DGTR Issues Final Findings of Anti-dumping Duty on Toluene Di-lsocyanate (TDI) (Starting Material for PU) from EU, Saudi Arabia in Sunset Review – No Change in Former Duty

·         Complainant: Sole Producer GNFCC (Gujarat Narmada Valley Fertilizers & Chemicals)

·         Anti-dumping Duty Extended by Three More Months to 1 March, 2026 by Notification No. 28/2025-Customs (ADD) dated 19 August, 2025

·          Notification 28/2021-Customs (ADD) dated 27 April, 2021 to Expire on 1 March. 2026

[DGFT Final Findings Case No. AD(SSR) – 05/2024 dated 12 November, 2025]

1. Background

·         Anti-dumping duties on Toluene Di-Isocyanate (TDI 80:20) from the EU and Saudi Arabia were first imposed in April 2021.

·         Gujarat Narmada Valley Fertilizers & Chemicals Ltd. (GNFC), the sole Indian producer, filed for a sunset review seeking continuation and enhancement of duties.

·         Investigation period: Apr 2023 – Jun 2024; injury period: 2020–21 to POI.

2. Product & Domestic Industry

·         Product under consideration (PUC): TDI 80:20, used in polyurethane foams.

·         DGTR confirmed that domestically produced TDI is a like article to imports.

·         GNFC is the only domestic producer, not importing the product, and meets standing requirements.

3. Dumping Analysis

DGTR examined cooperating exporters from the EU (BorsodChem, Covestro) and Saudi Arabia (Sadara, SABIC group, Dow entities).

Significant dumping margins were found:

·         BorsodChem (EU): ~90–100%

·         Covestro AG (EU): ~20–30%

·         Sadara (Saudi Arabia): ~50–60%

·         Non-cooperating exporters: even higher margins (up to 120%)

DGTR noted:

·         Exporters mostly sell to their related entities in India, who then resell at losses, distorting the real export price.

·         Actual export prices are significantly below normal value, confirming continued dumping.

4. Injury to Domestic Industry

DGTR found continued and significant injury:

Price Effects

·         Import prices remained below GNFC’s cost of sales, even when considering its more efficient plant.

·         Price suppression: Domestic prices could not rise in line with increasing costs.

·         Price undercutting was marginally positive but understated due to resale by related importers at below-cost prices.

Financial Deterioration

·         Profitability, cash profits, and return on capital collapsed after the base year.

·         GNFC reported heavy losses, cumulatively amounting to nearly half its capital employed.

·         Inventory build-up increased pressure.

Volume Effects

·         Although GNFC increased production and sales, this was due to attempts to spread fixed costs amid losses—not improved conditions.

·         No volume injury was claimed, but price injury was severe.

Non-Attribution

DGTR rejected claims that injury was due to:

·         Plant shutdowns – viewed as normal for TDI plants globally.

·         Raw material price changes – considered but did not explain injury.

·         Captive imports by related entities – all imports must be considered under law.

5. Likelihood of Recurrence

Even if current import volumes were lower, DGTR found:

·         Exporters have high dumping margins,

·         Highly concentrated global TDI industry with large surplus capacities,

·         History of dumping shifting between countries,
demonstrating high likelihood of continuation/recurrence of dumping and injury if duties expire.

6. Final Determination

DGTR concludes that:

·         Dumping persists from the EU and Saudi Arabia.

·         Injury to domestic industry continues.

·         Likelihood of intensified dumping and injury exists if duties are removed.

Therefore, continuation of the anti-dumping duty is warranted.

(Exact duty rates to be notified separately by the Ministry of Finance.)