Anti-dumping investigation concerning imports of “Ethyl Chloroformates (ECF) in any concentration” originating in or exp

1 To be published in Part-I Section I of the Gazette oflndia Extraordinary F. No. 6/03/2026-DGTR Govemment of India Ministry of Commerce & Industry Department of Commerce Directorate General of Trade Remedies 41h Floor, Jeevan Tara Building, 5, Parliament Street, New Delhi- 110001 Dated: 176 March2026

Case No. AD(OD - 0312026

SETU Case ID AD/OV 00412026 INITIATION NOTIFICATION

Subject: Initiation of an anti-dumping inyestigation concerning imports of ooEthyl

Chloroformates (ECF) in any concentration" originating in or exported from China PR. F. No. 6/03/2026-DGTR: Having regard to the Customs Tariff Act, 1975 as amended from time to time (hereinafter referred to as the "Act") and the Customs Tanff (Identification, Assessment and Collection of Anti-dumping duty on Dumped Articles for Determination of Injury) Rules, 1995 as amended from time to time (hereinafter referred to as the "Rules" or the "Anti-dumping Rules"), M/s. Paushak Limited (hereinafter also referred to as the "applicant" ) has filed an application before the Designated Authority (hereinafter referred to as the "Authority"), for initiation ofan anti-dumping investigation conceming imports of"Ethyl Chloroformate" (hereinafter referred to as "subject goods" or "product under consideration" or "PUC"). The present Application sought anti-dumping investigation concerning imports of the subject goods originating in or exported from China PR and Hong Kong. However, upon examination of the data received from the DG Systems, no presence of imports of the subject goods have been observed from Hong Kong during both Injury Period and POI. Hence, the Authority has considered China PR as the subject country in the present investigation. The applicant has alleged that dumped imports of the subject goods from the subject country are causing material injury and has requested the imposition of anti-dumping duty on the imports of the subject goods from the subject country. A.

mports of the subject goods from the subject country are causing material injury and has requested the imposition of anti-dumping duty on the imports of the subject goods from the subject country. A. PRODUCTUNDERCONSIDERATION The product under consideration in the present application is "Ethyl Chloroformate (ECF) in any concentration. " Page 1 of 8 2 3 4

5 ECF is an organic chemical compound. It is a colourless, volatile liquid with a pungent odour. Ethyl Chloroformate is widely used as an intermediate in organic chemical intermediate in the pharmaceutical and agrochemical industries. It belongs to the class of chloroformates and contains both an ester and a chloro functional group, making it highly reactive. Due to its corrosive and toxic nature, ethyl chloroformate is classified as hazardous, posing risks through inhalation, ingestion, and skin contact. Unit of measurement The prescribed unit of measurement for the product under consideration is Mekic Tons (MT) or Kilogram (Kg). The Applicant has informed that the product under consideration (PUC) does not have a dedicated HS code. The product is presently imported under various tariffheadings under Chapter 29 of the Customs TariffAct specially under the sub-headings 2915 12 90. The applicant has also alleged that the product under consideration is also imported under the code2915 l3 00, and 2915 90 99. However, the customs classification is indicative only and not binding on the scope of the product under consideration. The Applicant has not proposed any product control numbers (PCN) methodology in its application.

oms classification is indicative only and not binding on the scope of the product under consideration. The Applicant has not proposed any product control numbers (PCN) methodology in its application. The parties to the present investigation may provide their comments on the scope ofPUC and propose product control numbers (PCN) methodology, if any, within 15 days of circulation of the receipt of intimation of initiation of the investigation. B. LIKEARTICLE The applicant has stated that there are no significant differences in the article produced by the applicant and exported from the subject country. The article produced by the applicant and that imported from the subject country is comparable in terms of physical and chemical characteristics, manufacturing process and technology, functions and uses, product specifications, pricing, distribution and marketing, and tariff classification ofthe subject goods. The subject goods and the article manufactured by the applicant are technically and commercially substitutable. The applicant has claimed that the consumers of the product under consideration are using the subject goods and the article manufactured by the applicant interchangeably. Thus, for the purposes of initiation of the present investigation, the article produced by the applicant has been prima .facie considered as like article to the product being imported from the subject country. C. SUBJECTCOUNTRY 6 7 8 9 10. The subject country in the present investigation is China PR. Page 2 ol 8 Tariff classification

as like article to the product being imported from the subject country. C. SUBJECTCOUNTRY 6 7 8 9 10. The subject country in the present investigation is China PR. Page 2 ol 8 Tariff classification

