New Delhi names three Japanese, Malaysian and Thai producers in a circumvention probe on plastic pipe resin and extends a chemical duty for five more years, as India shifts from policing origins to policing routes
NEW DELHI, September 17, 2026. India’s trade remedy authority has opened an anti circumvention investigation naming three specific exporters in Japan, Malaysia and Thailand, alleging that chlorinated polyvinyl chloride resin from China is being routed through those countries to escape anti dumping duties that have been in force since 2020.
The Directorate General of Trade Remedies issued the initiation notification on Tuesday September 16, under file number 7 slash 29 slash 2026, signed by Designated Authority Amitabh Kumar. The notice is to be published in the Gazette of India.
It is the second document in three days in which the authority has found that Chinese goods are reaching the Indian market through a third country. On Monday September 14 the same authority, in final findings on aluminium foil, recorded that major producers and exporters in Thailand have related parties in China and that the pattern of imports indicates a clear shift in sourcing from China to Thailand, suggesting exporters have redirected trade flows to avoid the impact of measures imposed.
Taken together, the two documents mark a change of emphasis. India has spent years imposing duties by country of origin. It is now investigating the routes those goods take.
Three companies, named
The chlorinated polyvinyl chloride case is unusual in that it does not target three countries. It targets three firms.
The investigation is expressly limited to Sasia Chlorine Polymers Sdn. Bhd. of Malaysia, EBC Corporation of Japan and Sekisui Specialty Chemicals (Thailand) Co. Ltd., and does not extend to other producers in those jurisdictions.
The product under investigation is chlorinated polyvinyl chloride resin, whether or not further processed into compound, classified for indicative purposes under tariff items 3904 90 10 and 3904 90 90. It is the material used in hot and cold water plumbing, fire protection systems, reclaimed and chilled water piping, hydronic systems and industrial pipework. Its commercial significance in India is tied directly to construction and to municipal water infrastructure.
The applicants are DCW Limited, Epigral Limited and Lubrizol Advanced Materials India Private Limited. DCW and Epigral produced during the investigation period; Lubrizol began commercial production afterwards.
The period of investigation runs from April 1, 2025 to March 31, 2026, with injury assessed across the three preceding financial years.
The authority set out the circumvention allegation in direct terms in the notification, stating that “there is a change in the pattern of trade wherein imports of PUI from Japan, Malaysia and Thailand have increased to significant level without any sufficient cause or economic justification thereby undermining the remedial effects of the existing anti-dumping measure imposed on imports of PUC from China PR.”
On the condition of domestic producers, the notification records the applicants’ contention that “while the imports have increased, the domestic industry is operating with idle capacities.”
The measure alleged to be circumvented has a long history. The original investigation was initiated in March 2019. Provisional duties were imposed in August 2019, definitive duties in March 2020, and a sunset review begun in December 2023 led to final findings in May 2024 and continuation of the duty in August of that year. The current probe rests on section 9A(1A) of the Customs Tariff Act 1975, read with rules 25 and 26 of the 1995 anti dumping rules.
Exporters have 37 days to file questionnaire responses. Requests for extension must be lodged at least three days before the deadline. Filings must go through the authority’s SETU portal; the notification states that submissions sent by email or by any other route may not be considered, a procedural change that raises the cost of defending a case for smaller foreign exporters unfamiliar with the system.
The governments of Japan, Malaysia and Thailand are being informed through their embassies in New Delhi. No official response had been recorded by Thursday.
The chemical that pays 440 dollars a tonne
A day earlier, on Monday September 15, the same authority issued final findings in a sunset review recommending that anti dumping duty on sodium hydrosulphite from China continue for a further five years at 440 dollars a tonne.
The recommendation, in case number AD (SSR) 06 slash 2026, covers the product whether made by the zinc process or the sodium formate process, under tariff codes 2831 1010 and 2832 1020. The duty table carries two lines, both at 440 dollars a tonne: goods originating in China and exported from anywhere, and goods originating anywhere and exported from China. There are no exporter specific rates.
The applicant was Silox India Private Limited, supported by Demosha Chemicals, Gulshan Chemicals and Kutch Chemicals Industries. India has five producers of the chemical, which is used principally as a reducing agent in textile and paper bleaching.
What makes the finding notable is the evidentiary basis on which the duty was continued. The authority found that the domestic industry was profitable during the investigation period and had not suffered material injury. Subject imports from China had fallen to 23 tonnes in the investigation period, from 2,425 tonnes three years earlier. Total imports of the product from all sources were 23 tonnes.
The duty was extended entirely on likelihood of recurrence.
Two data points carried the argument. The first was post period import behaviour: 48.9 tonnes arrived between October 2025 and January 2026, an annualised rate of 147 tonnes, which the authority described as an increase of more than 500 per cent over investigation period levels. The second was the disposition of Chinese exports elsewhere.
“About 95% of Chinese exports to third countries are at prices below the prices prevailing in India, creating a strong possibility of diversion to India,” the authority wrote. It found that 99 per cent of those exports were at dumped prices and 98 per cent at injurious prices, and that the volume of Chinese exports to third countries at dumped and injurious prices exceeds the entire Indian demand for the product.
