DGTR Initiates Anti-Dumping Investigation on Copolymer Polyol Imports from China on Complaint of Expanded Polymer, Takes Cognizance of Pending High Court Case

DGTR has opened a fresh anti-dumping investigation into Chinese-origin/exported Copolymer Polyol (hydroxyl value ≥23.5), covering April 2025–March 2026. The initiation is based on prima facie findings of significant dumping, material injury and causal link. No anti-dumping duty has yet been imposed. The earlier 2024 investigation resulted in Final Findings dated 26 September 2025 without imposition of duty.

[DGTR Initiation Notification SETU Case ID: AD/O1/067/2026 dated 23.09.2026]

1. Product under investigation: “Copolymer Polyol of hydroxyl value ≥ 23.5”, also known as Polymer Polyol in market parlance.

2. Subject country: China PR — investigation concerns imports originating in or exported from China PR.

3. Applicant / Domestic Industry: M/s Expanded Polymer Systems Pvt. Ltd. has filed the application on behalf of the domestic industry.

4. Previous investigation: DGTR had earlier investigated the same product under Notification dated 30.09.2024, with POI April 2023–March 2024. Final Findings were issued on 26.09.2025, but no anti-dumping duty was imposed pursuant to those findings.

5. Pending Gujarat High Court proceedings: The present initiation is without prejudice to proceedings pending before the Hon’ble Gujarat High Court. The finality of the present proceedings will be subject to the Court's decision and any consequential Central Government action.

6. Uses of PUC: The product is mainly used in manufacturing flexible foam, particularly mattresses. It is also used for bra-cups and to improve the hardness of slab foam in polyurethane foam production.

7. Customs classification: The product falls under Chapter 39, Heading 3907. The applicant has claimed imports under:

o 39072010

o 39072090

o 39072910

o 39072990

8. Scope of PUC: Product coverage will be determined by the product description, not merely by customs classification. Therefore, products meeting the PUC description will be covered irrespective of the particular tariff item under Heading 3907.

9. Indian Standard: IS 18174:2023 (Polyether Polyol) is applicable, but the standard is not mandatory.

10. Unit of measurement: Metric Tonnes (MT).

11. PCN methodology: No Product Control Number (PCN) methodology has been proposed at initiation. Interested parties may submit comments/proposals on the PUC scope and PCNs within 15 days of initiation.

12. Like Article: DGTR has, prima facie, treated the domestically produced product and Chinese imports as like articles, considering their physical/chemical characteristics, manufacturing process, technology, functions, specifications, pricing, distribution and end-use.

13. Domestic industry standing: The applicant claims to be the sole producer in India, accounting for 100% of Indian production of the subject goods.

14. Applicant's import/relationship status: The applicant has stated that it did not import the subject goods from China PR during the injury period and is not related to any importer or exporter of the subject goods.

15. POI: 1 April 2025 to 31 March 2026 — 12 months.

16. Injury investigation period: 2022-23, 2023-24, 2024-25 and the POI (2025-26).

17. Normal value: For initiation, DGTR has treated China PR as a non-market economy. In the absence of information supporting another basis, normal value has been constructed using the price payable in India, based on the applicant's cost of production, adjusted for SG&A expenses and reasonable profit.

18. Export price: Based on CIF import prices from DG Systems import data, with adjustments, where applicable, for ocean freight, marine insurance, commission, inland freight, port expenses, bank charges and credit cost to arrive at the net ex-factory export price.

19. Prima facie dumping: Comparison of normal value and export price at the ex-factory level indicates that the dumping margin is above the de minimis level and significant.

20. Prima facie injury: DGTR records evidence indicating injury to the domestic industry, including:

• Increase in Chinese import volumes;
• Increase in China's share of Indian demand;
• Decline in the applicant's market share;
• Positive price undercutting;
• Landed value below the applicant's cost of sales;
• Price suppression/depression;
• Financial and cash losses;
• Negative return on investment;
• Capacity under-utilisation despite increased demand; and
• Increase in inventories.

21. Causal link: The applicant has claimed that no factor other than dumped imports from China PR caused the injury. DGTR found sufficient prima facie evidence of material injury and causal link to justify initiation.

22. Investigation initiated: DGTR has formally initiated an anti-dumping investigation under Section 9A of the Customs Tariff Act, 1975 read with Rule 5 of the Anti-Dumping Rules, 1995 to determine the existence, degree and effect of alleged dumping and, if warranted, recommend the appropriate anti-dumping duty.

23. No duty at initiation: This notification initiates an investigation; it does not itself impose anti-dumping duty.

24. Submission platform: All information, questionnaires and submissions must be filed only through the DGTR SETU Portal. Submissions by email or other modes may not be considered.

25. Main time limit: Confidential and non-confidential versions must be uploaded within 37 days from circulation/transmission of the non-confidential version of the domestic industry's application as specified in the notification.

26. PUC/PCN comments: The 15-day period for comments on PUC scope/PCN methodology runs concurrently with the principal submission deadline.

27. Possible additional extension: If DGTR subsequently modifies the PUC or PCN methodology, a 15-day extension will be available from the date of such modification. Further extensions will ordinarily not be granted except in exceptional circumstances.

28. Extension request: Any extension request must be submitted through SETU at least 3 days before the original deadline.

29. Confidentiality: Parties filing confidential information must simultaneously provide a non-confidential version, with adequate summarisation and a statement explaining the basis for confidentiality.

30. Comments on confidentiality: Interested parties may comment on another party's confidentiality claims within 7 days from circulation of the relevant non-confidential version.

31. Non-cooperation: A party that fails to provide required information, refuses access, or significantly impedes the investigation may be declared non-cooperative, with findings based on the facts available.