. The domestic industry
has also claimed that dumping of the product has adversely affected captive consumption as well and
therefore, the injury is required to be seen including captive consumption. The domestic industry has
suffered financial losses and loss before interest and tax. There is sufficient prima facie evidence of
injury being caused to the domestic industry by dumped imports of subject goods from the subject
countries.
H. INITIATION OF ANTI-DUMPING INVESTIGATION
23. On the basis of the duly substantiated written application by the domestic industry, and having
satisfied itself, on the basis of the prima facie evidence submitted by the domestic industry, about
dumping of the subject goods originating in or exported from the subject countries, injury to the
domestic industry and causal link between such alleged dumping and injury, and in accordance with
Section 9A of the Act read with Rule 5 of the AD Rules, the Authority, hereby, initiates an
investigation to determine the existence, degree and effect of any alleged dumping in respect of the
subject goods originating in or exported from the subject countries and to recommend the amount of
anti-dumping duty, which if levied, would be adequate to remove the injury to the domestic industry.
I. PROCEDURE
24. The principles as stipulated under Rule 6 of the said Rules shall be followed in the present
investigation.
J. SUBMISSION OF INFORMATION
25. All communication should be sent to the Designated Authority via email at the email address ds-
dgtr@gov.in and ad12-dgtr@gov.in, a copy to dir15-dgtr@gov.in, and consultant-
dgtr@govcontractor.in . It should be ensured that the narrative part of the submission is in searchable
PDF/MS Word format and data files are in MS Excel format.
26. The known producers/exporters in the subject countries, the government of the subject countries
through their embassy in India, the importers and users in India who are known to be associated with
the subject goods are being informed separately to enable them to file all the relevant information in
the form and manner prescribed within the time limit set out below.
27. Any other interested party may also make its submissions relevant to the investigation in the form
and manner prescribed within the time-limit set out below. Any party making any confidential
submission before the Authority is required to make a non-confidential version of the same available
to the other interested parties.
K. TIME LIMIT
28. Any information relating to the present investigation should be sent to the Designated Authority via
email at the following email addresses ds-dgtr@gov.in and ad12-dgtr@gov.in, a copy to dir15-
dgtr@gov.in, consultant-dgtr@ govcontractor.in within thirty (30) days from the date on which it
was sent by the Designated Authority or transmitted to the appropriate diplomatic representative of
the exporting countries as per Rule 6(4) of the Rules. If no information is received within the
prescribed time limit or the information received is incomplete, the Authority may record its findings
on the basis of the facts available on record in accordance with the Rules.
29. All the interested parties are hereby advised to intimate their interest (including the nature of interest)
in the instant matter and file their questionnaire responses within the above time limit.
L. SUBMISSION OF INFORMATION ON A CONFIDENTIAL BASIS
30. Any party making any confidential submissions or providing information on a confidential basis
before the Authority, is required to simultaneously submit a non-confidential version of the same in
terms of Rule 7(2) of the Rules. Failure to adhere to the above may lead to rejection of the response
/ submissions.
31. The parties making any submission (including appendices/annexures attached thereto), before the
Authority including questionnaire response, are required to file confidential and non-confidential
versions separately.
32. The "confidential” or “non-confidential” submissions must be clearly marked as “confidential" or
“non-confidential” at the top of each page. Any submission made without such marking shall be
treated as non-confidential by the Authority, and the Authority shall be at liberty to allow the other
interested parties to inspect such submissions.
33. The non-confidential version is required to be a replica of the confidential version with the
confidential information preferably indexed or blanked out (in case indexation is not feasible) and
summarized depending upon the information on which confidentiality is claimed. The non-
confidential summary must be in sufficient detail to permit a reasonable understanding of the
substance of the information furnished on a confidential basis. However, in exceptional
circumstances, the party submitting the confidential information may indicate that such information
is not susceptible to summary, and a statement of reasons why summarization is not possible must
be provided to the satisfaction of the Authority.
34. The Authority may accept or reject the request for confidentiality on examination of the nature of the
information submitted. If the Authority is satisfied that the request for confidentiality is not warranted
or if the supplier of the information is either unwilling to make the information public or to authorize
its disclosure in generalized or summary form, it may disregard such information.
35. Any submission made without a meaningful non-confidential version thereof or without a good cause
statement on the confidentiality claim shall not be taken on record by the Authority.
36. The interested parties can offer their comments on the issues of confidentiality claimed by the
domestic industry within 7 days of the circulation of the non-confidential version of the documents
filed before the Authority.
M. INSPECTION OF PUBLIC FILE
37. A list of registered interested parties will be uploaded on the DGTR's website along with the request
therein to all of them to email the non-confidential version of their submissions to all other interested
parties.
N. NON-COOPERATION
38. In case any interested party refuses access to, or otherwise does not provide necessary information
within a reasonable period, or significantly impedes the investigation, the Authority may declare
such interested party as non-cooperative and record its findings on the basis of the facts available to
it and make such recommendations to the Central Government as deemed fit.
SIDDHARTH MAHAJAN, Designated Authority
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