Initiation of anti-dumping investigation concerning imports of Stainless-Steel Seamless Tubes & Pipes originating in or

Case No. AD (MTR)-03/2025

Government of India Department of Commerce Ministry of Commerce & Industry Directorate General of Trade Remedies FINAL FINDINGS Mid-Term Review limited to the product scope of anti-dumping duty imposed on imports of “Stainless-Steel Seamless Tubes and Pipes” originating in or exported from People’s Republic of China (“China PR”)

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Table of Contents A. BACKGROUND OF THE CASE ..................................................................................... 3 B. PROCEDURE..................................................................................................................... 4 C. PRODUCT UNDER CONSIDERATION AND LIKE ARTICLE................................ 5 C.1 Submissions made by the applicant ............................................................................ 5 C.2 Submissions made by the domestic industry and Indian Stainless Seamless Pipes Manufacturers Association ................................................................................................ 7 C.3 Examination by the Authority ..................................................................................... 9 D. POST DISCLOSURE COMMENTS ............................................................................. 13 D.1 Submissions by the applicant ....................................................................................

............................................................................. 13 D.1 Submissions by the applicant .................................................................................... 13 D.2 Submissions made by the domestic industry and Indian Stainless Seamless Pipes Manufacturers Association .............................................................................................. 15 D.3 Examination by the Authority ................................................................................... 15 E. CONCLUSION AND RECOMMENDATIONS ........................................................... 17 F. FURTHER PROCURE ………………………………………………………………. 18

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To be published in Part-1 section 1 of Gazette of India Extraordinary

F. No. 7/13/2025-DGTR Government of India Ministry of Commerce & Industry Department of Commerce (Directorate General of Trade Remedies) 4th Floor, Jeevan Tara Building, 5, Parliament Street, New Delhi -110001

Dated: 24.06.2026 FINAL FINDINGS

Subject: Final Findings in the Mid-Term Review limited to the product scope of

anti-dumping duty imposed on Stainless-Steel Seamless Tubes and Pipes originating in or exported from China PR.

Having regard to the Customs Tariff Act, 1975 as amended from time to time and the Customs Tariff (Identification, Assessment and Collection of Anti-dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995 thereof, as amended from time to time (“AD Rules, 1995” or the “AD Rules” or the “Rules”).

BACKGROUND OF THE CASE

M/s Vedanta Limited (hereinafter also referred to as the “Petitioner” or “Applicant”) has filed an application before the Designated Authority (hereinafter also referred to as the “Authority”) in accordance with the Customs Tariff Act, 1975 as amended from time to time (hereinafter also referred to as the “Act”) and the Customs Tariff (identification, Assessment and Collection of Anti-dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995 as amended from time to time (hereinafter also referred to as the “Rules”) for initiation of mid-term review investigation limited to examine the scope of product under consideration as defined vide Notification No. 6/13/2021-DGTR dated 23.09.2022, to clarify that Casting & Tubing with premium threading (known as OCTG in market parlance) manufactured by using "Seal-Lock XD" process patented by HESPL (Hunting Energy Services Pte.

d 23.09.2022, to clarify that Casting & Tubing with premium threading (known as OCTG in market parlance) manufactured by using "Seal-Lock XD" process patented by HESPL (Hunting Energy Services Pte. Ltd.) originating in or exported from China PR (hereinafter also referred to as the “subject country”) is not covered within the scope of the product under consideration.

And whereas vide Notification No. 6/13/2021-DGTR dated 23.09.2022 recommended imposition of definitive anti-dumping duty on imports of “Stainless-Steel Seamless Tubes and Pipes with diameter up to and including 6 NPS, or comparable thereof in other 7/13/2025-DGTR I/131696/2026

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unit of measurement, whether manufactured using hot extrusion process or hot piercing process and whether sold as hot finished or cold finished pipes and tubes, including subject goods imported in the form of defectives, non-prime or secondary grades” (hereinafter also referred to as the “subject goods”) originating in or exported from China PR (hereinafter also referred to as the “subject country”) and the definitive anti-dumping duty was imposed by the Central Government vide Notification No. 31/2022-customs (ADD) dated 20.12.2022.

The Authority, on the basis of sufficient prima facie evidence submitted by the applicant, issued a public notice vide Notification No.

tification No. 31/2022-customs (ADD) dated 20.12.2022.

The Authority, on the basis of sufficient prima facie evidence submitted by the applicant, issued a public notice vide Notification No. 7/13/2025-DGTR dated 26th June 2025, published in the Gazette of India, initiating a mid-term review of anti-dumping duty imposed on imports of Stainless-Steel Seamless Tubes and Pipes originating in or exported from the subject country, limited to re-determination / clarification on product scope, in accordance with Section 9A of the Customs Tariff Act read with Rule 23 of the AD Rules, 1995.

