DGTR Initiates Anti-Circumvention Investigation on CPVC Resin from Malaysia, Japan & Thailand on DCW, Epigral and Lubrizol Advanced Materials Complaint

Ø  Sahu Jain Group Controls DCW, Epigral is with Meghmani Group while Lubrizol is the World Leader in CPVC and a Big Exporter Himself

Ø  CPVC is the Latest in PVC Capable of Handling Hot Liquids, Reliance is as yet only making PVC to Handle Cold Liquids, it has plans to make CPVC in Future (Chlorinated PVC)

[Initiation Notification SETU Case ID: AD/AC/006/2026 dated 16 September 2026]

1.    Anti-Circumvention Investigation Initiated

o    DGTR has initiated an anti-circumvention investigation concerning alleged circumvention of the existing anti-dumping duty (ADD) on Chlorinated Polyvinyl Chloride (CPVC) Resin – whether or not further processed into compound.

o    The alleged circumvention involves exports to India through Malaysia, Japan and Thailand of goods originating in/exported from China PR and Korea RP.

2.    Applicants / Domestic Industry

o    The application was filed by:

§  DCW Limited

§  Epigral Limited

§  Lubrizol Advanced Materials India Pvt. Ltd.

o    DGTR has found that the application has been made by or on behalf of the domestic industry under the applicable Anti-Dumping Rules.

o    DCW and Epigral were producers during the POI, while Lubrizol commenced commercial production subsequently.

3.    Product Under Consideration (PUC)

o    CPVC Resin – whether or not further processed into compound.

o    The product is used in:

§  Hot and cold-water plumbing

§  Fire protection

§  Reclaimed-water piping

§  Chilled-water piping

§  Hydronic piping

§  Various industrial piping applications.

4.    Product Under Investigation (PUI)

o    The investigation covers CPVC Resin exported by the following specified exporters:

§  Malaysia: Sasia Chlorine Polymers Sdn. Bhd.

§  Japan: EBC Corporation

§  Thailand: Sekisui Specialty Chemicals (Thailand) Co. Ltd.

5.    HS Classification

o    PUI is classified under:

§  3904 90 10

§  3904 90 90

o    DGTR has clarified that the customs classification is indicative only and does not determine the scope of the investigation.

6.    Existing Anti-Dumping Duty

o    The original investigation on imports from China PR and Korea RP was initiated on 28 March 2019.

o    Provisional ADD was imposed on 26 August 2019.

o    Definitive ADD was imposed vide Notification No. 05/2020-Customs (ADD) dated 7 March 2020.

o    Following a sunset review, the ADD was continued in modified form vide Notification No. 15/2024-Customs (ADD) dated 23 August 2024.

7.    Alleged Circumvention Route

o    Applicants alleged that CPVC resin is exported from China to Malaysia and Japan and subsequently exported to India.

o    They further alleged that CPVC resin or compound is exported from China to Thailand and subsequently exported to India by Sekisui Specialty Chemicals.

8.    Prima Facie Evidence

o    Applicants submitted evidence alleging:

§  The PUI is being dumped.

§  Imports have increased.

§  Domestic producers are operating with idle capacity.

o    DGTR found prima facie evidence of a change in the pattern of trade, with imports from Japan, Malaysia and Thailand increasing significantly without sufficient economic justification.

9.    DGTR's Decision to Initiate

o    DGTR concluded that sufficient prima facie evidence exists regarding the circumstances covered by Rule 25.

o    It also found, prima facie, that the allegedly circumventing imports are dumped.

o    Accordingly, the anti-circumvention investigation has been initiated under Section 9A(1A) of the Customs Tariff Act, 1975 read with Rules 25 and 26.

10.  Scope of Countries and Exporters

o    The investigation is specifically limited to exports to India by:

§  Sasia Chlorine Polymers Sdn. Bhd. — Malaysia

§  EBC Corporation — Japan

§  Sekisui Specialty Chemicals (Thailand) Co. Ltd. — Thailand

o    It does not extend to other producers/exporters of the product from these three countries.

11.  Period of Investigation

o    POI: 1 April 2025 to 31 March 2026.

o    Injury period: 2022-23, 2023-24, 2024-25 and the POI.

12.  Submission Through SETU Portal

o    All information, questionnaires and submissions must be filed only through the DGTR SETU Portal.

o    Email or other modes may not be considered.

o    Interested parties must register under SETU Case ID AD/AC/006/2026.

13.  Time Limit for Responses

o    Confidential and non-confidential questionnaire responses/submissions must be uploaded within 37 days from the date on which the Authority sends/transmits the notice calling for information.

o    Incomplete or late information may result in findings based on facts available.

14.  Extension Requests

o    Requests for extension must be submitted through the SETU Portal at least 3 days before the original deadline.

o    Requests submitted later will not be considered.

15.  Confidentiality Requirements

o    Parties submitting confidential information must simultaneously provide a non-confidential version.

o    The non-confidential version should replicate the confidential submission, with confidential information appropriately indexed/blanked out and adequately summarised.

o    Confidentiality claims must be supported by a good-cause statement.

16.  Consequences of Inadequate Confidentiality Compliance

o    Submissions without a meaningful non-confidential version or adequate justification for confidentiality may not be taken on record.

o    Other interested parties may submit comments on confidentiality claims within 7 days of circulation of the non-confidential version.

17.  Public File / Access

o    Non-confidential submissions will be accessible to other interested parties through their respective SETU Portal logins.

18.  Non-Cooperation

o    If an interested party refuses to provide necessary information, fails to provide it within the stipulated period, or significantly impedes the investigation, DGTR may declare the party non-cooperative.

o    Findings may then be based on the facts available on record.

Effect of the Notification

·         No new anti-dumping duty has been imposed by this initiation notification itself.

·         DGTR has commenced an investigation to determine whether the existing ADD on CPVC Resin from China PR and Korea RP is being circumvented through the specified exporters in Malaysia, Japan and Thailand.

·         The investigation could ultimately lead to recommendations concerning extension of the existing anti-dumping measure, but the present notification is an initiation of investigation, not a final determination.