Sulphonated Naphthalene Formaldehyde (SNF) from China in Dumping Investigation Net on Complaint of Himadri Plus Five

[Ref: Anti-dumping Initiation Notification No. 14/15/2016-DGAD dated 13th October 2016]

Subject: Anti-Dumping investigation concerning imports of “Sulphonated Naphthalene Formaldehyde” (SNF) originating in or exported from China PR.

M/s Himadri Speciality Chemical Ltd. (hereinafter referred to as the applicant) has filed an application before the Designated Authority (hereinafter also referred to as the Authority) in accordance with the Customs Tariff Act, 1975 as amended from time to time (hereinafter also referred to as the Act) and Customs Tariff (Identification, Assessment and Collection of Anti-Dumping Duty on Dumped articles and for Determination of injury) Rules, 1995 as amended from time to time (hereinafter also referred to as the Rules) for initiation of anti-dumping investigation and imposition of anti-dumping duty concerning imports of Sulphonated Naphthalene Formaldehyde (SNF) (also referred to as Subject goods). The Country concern is China PR. The above mentioned country also referred to as the Subject Country.

2.    And whereas, the Authority notes that sufficient prima facie evidence of dumping of the subject goods, originating in or exported from the subject country, ‘injury’ to the domestic industry and causal link between the alleged dumping and ‘injury’ exists justifying initiation of an anti-dumping investigation. The Authority hereby initiates an investigation into the alleged dumping, and consequent injury to the domestic industry in terms of Rule 5 of the Rules, to determine the existence, degree and effect of alleged dumping and to consider recommending an amount of antidumping duty, which if levied, would be adequate to remove the ‘injury’ to the domestic industry.

Domestic Industry & Standing

3.    The petition has been filed by M/s Himadri Specilaty Chemical Limited. There are other producers of the subject goods in India namely Mangalore Chemicals and Fertilisers Ltd (MCF)., LRC Specialty Chemicals Pvt. Ltd., Gujarat Polybands Pvt. Ltd., Gujarat Polysol Chemicals Pvt. Ltd., HR Johnson (India) produce SNF. The petition has been supported by Mangalore Chemicals and Fertilisers Ltd (MCF). The petitioner is not related to the exporters or importers of the alleged dumped article and the petitioner has not imported the product under consideration from subject countries. The facts of the case, clearly establish that petitioner should be considered eligible domestic industry within the meaning of Rule 2(b).

4.    The Authority holds that the petitioner along with supporting domestic producer constitutes an eligible domestic industry in terms of Rule 2 (b) and satisfies the criteria of standing also in terms of Rule 5 (3) of the Rules supra.

Product under consideration

5.    The product under consideration is "Sulphonated Naphthalene Formaldehyde


6.    Sulphonated Naphthalene Formaldehyde is a derivative of Naphthalene. Sulphonated Naphthalene Formaldehyde (SNF) Condensate is used as a water reducing admixture in construction industries for concrete. It is also used as dispersant for rubber chemicals, gypsum industries and specialty agro-chemicals industries. SNF is made from sulphonation of naphthalene and neutralization of the process by caustic soda. It is produced in 100% powder form and in liquid form in the range of solid content from 40% - 45%.

7.    Sulphonated Naphthalene Formaldehyde is used for the production of concrete admixtures, application in tanning industry, leather auxiliaries, textile auxiliaries, vat dyes, superior quality disperse dyes, agro dispersant formulations, rubber and latex emulsion.

8.    Sulphonated Naphthalene Formaldehyde is classified under Chapter 38 of the Customs Tariff Act under customs subheading 3824 40 90. The Customs classification is, however, indicative only and in no way binding on the scope of the proposed investigation and proposed measures.

Like Article

9.    The applicant has claimed that there is no known difference between the subject goods exported from the subject country and that produced by the domestic industry. Subject goods produced by the domestic industry and imported from the subject country are comparable in terms of essential product characteristics such as physical & chemical characteristics, manufacturing process & technology, functions & uses, product specifications, pricing, distribution & marketing and tariff classification of the goods. Consumers use the two interchangeably. The applicant has further claimed that the two are technically and commercially substitutable and, hence, should be treated as ‘like article’ under the Rules. Therefore, for the purpose of the present investigation, the Authority treats the subject goods produced by the domestic industry in India as ‘Like Article’ to the subject goods being imported from the subject country.

Countries involved

10.  The present investigation is in respect of alleged dumping of Sulphonated Naphthalene Formaldehyde (SNF) from China PR. (referred to as the “subject country”).

