Full Text
EXTRAORDINARY
PART I —Section 1
PUBLISHED BY AUTHORITY
No. 317] NEW DELHI, THURS DAY , DECEMBER 28, 2023/ PAUS HA 7, 1945
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MINISTRY OF COMMERCE AND INDUSTRY
(Department of Commerce )
(DIRECTORATE GENERAL OF TRADE REMEDIES )
NOTIFICATION
FINAL FINDINGS
New Delhi , the 28th December, 2023
(AD (OI) Case No. - 13/2022 )
Subject: Anti-dumping inves tigations on the imports of “Self -Adhesive Vinyl (SAV)” originating in or
exported from China PR.
F. No. 6/13/2022 -DGTR: - Having regard 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 thereof, as amended from time to time
(hereinafter referred as the Anti - Dumping Rules);
A. BACKGROUND OF TH E CASE
1. Whereas, Pioneer Polyleathers Limited (hereinafter referred to as the “applicant” or “domestic industry”) has
filed an application before the Authority in accordance with the Customs Tariff Act, 1975 and the Anti -
Dumping Rules for initiation of an anti-dumping inv estigation concerning imports of the Self -Adhesive Vinyl
(SAV) (hereinafter also referred to as the product under consideration or the subject goods) from China PR
(hereinafter also referred to as the subject country).
2. And whereas, in vie w of the duly sub stantiated application filed by the applicant, the Authority in accordance
with Section 9A of the Act read with Rule 5 of the Anti -Dumping Rules, initiated the anti -dumping
investigation vide File No. F.No.6/13/2022 -DGTR dated 29th Decembe r, 2022, publishe d in the Gazette of
India, to determine the existence, degree and effect of any 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 .
B. PROCEDURE
3. The procedure described below has been followed with regard to the investigation:
a. The Authority notified the embassy of the subject country in India about the receipt of the present
anti-dumping application before proceedi ng to initiate the investigation in accordance with Sub -Rule
(5) of Rule 5 supra.
b. The Authority issued a public notice dated 29th December, 2022 published in the Ga zette of India
Extraordinary, initiating anti -dumping investigation concerning import of the subject goods from the
subject country.
c. The Authority sent a copy of the initiation notification dated 29th December, 2022, to the embassy of
the subject country in India, the known producers and exporters from the subject country, known
importers and oth er interested p arties, as per the available information. The interested parties were
requested to provide relevant information in the form and manner prescribed an d make their
submissions known in writing within the prescribed time -limit.
d. The Authority als o provided a co py of the non -confidential version of the application to the known
producers/exporters and to the Embassy of the subject country in India in accord ance with Rule 6(3)
of the Anti -Dumping Rules.
e. The Embassy of the subject country in India was also requested to advise the exporters/producers
from their country to respond to the questionnaire within the prescribed time limit. A copy of the
letter and q uestionnaire sent to the producers/exporters was also sent to it along with the names and
addre sses of the known producers/exporters from the subject country.
f. The Authority sent questionnaires to the following known producers/ exporters in the subject cou ntry
in accordance with Rule 6(4) of the Rules:
i. Xusen HCR Digital Media Co. Ltd.
ii. Shanghai NAR Industrial Co., Ltd.
iii. Ningbo So -Fine Paper Products Co. Ltd.
iv. Tongxiang Zhenxing Industrial Fabric Manufacturing Co., Ltd.
v. Zhejiang Tianxing TechnicalTextil es Co., Ltd.
vi. Shanghai DER New Material Co., Ltd.
vii. Shanghai Hanker Plastics Co., Ltd.
viii. Jutu Technologies Ltd.
ix. Shanghai Unisign Industryco., Ltd.
x. Avery Dennison (China) Pvt Ltd.
xi. Daoming Optics and Chemicals Co. Ltd.
xii. Foshan KL Decorative Materials Co. Ltd.
xiii. Guangzhou KY Advertisement Equipment Co. Ltd.
xiv. Guangzhou Tome Advertisement Mate rial Ltd.
xv. Guangzhou YuQuan Composite Material Co. Ltd.
xvi. Jiangsu Aoli AD Material Co. Ltd.
xvii. Nantong Baina Digital New Material Co. Ltd.
xviii. Sunglobal Industri es and Trades Co. Ltd.
xix. Tongxiang Zhanyi Trading Co. Ltd.
xx. Zhaoqing Southern New Material Ltd.
xxi. Zheji an Yiya New Materials Co. Ltd.
xxii. Zhejiang Ganglong New Material Co. Ltd.
xxiii. Zhejiang So -Fine Self - Adhesive Products Co. Ltd.
g. In response to the above noti fication, follo wing exporters / producers have responded or submitted
exporter questionnaire responses :
i. Foshan KL Decorative Materials Co., Ltd.
ii. Zhejiang So -fine Self -Adhesive Products Co., Ltd. (So -Fine)
iii. Guangzhou YuQuan Composite Material Co., Ltd.
iv. Jiangsu Aoli New Materials Co., Ltd.
v. Xusen HCR Digital Media Co., Ltd.
vi. Guangdong Tome Ad Media Ltd.
vii. Guangzhou KY Technology Ltd.
viii. Zhaoqing Southern New Material Ltd.
ix. Zhejiang Fulai New Materials Co. Ltd.
x. Shanghai FLY Int ernational Trade Co. Ltd.
xi. Shanghai NAR Industr ial Co. Ltd.
xii. Avery Dennison (China) Co., Ltd.
xiii. Zhejiang Yiya New Materials Co. Ltd.
xiv. Nantong Baina Digital New Material Co. Ltd.
xv. 3M Innovation Singapore Pte. Ltd.
xvi. Tongxiang City Yizhan Trading Co., Ltd.
xvii. Guangzhou KK Advertisement Equipment Co. Limited.
h. The Authority sent questionnaires to the following known importers of the subject good s in India
calling for necessary information in accordance with Rule 6(4) of the Rules:
i. 3M India Limited
ii. Aditya Digital Technologies Pvt Limited
iii. ASM Marketing Pvt Li mited
iv. Gita & Company
v. Koncept Polypro Pvt Ltd
vi. Mars Polycotex India Pvt Limited
vii. Marut i Flex Pvt Limited
viii. Mohit Impex
ix. Orris Overseas
x. PV Media Vision Pvt Limited
xi. Rextone Digital Limited
xii. Sibco Overseas Pvt Limited
xiii. Southern Agencies
xiv. Sun Sign and Techno logies
xv. Tech Nova Imaging Systems (P) Limited
xvi. Avery Dennison (India) Pvt Limited
xvii. Flex Signs India Pvt Limited
xviii. Rudram Sun World LLP
xix. SignMax Exim Pvt Limited
xx. Vision Trade Links
xxi. Wonder Signs India Pvt. Ltd.
xxii. ITMS India Pvt. Ltd.
xxiii. Silver S ign Pvt. Ltd.
xxiv. Shreeji Polyplast
i. In response to the above notification, following im porters have responded or submitted exporter
questionnaire responses:
i. Aditya Digit al Technologies Pvt Limited
ii. Avery Dennison (India) Pvt Limited
iii. Flex Signs India Pvt Limited
iv. Gita & Company
v. Sibco Overseas Pvt Limited
vi. SignMax Exim Pvt Limited
vii. Sun Sign and Technologies
viii. TechNova Imaging Systems (P) Ltd
ix. Silver Sign Pvt. Ltd
x. Vision Trade Link
xi. Maruti Flex Traders LLP
xii. Southern Agencies.
xiii. 3M India Ltd.
xiv. Plasto India Pv t. Ltd.,
xv. Maruthi Associates.
xvi. Sirohia Corporation
xvii. Shree Balaji Polymers
xviii. Ajit Industr ies Pvt. Ltd.
xix. TechNova Imaging Systems Pvt. Ltd
j. The Authority sent questionnaires to the following known users / association of the subject goods in
India calling for ne cessary information in accordance with Rule 6(4) of the Rules:
i. Aidas
ii. Aimass Digital P rinting
iii. Akriti Print World
iv. Ambica Traders
v. Anupam Graphics
vi. Aone Graphics
vii. Chopra Signage
viii. Codex Media
ix. Creators
x. Deepa Advertising
xi. Deepa Public City
xii. Dev Painter
xiii. ForceAdvertisers
xiv. Ganesh Enterprises
xv. Global Flex Media
xvi. Gopi Raju Arts
xvii. Gravity
xviii. xviii. Idea Xerox
xix. JCW Flex
xx. JJ Plastic
xxi. Kolor Catalyst
xxii. Krishna Signage Pvt Limited
xxiii. Kushlam Urja Sansthan
xxiv. M&K Creatives
xxv. Metro Printing
xxvi. Micro Graphics
xxvii. Mukta Enterprise
xxviii. Peacock Art
xxix. Pooja Advertising Agency
xxx. Rameshwaram Giridhar Plaza
xxxi. Rampion Advertising
xxxii. Redarrows
xxxiii. Retail Impact
xxxiv. Retail Junction
xxxv. S K Uniprint Pvt Limited
xxxvi. Sai Aid Agency
xxxvii. Sapphire Media Service
xxxviii. Setia Arts
xxxix. Shiva Enterprises
xl. Shree Enterprises
xli. Shridhar Arts
xlii. Sign Solution
xliii. Ss Digital Point Pvt Limited
xliv. Status Graphics
xlv. Unique Adverti sing & Marketing
xlvi. Vimal Art
xlvii. Vishal Arts
xlviii. Yaagi Sign
xlix. Avery Dennison (India) Pvt. Ltd.
l. Tamil Nadu Printers Association.
li. Tamilnadu Signage Material and Machinery Trader s Association (TNSMMTA)
lii. Karnataka Association of Signage Industries
liii. Flex Banner Merch ant Association
k. Flex Banner Merchant Association, Tamilnadu Signage Material and Machinery Traders Association
(TNSMMTA) have filed response / submissions.
l. Largely simil ar views have been expressed by various interested parties, especially by the importers .
All relevant submissions have been included and considered while issuing this final finding .
m. The Authority made available non -confidential version of the evidence pres ented by various
interested parties. Submissions made by all interested parties have be en taken into account in this
final finding .
n. Request was made to the Directorate General of Commer cial Intelligence and Statistics (DGCI&S) to
provide transaction -wise d etails of imports of the subject goods for the past three years, including the
period o f investigation, which has been received by the Authority. The Authority has relied upon the
DGCI& S data for determination of volume and value of imports of product conc erned in India.
o. In accordance with Rule 6(6) of the Rules, the Authority provided oppor tunity to all interested parties
to present their views orally in a public hearing held on 14th A ugust, 2023. The parties, which
presented their views in the oral hearin g were requested to file written submissions of the views
expressed orally, followed by rejoinders submissions.
p. The non -injurious price (hereinafter referred to as 'NIP') based on th e cost of production and
reasonable profits of the subject goods in India , based on the information furnished by the domestic
industry on the basis of Generally Accepted Accounting Principles (GAAP) and Annexure - III to the
Anti-Dumping Rules, has been wo rked out so as to ascertain whether anti -dumping duty lower than
the dump ing margin would be sufficient to remove injury to the domestic industry.
q. Verification of the information provided by the domestic industry and other interested parties was
carried o ut by the Authority, to the extent necessary. Only such verified informati on with necessary
rectification, wherever applicable, has been relied upon for the purp ose of this final finding .
r. The period of investigation (POI) for the purpose of present invest igation is 1 July 2021 to 30 June
2022 (12 Months). The injury period inclu des 2018 -19, 2019 -20, 2020 -21, Apr 2021 to Jun 2022 and
the POI.
s. Information provided b y the interested parties on confidential basis was examined with regard to
sufficiency of the confidentiality claim. On being satisfied, the Authority has accepted the
confidentiality claims wherever warranted and such information has been considered as co nfidential
and not disclosed to other interested parties. Wherever possible, parties providin g information on
confidential basis were directed to provide sufficient non -confidential version of the information filed
on confidential basis.
t. Wherever an intere sted 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 present
disclosure on the basis of the facts available.
u. A disclosure statement containing the essential facts in this investigation which forms the basis of the
present final finding was issued to the interested parties on 20th December 2023. The post disclosure
statement submissions received from the domestic industry and other inte rested parties have been
considered, to the extent found relevant, in this final finding notification.
v. '***' in this notification represents information furnished by an in terested party on confidential basis
and so considered by the Authority under the Rules.
w. The exchange rate adopted by the Authority for the subject investigation is 1 US $= Rs. 76.33.
C. PRODUCT UNDER CONSIDERATION AND LIKE ARTICLE
C2. SUBMISSIONS B Y OTHER INTERESTED PARTIES
4. The other interested parties have submitted as follows with regard to the product under consideration and like
article:
a. That SAVs come in wide variety and grades and have different production methodology, different
combination an d grades of basic constituents (the vinyl film, adhesive and liner); different machinery
and methods for its manufacture and most importantly different end use applicati ons which mak es them
not commercially interchangeable.
b. That the applicant manufactures SAV by only laminating different bought out components and the small
quantity of SAV produced by the petitioner mainly comprises of monomeric calendared vinyl with clea r
permanent adhesive and single PE coated paper liner for short term indoor digital pri nting purpose and
limited applications. The p etitioner does not manufacture various other types of SAV films that are the
part of the product under consideration.
c. That a major fac tor which distinguishes the tapes imported by the applicant from the SAV pro duced by
the applicant is that these tapes do not have a liner/release paper attached to them.
d. That ability to produce a product cannot be a ground for its inclusion wit hin the sc ope of the product
under consideration and therefore, the Authority should re define the scope of the product under
consideration by including only those types which are being manufactured by the petitioner at present
and excluding those types whi ch are not being produced by the petitioner.
e. The other interested parties submitted tha t in terms of the definition of the “manufacture” provided in the
Excise Act and the definition of the domestic industry provided in the Anti -dumping Rules, it is amply
clear that manufacture includes any process i ncidental or ancillary to the completion o f the manufactured
product. Therefore, lamination may be considered as “manufacture”. However, in the present case, the
products manufactured by the applicant by only la minating different bought out components of t he
subject goods i.e., not manufacturing t he key components like PVC film, liner etc. shall not be included
within the scope of the PUC and should be excluded.
f. That the applicant by their own admission do not ma nufacture and sell reflective SAVs which ref lects
the vehicular lights and help in traf fic movements. They also do not manufacture the glow in the dark
SAVs or photoluminescent SAVs which absorbs light during the day and reflects it in the night or in
dark.
g. That the applicant also does not manufac ture and supply the SAVs used in the automot ive sector, for
instance, the automotive SAVs used around the gasoline tanks which are fire retardant and for B&C
pillars of passenger vehicles. These are specialty SAVs which are high end and carry features like anti-
scratch, anti -dust and waterproof. The y are used on vehicles by OEMs and last the life span of the
vehicle. Therefore, the automotive SAVs should be excluded from the product scope since the petitioner
thems elves excluded all automotive based SAVs fr om the imports and does not manufacture and supply
the same in the commercial market. These are also called paint protection SAVs.
h. The applicant itself has repeatedly admitted that production of the subject goods without producing the
substrate film (and carrying out only the laminating process) is not a financially viable business. We
understand that this is the reason as to why the Authority has not considered “lamination” as a
manufacturing process in the PCN no tice issued on 30th June, 2023.
i. The appli cant has itself also excluded the following ke ywords while sorting the PUC:
i. Sticker
ii. Tape
iii. Label
iv. Pouch
v. PP
vi. TPU
vii. Inkjet media (less than 50 micron)
viii. Profile
ix. Cloth
x. Reflective
xi. Metalized
xii. Glow Vinyl
xiii. HDPE
xiv. Floor marking tape
xv. Acrylic
xvi. BOPP
xvii. Automotive
j. It is submitted that all the above products are made from mate rials other than PVC. All these products
have different chemical formula, physical & chemical properties, usage, cost and prices etc. as compared
to the self-adhesive films made with PVC. It is clearly mentioned in the initiation notice that the name of
the PUC is Self -Adhesive Vinyl, self -adhesive polyvinyl chloride film or self -adhesive PVC film.