D. PERIOD OF INVESTIGATION (POI) l1 The Authority has considered the period from l" October 2024 to 30th September 2025 (12 months) as the period ofinvestigation (POI) for the present investigation (hereinafter referred to as "POI"). The injury investigation period shall cover the period l* Apil2022 to 3l'tMarch 2023, l$April 2023 to 3l"t March2024, l$ April 2024 1o31'tMarch2025 and the period of investigation. E. DOMESTIC INDUSTRYAND STANDING 12. The application has been filed by M/s. Paushak Limited. The applicant has submitted that they have not imported the subject goods from the subject country and is not related to producers and exporters from the subject country. The applicant has submitted that they are the sole domestic producer and accounts for 100% of the total production of the subject goods in India. Therefore, the applicant constitutes domestic industry within the meaning of Rule 2(b) of the ADD Rules, 1995 and the application satisfies the requirements of standing under Rule 5(3) ofthe AD Rules, 1995 F. BASISOFALLEGEDDUMPING a) Normal Vslue for China 13.

the meaning of Rule 2(b) of the ADD Rules, 1995 and the application satisfies the requirements of standing under Rule 5(3) ofthe AD Rules, 1995 F. BASISOFALLEGEDDUMPING a) Normal Vslue for China 13. The applicant has claimed that China PR should be treated as a non-market economy and the normal value should be determined in terms of Rule- 7 of Annexure I of the Rules. The applicant has cited Para 8(2) of Annexure I of the Rules and has stated that the Chinese producers should be directed to demonsffate that market economy conditions prevail in the industry producing the subject goods in terms of Para 8(3) ofAnnexure I of the Rules. The applicant has claimed that for China PR, normal value should be determined in accordance withParuT and 8 of Annexure I of the Rules. 14. The applicant has submitted that efforts were made to determine normal value on thebasis ofprice or constructed value in a market economy third country. However, the applicant could not get reliable information regarding the information on price or cost in market economy in a third country. Therefore, the normal value has been constructed based on cost of production of the applicant, duly adjusted for selling, general and administrative expenses, with reasonable profit. The same has been considered for the purpose of initiation of the investigation. b) Export Price 15.

applicant, duly adjusted for selling, general and administrative expenses, with reasonable profit. The same has been considered for the purpose of initiation of the investigation. b) Export Price 15. The export price ofthe product under consideration has been determined by considering the CIF price of the product under consideration as reported in DG System data. Adjustments have been made for ocean freight, inland fieight, marine insurance, handling charges, port expenses and dealers commission, bank charges. Page 3 of 8

c) Dumping Margin 16. The normal value and the export price have been compared at ex-factory level, which prima facie shows that the dumping margin is above the de-minimis level and is significant with respect to the product under consideration exported from the subject country. Thus, there is prima facie evidence that the product under consideration from the subject country is being dumped in the Indian market by the exporters fiom the subject country. G. EVIDENCE OFINJURYAND CAUSALLINK 17. The applicant has provided prima.facie evidence with respect to the injury suffered by the domestic industry due to the dumped imports. The volume of the subject imports from the subject country has increased in both absolute as well as relative terms. There is evidence ofprice suppression and depression due to imports. The subject imports have had an adverse impact on the profitability parameters of the domestic industry. 18.

