DG Safeguards Initiates Investigation on Dioctyl Phthalate Imports on Complaint of KLJ Plasticizers Plus Three

[Ref: F.No. D-22011/ 13/2011 dated 23 May 2012]

Sub: Initiation of safeguard investigation concerning imports of Dioctyl Phthalate (DOP) into India.

An application has been filed before me under Rule 5 of the Customs Tariff (Identification and Assessment of Safeguard Duty) Rules, 1997 by M/s. KLJ Plasticizers Ltd, Silvassa, M/s N K Polymers & Additives Mfg Co., Daman, M/s Payal Polyplast Ltd, Daman and M/s PCL Oil & Solvents Ltd, Daman for imposition of Safeguard Duty on imports of Dioctyl Phthalate (DOP) into India to protect the domestic producers of Dioctyl Phthalate (DOP) against serious injury caused by the increased imports of Dioctyl Phthalate (DOP) into India.

2. Domestic Industry: The application has been filed by M/s KLJ Plasticizers Ltd, Silvassa, M/s N K Polymers & Additives Mfg Co., Daman, M/s Payal Polyplast Ltd, Daman and M/s PCL Oil & Solvents Ltd, Daman for imposition of Safeguard Duty on imports of Dioctyl Phthalate (DOP). The applicants, taken together, account for 91% of the total production of the said product in India.

3. Product Involved: The product under consideration is Bis (2-ethylhexyl) phthalate, commonly abbreviated DEHP, is an organic compound with the formula C6H4 (C8H17COO)2. It is also known as dioctyl phthalate and abbreviated as DOP in market/trade parlance. It is the most important “phthalate”, being the diester of phthalic acid and the branched-chain 2-ethylhexanol. This product is a colourless viscous liquid, soluble in oil, but not in water. It possesses good plasticizing properties. Being produced on a massive scale by many companies, it has acquired many names and acronyms, including BEHP and di-2-ethyl hexyl phthalate. It is widely used as a plasticizer in manufacturing of articles made of PVC. Plastics may contain 1% to 40% of DEHP. It is also used as a hydraulic fluid and as a dielectric fluid in capacitors. DEHP also finds use as a solvent in glowsticks as it has suitable properties and the low cost. It has been used as a plasticizer in medical devices such as intravenous tubing and bags, catheters, nasogastric tubes, dialysis bags and tubing, and blood bags, transfusion tubing and air tubes. Dioctyl Phthalate (DOP) is classified under Customs sub-heading No. 29173920 under the Customs Tariff Act, 1975.

4. Period of investigation (POI): This is a fresh case based on the serious injury caused by the increased imports being faced by the domestic industry. The POI has been taken from 2008-09 onwards till 2011-12 (Q3).

5. Increased Imports: Dioctyl Phthalate (DOP) is imported into India from a number of countries, and primarily from Republic of Korea, Taiwan and Malaysia. The imports of Dioctyl Phthalate (DOP) have shown an increasing trend in absolute terms as well as compared to the domestic production. The imports and domestic production of Dioctyl Phthalate (DOP) during 2008-09 to 2011-12 (till Q3) remained as under:

Year

Total Imports (MT)

Domestic Production (MT)

2008-09

40608

60242

2009-10

35210

69468

2010-11

35346

77492

2011-12(Apr-Dec)

37450

51710

2011-12(Annualized)

49934

68946

The Imports have increased from 35210 MT in 2009-10 to 35346 MT in 2010-11 and further to 49934 MT in 2011-12(annualized) which shows an increase of 42% which is substantial. Further the imports with respect to domestic production were 50.68 % in 2009-10 which increased to 72.42 % in 2011-12(annualized).

6. Injury: The applicants have claimed that the increased imports of Dioctyl Phthalate (DOP) have caused and are threatening to cause serious injury to the domestic producers of Dioctyl Phthalate(DOP) as indicated by the following factors:

a) Production: The domestic production has fallen sharply from 77492MT in 2010-11 to 68946 MT in 2011-12(annualized) after showing a rising trend from 2008-09 to 2010-11.