Therefore, PET, PP, TPU, PE etc. films obviously do not meet the descripti on of the PUC .
k. It is sub mitted that cold lamination film and the PUC (SAV) are two diff erent products as their physical
properties, manufacturing process, cost, pricing etc. are different. The a pplicant has not produced and
sold self-adhesive cold laminati on film with thickness lower than 60 microns. Nor do they have the
technical capability to produce it. Hence, this type of SAV with film thickness below 60 microns must be
excluded from the scope of the PUC . This type of products below 60 microns thickness is not
commercially substitutable to the microns provided by the applicant .
l. That by ex cluding from the import data the items with description such as tapes and labels, sticker,
pouch, reflective SAVs, etc., the petitioner has tacitly conceded that these p roducts do not fall within the
scope of the PUC. If the petitioner has excluded these p roducts for the volume and price analysis of
imports, the automatic conclusion is that they should be excluded from the scope of the subject
investigation. The Authority should specifically exclude the following products from the scope of the
PUC (i) Tapes , labels and floor marking tapes, (ii) reflective SAVs (iii) glow in the dark SAVs (iv)
automotive SAV/paint protection SAVs (v) quick erase/white board films/dry erase SAVs.
m. That the production process described by the petitioner is rather simplistic and does not reflect the
technological capability required to manufacture all the different types of SAV. Petitioner does not have
the following special technology/ma chinery for manufacturing different types of SAV:
i. Special coating technology,
ii. Technology for top coating of vinyl/film,
iii. Separate machine for double -sided adhesive coating for
iv. Mounting vinyl,
v. Separate machine for adhesive coating of PET liners,
vi. Separa te machi ne for coating release liners with different types of adhesive textured rollers
require d for manufacturing Bubble -free SAVs.
n. That in order to produce various specialized SAVs such as quick erase/ whiteboard films/ dry erase films,
which are writabl e films, where one can write on the film with most white -board markers and erase them
to reuse o ver and over, the SAV producer will require specialized technology to top -coat the vinyl/film
with certain chemicals. Further, the chemicals that are used for s uch top -coating are the proprietary in
nature to each SAV producer. The applicant does not have such type of top coating technology or the
proprietary knowledge for the chemicals required for top coating and manufacture of quick
erase/whiteboard films/ dry erase SAVs.
o. That the applicant does not have separate machine for double -sided adhesive coating for mounting vinyl.
In case of mounting SAV, a double -sided coating liner is required. Mounting films have PVC film with
adhesive and liner on two sides ( one side paper liner and other side PET Liner). This product requires a
different and special coating line where adhesive coating can be done on both sides of the PVC film. The
petitioner does not possess this technology. This is because the specialty of mounting SAV is that it has
adhesive on two sides. For this, a double -headed coating machine is requir ed, to simultaneously coat the
adhesive on both the top side and the bottom side of the vinyl/film.
p. That the applicant does not have does not have separa te machine for adhesive coating of PET liners. The
petitioner only has one line for coating of the adh esive onto the release paper liner. However, this line
cannot be efficiently used for coating adhesive onto PET liners, for which a separate coating line /
technology is required. It is used to give dimensional stability to the print after storing and past ing. The
paper liner is replaced with plastic liner. The clarity of adhesive is also important to presence the image.
Technology for preparing the same is very different than paper liner, which the domestic industry does
not possess. Hence, SAVs with PET b ased liner must be excluded.
q. That the applicant does not have textured rollers required for manufacturing Bubble -free SAVs. Bubble -
free SAVs are special SAVs prepared fo r applications where direct manual pasting of SAVs are required
on various surfaces lik e fleet graphics. In the case of bubble free SAVs, the liners ensure that air gaps are
not trapped when applying them to a surface. This ensures that there is no damage to the paint of the
surface when the SAV is removed. Manufacture of this particular lin er requires air egress techno logy,
which is not possessed by the petitioner . These are different from regular SAVs in their production
process, usage and appearance of l iner and can be easily distinguished.
r. In case of SAV with one -way vision, punching mac hines/presses are required t o punch holes into the
SAV after its output from the laminating press. The petitioner does not have such a punching press. The
applicant has not produced and sold one way vision films with thickness lower than 120 microns. Nor
they have the technical capability to produce it. Hence, this type of SAV with film thickness below 120
microns must be excluded from the scope of the PUC . This type of p roducts below 120 microns
thickness is not commercially substitutable to the microns pr ovided by the applicant and thus the
applicant has not supplied a like article to the imported SAV to India.
s. That an inquiry at the local market in "Chuna Mandi" in Paha rganj, New Delhi revealed that all the SAV
dealers in this vicinity had conveyed that t he petitioner ’s products were not available in the market and
that they had not received any enquires for the SAV produced by the petitioner for a very long time. It
was also conveyed by some of the dealers in t his market that the feedback received from th e users of the
petitioner ’s SAV products in the past that there were severe qualitative issues with the petitioner ’s SAV
products because of which demand for the petitio ner’s SAV products had declined. For this reason, the
respondents highly doubts whether the above claimed products have been sold in the domestic market in
India.
t. Quoting certain Judgments of the Hon’ble CESTAT [ Anti -Dumping Appeal No. 51425 Of 2022 -
Tech nova Imaging Systems Vs Union of India & Ors ], it has been argued that since the Manual of
Standard Operating Practices of the Authority at para 3.10 provides that the product under consideration
should preferably include those items, which are produced an d commercially sold in the domestic market
by the domestic industry, it shall be just a nd fair to limit the scope of the PUC to those products which
have been produced and sold by the domestic industry and inclusion of imported products which were
not comp eting with the products offered by the domestic industry in the scope of the PUC has no
justification.
u. That even if the applicant claims to produce different types of SAV, it must be established that the
applicant has produced and sold the different types of the PUC in commercial quantities. It is a settled
position of law that a product mus t be manufactured and sold in commercial quantities in the POI in
order to include it within the scope of the PUC.
v. That in the previous investigation the Authority had r estricted the scope of the product under
consideration to "Monomeric SAV manufactured t hrough Calendaring process of White/Coloured/Clear
or Transparent in Gloss/Matt Finish of Thickness up to 120 Micron with Kraft Paper Liner of GSM
below 140 with Permane nt Glue in both ready to use and jumbo roll form" and therefore, the Authority
should r edefine the scope of the product under consideration by including only those types which are
being manufactured by the petitioner at present and excluding those types wh ich are not being produced
by the petitioner.
w. That the PCN methodology proposed by the Authority is grossly inadequate and does not sufficiently
reflect the relevant parameters on the basis of which the cost of the different types of the PUC will vary.
It is a settled position of law and practice, that where the PUC is not homogenous, and t hat there are
various grades and types of the PUC with different physical characteristics and variation in prices, the
Authority is required to ensure that a ‘fair compa rison’ of prices of the like article produced by the
domestic industry and the PUC impo rted from the subject country is made.
x. It has also been submitted by certain interested parties that lower thickness products are not
commercially substitutable for high er thickness products and the domestic industry has not produced and
sold self-adhesive vinyl with thickness lower than 80 microns, nor do they have the technical capability
to produce it. Hence, SAV with film thickness below 80 microns must be excluded fr om the scope of the
PUC .
y. It has been argued that perforated PVC film for one -way visio n film cannot be considered as a PCN
value.
z. That type of film, i.e., the extent to the film allows the flow of light – white, transparent, clear, ultra-
clear, transluce nt, opaque, coloured, printed should be included as separate PCN parameters/values.
aa. That the “colours” as a PCN parameter should be expanded to include other shades such as black and
grey, white -bluish, white -milky and super white, etc. as other values und er this parameter.
bb. That the Authority should also consider “removable glue” as another PCN parameter.
cc. That the thickness of film and release liners to be included a parameter in the PCN.
dd. That the type of coating on release liner should also be added a se parate PCN parameters, such as - Paper
with single side coating, paper with double side coating, paper with bubble free coating, PET Film and
other.
ee. That film surface features such as - concerning the surface of the SAV film - smooth or perforated,
texture d surface, grains -oriented surface, be embossed etc. should be included as a PCN parame ter.
C3. SUBMISSIONS BY DOMESTIC INDUSTRY
5. The domestic industry has submitted as follows with regard to the product under consideration and like article:
a. That while i t is true that SAVs come in wide variety and types, such difference depends upon differ ent
combination and types of basic constitue nts (the vinyl film, adhesive and liner used), the production
process of all types of SAV is essentially same involving, pre -lamination preparation, lamination, and
curing. The surface finish and other properties of the vinyl sheets depend on the types of films and liners
used and types of rollers used while rolling the films. It neither involves any rocket science nor any
advan ced technology or advanced machinery as has been argued by certain interested parties. The
interested parties have not provided any details of any special technology, or machinery required for
manufacturing such different types of SAV as alleged.
b. The same lamination and curing and finishing lines are capable of using any types of PVC films a nd
release liners, as well as adhesives. Th e applicant has the capacity and capability to produce all types of
SAVs ( excluding reflective SAV).
c. That though the domestic industry is backwardly integrated to produce monomeric PVC films for SAV,
all other mat erials including other types of PVC films, release liners and adhesive materials are being
procured or can be procured from the market for production of different types of SAVs as and when
demanded by the consumers depending upon the demand and price offer ed.
d. That SAV production is not a complic ated technology and involves certain very simple processes as
explained in the production process chart submitted by the applica nt. This basic production process has
not been disputed by any of the interested partie s. In fact, most of the exporters from th e subject country
adopt the same basic methods and manufacture various types of SAVs from bought out components. For
example, M/ s Zhejiang Yiya New Material Company Ltd., China PR declares its production process as
follows:
“SAV is produced by bringing t ogether a desired PVC film, release liner with a suitable adhesive in
between the two, rolled and cured in an appropriate heat tr eatment line. The SAV is produced in
jumbo rolls and then cut into desired length or wi dth. The surface finish and other proper ties of the
vinyl sheets depend on the types of films and liners used and types of rollers used while rolling the
films.”
e. That th e above producer further declares that materials used in manufacturing include glue, re lease
paper, PVC film and packing materials. It further states that Materials and utilities are purchased from
domestic suppliers. Thus, it is absolutely clear that the production process adopted by the applicant
domestic industry and the producers in Chin a are identical.
f. That it is absolutely clear that various types of SAVs depend upon the types of film used, and/or release
liner used and/or adhesives used and with vari ous permutation and combination of these three basic
components all types of SAV can be laminated in the same lamination line and cured and finished in
same finishing line without any additional technology or equipment being used. Therefore, the
arguments of the interested parties that production of certain types of SAVs requires additional
technology or equ ipment are baseless, except certain product types such as one way vision SAV which
requires a perforation line which the domestic industry already posse sses.
g. Despite the specific instructions from the Authority to the said interested part ies to provide d etails of
plants and machinery and technology required and production process involved for such specific product
types, as argued during the oral hearing , the interested parties have failed to provide any details except
very generic comment s that certain p roduct types require specific technology or machinery, whereas the
production process provided by some of the same interested parties show the very ident ical production
process adopted by them as that of the domestic industry . On the other hand, the domest ic industry has
already demonstrated, and is prepared to demonstrate to the Authority again, the production of various
types of SAVs in the same line to refute the claims of the interested parties that various types of SAVs
cannot be produc ed in the same l ine of the domestic industry.
h. That as regards the reference made by the interested parties to para 3.10 of the Manual of Standard
Operating Practices of the Authority the attention of the Authority is drawn to Para 3.15 of the same
manual as quoted above which reads as follows:
“3.15. The different grades/form/types/strengths/sizes of product may not mean different products.
They are subsets of one produc t that is proposed to be investigated and hence is alike as far as their
essential phys ical & technic al characteristics are concerned, at best they can constitute PCNs”.
i. Thus, the operating procedure laid down at Para 3.10 cannot be or should not be read i n isolation and
must be read conjointly with the provisions laid down in Para 3.15 of t he said Manua l. In this connection
attention of the Authority is also drawn to the WTO Panels Ruling in In EC – Fasteners (China) case
wherein the Panel concluded that A rticles 2.1 and 2.6 did not require the investigating Authority to
define the product u nder consideration to include only products that are "like". The Panel remarked that
"the mere fact that a dumping determination is ultimately made with respect to "a pr oduct" says nothing
about the scope of that product. There is c ertainly nothing in the text of Article 2.1 that can be
understood to require any consideration of 'likeness' in the scope of the exported product investigated”.
The Panel concluded that "while Article 2.1 establishes that a dumping determination is to be made for a
single 'produ ct under consideration’ there is no guidance for determining the parameters of that product,
and certainly no requirement of internal homogeneity of that product, in tha t Article".
j. Further, the Panel in EC - Salmon (Norway) conside red Norway's claim that t he "product under
consideration" must consist of a single, internally homogeneous product or, alternatively, categories that
are each individually "like" each other so a s to constitute a single homogenous product. The Panel found
that "there is simply noth ing in the text of Article 2.1 that provides any guidance whatsoever as to what
the parameters of that product should be. The mere fact that a dumping determination is u ltimately made
with respect to 'a product' says nothing about the scope of the relevant product. There is certainly nothing
in the text of Article 2.1 that can be understood to require the type of internal consistency posited by
Norway.
k. That it is absolute ly clear from the panels rulings as quoted above that there i s no requirement of intern al
homogeneity or "inter se likeness” of various product types to be included in the scope of the product
under consideration as has been argued by the other interested parties.
l. That it may also be kept in mind that the domestic industry has been forced t o operate at an abysmally
low-capacity utilization of below ***% because of the dumped imports which occupy over ***% of the
market share. While operating at such low -capacity utilization, the domestic industry is forced to focus
only on the low hanging fr uits and produce what it can reasonably sell in the market and minimize its
losses rather than produce and sell all product types, majority of which are niche products w ith
extremely low volumes. Therefore, it is a classical chic ken and egg paradox, where the dumped imports
do not allow the domestic industry to commercially establish its production of various product types in
spite of having capacity and capability.
m. That the PUC covers all types of SAV made of polyvinyl chloride (PVC) film and the domestic industry
has the capacity and capability to produce and supply all types/varieties of SAV using various types of
films, liners and adhesives using the same manufacturin g line and in fact the domestic industry has
manufactured and supplied various types of SAV depending upon their demand and price suitabili ty.