ll as relative terms. There is evidence ofprice suppression and depression due to imports. The subject imports have had an adverse impact on the profitability parameters of the domestic industry. 18. From the foregoing, the Authority prima facie finds suflicient evidence of dumping of the subject goods originating in or exported from the subject country injury to the domestic industry and causal link between the alleged dumping and injury exist to justi$ initiation of an anti-dumping investigation in terms of Rule 5 of the Rules, to determine the existence, degree, and effect of alleged dumping and to recommend the amount of anti-dumping duty, which if levied, would be adequate to remove injury to the domestic industry. H. INITIATIONOFANTI-DUMPINGINVESTIGATION I. PROCEDURE 20. The provisions stipulated in Rule 6 of the Anti-Dumping Rules shall be followed in this investigation. Page 4 of I 19. On the basis of the duly substantiated written application submitted by the applicant and having reached satisfaction based on the priz a facie evidence submitted by the applicant conceming the dumping of the product under consideration originating in or exported from the subject country the consequential injury to the domestic industry as a result of the alleged dumping of the product under consideration and the causal link between such injury and the dumped imports, and in accordance with Section 9,A' of the Act read with Rule 5 of the AD Rules, the Authority, hereby, initiates an anti-dumping investigation to

sal link between such injury and the dumped imports, and in accordance with Section 9,A' of the Act read with Rule 5 of the AD Rules, the Authority, hereby, initiates an anti-dumping investigation to determine the existence, degree, and effect of the dumping with respect to the product under consideration originating in or exported from the subject country and to recommend the appropriate amount of anti-dumping duty, which if levied, would be adequate to remove the injury to the domestic industry.

J. SUBMISSIONOFINFORMATION 21. All the interested parties are required to register themselves on SETU Portal (https://setu.dgtr.gov.in). All communications and submissions from the interested parties shall be uploaded on the SETU portal under their registered name and corresponding SETU Case ID no. AD/OI/00412026.I1 should be enswed that the narrative part of the submission is in searchable PDF/MS-Word format and data files are in MS-Excel format. 22. The known producers/exporters in subject country, the govemment of subject country through its Embassy in India, and the importers and users in India who are known to be associated with the product under consideration are being informed separately to enable them to file all the relevant information within the time limits mentioned in this initiation notification. All such information must be filed in the form and manner as prescribed by this initiation notification, the Rules, and the applicable trade notices issued by the Authority. 23.

tiation notification. All such information must be filed in the form and manner as prescribed by this initiation notification, the Rules, and the applicable trade notices issued by the Authority. 23. Any other interested party may also make a submission relevant to the present investigation in the form and manner as prescribed by this initiation notification, the Rules, and the applicable trade notices issued by the Authority within the time limits mentioned in this initiation notification. 24. Any party making any confidential submission before the Authority is required to make a non-confidential version of the same available to the other interested parties. 25. The interested parties are further advised to keep a regular watch on the offrcial website of the Directorate General of Trade Remedies at www.dgtr.gov.in and SETU portal (https://setu.dgtr.gov.in) for any updated information with respect to this investigation. Interested parties are directed to regularly visit the website of DGTR (https://w"ww. dgtr. gov. in ) to stay apprised with the further developments in the subject investigation and remain informed regarding notices that may be issued from time to time regarding questionnaire formats, PCN methodology, PCN discussion/meeting schedule, notice of oral hearing, corrigendum, amendment notifications, and other such information. K. TIME LIMIT 26. Any information relating to the present investigation should be uploaded on the SETU portal (h@s://selu.dgtr.gov.in) under their registered name and corresponding case ID - ADIOU 00412026. 2'7 .

26. Any information relating to the present investigation should be uploaded on the SETU portal (h@s://selu.dgtr.gov.in) under their registered name and corresponding case ID - ADIOU 00412026. 2'7 . Both versions of each submission, the confidential version (CV) and the non-confidential version (NCV) must be uploaded in the respective designated columns within 37 days from the date on which the nonconfidential version of the application filed by the domestic industry would be circulated by the Authority or transmitted to the appropriate Page 5 of 8

diplomatic representative of the exporting country as per Rule 6(4) of the AD Rules, 1995. If no information is received within the stipulated time limit or the information received is incomplete, the Authority may record its findings based on the facts available on record and in accordance with the AD Rules, 1995. 28. All the interested parties are hereby advised to intimate their interest (including the nature of interest) in the instant matter and file their questionnaire responses within the above time limit as stipulated in this notification through SETU portal only. 29. The l5-day period to file comments on the scope of the PUC/ PCN Methodology shatt run concurrently with the time limit mentioned in pa,ra 27 above of this Initiation Notification. 30. Extension due to Modification of PUC/PCN: An extension of time by l5 days shall be granted if the Authority, through a subsequent notice, modifies the PUC, and PCN that was not previously proposed or is different from the initiation notification.