The price effect is measurable. The landed price without duty was 91,044 rupees a tonne. With duty it was 1,29,220 rupees, a gap of 42 per cent.
The authority also pre-empted objections from downstream users, noting that “the subject goods are used mainly as a chemical additive in downstream applications and do not constitute a major part of the cost of the downstream products,” and recording that “no user filed a questionnaire or Economic Interest Questionnaire response or placed evidence on record showing adverse impact of the existing duty.”
That absence is itself striking. In a five year extension affecting every Indian textile and paper bleaching operation, not one user industry participated.
A crowded fortnight
The two decisions sit inside an unusually busy period for the authority.
On September 16 it also issued final findings in an anti dumping investigation on copper data cables from China, under file number 6 slash 44 slash 2025. The case was initiated on September 18, 2025, and the findings were published almost exactly at the twelve month statutory mark. The applicants were Birla Cable Limited and Sterlite Technologies Limited, and the product scope as initiated covers category five enhanced through category seven augmented cables and related patch cords used in local area networks and telecommunications infrastructure. The duty rates recommended were not available in machine readable form at the time of writing and had not been reported by any outlet.
The same day a disclosure statement was issued in a countervailing duty investigation on jute products from Bangladesh and Nepal, and an oral hearing was held by video conference in the anti dumping investigation on cold rolled flat products of stainless steel in the 300 and 400 series from China, Indonesia and Vietnam.
That last case is the largest in the pipeline by value. It was initiated on September 29, 2025 on an application by the Indian Stainless Steel Development Association, covering a wide span of tariff lines under headings 7219 and 7220. The hearing had been scheduled for September 11 and was adjourned to September 16 at 3.30 pm, conducted through digital video conferencing only, with the notice signed by Dr Dileeraj Dabhole, Joint Director General of Foreign Trade at the authority. Parties had to register attendance by September 14.
With the hearing complete, final findings are due at the one year mark on September 29, within a fortnight.
The context is substantial. India’s stainless steel imports reached 1.73 million tonnes in the 2025 financial year, with China, Indonesia, Vietnam and South Korea the main contributors, according to market intelligence provider BigMint.
Abhyuday Jindal, managing director of Jindal Stainless, set out the domestic producers’ case when the association filed its application, in comments to Press Trust of India.
“Definitely, because for a very long time we have been suffering with substandard dumped material from countries like China, Vietnam, Indonesia, and looking at now absolutely these trade uncertainties globally, it’s definitely required to protect our borders, protect our homegrown companies,” he said.
“Situation is urgent because this is where the growth is coming,” he added. “India is where the market is growing.”
What aluminium foil shows
The aluminium foil sunset review completed on September 14 offers the clearest available demonstration of why India’s producers keep returning to the authority, and why the transhipment question has become central.
The case covers foil of 80 microns and below from China, Indonesia, Malaysia and Thailand. Duties on the thicker range, between 5.5 and 80 microns, were first imposed in May 2017 and lapsed in May 2022. Duties below 5.5 microns were imposed in September 2021 and remain.
The import series in the findings tracks what happened after the lapse. Chinese imports in the 5.5 to 80 micron band ran at 73,112 tonnes in the 2017 financial year, fell to 19,343 tonnes by 2019 and to 17,145 tonnes in 2022 while duties applied, then rebounded to 40,806 tonnes in 2023, 64,101 tonnes in 2024 and 73,692 tonnes in the 2025 investigation period. That final figure is the highest in the nine year series and exceeds the pre duty base year.
Thai volumes tell the complementary story. They were 260 tonnes in 2017, reached 6,109 tonnes in 2019, peaked at 36,448 tonnes in 2023 and stood at 13,724 tonnes in the investigation period. That rise began after duties were imposed on China and, in the authority’s assessment, reflects related party sourcing rather than independent Thai production.
Cumulated dumped imports from the four subject countries accounted for 15.81 per cent of total imports of the product.
Jute, and the southern neighbours
Not every case this week points east. On September 16 the authority also issued a disclosure statement in a countervailing duty investigation covering jute products from Bangladesh and Nepal, a file with a different political weight to the chemical and steel cases.
Jute is one of the few sectors where India’s trade remedy machinery is aimed at its immediate neighbours rather than at East Asian exporters, and where the domestic constituency is agricultural rather than industrial. India has maintained anti dumping measures on Bangladeshi and Nepalese jute goods for several years, covering sacking bags, hessian and yarn, on applications from mills concentrated in West Bengal. A countervailing action adds a second layer, targeting subsidies rather than pricing.
A disclosure statement is the stage at which the authority sets out its essential facts and gives interested parties a final opportunity to comment before issuing findings. Its publication signals that a determination is close.
The case illustrates a tension in India’s trade policy that the headline numbers obscure. New Delhi is simultaneously liberalising toward Europe, defending against China and East Asia, and tightening against South Asian neighbours whose exports compete with politically sensitive domestic sectors. Those are three different postures running through one institution.