Therefore, the CESTAT judgment quoted has no relevance in the present case.
n. That various types of SAV cannot be d istinguished from each other visually unless the products are
subjected to a destructiv e testing method. Therefore, any exclusion of any p roduct type will lead only to
circumvention of the duties as it would not be practicable to impose 100% testing condit ion for clearing
the goods without duty.
o. That scrutiny of the import data as available with the applicant for the entire injury period g ives a very
interesting insight. Out of a long list of some 31 product types demanded by the interested parties for
exclusion, as per the analysis of the import data carried out by the applicant there is "N il” import in
respect of about 12 product types in the entire injury period, including the POI or they have been
described in generic terms and not identifiable as such. There are less than 10 transactions in respect of 9
product types in the entire injury period or they have been described in generic ter ms and not identifiable
as such. Only in respect of the remaining 10 product types, there are sizeable imports during t he injury
period, which includes the POI, and all of them are either being produced by the domestic industry , or
the domestic industry is capable of producing the same. The data also shows that the import prices are
abysmally low, belying the claim of the interested parties that these are value -added products or special
products requiring hi gher technology etc.
p. As regards the demand for e xclusion of SAV with films below certain thicknesses on the ground that
these SAVs are not commercially substitutable to the SAV produced by the domestic industry , and are
not being produced by the domestic industry as per their website information, it may be noted that the
domestic industry can produce and is producing SAV with all film thicknesses, irrespective of what ha s
been posted in the website a long time back, subject to local regulative restrictions on use of single use
plastics, including PVC fil ms, below 100 micron which are also prohibited for imports from 31st
December 2021.
q. Notwithstanding the fact that the domestic industry manufactures and supplies SAVs with PVC films of
all thicknesses, with in the regulatory framework, it may be noted tha t SAVs with various film
thicknesses are having same chemical composition and physical properties and produced in the sam e
production process and are technically and commercially substitutable, though certain thicknesses may
be more suitable for certain us ages. Therefore, the SAV of the thicknesses indicated by the interested
party concerned are "like articles” to the SAV be ing produced by the domestic industry within the
meaning of the term under above rules. Thus, the arguments of the interested party con cerned are not tenable.
r. All claims of the interested parties for exclusion of various product types from the scope of th e
investigation needs to be rejected and the PUC as notified needs to be confirmed for determination of the
dumping and injury for the " product as a whole” and not on a truncated product.
s. That the purpose of the PCN methodology is for the like -to-like comp arison for the purpose of
determination of dumping and injury margins keeping in view t he factors which affect price
comparability and not to define the PUC. Therefore, the PCN should be designed keeping in view this
aspect alone and should not be made com plicated and complex unnecessarily. The contentions of the
other interested parties tha t PCN should be so designed as to define th e PUC and to exclude the PCNs
not manufactured by the domestic industry is totally misplaced and beyond the scope and purpose of the
PCN methodology and therefore, must be rejected.
t. That as far as the demand of t he other interested parties for inclusion of thickness of the films and release
liners as a factor for PCN is concerned, it may be noted that thickness becomes relevant when the unit of
measurement for comparison purpose is in terms of area (square meters ). In the current investigation the
unit of measurement adopted is in weight term and the thickness of the material gets subsumed and the
cost and price differences either completely vanish or become negligible. Therefore, there is no need to
add thickness of the material as a separate criterion in the PCN.
u. The PCN methodology notified by the Authority is just, fair and adequate and covers all broad
parameters which capture the price comparability for various determinations and there is no need to
furth er sub-categorize some of the parameters as d emanded by the other interested parties.
C3. EXAMINATION BY THE AUTHORITY
6. In the initiation notification, the PUC was defined as follows:
3. The product under consideration is “Self - Adhesive Vinyl (SAV)” ori ginating in or exported from China
PR. Self-Adhesive Vinyl is popularly known in the market as “self -adhesive polyvinyl chloride film”,
“adhesive vinyl”, “vinyl”, “vinyl film”, “self -adhesive PVC film” “One Way Vision Vinyl” or “cold
lamination film”. The prod uct is an adhesive backed vinyl tha t allows its application on various surfaces.
Further the applicant claims that the product under consideration covers all types of SAV.
4. Self -adhesive vinyl is a flexible and versatile material, which is ideal for mounting on walls or rigid
surfaces. It has three distinct layers or materials i.e., (i) Polyvinyl chloride (PVC) film; (ii) an adhesive
layer; and (iii) release liner. The polyvinyl chloride (PVC) can be monomeric, polymeric and cast and its
thickness ma y vary depending upon usage. This laye r ultimately gets transferred to the intended surface as a
lamination or an advertisement material etc. Adhesive layer is placed between the film and the release liner
and ultimately gets transferred to the film to giv e it the self -adhesive property. Relea se liner could be a paper
or a PET film or any other material which gets released and discarded.
5. SAV is produced by bringing together a desired PVC film, release liner with a suitable adhesive in
between the two, r olled and cured in an appropriate hea t treatment line. The SAV is produced in jumbo rolls
and then cut into desired length or width. The surface finish and other properties of the vinyl sheets depend
on the types of films and liners used and the types of r ollers used while rolling the films.
6. The alleged dumped goods are classified under heading 3919 of Schedule I to the Customs Tariff Act,
1975. The petitioner submits that, it does not have a dedicated tariff code, and is generally classifiable under
3919 9 0 90. The petitioner claims that the product under consideration is also being imported under
following customs classifications: 3919 90 90, 3919 10 00, 3919 90 10, 3919 90 20, 3920 99 19, 3920 99 59,
3920 99 99, 3920 69 29, 3921 90 99, 3926 90 99. The customs classification is indicativ e only and is not
binding on the scope of the product under consideration in the present petition .”
7. The Authority has carefully examined the comments and views of the other interested parties and the applicant
domestic i ndus try with regard to the scope of the product under consideration, PCNs and like article.
8. The Authority had granted an opportunity to all the interested parties to file their submissions on the scope of the
PUC and PCNs. The Authority notes that the other interested parties have proposed several PCNs based on
certain properties of the product which may only be noted at the time of usage. Such characteristics are subjective
and intangible and may not be amenable to distinct identification. Certain prod ucts only differ on the basis of their
application but may have no technical characteristics which differentiate it from the PUC’s technical
characteristics. Further, sufficient evidence has also not been furnished by the parties to establish that they are not
like products of the PUC.
9. Further, the interested parties were asked to provide the details of cost and selling price difference for different
parameters and values as suggested in their proposed PCN methodology. However, the other interested parties
failed to provide the required detail and substantiate their claim with evidence.
10. The Authority on the basis of the submission made by the domestic industry and various interested parties devised
the following PCN matrix in consultation with them so as to as sess PCN -wise dumping and in jury on an apple -to-
apple basis.
SN. Parameters Values Code
1. Manufacturing Process Calendared PVC Film
a. Monomeric
b. Polymeric
Cast PVC Film
M =Monomeric
P = Polymeric
C = Cast
2. Type of SAV Film Perforated (one way vision film) O
Non-perforated N
11. The Authority also carried out an on -spot verification of the production process of the domestic industry to
understand the product and its various types and their production methodology. The Authority has also examined
the pro duction me thodology employed by exporters in China as provided in their questionnaire response.
Examination of the production process shows that the production process of SAV is essentially a lamination
process by bringing together (i) a desired type of PV C film of desired thickness and texture, etc., (ii) a desired
release liner, (iii) a suitable adhesive in between the two, rolled and cured in an appropriate heat treatment line.
12. The examination of the production process and various components used for th e production of SAV reveals that
the polyvinyl chloride (PVC) film used in manufacturing the PUC, which ultimately gets transferred to the
intended surface as a lamination or an ad vertisement material, etc., can be calendared film (monomeric or
polymeric) or cast film, and its thickness, texture and other technical characteristics may vary depending upon the
desired usage of the SAV. The adhesive layer is placed between the film and the release liner, and it ultimately
gets transferred to the film to give i t the self -adhesive property. The types of adhesives to be used may also vary
depending upon the intended usage. The release liner could be paper or PET film or any other material which gets
released and discarded while transferring the adhesive backed PVC film on to the intended surface. The type of
release liner used also depends upon the intended use of the finished SAV.
13. The other interested parties have not disputed this production process. Further, none of the participating
producers/exporters have cl aimed to be fully backward integrated for the production of the SAV. In fact, some of
the responding exporters have confirmed the very same production process starting from bought out PVC Films,
liners and adhesives. Thus, whether the applicant produces or not produces a particular type of PVC film or all
types of PVC film to produce all kinds of SAV becomes immaterial. If a particular component of intermediate is a
bought -out item or can be a bought -out to produce the finished goods it is immaterial whethe r a producer has
backward integration for the same or not. Verification of the production line of the applicant reveals that it has the
complete line for preparation of the films and liners, lamination process and curing process which is flexible
enough to use any kind of the three basic components i.e., films, adhesives and liners.
14. As regards the arguments of the other interested parties that the domestic industry does not have the capability to
handle different types of films, with various thicknesses, v arious types of release liners and adhesives, because the
technology for producing such SAVs are different which the domestic industry does not have, despite specific
request by the Authority to those interested parties to provide details of plants and equ ipment required as far as
the production of SAV is concerned, the said parties have failed to provide the same. On the other hand, the
applicant domestic industry has demonstrated during the verification that the same plant and equipment installed
in its p roduction facility is capable of handling various types of films, both calendared as well as cast, of various
thicknesses, and produce various SAVs, subject to regulatory restrictions on thickness of films etc.
15. As regard the reference made by the interest ed parties to the scope of the PUC in the previous investigation, the
Authority has verified the production process of the applicant domestic industry and flexibility of production of
various product types using the same line has been demonstrated by the a pplicant. Therefore, there is no reason to
restrict the scope of the PUC to the film produced by them through backward integration.
16. As regards, certain specialty SAVs for which specific exclusion has been sought by the other interested parties on
the grou nds that the domestic industry has not produced and commercially sold the same, the Authority notes that
the domestic industry has submitted a detailed list and proof of product types produced and sold by them, though
in small quantities, because of the la ck of orders due to dumped imports, and also claimed that other products can
be produced in the same set of plant and equipment as and when demanded as there is no material difference in
the production process for producing these product types. Examination of the production process of some of the
responding exporters also shows that the process is essentially the same. Further, the Authority notes that the ratio
of the case decided by the Hon’ble CESTAT Technova Imaging Systems Vs Union of India & Ors. , is n ot
applicable to this case as it has been demonstrated that the plant and equipment available with the applicant has
the capability and flexibility to produce and supply all types of SAV, except the ones specifically excluded by the
applicant.
17. It is to be noted that the expression “ Domestic Industry ”, as defined under Rule 2(b) of AD Rules, means the
domestic producers engaged in the manufacture of like article and any activity connected therewith or those
whose collective output of the said article consti tutes a major proportion of total domestic production of that
article. Further, the expression “ Like Article ”, as defined under Rule 2(d) of the AD Rules, means an article,
which is identical or alike in all respects to the article under investigati on for being dumped in India or in the
absence of such an article, another article which although not alike in all respects, has characteristics closely
resembling those of the articles under investigation.
18. It is submitted that nowhere in the Act or under Rule 2( b) or 2(d) of the AD Rules, it has been provided that the
domestic industry has to satisfy the criteria of production or sale of like articles in commercial volumes. Even
Articles 2 and 4 of the WTO Agreement on the Implementation of Article VI of GATT, do es not prescribe the
requirement of “ commercial volumes ” while defining the scope of the domestic industry or like article.
19. If the criteria of “ commercial volumes ” is accepted it would impose a presumptive bar on the initiation of anti -
dumping inv estigatio ns on all such domestic industry that are not able to produce or sell the like article in
commercial volumes, which was never envisaged in the statutory framework of anti -dumping investigations.
20. The basic idea behind imposing anti -dumping duty is to safegu ard the domestic industry from the onslaught of
cheap imports that may cause injury to them, in terms of decrease in sales, price undercutting, etc. If the
contention is accepted, it would create a precarious situation, where the domestic industry that is unab le to
produce and sell its goods in “commercial volumes” due to dumping, would be prohibited from seeking remedy
against such dumping because it is not able to produce and sell its goods in “ commercial volumes”.
21. As regards the reference to para 3.10 o f the Manual of Standard Operating Practices attention of the Authority has
been drawn to para 3.15 of the same Manual and various WTO decisions which essentially states that there is no
require ment for internal homogeneity or inter se likeness of various product types to be included in the scope of
the product under consideration. Various types of SAVs produced using various types of films, adhesives and
release liners might have certain specifi c uses, but they are essentially different ‘sub -types’ produce d through the
same production process and are not separate ‘ products’ . Therefore, the argument of the other interested parties to
exclude certain product types from the scope of the product unde r consideration is not tenable.
22. The Authority notes that in i ts application and submissions, the domestic industry has clarified that its application
is with regard to self -adhesives made out of PVC alone and all other self -adhesives produced using any o ther
film, other than PVC, are outside the scope of the PUC. It has also been clarified by the applicant domestic
industry that their application is with regard to the SAVs imported in Roll form only and certain marking tapes
etc. imported in smaller width and certain types of SAVs not being imported in roll form are outside the scope of
the PUC.
23. The Authority has also excluded certain products which the domestic industry has specifically removed in the
petition either explicitly in their submission or in the PUC while segregating the import data. The domestic
industry has admitted that the following kinds of films are not SAV films and therefore excluded from the scope
of the PUC:
a. Reflective films,
b. Sun control films or
c. Glass safety films
24. The Authority notes that the domestic industry has excluded the following produ cts from the scope of the PUC in
its application. The Authority, therefore clarifies that self -adhesive films like sticker, tape, label, pouch, PP, PET,
TPU, inkjet media (less than 50 micron), profile, cloth, reflective, metalized, glow vinyl, HDPE, floor marking
tape, acrylic, BOPP, automotive are not covered within the scope of the PUC. All other self -adhesive films made
using other than PVC films, are outside the scope of the PUC .
25. Accordingly, the Authority proposes to confirm the scope of the product u nder consideration as follows:
“The product under consideration (PUC) in the present investigation is “self -adhesive vinyl” (SAV),
popularly known in the market as “self -adhesive polyvinyl chloride film”, “adhesive vinyl”, “vinyl”, “vinyl
film”, “self -adhe sive PVC film” “One Way Vision Vinyl” or “cold lamination film”. The product is an
adhesive -backed vinyl with release paper/liner that allows its application on various surfaces. The product
under consideration covers all types of SAV, with PVC film thickn ess above 100 microns, made by using
Polyvinyl Chloride Films and imported in roll form only.
Self-adhesive vinyl is a flexible and versatile material, which is ideal for mounting on walls or rigid surfaces.
