Anti-dumping investigation concerning imports of “Methyl Chloroformates (MCF) in any concentration” originating in or ex

To be published in Part-l Section I of the Gazette oflndia Extraordinary F. No. 6/08i2026 - DGTR Govemment of India Ministry of Commerce & Industry Department of Cofilmerce Directorate General of Trade Remedies 4th Floor, Jeevan Tara Building, 5, Parliament Street, New Delhi- I 10001 Date:19.03.2026

Case No. AD(OI) - 0812026

SETU Case ID No. - ADiOIl009/2026

Subject: Initiation of an anti-dumping investigation concerning imports of "Methyl

Chloroformates (MCF) in any concentration" originating in or exported from China PR F. No. 6/08/2026 -DGTR: Having regard to the Customs Tariff Act, 1975 as amended from time to time (hereinafter referred to as the "Act") and the Customs Tariff (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, M/s Superform Chemistries Limited and UPL Limited (hereinafter also referred to as the "applicants" ) has filed an application before the Designated Authority (hereinafter referred to as the "Authority"), for initiation of an anti-dumping investigation conceming imports of "Methyl Chloroformate" (hereinafter referred to as "subject goods" or "product under consideration" or "PUC"), originating in or exported from China PR (hereinafter referred to as "subject country") The applicants have 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 ofthe subject goods from the subject country. A. PRODUCTUNDERCONSIDERATION The product under consideration in the present application is "Methyl Chloroformate (MCF) in any concentration. " MCF is an organic chemical compound. It is a colourless, volatile liquid with a pungent odour. Melhyl Chloroformate is widely used as an intermediate in organic chemical intermediates and widely finds its usage 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, Page 1 of I 2 J 4 INITIATION NOTIFICATION

) methyl chloroformate is classified as hazardous, posing risks through inhalation, ingestion, and skin contact. The prescribed unit of measurement for the product under consideration is Metric Tons (MT) or Kilogram (Kg). The applicants have informed that the product under consideration (PUC) does not have a dedicated HS code. The product is presently imported under various tariff headings under Chapter 29 ofthe Customs TariffAct specially under the sub-headings 2915 1290. The applicants have also alleged that the product under consideration is also imported under the code 2915 13 00, 2915 90 99 and 2933 39 90. However, the customs classification is indicative only and not binding on the scope of the product under consideration. The applicants have not proposed any product control numbers (PCN) methodology in its application. The parties to the present investigation may provide their comments on the scope of PUC and propose product control numbers (PCN) methodology, if any, within 15 days ofcirculation ofthe receipt of intimation ofinitiation ofthe investigation. B. LIKEARTICLE The applicants have stated that there are no significant differences in the article produced by the applicants and exported from the subject country. The article produced by the applicants 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 tadff classification of the subject goods. The subject goods and the article manufactured by the applicants are technically and commerciatly substitutable. The applicants have claimed that the consumers of the product under consideration are using the subject goods and the article manufactured by the applicants interchangeably. Thus, for the purposes of initiation ofthe present investigation, the article produced by the applicants have been prima facie considered as like article to the product being imported lrom the subject country. C. SUBJECTCOUNTRY 6 7 8 9. The subject country in the present investigation is China PR. Unit of measurement Tariff classification Page 2 of I

D. PERTOD OF TNVESTTGATTON (POr) 10. The Authority has considered the period from I't October 2024 to 30th September 2025 (12 months) as the period of investigation (POI) for the present investigation (hereinafter refened to as "POI"). The injury investigation period shall cover the period 1il April 2022 to3l'f March2023, 1'tApril 2023to31stMarch2024,1'tApril 2024to31'tMarch2025 and the period of investigation. E. DOMESTICINDUSTRYANDSTANDING 11. The application has been fi1ed by N{/s. Paushak Limited, UPL Limited and Superform Chemistries Limited. The applicants have submitted that they have not imported the subject goods from the subject county and is not related to producers and exporters from the subject country. The applicants have submitted that they are the only domestic producer and accounts for 100% oithe total production ofthe subject goods in India. 12. The applicants have submitted that UPL Limited commenced the production of PUC in the month of h:ne 2024 at Dahej Plant and from June 2024 to November 2024, UPL produced the subject goods. December 2024 onwards PUC was produced by Superform Chemistries Limited pursuant to its transfer of speciality chemicals business by UPL Limited to Superform Chemistries Limited. Paushak Limited produced the PUC throughout the injury period and POI. 13. The applicants constitute 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) of the AD Rules, 1995 F. BASIS OFALLEGED DUMPING a) Normal Value for China 15. The applicants have submitted that efforts were made to determine normal value on the basis of price or constructed value in a market economy third country. However, the applicants 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 Page 3 of 8 14. The applicants have 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 applicants have cited Para 8(2) of Annexure I of the Rules and has stated that the Chinese producers should be directed to demonstrate that market economy conditions prevail in the industry producing the subject goods in terms of Para 8(3) ofAnnexure I of the Rules. The applicants have claimed that for China PR, normal value should be determined in accordance with Para 7 and 8 ofAnnexure I ofthe Rules.