Normal Value


11.  Applicant has claimed that China should be treated as a non-market economy and normal value in case of China should be determined in accordance with para-7 and 8 of Annexure I of the Rules. The applicant has claimed normal value for China PR on the basis of cost of production in India, duly adjusted. In terms of Para 8 in Annexure 1 to the Rules it is presumed that the producers of the subject goods in China PR are operating under non market economy conditions. In view of the above non-market economy presumption and subject to rebuttal of the same by the responding exporters from China PR, normal value of the subject goods in China PR has been estimated in terms of Para 7 of Annexure 1 to the Rules.

Export Price

12.  The applicant has determined ex-factory export price on the basis of transaction wise import data procured from IBIS a secondary source and providing evidence and basis of adjustments on account of ocean freight, marine insurance, port expenses, inland freight, bank charges, commission and VAT adjustment.

Dumping Margin

13.  The comparison of normal values with the ex-factory export price has been carried out, which shows a significant dumping margin in respect of the subject goods exported by the subject country.

Injury and Causal Link

14.  The petitioner has furnished evidence regarding injury due to alleged dumping due to increased imports in absolute terms and relative to production and consumption in India, price depression, price underselling and adverse impact on profitability, return on capital employed, and cash flow of the domestic industry. There is sufficient prima facie evidence of the ‘injury’ being suffered by the domestic industry caused by alleged dumped imports from the subject countries to justify initiation of an antidumping Investigation.

Period of Investigation (POI)

15.  The period of investigation for the present investigation is from April 2015 – March 2016 (12 Months). The injury investigation period has been considered and proposed to cover the periods Apr’12-Mar’13, Apr’13-Mar’14, Apr’14-Mar’15 and the period of investigation.

Submission of information

16.  The known exporters in the subject countries, the Government of the subject countries through their embassies in India, the importers and users in India known to be concerned with the product are being addressed separately to submit relevant information in the form and manner prescribed and to make their views known to the Authority at the following address:

The Designated Authority,

Directorate General of Anti-Dumping & Allied Duties,

Ministry of Commerce & Industry, Department of Commerce

4th Floor, Jeevan Tara Building, 5 Parliament Street,

New Delhi -110001.

17.  Any other interested party may also make its submissions relevant to the investigation in the prescribed form and manner within the time limit set out below.

Time limit

18.  Any information relating to the present investigation and any request for hearing should be sent in writing so as to reach the Authority at the address mentioned above not later than forty days (40 Days) from the date of publication of this Notification. If no information is received within the prescribed time limit or the information received is incomplete, the Authority may record its findings on the basis of the facts available on record in accordance with the Anti-dumping Rules.

19.  All the interested parties are hereby advised to intimate their interest (including the nature of interest) in the instant matter and file their questionnaire responses and offer their comments to the domestic industry’s application regarding the need to continue or otherwise the Antidumping measures within 40 days from the date of initiation of this investigation.

Submission of Information on Non-Confidential basis

20.  In case confidentiality is claimed on any part of the questionnaire’s response/submissions, the same must be submitted in two separate sets (a) marked as Confidential (with title, index, number of pages, etc.) and (b) other set marked as Non Confidential (with title, index, number of pages, etc.). All the information supplied must be clearly marked as either “confidential” or “non-confidential” at the top of each page.

21.  Information supplied without any confidential marking shall be treated as nonconfidential and the Authority shall be at liberty to allow the other interested parties to inspect any such non-confidential information. Two (2) copies of the confidential version and five (05) copies of the non-confidential version must be submitted by all the Interested parties.

22.  For information claimed as confidential; the supplier of the information is required to provide a good cause statement along with the supplied information as to why such Information cannot be disclosed and/or why summarization of such information is not possible.

23.  The non-confidential version is required to be a replica of the confidential version with the confidential information preferably indexed or blanked out / summarized depending upon the information on which confidentiality is claimed. The non-confidential summary must be in sufficient detail to permit a reasonable understanding of the substance of the information furnished on confidential basis. However, in exceptional circumstances, parties submitting the confidential information may indicate that such information is not susceptible to summarization; a statement of reasons why summarization is not possible must be provided to the satisfaction of the Authority.

24.  The Authority may accept or reject the request for confidentiality on examination of the nature of the information submitted. If the Authority is satisfied that the request for confidentiality is not warranted or the supplier of the information is either unwilling to make the information public or to authorize its disclosure in generalized or summary form, it may disregard such information.

25.  Any submission made without a meaningful non-confidential version thereof or without a good cause statement on the confidentiality claim may not be taken on record by the Authority. The Authority on being satisfied and accepting the need for confidentiality of the information provided; shall not disclose it to any party without specific authorization of the party providing such information.

Inspection of Public File

26.  In terms of rule 6(7) any interested party may inspect the public file containing non-confidential versions of the evidence submitted by other interested parties.


27.  In case any interested party refuses access to and otherwise does not provide necessary information within a reasonable period, or significantly impedes the investigation, the Authority may declare such interested party as non-cooperative and record its findings on the basis of the facts available to it and make such recommendations to the Central Government as deemed fit.