It has three distinct layers or materials i.e., (i) Polyvinyl chloride (PVC) film; (ii) an adhesive layer; and (iii)
release liner. The polyvinyl chloride (PVC) can be monomeric, polymeric and cast and its thickness may vary
depending upon usage. This layer ultimately gets transferred to the intended s urface as a lamination or an
advertisement material etc. Adhesive layer is placed between the film and the release liner and ultimately
gets transferred to the film to give it the self -adhesive property. Release liner could be a paper or a PET film
or any other material which gets released and discarded.
Self-adhesive films like sticker, tape, label, pouch, PP, PET, TPU, inkjet media (less than 50 micron), profile,
cloth, r eflective, metalized, glow vinyl, HDPE, floor marking tape, acrylic, BOPP, automotive are not
covered within the scope of PUC. Further, reflective films, sun control films and glass safety films and s elf-
adhesive products made using other than PVC films su ch as PET, PU, BOPP, etc. outside the scope of the
product under consideration. ”
26. The product under consideration is classified under heading 3919 of Schedule I to the Customs Tariff Act, 1975.
The product under consideration is being imported under follo wing customs classifications: 3919 90 90, 3919 10
00, 3919 90 10, 3919 90 20, 3920 99 19, 3920 69 29, 3921 90 99. The customs classification is indicative only
and is not binding on the scope of the product under consideration in the present petition.
D. DOMESTIC INDUSTRY AND STANDING
D1. Submissions by other interested parties
27. No com ment s received by the interested parties on the standing.
D2. Submissions by domestic industry
28. Following submissions have been made by the domestic industry with regard to the domestic industry and
standing:
a. The applicant, namely Pioneer Polyleathers Lim ited is a sole producer of the subject goods
constituting 100% of the domestic production in India.
b. Petitioner has not imported the subject goods fr om the subject country during the POI.
c. The applicant is not related to the exporter or importer of the subje ct goods in India.
D3. Examination by the Authority
29. Rule 2(b) of the Anti -Dumping Rules defines 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 c onne cted therewith or those whose collective output of the said article constitutes a
major proportion of the total domestic produc tion of that article except when such producers are related to the
exporters or importers of the alleged dumped article or ar e themselves importers thereof in such case the term
‘domestic industry’ may be construed as referring to the rest of the producers ”.
30. The application has been filed by Pioneer Polyleathers Limited as the domestic industry. The applicant is the
sole produce r of the subject goods in India.
31. As the sole producer, the production of the applicant accounts for 100% of the total domestic production.
Hence, the applicant constitutes the domestic industry under Rule 2 (b) of the Anti -Dumping Rules and the
application has been made by the domestic in dustry, satisfying the requirements of Rule 5(3).
E. CONFIDENTIALITY
E1. Submissions by other interested parties
32. The applicant has claimed confidentiality in gross violation of Trade Notice No. 10/2018 dated 07 Septem ber,
2018 (hereinafter referred to as “Trade Notice”) and Rule 7 of the Anti -dumping Rules since they have not
provided the basic information like non-injurious price in actual figure range -±10% etc.
33. Each and every information submitted by a party on a con fidential basis cannot be regarded as confidential
unless the same is supported by reasons and is so accepted by the Authority. In other words, Rule 7 does not in
any m anner mean that the applicant can get away with minimal information; rather it casts a r esponsibility on
the applicant to furnish summaries in sufficient details so as to permit a reasonable understanding of the
substance of the information submitted on co nfidential basis. The purpose of this clause is to facilitate all
interested parties to have the meaningful non -confidential summary of the information submitted to the
Authority on confidential basis to enable them to give their submission and to assist t he Authority in arriving at
the correct determinations.
34. The decision of the Hon'ble Supr eme Court of India with respect to confidentiality in anti -dumping duty cases
in Sterlite Industries (India) Ltd. v. Designated Authority 2003 (158) E.L.T. 673 (S.C.) is directly applicable
in the present case. In the said case, on the issue of treatment of confidential information, the Hon'ble Supreme
Court held that confidentiality was not to be granted automatically and should be based on thorough scrutiny.
E2. Submissions by the domestic industry
35. Following submissions have been made by the domestic i ndus try regarding confidentiality:
a. Interested parties have claimed excessive confidentiality.
b. Incomplete response filed by the producers/exporters as responses not filed of the complete value
chain.
c. Questionnaire Responses filed by the producers/exporters are liable for rejection because of breach
of non -confidential disclosure requirements and incomplete responses and value chains.
E3. Examination by the Authority
36. With regard to confidentiality of information, Rule 7 of the Rules provide as follows:
“Con fidential information: (1) Notwithstanding anything contained in sub -rules (2), (3) and (7)of
rule 6, sub -rule(2) of rule 12, 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 sha ll 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 confidential basis to
furnish non-confidential summary thereof and if , in the opinion of a party providing such
information, such information is not susceptible of 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 authorise its disclosure in a generalized or summary f orm, i t
may disregard such information.”
37. The Authority considers that any information which is by nature confidential (for example, because its
disclosure would be of significant competitive advantage to a competitor or because its disclosure would have a
signif icantly adverse effect upon a person supplying the information or upon a person from whom that person
acquired the information), or which is provided on a confidential basis by the parties to an investigation shall,
upon good cause shown, should be treated as such by the Authority. Such information cannot be disclosed
without the specific permission of the party submitting it.
38. The Authority has considered the claims of confidentiality made by the applicant and the other interested
parties and on being sati sfied about the same, the Authority has allowed the claims on confidentiality. The
Authority made available to all the intere sted parties the nonconfidential version of evidence submitted by
various interested parties for inspection.
F. NORMAL VALUE , EX PORT PRICE AND DUMPING MARGIN
F1. Submissions by other interested parties
39. When the export price is between an exporter and its associated importer, the net export price for anti-dumping
duty purposes is to be constructed on the basis of the price at whic h the PUC is first resold to an independent
buyer. The DGTR’s Manual under the chapter “Determination of Net Export Price” provides that “Export
Price” is generally based on the price to the f irst unaffiliated purchaser in India. In the present case, s ince 3M
Singapore and 3M India are part of 3M group of companies which are associated to each other, the net export
price must be constructed considering the profits earned by the 3M group as a wh ole.
40. The pricing between 3M Singapore and 3M India are [ ***] which cannot be relied upon for pricing and
dumping / injury analysis. It is also the practice of the Authority to not rely on the prices between
producer/exporter and importer when they are ass ociated entities unless otherwise proved by the foreign
produ cer/exporter. This approach has been taken by the Authority in the Final Findings in the Anti -dumping
Investigation (Material -Retardation) concerning imports of “Vinyl Tiles other than in roll or sheet form”
originating in or exported from China PR, Taiwan and Vietnam [Case No.-AD (OI) -16/2021 ].
41. In the present case, 3M Singapore transfer the PUC to 3M India at [***]. Hence, for computing the profitability
of the PUC purchased and sold by 3M group, the gross margins and total expenses of both 3M Singapore a nd
3M India must be considered. It would be seen that 3M Singapore purchases the PUC from Nar and resells it
throug h its related entity 3M India to unrelated customers in the India market.
42. However, the comparison of same NIP with LV for exports made throug h the 3M Group (exporter /importer
traders) should be made at a comparable level of trade to yield a fair comparis on. The price of the domestic
industry in India competes with the price at which 3M India re -sells in the domestic market and not with the
[***] at which the PUC is sold by 3M Singapore to 3M India. Therefore, in order ensure principle of fair
comparison, the NIP of the domestic industry should be compared with the resell price of the PUC by 3M
India.
F2. Submissions by the domestic industry
43. The submissions m ade by the domestic industry with regard to normal value, export price and dumping margin
are as follows:
a. None of the producers and exporters in China has claimed MET, but some of them have claimed
their normal values based on their domest ic sales, which needs to be rejected.
b. The Authority has treated China as a non-market economy in all past investigations and all exporters
in the previous investigation were also treated as non -market economy - the same should be
extended to the present in vestigation and all responding exporters and producers may be treated as
operating under non -market economy conditions.
c. The applicant has already submitted necessary information for construction of normal value in China
on a reasonable basis as per the ru les and requests the Authority to determine the normal values in
China base d on this verifiable information i.e., to construct the normal value for China PR on the
basis of the price payable in India, calculated as cost of production in India, duly adjuste d, and after
adding selling, general & administrative expenses with reasona ble profit.
d. In the previous investigation the Authority had determined a dumping margin of upto 50% though
the investigation had to be terminated as withdrawn after issuance of disc losure statement. The
dumping has intensified thereafter as can be seen fr om the estimates of dumping margin made by the
applicant as given in the application.
e. Subject to compliance to the above and verification and acceptance of the information filed by t he
producers / exporters, keeping in view the obligations under Rules, th e Authority may examine the
compensatory arrangements between the parties (Producers and Exporters, Exporters and Importers)
and construct the export prices as per the relevant Rules. Further, various adjustments towards
various expenses to arrive at the e x-works prices need to be carefully examined.
F3. Examination by the Authority
44. Under section 9A (1) (c), normal value in relation to an article means:
(i) the comparable price, in the ordinary course of trade, for the like article when destined for
consumption in the exporting country or territory as determined in accordance with the rules
made under sub -section (6); or
(ii) when there are no sales of the like article in the ordinary course of trade in the domestic
market of the exporting country or territory, or when because of the particular market
situation or low volume of the sales in the domestic market of the exporting country or territory,
such sales do not permit a proper com parison, the normal value shall be either –
(a) comparable representative price of the like article when exported from the
exporting country or territory to an appropriate third country as determined in
accordance with the rules made under sub -section (6); or
(b) the cost of production of the said article i n the country of origin along with
reasonable addition for administrative, selling and general costs, and for profits,
as determined in accordance with the rules made under sub - section (6):
Provided that in the case of import of the article from a country other than the country of
origin and where the article has been merely transshipped through the country of export or
such article is not produced in the country of export or there is no comp arable price in the
country of export, the normal value shall be determined with reference to its price in the
country of origin.
45. Article 15 of the China’s Accession Protocol with the WTO provides as follows:
“Article VI of the GATT 1994, the Agreement on Implementation of Art icle 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 comparabil ity 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 my conditions prevail in the industry
producing the like product with regard to the manufacture, production and s ale 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 domes tic 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 und er Parts II, III and V of the SCM Ag reem ent, when addressing subsidies
described in Articles l4(a), l4(b), I4(c) and 14(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 methodologie s 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 methodolog ies, where
practicable, the importin g WT O 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 wit h
subparagraph (a) to the Committee o n An ti-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 i mporting WTO Member, that it is a
mark et 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 subpara graph (a)(ii) shall expire 15 years af ter 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 econom y provisions of subparagraph (a) shall no longer apply to that
industry or sector."
46. It is noted that while the provisions contained in Article 15(a)(ii) have expired on 11.12.2016. However, the
provisions under Article 2.2.1.1 of the WTO read with obligation under 15 (a) (i) of the Accession protocol
require the criterion stipulated in para 8 of Annexure I of India's AD Rules to be satisfied through the
information/data to be provided in the supplementary questionnaire for claiming the market econom y status.
47. At the stage of initiation, the Aut hority proceeded as per the information given by the applicant. Upon
initiation, the Authority advised the producers/ exporters in China PR to respond to the notice of initiation and
provide information relevan t to the determination of their market economy status. The Authority sent copies of
the supplementary questionnaire to all the known producers/ exporters for rebutting the presumption of non -
market economy in accordance with criteria laid down in Para 8(3 ) of Annexure -I to the Rules and furnish
relev ant detailed information. The Authority also requested the Government of China PR to advise the
producers/ exporters in China PR to provide the relevant information .
48. The following producers/exporters have co -operated in this investigation by filing the pre scribed questionnaire
responses:
i. Foshan KL Decorative Materials Co., Ltd.
ii. Zhejiang So -fine Self -Adhesive Products Co., Ltd. (So -Fine)
iii. Guangzhou YuQuan Composite Material Co., Ltd.
iv. Jiangsu Aoli New Materials Co., Ltd.
v. Xusen HCR Digital Media Co., Ltd.
vi. Guang dong Tome Ad Media Ltd.
vii. Guangzhou KY Technology Ltd.
viii. Zhaoqing Southern New Material Ltd.
ix. Zhejiang Fulai New Materials Co. Ltd.
x. Shanghai FLY International Trade Co. Ltd.
xi. Shanghai NAR Industrial Co. Ltd.
xii. Avery Dennison (China) Co., Ltd.
xiii. Zhejiang Yiya New Mat erials Co. Ltd.
xiv. Nantong Baina Digital New Material Co. Ltd.
xv. 3M Innovation Singapore Pte. Ltd.
xvi. Tongxiang City Yizhan Trading Co., Ltd.
49. None of the exporters/producers contested the non -market economy status of China. Thus, in view of the above
position and in the absence of rebuttal of the non -market economy presumption by any Chinese exporting
company, the Authority, consider it appropri ate to treat China PR as a non -market economy country in the
present investigation and proceeds with para 7 of Annexure -I to the Rules for determination of normal value in
case of China PR.
F3.1. Determination of normal value for all producers/exporte rs from China PR
50. Para 7 of Annexure I of the Rules reads as under:
“In case of imports from non -market economy countries, normal value shall be determined on the
basis if the price or constructed value in the market economy third country, or the price from such
a third country to other countries, including India or where it is not possible, or 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 select ed 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 selection.
Accoun ts shall be taken within time limits, where appropriat e, of the investigation made in any
similar matter in respect of any other market economy third country. The parties to the
investigation shall be informed without any unreasonable delay the aforesaid s election of the
market economy third country and shall be given a reasonable period of time to offer their
comments.”
51. The Authority notes that the prices or constructed value of the product in an appropriate market
economy third country or the price fro m such a third country to other countries, including In dia have
neither been made available by the applicant or an interested party. It is also noted that the interested
parties have not provided any verifiable information which could have been adopted by the Authority.
The Authority has relied on the determin ation of normal value for China on the basis of the
constructed cost in India with reasonable profit. The normal value considered is given below in the
dumping margin table.
F3.2 Determination of export price
F3.2.1. Determination of export price fo r producers/exporters from China PR
52. The Authority notes that export price for co -operating producers/exporters has been considered based on the
information submitted by such producers/ exporters in their questionnaire responses. The following
producers/exp orters have filed the prescribed que stionnaire response:
i. Shanghai NAR Industrial Co. Ltd.
ii. 3M Innovation Singapore Pte. Ltd.
iii. Zhejiang So -fine Self -Adhesive Products Co., Ltd. (So -Fine)
iv. Avery Dennison (China) Co., Ltd.
v. Xusen HCR Digital Media Co., Ltd.
vi. Fosha n KL Decorative Materials Co., Ltd.
vii. Guangzhou YuQuan Composite Material Co., Ltd.
viii. Jiangsu Aoli New Materials Co., Ltd.
ix. Zhaoqing Southern New Material Ltd.
x. Guangzhou KY Technology Ltd.
xi. Guangdong Tome Ad Media Ltd.
xii. Nantong Baina Digital New Material Co. Ltd.
xiii. Zhejiang Fulai New Materials C o. Ltd.
xiv. Shanghai FLY International Trade Co. Ltd.
xv. Zhejiang Yiya New Materials Co. Ltd.
xvi. Tongxiang City Yizhan Trading Co., Ltd.