administrative expenses, with reasonable profit. The same has been considered for the purpose of initiation ofthe investigation. b) Export Price 16. 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 freight, marine insurance, handling charges, port expenses, dealers commission and bank charges. c) Dumping Margin 17. 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 primo .facie evidence that the product under consideration from the subject country is being dumped in the Indian market by the exporters from the subject country. G. EVIDENCE OF INJURY AND CAUSAL LINK 18. The applicants have provided prl ma 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 during the injury period. There is evidence of price suppression and price depression due to imports. The subject imports have had an adverse impact on the prof,rtability parameters of the domestic industry. 19. From the foregoing, the Authority prima facie finds sufficient 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 justiff 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 20. On the basis of the duly substantiated written application submitted by the applicants and having reached satisfaction based onlhe primafacie evidence submitted by the applicants 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 ofthe product under consideration and the causal link between such injury and the dumped imports, and in accordance with Section 9A of the Act read with Page 4 of 8

Rule 5 ofthe 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. I. PROCEDURE 21. The provisions stipulated in Rule 6 of the Anti-Dumping Rules shall be followed in this investigation. J. SUBMISSIONOFINFORMATION 22. All the interested parties are required to register themselves on SETU Portal (htps://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 - AD/OI/00912026. lt should be ensured that the nanative part of the submission is in searchable PDF/MS-Word format and data files are in MS-Excel format. 23. The known producers/exporters in the subject country, the govemment ofsubject 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. 24. 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. 25. Any party making any confidential submission before the Authority is required to make a non-confidential version ofthe same available to the other interested parties. 26. The interested parties are further advised to keep a regular watch on the official website of the Directorate General of Trade Remedies at www.dgtr.gov.in and SETU portal (https://seru.dgtr.gov.in) for any updated information with respect to this investigation. Interested parties ^re directed to regularly visit the website of DGTR (https:i/www.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. Page 5 of I

K. TIMELIMIT 27. Any information relating to the present investigation should be uploaded on the SETU portal (https://setu.dgtr.gov.in) under their registered name and conesponding SETU Case ID AD/OII 00912026. 28. 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 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. 29. 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. 30. The l5-day period to file comments on the scope of the PUC/ PCN Methodology shall run concurrently with the time limit mentioned in para 28 above of this Initiation Notification. 31 . Extension due to Modification of PUC/PCN: An extension of time by 15 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 extension of 15 days shall be granted from date of such notihcation of modified PUC and PCN. Extension of time 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), witl ordinarily not be considered except in case ofexceptional circumstances, in line with the Rule 6(4) of the AD Rules. 32. 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. L, ST]BMISSION OF INFORMATION ON CONFIDENTIAL BASIS 33. Where any party to the present investigation makes confidential submissions or provides information on a confidential basis before the Authority, 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 Page 6 of I

in this regard. Failure to adhere to the above may lead to rejection of the response/submissions. 34. The parties making any submission (including Appendices/ Annexures attached thereto), before the Authority including questionnaire responses, are required to file confidential and non-confidential versions separately. 35. 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-confidential' information by the Authority, and the Authority shall be at liberty to allow other interested parties to inspect such submissions. 36. 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, the supplier ofthe information is required to provide a good cause statement along with the supplied information as to why such information cannot be disclosed. 37 . The non-confidential version of the 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. 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. 38. The interested parties can offer their commsnts on the issues of confidentiality within 7 days from the date ofcirculation of the non-confidential version of the documents. 39. The Authority may accept or reject the request for confidentiality on examination of the 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. 40. Any submission made without a meaningful non-confidential version thereof or a suffrcient 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. Page 7 of 8

M. INSPECTION OFPUBLIC FILE 41. All non-confidential versions of submissions made by any interested party witl be accessible to other interested parties through their respective login on the SETU portal. N. NON-COOPERATION 42. 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 tn this initiation notification, 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 Government as it deems fit. hfi-* (Amitabh Kumar) Designated Authority Page 8 of 8