Untreated
Fumed Silica from China in Sunset Review – DGTR Recommends Antidumping Duty of
US$1296 per MT on Application by Sole Producer Cabot Sanmar
Ltd, No Injury to Sanmar at Present, Future Injury
Countered by ADD
Ø No Change in Duty
Ø Korea Out of the Net
Ø Notification No. 66 /2021-Customs (ADD)
dated 11 November 2021 to Expire on 10 Feb, 2027
[DGTR final Findings Case No. AD
(SSR)-05/2026 dated 06.11.2026]
Based on the provided Sunset Review investigation
document, here is a comprehensive summary of the Final Findings
concerning imports of "Untreated Fumed Silica" from China PR:
The Directorate General of Trade Remedies (DGTR),
Ministry of Commerce & Industry, has concluded its sunset review
investigation (Case No. AD (SSR)-05/2026) regarding the anti-dumping duty
(ADD) on Untreated Fumed Silica originating in or exported from China
PR. The review was initiated following an application from Cabot Sanmar Limited, the sole producer of the product in
India.
Key Highlights & Strategic
Determinations
·
The Product & Market Segments: The
product under consideration is Untreated Fumed Silica, widely used as a
tableting agent in pharmaceuticals and an anti-caking agent in foods, paints,
and polymers. While interested parties requested different Product Control
Numbers (PCNs) for higher-value pharmaceutical grades vs. industrial grades,
the DGTR declined to adopt a PCN methodology because no material
variance in the actual cost of production was proven.
·
Non-Market Economy (NME) Status: Chinese
producers failed to file the specific questionnaire to rebut the presumption of
China being a non-market economy. Consequently, the DGTR determined China’s
Normal Value using the surrogate country methodology, benchmarking it
against the average export price from Japan to India (the top
non-subject exporter).
·
Duty Absorption Tactics: The
authority noted that a prior anti-absorption investigation in 2025 confirmed
that Chinese exporter Shandong Dongyue Silicone
Material Co., Ltd. had been actively absorbing duties to aggressively
preserve Indian market share, which previously led to an upward modification of
their ADD rates.
Dumping & Injury Margin
Matrix
The investigation verified that despite existing
duties, positive and significant dumping from China has continued. The
calculations for the Period of Investigation (1st October 2024 to 30th
September 2025) are structured as follows:
|
Producer / Exporter |
Dumping Margin Range (%) |
Injury Margin (%) |
Final Status / Likelihood Evaluation |
|
Shandong Dongyue
Silicone Material Co., Ltd. |
130% – 140% |
40% – 50% |
Significant continuing dumping; landed price is
below the domestic cost of sales. |
|
Wacker Chemicals Fumed Silica (Zhangjiagang) Co.,
Ltd. (via Wacker China) |
50% – 60% |
Negative |
Negative injury margin, but third-country export
analysis shows high dumping levels. |
|
All Other Chinese Producers / Exporters |
150% – 160% |
50% – 60% |
Residual category evaluated under facts
available. |
Likelihood of Recurrence of
Injury
The DGTR concluded that while the domestic industry
is not currently suffering material injury—thanks to the anti-dumping
protections in place—injury is highly likely to recur if the duties are
allowed to lapse due to the following triggers:
·
Massive Surplus & Idle Capacities: China
holds nearly 43% of global fumed silica capacity. It possesses an
additional exportable capacity that is 25 times the total demand in India,
combined with massive internal unutilized capacity.
·
Price Depression Model:
Financial simulations reveal that if the sole domestic industry is forced to
match the duty-free landed prices of Chinese imports, its current non-pharma
profits will rapidly collapse into severe financial and cash losses.
·
Third-Country Diversion Incentives: Analysis
of Chinese global shipments showed that 95% to 100% of their exports to
third countries are heavily dumped and priced below Indian export levels,
creating a massive incentive to divert those volumes to India.
Public Interest & Balanced
Protection
While downstream users argued that the duties drive
up raw material costs, the DGTR determined that Untreated Fumed Silica accounts
for a minimal share (<1%) of the total cost of final downstream products.
Imposing fair-trade pricing ensures that the Indian ecosystem does not become
entirely dependent on a monopolistic foreign supply line, while allowing
domestic producers to proceed with multi-crore greenfield expansions.
If you want to review specific elements of this
sunset review, let me know if you would like to explore:
·
The precise methodology used to adjust the
Japanese CIF export price down to the ex-factory normal value level
·
The exact timeline for Cabot Sanmar's
upcoming greenfield capacity expansion in India
·
A breakdown of how the Wacker Group's global
reference pricing model was evaluated during the probe