A. Shanghai NAR Industrial Co. Limited
53. Shanghai NAR Industri al Co. Ltd has exported the subject goods to an extent of *** MT. Out of which ***
MT at ex-factory terms is exported directly to unr elated customer in India and *** MT is exported throu gh 3M
Innovation Singapore to related Indian customer namely 3M India.
54. The exporter has submitted that the exp ort price between 3M Innovation Singapore and 3M India should not be
accepted as both are associated entities. Accordingly, the net export price for anti -dumping duty purposed is to
be constructed on the basis of the price at which the PUC is first resold to an independent buyer. In this
context, the Authority notes that in terms of Explanation (b) to Section 9(A)(1) of the Act which defines the
export price, the export price may be constructed on the basis of the pric e at which the imported articles are
first resold to an independent buyer where the export price is unreliable because of association or a
compensatory arrangement between the exporter and the importer.
55. It is noted that there is no reason to believe that the export price between 3M Innovation Singapore and 3M
India is unreliable. The Authority had provided them an opportunity to explain as to why they are requesting to
consider price at which the PUC is first resold to an independent buyer along with rele vant provisions.
However, the producer / exporter has not filed any reply. Further, it is the discretion of the Authority and not
the interested parties to consider the price at which the PUC is first resold to an independent buyer in case the
prices are found to be unreliable. Therefore, the A uthority has considered the export price of 3M Innovation
Singapore for the determination of the dumping and injury margin.
56. After allowing the adjustment on account of ocean freight, insur ance, inland transport ation, port and other
related expenses, credit cost etc., the weighted average ex-factory export price and weighted average landed
value for the PCN’s which have been produced by the domestic industry during POI comes to ***
US$/MT and *** US$/MT respectively.
57. M/s Nantong Baina Digital New Material C o., Ltd, China PR is the subsidiary of Shanghai NAR Industrial Co.
Limited. Accordingly, weighted average margins are granted to Shanghai NAR Industrial Co. Limited and M/s
Nantong Baina Digital New Material Co., Ltd, China PR as per the consistent practic e of the Authority.
B. Nantong Baina Digital New Material Co. Limited (producer) and Shanghai NAR Industrial Co. Limited
(exporter)
58. Nantong Baina Digital New Material Co. Ltd. has exporte d the subject goods to an extent of *** MT during
the POI including PCN s produced by the domestic industry during POI. It is to be noted that Nantong Baina
did not export directly to India but exported some quantities solely through its parent entity, Shan ghai NAR .
After allowing the adjustment on account of ocean freight, in surance, inland transportation, port and other
related expenses, credit cost etc., the weighted average ex-factory export price and weighted average landed
value for the PCN’s which have been produced by the domestic industry during POI comes to *** US$/MT
and *** US$/MT respectively.
59. Shanghai NAR Industrial Co. Limited. is the holding company of M/s Nantong Baina Digital New Material
Co., Ltd, China PR. Accordingly, weighted average margins are granted to M/s Nantong Baina Digital New
Material Co., Ltd, Ch ina PR and Shanghai NAR Industrial Co. Limited as per the consistent practice of the
Authority.
C. Zhejian g So-Fine Self -Adhesive Products Co. Limited
60. Zhejiang So -Fine Self -Adhesive Products Co., Ltd. has exported the subject goods to an extent of *** MT on
FOB & CIF terms during the POI including PCNs produced by the domestic industry during POI. After
allowing the adjustment on account of ocean freight, insurance, inland transportation, port and other related
expenses, credit cost etc., the weighted average ex-factory export price and weighted average landed value for
the PCNs which h ave been produced by the domestic industry during POI comes to *** US$ / MT and ***
US$ / MT respectively.
D. Avery Dennison (China) Pvt. Ltd.
61. Avery Dennison (China) Pvt. Ltd. has e xported the subject goods to an extent of *** MT on ex -factory terms
during the POI including PCNs produced by the domestic industry during POI. After allowing the adjustment
on account of ocean freight, insurance, inland transportation, port and other rel ated expenses, credit cost etc.,
the weighted average ex- factory export price and weighted average landed value for the PCN’s which have
been produced by the domestic industry during POI comes to *** US$/MT and *** US$/MT respectively.
E. Xusen HCR Digital M edia Co. L td., China PR
62. Xusen HCR Digital Media Co. Ltd. has exported the subject goods i.e. self-adhesive polyvinyl chloride totaling
*** MT on FOB ex -factory terms during the POI including PCNs produced by the domestic industry during
POI. After allowing the adjustment on account of ocean freight, insurance, inland transportation, port and other
related expenses, credit cost etc., the weighted average ex-factory export price and weighted average landed
value for the PCN’s which have been produced by the domes tic industry during POI comes to *** US$/MT
and *** US$/MT respectively.
F. Foshan KL Decorative Materials Co. Limited (producer/exporter) and Guangzhou YuQuan Composite
Material Co. Limited (exporter)
63. Foshan KL Decorative Ma terials Co., Ltd. (Foshan) ha s exported the subject goods during the POI directly as
well as through a related company i.e., Guangzhou YuQuan Composite Material Co., Ltd (YuQuan). Foshan
has directly exported the subject goods to an extent of *** MT on FOB terms and YuQuan has exporte d the
subject goods to an extent of *** MT on EXW terms during the POI including PCNs produced by the domestic
industry during POI. Guangzhou YuQuan Composite Material Co. Ltd. has filed the Exporter Questionnaire
Response. After allowing the adjustment on account of inland transportation, port and other related expenses,
credit cost etc., the weighted average ex-factory export price and weighted aver age landed value for the PCN’s
which have been produced by the domestic industry during POI comes to *** US$ / MT and *** US$ / MT
respectively.
G. Jiangsu Aoli AD Material Co. Ltd., China PR
64. Jiangsu Aoli AD Material Co. Ltd. has exported the subject goods to an extent of *** MT on CIF ex -factory
terms during the POI including PCNs produced by the domestic industr y during POI. After allowing the
adjustment on account of ocean freight, insurance, inland tra nsportation, port and other related expenses, credit
cost etc., the weighted average Ex - factory export price and weighted average landed value for the PCNs which
have been produced by the domestic industry during POI comes to *** US$/MT and *** US$/MT
respectively.
H. Zhaoqing Southern New Material Limited , China PR (producer); Guangzhou KY Advertisement
Equipment Co. Ltd. and Guangzhou Tome Advertisement Material Ltd. (exporters)
65. Zhaoqing Southern New Material Limited has exported the subject goods i.e. self-adhesive polyvinyl chloride
(*** MT) through two entities, Guangdong Tome Ad Media Ltd ( *** MT) on ex -factory terms and Guangzhou
KY Technology Ltd ( *** MT) on ex-factory terms. Guangdong Tome Ad Media Ltd, in turn, exported *** MT
on ex -factory terms directly to India and *** MT on ex -factory terms through Guangzhou KY Technology Ltd.
Guangzhou KY Technology Ltd exported *** MT on ex -factory terms directly to In dia and *** MT on ex -
factory terms through Guangzhou KK Advertisement Equipment Co., Ltd. Gu angzhou KK Advertisement
Equipment Co. exported the entire *** MT directly to India.
66. After allowing the adjustment on account of ocean freight, insurance, inland tr ansportation, port and other
related expenses, credit cost etc., the weighted average ex-factory export price and weighted average landed
value for the PCN’s which have been produced by the domestic industry during POI comes to *** US$/MT
and *** US$/MT re spectively.
I. Zhejiang Fulai New Material Co., Ltd ., China PR (producer) and Shanghai FLY International Trade
Co., Ltd. , China PR (exporter)
67. Zhejiang Fulai New Material Co., Ltd has exported the subject g oods i.e. Self - Adhesive Polyvinyl Chloride
(*** MT) through Shanghai FLY International Trade Co., Ltd. on ex -factory terms.
68. After allowing the adjustment on account of inland transportation, port and other related expenses, credit cost
etc., the weighted average ex-factory export price and weighted average landed value for the PCN’s which
have been produced by t he domestic industry during POI comes to *** US$/MT and *** US$/MT
respectively.
J. Zhejian Yiya New Materials Co. Ltd. (producer/ exporter) and Tongxiang Zhanyi Trading Co. Ltd.
(trader)
69. Zhejiang Yiya New Materials Co., Ltd. is a producer of the subject goods in China PR and has exported the
product to India directly and through related trading company, Tongxiang Zhanyi Trading Co., Ltd, (Exporter).
It is noted that during the POI, Zhejiang Yiya New Ma terials Co., Ltd., China PR has exported *** MT of
subject goods directly and *** MT through related company i.e. Tongxiang Zhanyi Trading Co., Ltd,
(Exporter). After allowing the adjustment on account of ocean freight, insurance, inland transportat ion, port
and other related expenses, credit cost etc., the weighted average ex-factory export price and weighted average
landed value for the PCN’s which have been produced by the domestic industry during POI comes to ***
US$/MT and *** US$/MT respectivel y.
F3.2.2. Determination of export price for non -cooperative producers
70. The Authority has considered the export price for non -cooperative producers / exporters as per ‘facts available’
in terms of Rule 6(8) of the Anti -Dumping Rules.
F4. Determination of Dump ing Margin
71. Considering the normal value and export price as above, the dumping margins for cooperative
producers/exporters of the subject goods from the subject country is given below. It is seen that the dumping
margin is significant.
SN Producer Weig hted
Normal
Value
($/MT) Weighted
Average
Export
Price
($/MT) Weighted
Dumping
Margin
($/MT) Weighted
Average
Dumping
Margin
(%) Weighted
Average
Dumping
Margin
(Range
%)
1 Foshan KL Decorative Materials Co., Ltd. *** *** *** *** (30-40)
2 Zhejiang So -fine Self Adhesive Products Co., Ltd.
*** *** *** *** 10-20
3 Xusen HCR Digital Media Co., Ltd., China PR *** *** *** *** 20-30
4 Zhaoqing Southern New Material Limited, China
PR *** *** *** *** 90-100
5. Jiangsu Aoli New Materials Co., Ltd., China PR *** *** *** *** 90-100
6. Avery Dennison (China) Co., Ltd
*** *** *** *** (40-50)
7. Shanghai NAR Industrial Co. Ltd, China PR
*** *** *** *** 10-20
8. Nantong Baina Digital New Material Co., Ltd,
China PR *** *** *** *** 10-20
9. Zhejiang Yiya New Materi als Co. Ltd., China PR
*** *** *** *** 20-30
10. Zhejiang Fulai New Materials Co., Ltd., China PR *** *** *** *** 0-10
11. Others *** *** *** *** 90-100
G. EXAMINATION OF INJURY AND CAUSAL LINK
G1. Submissions by other interested parties
72. The appli cant claimed “material injury” and not “material retardation” in the earlier investigation. In other
words, the applicant claimed in the earlier investigation that it is an established industry, which is in operation
since 2012. In such a case, it cannot c laim that it is not an established industry in this investigation.
73. Without prejudice to the above, it is submitted that the Authority initiated this investigation to assess the
“material injury” and not “material retardation”. Accordingly, it is not permi ssible to modify the scope of the
investigation at this stage of the investigation i.e., to include material retardation under any circumstances .
74. The applicant had also claimed material retardation i n its application. However, the applicant accepted during
the oral hearing dated 14 August, 2023 that since the initiation is done only for material injury, they are giving
up on their claim for material retardation. Without prejudice to the same, kind att ention of the Authority is
invited to the fact that the c once pt of material retardation is invoked to provide protection to the domestic
industry, which is not yet established and which has not yet performed for a reasonable period of time i.e., is in
a nascent (just started) or embryonic stages (in process of s tarting).
75. The injury information provided by the applicant is incorrect and misleading as information relating to the
products which are merely laminated by the applicant must also be removed from t he injury information .
76. The applicant has claimed dumping m argin to the tune of 50 -60% which appears extremely exaggerated and
not based on proper facts. We request the Authority to consider the net export price as per the responses filed
by the responding exporters and not based on the information supplied by the applicant. It is also apparent that
the applicant has resorted to making unsubstantiated adjustments to show a lower net export price and
adjustments may be worked out based on the respo nses by cooperating exporters only.
77. The applicant has revised their i njury information post initiation since there has been a change in the POI at the
time of initiation viz. what has been proposed by the applicant. An updated injury information has been
submitted on 1st August, 2023 in view of the PCN eventually determined and it was apparent that the
submission had many indexation errors and a corrected version was circulated on 4th August, 2023. However,
the indexation for the period April 21 to June 21 still appears incorrect and proper annualization for such period
is apparently not done to ensure proper comparisons. The injury information as such creates serious doubts on
its correctness.
78. The applicant claimed constant capacity throughout the period of injury while NFA significantly increased
from 100 (indexed) in the b ase year to 160 (indexed) in the FY 19 -20. It seems that the applicant provided
misleading information to prove a non -existent case of dumping, injury and causal link.
79. It has been submitted that such losses ha ve not been caused because of the subject impo rts but because of
extremely high costs of production. Other interested parties refuted the applicant’s claim that the applicant was
backward integrated to produce monomeric and po lymeric PVC films by calendaring process and procures
other types of PVC fil ms s uch as cast PVC films, as and when required or demanded, to produce the desired
SAV as per customers’ requirement.
80. Only the injury information of the products which were manuf actured and sold by the applicant in commercial
quantities during the POI can be included in the injury information. However, as per our understanding, the
applicant also included information of the products so -called manufactured (merely laminated) and so ld by it in
the POI even in miniscule quantities in the injury information. T he respondents request the Authority to not
accept the injury information filed by the applicant as the same is misleading and terminate the investigation
outright.
81. Without preju dice to the above, there is no substance in the applicant’s claims that it has suffered injury on
account of imports of the subject goods from China PR as evidenced from the following facts.
a. Significant increase in the import price from China PR: The pric es from China PR increased
significantly from 100 (Index) in the base year to 1 25 (Index) in the POI. Therefore, it is clear that
the applicant has not suffered any injury on account of the imports of the subject goods from China.
b. Significant decline in the closing inventory: The opening inventory of the POI was 422 (Index)
which dec lined significantly to 52 (Index) in the POI. Therefore, it is clear that the applicant has not
suffered any injury on account of the imports of the sub ject goods from China PR.
c. No price suppression and depression: The prices from China PR increased signi ficantly from 100
(Index) in the base year to 125 (Index) in the POI. The domestic sales realization per unit also
increased significantly from 100 (In dex) in the base year to 134 (Index) in the POI. Therefore, it is
clear that there is no price suppressio n and depression. Accordingly, it can be clearly seen that the
imports from China PR had not injured the performance of the applicant.
82. The applicant i ndustry has suffered the injury, if any, not because of the imports of the subject goods from
China PR but on account of their internal inefficiencies and decline in the prices of the subject goods globally.