Producers press, users stay away
The pattern of participation in these cases is one sided and worth stating plainly.
On the applicant side the names are familiar and well resourced: the Indian Stainless Steel Development Association and Jindal Stainless on stainless steel; DCW, Epigral and Lubrizol on pipe resin; Silox India with three supporters on sodium hydrosulphite; Birla Cable and Sterlite Technologies on copper data cables; Hindalco and others on aluminium foil.
On the opposing side the record is close to empty. In the sodium hydrosulphite case the authority expressly noted that no user filed any response. On aluminium foil, whose downstream users include flexible packaging converters, pharmaceutical blister pack manufacturers, food service operators and industrial laminators, no Indian user body appears on the record. Nor do importers or user industries appear in the stainless steel file.
That asymmetry has consequences for the outcome. Anti dumping procedure is adversarial in design. Where only one side appears, the authority is left assessing injury and public interest on evidence supplied by the party seeking the duty.
The wider picture
The Directorate General of Trade Remedies was created in 2018 by merging three separate bodies, and now serves as India’s single window trade defence authority under the Department of Commerce. Its caseload has grown steadily. Trade counsel at Lakshmikumaran and Sridharan, reviewing the authority’s output earlier this year, recorded 25 investigations initiated in a single month and described the volume as “reflecting both the responsiveness of the system and the continued reliance of domestic industry on trade remedies as a means of redressal for unfair trade.”
The trade remedy programme runs alongside a broader safeguard on steel. Following a recommendation from the authority, India imposed a three year staggered safeguard duty on flat rolled steel: 12 per cent from April 2025, 11.5 per cent from April 2026, and 11 per cent from April 2027. The current rate is 11.5 per cent. No new safeguard action was taken this week.
The direction of travel contrasts with India’s posture toward Europe. Negotiations on a free trade agreement with the European Union concluded in January 2026, and the European Commission put proposals to the Council for signature this month. India is opening toward Brussels while tightening against East Asia.
That opening carries a cost of its own. Indian negotiators pressed hard against the European Union’s Carbon Border Adjustment Mechanism during the talks and did not succeed in exempting Indian exports from it. The mechanism entered its paying phase on January 1 this year and covers iron, steel and aluminium, three sectors in which India has substantial export exposure to Europe. Brussels pledged financial support to help Indian producers cut emissions rather than agreeing a carve out.
The sequencing is awkward for Indian exporters. The free trade agreement removes European tariffs on Indian steel and aluminium at roughly the same moment the carbon mechanism begins charging for the emissions embedded in them, and the European Parliament voted on September 15 to extend that mechanism to 457 downstream product categories. Indian mills that gain duty free access to the European market will find part of the benefit absorbed by a carbon charge calculated on the intensity of Indian production, which is heavily coal based.
The same authority now recommending duties on Chinese, Indonesian and Vietnamese steel entering India is therefore watching its own producers face an analogous charge at the European border. Trade remedy policy and carbon policy are converging on the same set of steel flows from opposite directions.
There is a further structural point about the timing of these cases. Indian anti dumping investigations run on a twelve month statutory clock from initiation to final findings, with a possible extension. That means the September cluster reflects decisions to initiate taken in September 2025, when Chinese steel and chemical export prices were falling and Indian producers were filing in volume. The cases arriving now are the output of a filing wave a year old, which implies the caseload will remain elevated through the coming quarters regardless of what happens to import prices in the meantime.
Implications for exporters and importers
Four consequences follow for companies trading with India.
The first is that named company circumvention proceedings are a sharper instrument than country wide duties, and carry reputational weight beyond the duty at stake. Sekisui Specialty Chemicals in Thailand and EBC Corporation in Japan are established, non Chinese businesses. Being named individually in an Indian circumvention file is a different proposition from being caught by a country wide rate.
The second is that Japan’s appearance is an escalation. India rarely targets Japanese exporters. Doing so in a circumvention context, while simultaneously running an investigation into grain oriented electrical steel and amorphous metal that covers Japan and South Korea alongside China and Russia, points to a widening of focus beyond the usual Chinese subject.
The third is retroactive exposure for importers who have already re-sourced. Anti circumvention duties, once imposed, extend the existing measure to the circumventing route. Buyers who shifted chlorinated polyvinyl chloride procurement to Malaysia, Japan or Thailand, or aluminium foil procurement to Thailand, are now carrying a contingent liability that did not exist when those contracts were signed. Supply agreements written on the assumption that origin determines duty exposure need review.
The fourth is evidentiary. The sodium hydrosulphite finding continued a duty for five years while expressly finding no material injury and a profitable domestic industry, relying instead on third country export pricing and a post period import uptick from a very low base. Exporters and their counsel will read that as a signal that Indian sunset reviews are close to automatic, and will price the probability of duty removal accordingly.
The immediate date to watch is September 29, when final findings on stainless steel cold rolled flat products from China, Indonesia and Vietnam fall due. Against 1.73 million tonnes of annual import exposure, it is the largest decision in the queue.