tension of time by l5 days shall be granted if the Authority, through a subsequent notice, modifies the PUC, and PCN that was not previously proposed or is different from the initiation notification. This extenston of 15 days shall be granted from date of such notification of modified PUC and PCN. Extension oftime by 15 days stated in this paragraph is not applicable in instances where there is no change in the PUC, and PCN methodology after initiation of investigation. Requests for a further extension of time, beyond the 15-day extension (if granted), will ordinarily not be considered except in case ofexceptional circumstances, in line with the Rule 6(4) of the AD Rules. L, ST]BMISSION OF INFORMATION ON CONFIDENTIAL BASIS 32. Where any party to the present investigation makes confidential submissions or provides information on a confidential basis before the Authoriry such party is required to simultaneously submit a non-confidential version of such information in terms of Rule 7(2) ofthe Rules and in accordance with the relevant trade notices issued by the Authority in this regard. Failure to adhere to the above may lead to rejection of the response/submissions. 33. The parties making any submission (including Appendices/ Annexures attached thereto), before the Authority including questionnaire responses, are required to file confidential and non-confi dential versions separately. 34. Such submissions must be clearly marked as 'confidential'or'non-confidential'at the top of each page.

naire responses, are required to file confidential and non-confi dential versions separately. 34. Such submissions must be clearly marked as 'confidential'or'non-confidential'at the top of each page. Any submission that has been made to the Authority without such markings shall be treated as 'non-conhdential' information by the Authority, and the Authority shall be at liberty to allow other interested parties to inspect such submissions. Page 6 of I 31. Any request for an extension must be submitted by the concemed parties through the SETU portal at least one day before the original deadline specified above. Requests submitted after this time will not be considered.

35. The confidential version shall contain all information which is, by nature, confidential, and/or other information, which the supplier ofsuch information claims as confidential. For the information which is claimed to be confidential by nature, or the information on which confidentiality is claimed because ofother reasons, t}re supplier ofthe information is required to provide a good cause statement along with the supplied information as to why such information cannot be disclosed.
36. The non-confidential version ofthe information filed by the interested parties is required to be a replica of the confidential version with the confidential information preferably indexed or blanked out (where indexation is not possible) and such information must be appropriately and adequately summarized depending upon the information on which confidentiality is claimed.

ably indexed or blanked out (where indexation is not possible) and such information must be appropriately and adequately summarized depending upon the information on which confidentiality is claimed. The non-confidential summary must be in sufficient detail to permit a reasonable understanding of the substance of the information fumished on a confidential basis. However, in exceptional circumstances, the party submitting the confidential information may indicate that such information is not susceptible to summary and a statement ofreasons containing a sufficient and adequate explanation as to why such summarization is not possible, must be provided to the satisfaction of the Authority. 37. The interested parties can offer their comments on the issues of confidentiality within 7 days from the date of circulation of the non-confidential version of the documents. 38. The Authority may accept or reject the request for conhdentiality on examination ofthe nature of the information submitted. If the Authority is satisfied that the request for confidentiality is not warranted or if the supplier of the information is either unwilling to make the information public or to authorize its disclosure in generalized or summary form, it may disregard such information. 39. Any submission made without a meaningful non-confidential version thereof or a sufficient and adequate cause statement in terms of Rule 7 of the Rules, and appropriate trade notices issued by the Authority, on the confidentiality claim shall not be taken on record by the Authority. M, INSPECTION OF PUBLIC FILE 40.

nt in terms of Rule 7 of the Rules, and appropriate trade notices issued by the Authority, on the confidentiality claim shall not be taken on record by the Authority. M, INSPECTION OF PUBLIC FILE 40. All non-confidential versions of submissions made by any interested party will be accessible to other interested parties through their respective login on the SETU portal. N. NON-COOPERATION 41. In case any interested party refuses access to and otherwise does not provide necessary information within a reasonable period or within the time stipulated by the Authority in PageT of 8

this initiation notlfication, or significantly impedes the investigation, the Authority may declare such interested party as non-cooperative and record its findings based on the facts available and make such recommendations to the Central Govemment as it deems fit. (Amitabh Kumar Designated Authority ) Page 8 of 8