Any potential injury is attributable to factors unrelated to subject imports, such as high production costs and an
inability to compete globally. Certain costs should not be included in calculating prices. The applicant’s claim
of price undercutting is challenged due to the absence of supporting data, a nd the other interested parties
believe that this suggests that the subject imports may actually have high er landed values, weakening the injury
claim.
83. Focus on export markets: The exports sales of the applicant increased significantly from 100 (Index) in the
base year to 155 (Index) in the POI. Therefore, it is clear that the primary market of the applicant i s the exports
market and not domestic market .
G2. Submissions by the domestic industry
84. Following submissions have been made by the domestic industry with regard to injury and causal link:
a. Though the petitioner began commercial production in December, 201 6 from its integrated plant, it
has not been able to find its place in the market and utilize the production facility to produce all
ranges of the subject goods due to intensive dumping. Fur ther, the petitioner is suffering extremely
poor utilization of ca pacity, increasingly higher losses and its ability to continue operations itself is
under a threat. Therefore, the petitioner requests the Authority to examine the case from the
perspective of material retardation as well, along with the material injury be ing suffered by the
petitioner.
b. Because of the dumped imports from China, and injury being suffered by the domestic producer, the
applicant approached the Authority again in 202 0 and an investigation was initiated 7th February
2020. Though the Authority ca me o ut with a positive finding on dumping, injury and causal links in
its disclosure statements issued on 21.01.2021 and again on 20.07.2021, the Authority came out with
a trunc ated product scope which would have led to blatant circumvention of the duty th ereby
completely nullifying the effect of the proposed duty. Therefore, the applicant was forced to
withdraw the application under Rule 14(a) of the anti-dumping rules with the liberty to file a fresh
application and the investigation was accordingly termi nated on 03.08.2021.
c. In the previous investigation , the Authority had concluded that the applicant domestic industry had
suffered material injury and also found significant inj ury margins.
d. After withdrawal and termination of the investigation , the conditi on o f the domestic industry has
further deteriorated in all physical and financial parameters as can be seen from the data presented in
the application.
e. The applicant’s SAV plant is operating at an abysmally low -capacity utilization of less than ***% at
present down from ***% during the POI (down from about ***% in the previous investigation
period), while the dumping has intensified.
f. The imports from the subject country ha ve increased significantly by almost 50% over the base year
to about 13,000 MTs in the POI.
g. The production and domestic sales of the domestic industry have become almost half in the POI
compared to the base year, which itself was abysmally low due to the presence of dumped imports,
showing serious injury.
h. The market share of the domest ic industry ha s fallen to a level as low as ***%, whereas the dumped
imports corner almost ***% of the market share despite the fact that the domestic industry is capable
of meeting almost ***% of the market demand.
i. There is a significant price undercutti ng and unders elling of the domestic prices by the dumped
imports and the domestic process are seriously suppressed and depressed due to the price effects of
the dumped imports.
j. All these factors have contributed to a significant loss for the domestic indu stry and the losses have
alarmingly increased and almost doubled after the last investigation was terminated.
G3. Examination by the Authority
85. The Authority has taken note of various submissions of the domestic industry and has analyzed the same
consider ing the facts available on record and applicable laws. The injury analysis made by the Authority here
under ipso facto addresses the various subm issions made by the interested parties.
86. The applicant had submitted that the dumped imports have clearly retard ed its establishment all along since
2016 -17 and the applicant requested the Authority to include material retardation along with material injur y in
the investigation.
87. The applicant had earlier filed an application requesting for initiation of anti -dumpin g investigation concerning
imports of the subject goods originating in or exported from China PR, which was withdrawn after issuance of
the dis closure statements. The applicant had claimed in its application that it was manufacturing the PUC since
2012. Fu rther, the applicant had claimed “material injury” and not “material retardation” in the previous
investigation.
88. The Authority notes that the applicant is in production of the subject goods for a long period of time. The
applicant did not even claim materi al retardation in the previous investigation. The Authority notes that
material retardation is applicable in the case of new units, where data / information is not available for the
injury period. The concept of material retardation is invoked to provide p rotection to the domestic industry,
which is not yet established and which has not yet performed for a reasonable period of time i.e., is in a nascent
(just started) or embryonic stages (in process of starting). In the present case, since the applicant is an
established industry, the claim that the imports from China PR are materially retarding its establishment in
India cannot be accepted.
89. Rule 11 of Antidumping Rules read with Annexure II provides that an injury determination shall involve
examination of factors that may indicate injury to the domestic industry, “…taking into account all relevant
facts, including the volume of dumped imports, their effect on prices in the domestic market for like articles
and the consequent effect of such imports on domes tic producers of such articles…”. In considering the effect
of the dumped imports on prices, it is considered ne cessary to examine whether there has been a significant
price undercutting by the dumped imports as compared with the price of the like article in India, or whether the
effect of such imports is otherwise to depress prices to a significant degree or preven t price increases, which
otherwise would have occurred, to a significant degree. For the examination of the impact of the dumped
imports on the dome stic industry in India, indices having a bearing on the state of the industry such as
production, capacity u tilization, sales volume, inventory, profitability, net sales realization, the magnitude and
margin of dumping, etc. have been considered in acc ordance with Annexure II of the anti- dumping rules.
90. For the purpose of current injury analysis, the Authority has examined the volume and price effects of dumped
imports of the subject goods on the domestic industry and its effect on the prices and profit ability to examine
the existence of injury and causal links between the dumping and injury, if any. The Authori ty has taken note
of the various submissions made by the domestic industry and the other interested parties during the course of
investigations w ith regard to injury and causal link and has examined the injury to the domestic industry in
accordance with th e rules.
91. It is not necessary that all parameters of injury show deterioration. Some parameters may show deterioration,
while some may not. The Au thority considers all injury parameters and, thereafter, concludes whether the
domestic industry has suffered injury or not.
G3.1. Volume effect of dumped imports on domestic industry
a. Assessment of Demand / Apparent Consumption
92. The Authority has taken into consideration, for the purpose of the present investigation, demand or apparent
consumption of the product in India as the sum of domestic sales of the Indian Producers and imports from all
sources. With regard to the volume of the dumped import s, the Authority is required to consider whether there
has been a significant increase in d umped imports, either in absolute terms or relative to production or
consumption in India. For the purpose of injury analysis, the Authority has relied on the transa ction wise
import data procured from DGCI&S.
Particular Unit 2018 -19 2019 -20 April 2020 – June
(Annualised) POI (Jul 21 –
Jun 22)
Domestic Sales MT *** *** *** ***
Trend Indexed 100 74 36 47
Subject Imports from China MT 12,638 13,080 8,098.24 10,519
Trend Indexed 100 103.5 64 83
Imports from other countries MT 3,263 2,925 2,729.02 1,310
Trend Indexed 100 89 83 40
Total Demand MT *** *** *** ***
Trend Indexed 100 98 65 72
93. It is seen that the demand for the subject goods has decreased through the injury period but increased
marginally in the period of investigation.
b. Import volume from the subject country
Particulars Unit 2018 -19 2019 -20 April 2020 – June
2021 (Annualised) POI (Jul 21 –
Jun 22)
Subject Country – China MT 12,638 13,080 8,098.24 10,519
Trend Indexed 100 103 64 83
Other Countries MT 3,263 2,925 2,729.02 1,310
Trend Indexed 100 89 83 40
Total Imports MT 15,901 16,005 10,827.26 11,829
Indexed 100 100 68 74
Imports in relation to 2018 -19 2019 -20 April 2020 – June
2021 ( Annu alised) POI (Jul 21 –
Jun 22)
Total Import into India % 79 82 75 89
Indian Demand % *** *** *** ***
Trend Indexed 100 105 99 116
Indian Production % *** *** *** ***
Trend Indexed 100 146 1281 177
94. It is seen that:
a. From the base year 2018 -19, subje ct imports have increased in 2019 -20, declined in 2020 -21 but
increased during the period of investigation.
b. Similarly, the subject imports in relation to domestic production and demand have also considerably
increased in the injury period but reduced in th e PO I.
c. The share of the subject imports in total imports ha s increased when compared to the previous year and
base year during the period of investigation.
G3.2. Price effect of dumped imports on domestic industry
95. With regard to the effect of the dumped impo rts on prices, it is required to be analyzed 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 pri ces 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 subj ect country has been examined with reference to price
undercutting, pr ice underselling, price suppression and price depression, if any. For the purpose of this
analysis, the cost of production, net sales realization (NSR) and the non - injurious price (NIP) of the domestic
industry have been compared with landed price of impo rts of the subject goods from the subject country.
a. Price Undercutting
96. To determine the price undercutting, a comparison has been made between the landed value of the product and
the average selling price of the domestic industry, net of all rebate s and taxes, at the same level of trade.
Particulars Unit POI
Sales Realisation ₹/MT ***
Landed Price ₹/MT 1,88,975
Price Undercutting ₹/MT ***
% ***%
Range 0-10
97. It is seen that the landed price of imports has been below the net sales realization of the domestic industry,
showing positive price undercutting.
B. Price Suppression and Depression
98. 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 si gnificant degree or prevent price increases which otherwise would
have occurred in normal course, the changes in the costs and prices over the injury period, were compared as
below:
Particulars Unit 2018 -19 2019 -20 April 2020 –
Jun 2021
(Annualised) POI (J ul
21 – Jun
22)
Cost of Sales (ex -
factory) ₹/MT *** *** *** ***
Trend Indexed 100 94 109 143
Net Sales
Realisation ₹/MT *** *** *** ***
Trend Indexed 100 102 110 133
Landed Price ₹/MT 1,67,542
1,59,028
1,71,602 1,88,975
Trend Indexed 100 95 102 113
99. It is observed that the landed prices decreased in 2019 -20 when compared to 2018 -19 (base year) but
proceeded to increase in 2020 -21 and the POI . The domestic industry has not been able to sell the product
above its cost of production throughout the inj ury period. Therefore, it is noted that the subject imports are
suppressing and depressing the prices of the domestic industry.
G3.3. Economic parameters of the domestic industry
100. Annexure II to the anti-dumping rules requires that the determination of in jury shall involve an objective
examination of the consequent impact of dumped imports on domestic producers of such products. With reg ard
to consequent impact of dumped imports on domestic producers of such products, the anti-dumping 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 potentia l decline in sales, profits, output, market share,
productivity, return on investments or utilization of capacity; factors affecting do mestic prices, the magnitude
of the margin of dumping; actual and potential negative effects on cash flow, inventories, e mplo yment, wages,
growth, ability to raise capital investments.
101. The Authority has examined the injury parameters objectively taking into account various facts and arguments
made by the interested parties in their submissions.
a. Production, Capacity, Capa city utilization and Sale
102. Capacity, production, sales and capacity utilization of the domestic industry over the injury period is given in
the following table:
Particulars Unit 2018 -19 2019 -20 April 2020 – Jun 2021
(Annualised) POI (Jul 21
– Jun 22)
Installed Capacity (PUC) MT *** *** *** ***
Trend Indexed 100 100 100 100
Production Qty MT *** *** *** ***
Trend Indexed 100 71 36 47
Capacity Utilization % *** *** *** ***
Trend Indexed 100 70 36 46
Domestic Sales MT *** *** *** ***
Trend Indexed 100 74 36 47
103. The Authority notes that the production and capacity utilization has decreased throughout the injury period but
increased marginally in the POI. Domestic sales ha d increased in the POI when compared to the previous year
but deduced when compa red to the previous year .
b. Market Share
104. Market share of the domestic industry and imports over the period was as below:
Particular Unit 2018 -19 2019 -20 April 2020 – Jun
2021 (Annualised) POI (Jul 21
– Jun 22)
Domestic Industry % *** *** *** ***
Tren d Indexed 100 76 55 66
Imports from Subject country - China % *** *** *** ***
Trend Indexed 100 105 98 115
Imports from other countries % *** *** *** ***
Trend Indexed 100 91 127 55
105. It is seen that the market share of the subject imports from Chin a increased in 2019 -20 when compared to
2018 -19 (base year) but reduced in 2020 -21. Market share of the subject imports from China thereafter
substantially increased in the POI when compared to the base year . It is noted that the market share of the
domest ic industry has declined throughout the injury period but remain ed constant in the POI when compared
to the previous year.
c. Inventories
106. Inventory position with the domestic industry over the injury period is given in the table below:
Particular Unit 2018-19 2019 -20 April 2020 – Jun 2021
(Annualised POI (Jul 21 –
Jun 22)
Average Inventory MT *** *** *** ***
Trend Indexed 100 172 192 136
107. It is seen that the average inventories with the domestic industry increased throughout the injury period but
reduce d in the POI when compared to the previous year.
d. Profitability, return on investment and cash profits
108. Profitability, return on investment and cash profits of the domestic industry over the injury period is given in
the table below:
Particular Unit 2018 -19 2019 -20 April 2020 –
Jun 2021
(Annualised) POI (Jul 21
– Jun 22)
Cost of Sales ₹/MT *** *** *** ***
Trend Indexed 100 94 109 143
NSR / Unit ₹/MT *** *** *** ***
Trend Indexed 100 102 110 134
PBT ₹/MT *** *** *** ***
Trend Indexed (100) (43) (102) (214)
PBIT ₹/MT *** *** *** ***
Trend Indexed (100) (31) (96) (226)
Cash Profit ₹/MT *** *** *** ***
Trend Indexed (100) 0 (31) (202)
ROCE % *** *** *** ***
Trend Index (100) (605.99) (624.41) (126.64)
109. The Authority notes that the domest ic industry incurred losses through out the injury period. The domestic
industry has also suffered cash losses and its return on capital employed is negative throughout the injury
period.
e. Employment, Wages and Productivity
110. The Authority has examine d the information relating to employment, wages and productivity, as given below:
Particular Unit 2018 -19 2019 -20 April 2020 – Jun
2021 (Annualised) POI (Jul 21 –
Jun 22)
No of employees Nos. *** *** *** ***
Trend Indexed 100 76 51 43
Salaries & Wages ₹ Lacs *** *** *** ***
Trend Indexed 100 76 47 51
Productivity per day
MT/Day *** *** *** ***
Trend Indexed 100 71 36 47
Productivity per employee MT/MT *** *** *** ***
Trend Indexed 100 94 70 109
111. It is seen that the number of employees and wages of the domestic industry has decreased throughout the injury
period. Productivity per day of the domestic industry has also decreased throughout the injury period but
increased in the POI.
f. Ability to Raise Capital Investment
112. The Authority notes that the domestic industry has made significant investments in plant and machinery and set
up capacity for the product under consideration. However, the performance of the domestic industry has
suffered considerably as it has incurred significant losses and neg ative returns. This indicates that the imports
have adversely impacted the ability of the domestic industry to raise further investment.