YEAR

Index

Production (MT)

2008-09

100

60242

2009-10

115

69468

2010-11

129

77492

2011-12(Apr-Dec)

 

51710

2011-12(annualized)

114

68946

(b) Domestic sales: Domestic sales have also declined from 72035 MT in 2010-11 to 61912 MT in 2011-12(annualized) after showing a rising trend from 2008-09 to 2010-11. This is evident from the table below:

Year

Index

Domestic Sales (MT)

2008-09

100

58880

2009-10

115

67959

2010-11

122

72035

2011-12 (Apr-Dec)

 

46434

2011-12(annualized)

105

61912

(c) Consumption/Demand: The sale has increased till 2010-11 but has declined thereafter sharply even though there is a surge in demand for the same period. As the import has increased from 2009-10 till 2011-12 (annualised), the increase in imports have affected the DI’s share of sale, resulting in injury.

Year

DI Sale (MT)

Demand (MT)

Import(MT)

% of DI sale in Demand.

2008-09

58880

99488

40608

59

2009-10

67959

103169

35210

66

2010-11

72035

107381

35346

67

2011-12 (Apr-Dec)

46434

83884

37450

55

2011-12(annualized)

61912

111846

49934

55

(d) Exports: There has been a continuous growth in exports by the DI till the most recent period that too at lower prices in order to minimize losses due to mounting inventory, especially during 2009-10 to 2011-12 (annualized). This situation is further aggravated by increase in demand but sharp decrease in share of sale in domestic market in the most recent period.

Year

Domestic Sale(MT)

Indexed average domestic Sale price (Rs./Kg)

Export(MT)

Indexed average Export Sale price (Rs./Kg)

2008-09

58880

100

1326

100

2009-10

67959

93

1892

86

2010-11

72035

118

4274

105

2011-12 (Apr-Dec)

46434

124

6194

112

2011-12(Annualised)

61912

124

8258

112

(e) Capacity Utilization: Capacity utilization of the domestic industry has declined in the most recent period, from 50% in 2010-11 to 42% in 2011-12(annualized). As compared to 2010-11, the capacity utilization has further declined in the most recent period by 8 % even though there is an addition of 6.42 % in the installed capacity.

Year

Installed Capacity (MTS)

Capacity utilization %

2008-09

155750

39

2009-10

155750

45

2010-11

155750

50

2011-12 (April -Dec)

124313

42

2011-12 (Annualized)

165750

42

(f) Share of domestic industry in domestic consumption: Market share of domestic industry has fallen significantly. The applicants had market share of 94% in 2009-10 in domestic market which fell to 91% during 2010-11 and remained at 91% in 2011-12(annualized).

(g) Profit/loss – the profitability of the domestic industry has steeply deteriorated to such a situation that the domestic industry is now suffering financial losses. This is evident from the table below:-

Financial Year

Profit (Rs.in lakhs)

2008-09

 -1599

2009-10

 471

2010-11

448

2011-12 (Annualized)

-4600

(h) Inventories – The average inventories with the domestic industry have increased significantly. The table below depicts the inventories level which have witnessed an increasing trend from 823 MT in 2009-10 to 1338 in 2011-12(annualized), reflecting the plight of the domestic industry.

YEAR

Index

Inventory(MT)

2008-09

100

1066

2009-10

77

 823

2010-11

115

1223

2011-12(April-Dec)

129

1376

2011- 12 (annualized)

126

1338

7. The domestic industry has requested for immediate imposition of safeguard measures in their application. The domestic industry’s request for imposition of provisional safeguard duty is in light of critical circumstances, since interim measures are imperative in view of steep deterioration in performance of the domestic industry as a result of increased imports of product under consideration. Significant drop in sales volumes of the domestic industry and consequently in production, capacity utilization, rising inventories and significant drop in profits to a situation of financial losses, justify immediate imposition of safeguard duty on imports of DOP.

8. The application has been examined and it has been found that prima facie increased imports of Dioctyl Phthalate (DOP) have caused and are threatening to cause serious injury to the domestic producers of Dioctyl Phthalate (DOP) and such increase in imports has caused irreparable damage to the domestic industry and accordingly, it has been decided to initiate an investigation through this notice.

9. All interested parties may make their views known within a period of 30 days from the date of this notice to:

The Director General (Safeguards)

Bhai Vir Singh Sahitya Sadan: 2nd Floor,

Bhai Vir Singh Marg,

Gole Market, New Delhi-110 001, INDIA.

Telefax: 011-23741542/ 23741537

E-mail: dgsafeguards@nic.in

10. All known interested parties are also being addressed separately.

11. Any other party to the investigation who wishes to be considered as an interested party may submit its request so as to reach the Director General (Safeguards) on the aforementioned address within 21 days from the date of this notice.