G3.4. Magnitude of Injury and Injury Margin
113. The Authority has considered the non-injurious price for the domestic ind ustry on the basis of principles laid
down in Anti -Dumping Rules read with Annexure III, as amended. The non -injurious price of the product
under consideration has been considered by adop ting the verified information/data relating to the cost of
production for the period of investigation. The non -injurious price of the domestic industry has been worked
out and it has been compared with the landed price from each of the producers/exporters from the subject
country for calculating injury margin as tabulated b elow . The injury margin for the non -cooperative exporters
has been considered based on the facts available.
SN Producer / Exporter Weighted
Average
NIP
($/MT) Weighted
Average
Landed
Value
($/MT) Weighted
Average
Injury
Margin
($ /MT) Weighted
Average Inju ry
Margin (%) Weighted
Average
Injury
Margin
(Range
%)
1 Foshan KL Decorative Materials Co., Ltd.
*** *** *** *** (40-50)
2 Zhejiang So -fine Self Adhesive Products Co., Ltd.
*** *** *** *** 0-10
3 Xusen HCR Digital Media Co., Ltd., China PR *** *** *** *** 0-10
4 Zhaoqing Southern New Material Limited, China
PR *** *** *** *** 50-60
5. Jiangsu Aoli New Materials Co., Ltd., China PR *** *** *** *** 70-80
6. Avery Dennison (China) Co., Ltd
*** *** *** *** (50-60)
7. Shanghai NAR Industrial Co. Ltd, Chi na PR
*** *** *** *** 0-10
8. Nantong Baina Digital New Material Co., Ltd,
China PR *** *** *** *** 0-10
9. Zhejiang Yiya New Materials Co. Ltd., China PR
*** *** *** *** 0-10
10. Zhejiang Fulai New Materials Co., Ltd., China PR *** *** *** *** (0-10)
11. Others *** *** *** *** 80-90
H. NON -ATTRIBUTION ANALYSIS
114. As per the anti-dumping Rules, the Authority, inter alia , is required to examine any known factors other than
the dumped imports which at the same time are injuring the domestic industry, so that the injury caused by
these other factors may not be attributed to the dumped imports. Factors which may be relevant in this respect
include, inter alia , the volume and prices of imports not sold at dumped prices, contraction in demand or
changes in t he patterns of consumption, trade restrictive practices of and competition between the foreign and
domestic producers, developments in technology and the export performance and the productivity of the
domestic industry. It has been examined below whether f actors other than dumped imports could have
contributed to the injury to the domest ic industry.
H1. Volume and prices of imports from third countries
115. It is seen that other than imports from the subject country, the volume of imports from Korea RP are
significant. However, the imports from Korea RP are priced much higher than the price of imports from subject
country, as well as the cost of production and selling price of the domestic industry. Therefore, the imports
from these countries are not causing in jury to the domestic industry. The volume of imports from countries,
other th an the aforesaid country, is not insignificant. Thus, the injury to the domestic industry cannot be
attributed to imports from other countries.
H2. Contraction in demand
116. The dem and for the subject goods has increased over the period except FY 2020 -21, and thus, contraction in
demand has not caused injury to the domestic industry. Since the demand for the subject goods has increased
over the period, the domestic industry has not s uffered on account of this factor.
H3. Changes in the pattern of consump tion
117. No material changes in the pattern of consumption of the product under consideration have been adduced by
the domestic industry or other interested parties. Hence, changes in th e pattern of consumption have not caused
injury to the domestic industry.
H4. Trade restrictive practices
118. The Authority notes that there is no trade restrictive practice, which could have caused injury to the domestic
industry.
H5. Change in technology
119. The Authority notes that there has been no known material change in the technology for the production of the
product under consideration.
H6. Export performance
120. The information provided has been considered only for domestic operations of the domestic i ndus try.
H7. Performance of other products
121. The Authority has only considered data relating only to the performance of the subject goods. Therefore,
performance of other products produced and sold by the applicant is not a possible cause of the injury t o the
domestic industry.
I. INDIAN INDUSTRY’S INTERESTS AND OTHER ISSUES
I1. Submissions by other interested parties
122. The following submissions have been made by the other interested parties during the course of the
investigation:
a. Imposition of anti -dumping duties would severely affect downstream users. There exists a strong public
interest element that should guide the determination of recommending anti -dumping duty. The other
interested parties submit that if antidumping duties ar e imposed, the cos ts of SAV for users who are
SMEs and MSMEs would go up immediately as the importers who are trading in the SAV will be
constrained to pass on the resulting price hike to the users. This would squeeze the profit margins of the
users, many of whom are small scale industries, impact cash flows and greatly lower profitability or
result in loses to them. Indirectly, this would force the users to reduce capital expenses, labour costs and
other overheads to stay afloat or decide to close their ma nufacturing units, resulting in loss of jobs.
b. The applicant has calculated the impact on the downstream user of the PUC. As per the applicant , if 20%
anti- dumping duty is imposed on imports of the PUC from China PR, then it will lead to only 4%
increase in the INR/ Sq. Mtr . cost to the end user. Similar, the petitioner has also claimed that if 20%
anti- dumping duty is imposed on imports of the PUC from China PR, then it will lead to only 6%
increase i n the INR/ Sq. Mtr. cost to the end user.
c. It is submitted that the calcul ations made by the petitioner are grossly incorrect and misleading and do
not present the whole picture. The respondents submit that there are three scenarios under which the
impact of the anti -dumping duty, if imposed, can be analysed. The three scenarios are:
i. Scenario A: Scenario where anti-dumping duty on imports of SAV is not passed on to a
user/convertor
ii. Scenario B: Scenario where anti-dumping duty on imports is passed on by an importer to the
user/convertor
iii. Scenario C: Scenario where anti-dumping duty on imports of SAV passed on to a
convertor/user is further passed on to the final consumer.
d. Since the revised petition claims both dumping and injury margins in the range of 30 -40%, respondents
have considered anti-dumping duty of 30% and 40% for assessi ng the impact of anti-dumping duty on
the importers and the users/convertors. Further, we have considered average CIF price of Rs. 45 per
square meter as mentioned in the revised petition for this analysis.
e. When anti-dumping duty in the range of 30% and 40% ar e imposed and the importer is forced to absorb
the impact of the same to maintain the market, the importers’ profits of 10% turn into losses of 13% and
19% respectively. When the importer passes the anti-dumping duty onto the end
users/convertors/pro cessors but they absorb the impact of the anti-dumping duty , the net profits of 5%
turn into net losses of 8% and 13% respectively. When these end users/convertors/processors pass on the
impact of the anti-dumping duty onto the final consumers, there is an increase in selling price by 14%
and 19%.
f. From the above analysis, it is clear that when there is such high contribution of the cost of the PUC in
the finished product, then any anti-dumping duty imposed on the subject imports will consequently have
a highe r impact on the total cost thereby making the business unviable. This will pose a grave threat to
the survival of the small printers / convertors in the MSME sector. The user industry will not b e in a
position to pass on the impact of anti -dumping duty on its customers.
g. The respondents further submit that the user industry works on slim margins and imposition of anti-
dumping duty will push the user industry into loss -making situation. Hence, any imposition of anti-
dumping duty will be a death knell to the e ntire user industry in India. Further, given that there is
shortage of supply of domestically manufactured the PUC in the market, the imposition of anti-dumping
duty will only worsen the demand -supply gap in India.
h. The respondents also submit that even if anti-dumping duty is imposed, the quality issues with the SAV
produced by the petitioner are so severe that the importers/users will not switch to the petitioner ’s
products. The respondents also submit that if they impact of the anti-dumping duty becomes u nviable,
they will be forced to shut shop. This will have severe ramifications for the advertising industry in India.
i. The facts as emerged from the discussions above shows that any anti-dumping duty as requested by the
applicant shall have serious repercus sions on the users and public interest in general. As stated in the
initiation itself, self -adhesive vinyl is a flexible and versatile material, which is ideal for mounting on
walls or rigid surfaces and the subject goods are widely used in various applica tions across the country.
By the admission of the applicant, any anti-dumping duty to the tune of 20% will have an impact of
about 4% effect on the cost of the end user which is a significant impact.
I2. Submissions by the domestic industry
123. The followin g submissions have been made by the domestic industry during the course of the investigation:
a. The imposition of the duty will have a very minimal impact on the end - users. The advertising
industry is the largest consumer/user of the product and this indu stry operates on a very high margin
and has the capacity to absorb marginal increase in the cos t of the advertising material due to
increase in the cost of the SAV.
b. A sample/indication of the impact of the increase in the price of SAV on the advertisers or users of
the SAV is given below:
Impact analysis (Keeping SAV at 250 GSM)
Rs./Sq. Mtr. Remarks
Average Price CIF of SAV per Sq. Mtr.
40.75
Average Landed Value per Sq. Mtr.
45.25
Average Landed Value per Sq. Mtr - cost to the end user
49.76 with inland freight and
trading margins @10%
Average price paid by the end user of a printed SAV material /
advertiser per Sq. Mtr.
Percentage of the cost of SAV in the final price to the end user
50%
Cost of SAV per Sq. Mtr. with 20% anti-dumpi ng duty
58.72
Impact on end user
4% Negligible
Cost of SAV per Sq. Mtr. with 30% anti-dumping duty
63.20
Impact on end user
6% Negligible
I3. Examination by the Authority
124. The Authority issued Gazette Notification inviting views from a ll the interested parties, including importers,
consumers and other interested parties. The Authority also prescribed a questionnaire for the consumers to
provide relevant information with regard to the present investigatio n, including possible effect of a nti-dumping
duty on their operations. The Authority sought information on, inter -alia, interchangeability of the product
supplied by various suppliers from different countries, ability of the consumers to switch sources, ef fect of
anti-dumping duty on the consumers, factors that are likely to accelerate or delay the adjustment to the new
situation caused by imposition of antidumping duty.
125. It is noted that anti -dumping duty does not restrict imports, but only ensures that th e imports enter the market at
fair prices. Thus, the users will continue to have the broader choice and liberty to import the subject goods at
fair prices, which will ensure better competition in the market. Further as stated in earlier paras the Authority
has proposed to apply the measure s to the product varieties produced in POI which faced material injury.
126. Similarly, with regard to quality and demand -supply gap, it is noted that the imposition of anti -dumping duty
does not act as a ban on imports. The purpose of imposition of anti - dumpi ng duty, in general, is to address the
issue of trade distortion caused by the unfair trade practices in order to re -establish the situation of open and
fair competition. In any case, the Authority notes tha t if there is a demand supply gap in the country, the
foreign producers can certainly fill the gap in the country by bringing the product at a fair price. However,
existence of demand supply gap does not justify dumping of the product.
127. With regard to impa ct on user industry, only the domestic industry ha s quantified the impact of impact of anti -
dumping duty on the end user and that is in the range of 4 -6%. The other interested parties have not quantified
the impact of the anti -dumping duty on the end user and instead have quantified impact for the importe rs.
Further, the Authority notes the submission of the domestic industry that advertisement is consumed by the
advertisers and not the advertisement material suppliers and the advertisement materials, to wh ich the PUC
goes, constitutes a miniscule portion of the value of the underlying goods and services advertised. Therefore, a
cost increase of say 6% on the advertisement material will have an insignificant impact on the advertiser who
uses the advertisemen t.
J. POST DISCLOSURE COMMENTS
J1. Submis sions by other interested parties
128. The following submissions have been made by the other interested parties:
a. Production process noted by the Authority is rather simplistic and does not reflect the technological
capability required to manufacture all the dif ferent types of SAVs.
b. The p etitioner does not have separate machine s for manufacturing different types of SAV such as
mounting vinyl, adhesive coating of PET liners, textured rollers for bubble -free SAVs, coating
release liners with different types of adhe sives.
c. There is an ambiguity in the definition of the PUC since i t is not clear whether the specification of
100 microns applies to PVC film or for the SAV product as a whole or for the film + adhesive. The
Authority is requested to modify the definition of the PUC and clarify that it pertains to thickness of
the PVC fi lm. The Authority may clarify whether the micron covers the thickness of film only or is
it the total thickness considering the film, glue and the liner or any other basis.
d. The PUC definiti on does not include reference to release paper/liner. The Authorit y is requested to
revise the scope of the PUC and make it wholesome by including a reference to the release
paper/liner.
e. While confirming the scope of the p roduct under consideration, the Au thority has not covered the
exclusion of self-adhesive films like sticker, tape, label, pouch, PP, TPU, inkjet media (less than 50
micron), profile, cloth, reflective, metalized, glow vinyl, HDPE, floor marking tape, acrylic,
automotive, reflexive films, sun control films, or glass safety films in Para 25 of the disclosure
statement. It is further submitted that the domestic industry does not manufacture SAV through cold
lamination process and hence the same should also be excluded from the scope of PUC.
f. The Authority is requested to kindly specif y the PUC exclusions in the definition of the scope of the
PUC in the final findings and the duty table forming part of the final findings to avoid confusion in
the minds of the customs authorities, at the time of i mple mentation.
g. Dumping margin of 90 -100% and injury margin of 80 -90% determined by the Authority for the all -
others category is very high and there is wide variation in the dumping margin and injury margin
calculations for the participating producers/expor ters. Producers/exporters have argued that this
disparity is due to the wrong PCN methodology adopted by the Authority.
h. The other interested parties submitted that data filed by the applicant is unreliable as they have
changed data time and time again. The domestic industry filed updated petitions and updated injury
information on multiple occasions during the course of the investigation. Further, some of the injury
information for the previous years were also different in the revised injury information as compared
to the information provided in the application.
i. Increase in subject imports is because of increase in demand f or the PUC in India, which the
domestic industry is unable to cater to. The d omestic industry has not taken any steps towards
increasing its production in spite of high demand for the PUC in India.
j. Volume of subject imports in relation to total imports is not a relevant parameter under the anti-
dumping rules for examining volume effect.
k. Price undercutting of 0 -10% in the POI is not signifi cant. Price undercutting data for the injury
period as a whol e is required and not just the POI.
l. Zhejiang Fulai New Materials Co., Ltd submitted that they fully agree to the conclusions drawn by
the Authority in the disclosure statement that they are not causing injury to the domestic industry.
The interested part y requested that NIL duty may be granted to Zhejiang Fulai New Materials Co.,
Ltd in the final findings based on the injury margin determined in the disclosure statement.
m. Foshan KL Decorative Mate rials Co. Limited (producer/exporter) submitted that the Authority’s
request for clarification and justification on variation in the export quantity and price provided in its
EQR and the imports as per Indian imports data is at the fag end of the investiga tion and is thus
unwarranted.
n. Foshan KL Decorative Materials Co. Limited further submitted that the data filed by them in the
EQR is correct and requires no changes. No discrepancy has been found or questions raised about
data kep t by the exporter at the t ime of verification. Invoices set including proforma invoice,
commercial invoice, packing list, bill of lading, freight & port expenses invoice, export declaration
form and bank advice matched.
o. Foshan KL Decorative Materials Co. Limited further submitted t hat similar issues raised earlier were
also rejected by the Authority as no such mismatch was found in the records of the export which
alone can be the basis for determinations in terms of the Act and the Rules. In fact, the appl icant
industry has raised t he same issue in the earlier investigation on the same subject goods, wherein
two disclosure statements were issued.
p. Foshan KL submitted that in certain investigations, where the Authority found that the Indian
customs data did not capture the complete dat a accurately and did not match with the data /
information submitted by exporters, the Authority proceeded to rely on the verified data of the
exporters.
q. Foshan KL submitted that data captured by DG systems data (Indian customs data) in incorrect and
canno t be replied on. The Authority, normally, does not consider DG System data as it does not
capture the accurate information, which is a known fact. Kind a ttention of the Authority is invited to
the anti -dumping investigation against imports of Viscose Rayo n Filament Yarn originating in or
exported from China PR [F. No 06/06/2022 -DGTR dated 29.02.2023], wherein the Authority had
procured the import data from both DGCI&S and DG System but relied on the DGCI&S data for the
purpose of the investigation. The dir ect exports to India details of the exporter as per the Indian
Customs / DG System data shows only *** entries while the exporter exported *** invoices di rectly
to India during the POI. The exporter exported much more quantity than the one reported in the
Indian Customs / DG System data.
r. Foshan KL humbly submitted that the difference, if any, between the information filed by the
exporter in its response an d Indian customs data is on account of the misdeclaration by the unrelated
importers. Accordingly, the expo rter shall not be held responsible for any misdeclaration by the
unrelated importers. The related trader of the exporter, namely Guangzhou YuQuan Com posite
Material Co., Ltd. is trading the subject goods to India which it procures from the exporter as well as
other sources. In such a situation, it is not possible to identify the entries related to the exporter and
other producers from the information p rovided in the data of Indian Customs / DG System. The
information relating to bill of entry is availab le only with the importers and not the exporter. It may
kindly be noted that none of the importers are related to the exporter.
s. The d omestic industry has been able to increase its selling price in accordance with increase in cost
of sales. Decline in lande d value has not caused the domestic industry to decrease or present an
increase in selling price.
t. Operational parameters have increased in the POI. Hence, there is no injury.
u. Market share of the subject imports has been at the same level throughout the in jury period. Decline
in petitioner’s market share in April 2020 to June 2021 ( annualized) from 20 19-20 can be attributed
to the steep increase in the market share of imports from other countries.
v. Inventory has increased over injury period in spite of alleg ed decrease in production over the injury
period. The claim of the domestic industry seems suspi cious.
w. Wages and productivity are not major factors for determining existence of injury to the domestic
industry.
x. The profit before interest and tax (PBIT) decl ined sharply between POI and immediate previous year
and the drop was about 130 basis points. However, the return on capital employed (ROCE) shows a
massive improvement of about 498 points during the POI viz. the immediate previous year.
y. Unless the domest ic industry expresses interest and commitment to meet the qualitative
requirements of the use r industry and the varieties of SAV required by the user industry, the
domestic industry would not take any decision to make such capital investments.
z. Injury, if any, to the domestic industry is due to poor quality of SAV produced by the domestic
indust ry. Some of the common quality issues faced by users/traders of the SAV produced by the
petitioner are gumming issues, ink transference, poor holding capacity, inco nsistent thickness of
SAV.
aa. When the volume of subject imports decreased by over 5000 MT from 2019 -20 to April 2020 -June
21 (annualized), instead of improving, the petitioner’s economic parameters further declined during
this period.
bb. When the volume of s ubject imports increased from April 2020 -June 21 ( annualized) to the POI, the
petitioner’ s operational parameters improved.
cc. There is no correlation between movement in volume of subject imports and petitioner’s economic
performance. Hence, there is no caus al link between subject imports and petitioner’s alleged injury.
dd. There is only one dom estic producer of the like article in India, who also is not able to match the
quantitative, qualitative, and variety -related requirements of the user industry in India. The user
industry is entirely dependent on subject imports from China PR for meeting i ts requirements. Levy
of the anti -dumping duty will establish monopoly of the petitioner.
ee. It is denied that the impact of anti -dumping duty on the end -user will be only 4-6%, as calculated by
the domestic industry.
ff. When anti-dumping duties in the range of 80 % and 90% are imposed and the importer is forced to
absorb the impact of the same to m aintain the market, the importers’ profits of 10% turn into losses
of 36% and 39 % respectively.
gg. When the importer passes the anti-dumping duty onto the end users/convertors/processors but they
absorb the impact of the anti-dumping duty , the net profits of 5% turn into net losses of 34% and
39% respectively.
hh. There are lakhs of people in small scale printing machine units all over India who are d ependent on
affordable availability of SAV as a raw material for their livelihood purposes. If anti -dumping duty
is imposed, this will severely affect such printing units.
J2. Submissions by the domestic industry
129. The following submissions have been made by the domestic industry:
a. Domestic industry submitted that the minimum thickness criteria of 100 microns in the product
under consideration be removed.
b. It was submitted by that glow vinyl and automotive vinyl not be removed from the scope of the PUC
as submitted by the domestic industry in the rejoinder submission.
c. It was submitted that the producers/exporters have claimed excessive confidentiality are in violation
of Rule 7. Most of the produc ers/exporters have kept their product descriptions and description of
products being exported to India confidential while all of them are arguing for exclusion of various
product types without disclosing to the domestic industry what actually they are expo rting to India
and what their characteristics are.
d. The domestic industry has further submitted that the Authority accepted the questionnaire responses
of the producers/exporters without verification of the data and other information despite several
defici encies and inaccuracies. The dumping / injury margins determined for the producer/exporters
appears to be impracticable.
e. The domestic industry further submitted that even though a certain producer/exporter themselves
raised the question about the reliabili ty of the transactions between its related exporter and importer,
warranting a rejection of the export price between them, the Authority has not resorted to
construction of the export price to determine margin.
f. The domestic industry submitted that for Fosh an K L Dec orative Materials Co. Limited
(producer/exporter), as per the transaction -wise data relied upon by the applicant, the average CIF
price of the exporter is much less compared to the other exporters from the subject country and
therefore, a negative dumping and injury margin determination for this exporter is a surprise for the
applicant domestic industry.
g. The domestic industry submitted that it is aggrieved with the drastic reduction of the non -injurious
price (NIP) by over 30% from ₹ ***/- per MT a s claime d by the DI to ₹ ***/- per MT without any
clear justification in the NIP disclosure given to the domestic industry. Certain elements of costs,
such as raw material costs, packing costs, consumables, utilities, salaries and wages, selling and
distri bution expenses and NFA/ROCE, have been first reduced significantly.
J3. Examination of the authority
130. The Authority notes the submissions of the interested parties regarding the thickness criteria of 100 microns. In
this regard, relevant changes have bee n ma de to the definition of the product under consideration .
131. The domestic industry, in their petition, had specifically excluded the words “glow vinyl” and “automotive” in
the methodology of sorting import data. The Authority notes that the domest ic indust ry’s submission at the
rejoinder stage regarding non -exclusion of glow vinyl and automotive vinyl cannot be accepted .
132. The domestic industry, in their post -disclosure comments, has submitted that their argument regarding
excessive confidentiality, which the y ma de in their rejoinder, was not addressed by the Authority. The
Authority notes that as given in para 31 of the ini tiation notification, any submissions about excessive
confidentiality have to be made within seven days of receiving the non -confidential version of the document.
Further the comments on confidentiality were made in rejoinder and not circulated to other in terested parties.
Therefore, the Authority is of the view that submissions pertaining to excessive confidentiality are precluded
from bein g introduced or entertained during the rejoinder stage.
133. It was also submitted by the domestic industry that certain r esponding producers/exporters have suppressed
vital information and the Authority has not conducted proper verification of the same. Verifi cation of the
information provided by the interested parties was carried out by the Authority, to the extent necessar y. The
Authority further notes that domestic industry, in its rejoinder, rested its submission on web -based information
which lacked any su bstantive depth relevant for establishing the authenticity of the argument presented. It is
pertinent to note that th e domestic industry has not even mentioned the domain name of the website(s) they
have relied on. No evidence has been brought on record by the domestic industry to prove that the export price
of the participating producers/exporters is unreliable . In the absence of any evidence to this effect, the
Authority is not in a position to make any determination to this effect.
134. As far as the domestic industry’s argument regarding reliability and construction of export price of
producers/exporters is concerned, The Authority in such cases, examines the reliability of export prices where
there is an association or compensatory arrangement between the ex porter and importer and the Authority may
find it unreliable. It falls outside the purview of the producer/exporter to argue that its own export price is
unreliable and to request the Authority to construct the export price, as it remains within the Author ity’s
discretion to determine the credibility and reliability of the same.
K. CONCLUSION AND RECOMMENDATION
135. Based on the submissions made, substantiated information provided by the interested parties and the facts
available before the Authority as re corded and examined in the aforementioned paragraphs and on the basis of
determination of dumping and consequent injury to the domestic industry in the form of material retardation of
the establishment of the domestic industry, the Authority concludes the following:
i) The product under consideration (PUC) in the present investigation is “self -adhesive vinyl”
(SAV), popular ly known in the market as “self -adhesive polyvinyl chloride film”, “adhesive
vinyl”, “vinyl”, “vinyl film”, “self -adhesive PVC film” “One Way Vision Vinyl” or “cold
lamination film”. The product is an adhesive -backed vinyl with release paper/liner that all ows
its application on various surfaces. The product under consideration covers all types of SAV,
with PVC film thickness above 100 micron s, made by using Polyvinyl Chloride Films and
imported in roll form only.
ii) The subject goods exported from the subject countries and the article manufactured by the
domestic industry are ‘like article’ to each other in terms of Rule 2 (d) of the AD Rules, 1 995.
iii) The petitioner is the sole producer of the product and accounts for 100% of the Indian
production. The petitioner satisfies the requirements stipulated under Rule 2 (b) of the AD
Rules, 1995 and the petition satisfies the standing requirements under R ule 5(3) of the AD
Rules, 1995.
iv) The dumping margin of the subject goods from the subject countries and by 7 of the 10
responding producers/exporters is positive and significant.
v) The volume of the import from the subject country has declined in the POI but it is still
significant compared to production and demand in India
vi) The market share of the domestic industry during th e POI has decreased significantly and in
the POI the market share of the DI is 4.97% only.
vii) The landed price of imports is below the net sa les realisation of the domestic industry in the
POI and is therefore undercutting the prices of the domestic industry. Further, the selling price
is even below the level of cost of sales throughout the injury period.
viii) As regards the effect of such dumped o n the economic parameters of the domestic industry, the
following conclusions were reached:
a. Production and capacity ut ilization has decreased throughout the injury period but
increased marginally in the POI. The capacity utilization is notably low and the
dome stic industry is operating at 13% capacity utilization in the POI.
b. The average inventories with the domestic industry increased throughout the injury
period but reduced in the POI when compared to the previous year.
c. The domestic industry incurred loss es throughout the injury period. The domestic
industry has also suffere d cash losses and its return on capital employed is negative
throughout the injury period.
d. The number of employees and wages of the domestic industry has decreased
throughout the injury period. Productivity per day of the domestic industry has also
decreas ed throughout the injury period but increased in the POI.
ix) The domestic has suffered injury as a result of the dumped imports. The injury margin is
significant.
x) The Authority has examin ed the submissions made by other parties on any other factors which
could have caused injury to the domestic industry. No other factor appears to have caused
injury to the domestic industry. The Authority concludes that the injury to the domestic
industry has been caused by the dumped imports from the subject countries.
xi) The a ntidumping duty is in the public interest. Anti -dumping duty does not restrict imports,
but only ensures that the imports enter the market at fair prices. users will continue to have th e
broader choice and liberty to import the subject goods at fair prices , which will ensure better
competition in the market.
xii) With regard to impact on user industry, the impact of the anti -dumping duty on the end user is
in the range of 4 -6%. The Authority has examined the increase in cost of around 6%, which
will have an impact of 0.006% on the advertiser who is the eventual use r of the PUC.
136. The Authority notes that the investigation was initiated and notified to all interested parties and adequate
opportun ity was given to the domestic industry, embassies of the subject countries, exporters, importers and
other interested partie s to provide positive information on the aspect of dumping, injury and causal link.
Having initiated and conducted an investigation into dumping, injury and causal link in terms of Rules and
having established positive dumping margin caused by such imports , the Authority is of the view that
imposition of antidumping duty is necessary.
137. Having regards to the lesser duty rule followed, th e Au thority recommends imposition of anti -dumping duty
equal to the lesser of the margin of dumping and the margin of injur y so as to remove the injury to the domestic
industry. Accordingly, the Authority recommends imposition of the anti -dumping duty on t he imports of
subject goods originating in or exported from the subject countries, for a period of 3 years, from the date o f
notification to be issued in this regard by the Central Government, equal to the amount mentioned in Column 7
of the duty table app ende d below.
DUTY TABLE
Sl.
No. Heading Description Country
of
Origin Country of
Export Producer Amount Unit Currency
(1) (2) (3) (4) (5) (6) (7) (8) (9)
1. 39199090,
39191000,
39199010,
39199020,
39209919,
39206929,
39219099 All types of
SAV, with
PVC film
thickness
above 100
microns,
made by
using
Polyvinyl
Chloride
Films and China
PR Any country,
including
China PR Foshan KL
Decorative
Materials Co.,
Ltd.
NIL MT USD
imported in
roll form
only*
2. -do- -do- -do- -do- Zhejiang So -
fine Self
Adhesive
Prod ucts Co.,
Ltd. 4 -do- -do-
3. -do- -do- -do- -do- Xusen HCR
Digital Media
Co., Ltd., China
PR 112 -do- -do-
4. -do- -do- -do- -do- Zhaoqing
Southern New
Material
Limited, China
PR 942 -do- -do-
5. -do- -do- -do- -do- Jiangsu Aoli
New Materials
Co., Ltd., China
PR 1824 -do- -do-
6. -do- -do- -do- -do- Avery Dennison
(China) Co., Ltd NIL -do- -do-
7. -do- -do- -do- -do- Shanghai NAR
Industrial Co.
Ltd, China PR 119 -do- -do-
8. -do- -do- -do- -do- Nantong Baina
Digital New
Material Co.,
Ltd, China P R 119 -do- -do-
9. -do- -do- -do- -do- Zhejiang Yiya
New Materials
Co. Ltd., China
PR 201 -do- -do-
10. -do- -do- -do- -do- Zhejiang Fulai
New Materials
Co., Ltd., China
PR NIL -do- -do-
11. -do- -do- -do- -do- Any other 1865 -do- -do-
12. -do- -do- -do- Any country
other than
China PR China PR 1865 -do- -do-
*Self-adhesive films like sticker, tape, label, pouch, PP, PET, TPU, inkjet media (less than 50 micron), profile, cloth,
reflective, metalized, glow vinyl, HDPE, floor marking tape, acrylic, BOPP, automotive are not covered within the
scope of PUC. Further, reflective films, sun control films and glass safety films and self -adhesive products made using
other than PVC films such as PET, PU, BOPP, etc. outside the scope of the product under considera tion.
L. FURTHER PROCEDURE
138. An appeal against the determination of the Designated 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.
ANANT SWA RUP, 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.
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