PROCEDURE

The following procedure has been followed with regard to this investigation:

a. The Authority issued a public notice dated 26th June, 2025, published in the Gazette of India Extraordinary, initiating the anti-dumping investigation concerning imports of the subject goods from the subject country. b. The Authority informed the Embassy of China PR in India about the initiation of the subject investigation requesting them to inform concerned exporters/producers about the same. c. The Authority made available copies of the non-confidential petition to the domestic industry in the original investigation. d. The Authority also circulated copy of the non-confidential version of the application filed by the applicant with the known producers/exporters, known importers/users and to the Embassy of the subject country in India in accordance with Rule 6(3) of the AD Rules, 1995. e.

plication filed by the applicant with the known producers/exporters, known importers/users and to the Embassy of the subject country in India in accordance with Rule 6(3) of the AD Rules, 1995. e. Since the petition is for a limited purpose of exclusion of a certain type of product under consideration, the Authority is not required to evaluate the quantum of dumping and injury, therefore, stipulation of POI is not required. f. The Authority examined the information furnished by the applicant and the domestic industry to the extent possible to verify the claims made by the applicant. Further information was sought from the applicant and the domestic industry to the extent deemed necessary. Verification of the data and claims of the applicant was conducted to the extent considered necessary for the purpose of the investigation. g. Verification of data and claims of the domestic industry was also carried out to the extent considered necessary for the purpose of the investigation. 7/13/2025-DGTR I/131696/2026

estigation. g. Verification of data and claims of the domestic industry was also carried out to the extent considered necessary for the purpose of the investigation. 7/13/2025-DGTR I/131696/2026

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h. In accordance with Rule 6(6) of the Rules, the Authority also provided opportunity to the interested parties to present their views orally in an oral hearing held on 11th August, 2025. The parties, which presented their views in the oral hearing, were requested to file written submissions of their views expressed orally, followed by rejoinder submissions. i. In accordance with the Rules, the Authority disclosed the essential facts of the case that would form the basis of its findings in the form of a disclosure statement on 14th November 2025 and the interested parties were allowed time up to 21st November 2025 to comment on the same. The comments of the interested parties, to the extent relevant, have been considered by the Authority and have been addressed in this finding. j. Due to change in the Designated Authority, a fresh oral hearing was conducted on 10th March 2026. The parties, which presented their views in the oral hearing were requested to file written submissions of their views expressed orally, followed by rejoinder submissions.
k. The essential facts of the investigation gathered by the Authority during the present investigation and analysed by the Authority were disclosed to the interested parties in order to enable them to offer their comments on these facts. l.

gathered by the Authority during the present investigation and analysed by the Authority were disclosed to the interested parties in order to enable them to offer their comments on these facts. l. ‘***’ in the final findings represents information furnished by an interested party on confidential basis and so considered by the Authority under Rule 7 of AD Rules, 1995.

PRODUCT UNDER CONSIDERATION AND LIKE ARTICLE

C.1. Submissions made by the applicant

The submissions made by the Applicant are as follows:

i. The original investigation covered only seamless stainless pipes and tubes made by hot extrusion or piercing and not OCTG pipes made with the SEAL Lock XD (SLXD) process. ii. Threading is a critical process as it increases the sealing ability and resistance to high pressure and corrosion faced in drilling. Due to this, the product concerned is imported as per specific requirement for cut size and dimensions etc. iii. The product concerned differ from products covered by the original investigation in terms of price, physical characteristics, manufacturing process and technology, functions, end-uses and technical specifications, and are neither technically nor commercially substitutable from the consumer’s perspective. iv. Commercial orders to Jindal SAW Limited (JSL) were placed post the period of investigation in 2022. During the period of investigation of the original anti- 7/13/2025-DGTR I/131696/2026

tive. iv. Commercial orders to Jindal SAW Limited (JSL) were placed post the period of investigation in 2022. During the period of investigation of the original anti- 7/13/2025-DGTR I/131696/2026

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dumping investigation, there was no domestic manufacturer of the product concerned. v. The inclusion of OCTG, which was not produced domestically during the period of investigation, to the product scope would create a monopoly for Jindal SAW Limited which is the only local producer. vi. Jindal SAW Limited did not have the license or API Certification during the period of investigation of the original investigation to produce OCTG with SLXD. The responses from Chandan Steel and Tubacex Prakash show that OCTG was not offered domestically until 2022 and differs from stainless steel seamless pipes and tubes. vii. There is no proven commercial availability of the product during 2017 to 2021. The only domestic licence for the Seal-Lock threading process was obtained in March–April 2022, that is, after the period of investigation of the original investigation. Thus, the product could not have formed part of the original product scope. This shows that the domestic producers received license post POI which shows changed circumstance.
viii. Commercial records submitted by JSW only show indexed values and lack proof of production for the period before 2022.

c producers received license post POI which shows changed circumstance.
viii. Commercial records submitted by JSW only show indexed values and lack proof of production for the period before 2022. Further, the production data filed by JSW pertains to casing and tubing of steel tubes and pipes, not specifically to casing and tubing with premium-threading OCTG using Seal-Lock XD process. ix. Domestic production and sales of premium-threaded products by Jindal was 100 MT in 2020-21, 85 MT in 2021-22 and 29 MT in 2022-23. Further, the findings in the original investigation shows that there is no data for the previous years, 2017– 2020. Thus, the segment was commercially nascent and absent from the original investigation. The product concerned was not commercially ready or technically interchangeable with the imported product, and under the CESTAT decision in Oxo Alcohols Industries’ Association v. Designated Authority, the non-interchangeable product cannot be treated as dumped product. x. There are scale constraints and only limited supply of the product concerned by Jindal Saw Limited. There is a need for commercial supply of the product in order for inclusion of the same in the scope of the product under consideration.
xi. Jindal Saw Limited has not applied for the global tender floated by Vedanta in 2022 which shows supply constraints.
xii.

clusion of the same in the scope of the product under consideration.
xi. Jindal Saw Limited has not applied for the global tender floated by Vedanta in 2022 which shows supply constraints.
xii. Paragraph 128 of the Final Findings in the original investigation records the landing value of the subject goods at ₹ 2.3 lakh per MT to ₹ 2.84 lakh per MT, whereas the domestic industry stated that the product concerned is priced at ₹ 8 lakh per MT to ₹ 9 lakh per MT. Imports at high price shows product is not dumped and duty cannot be imposed on them. xiii. Even after first domestic production ONGC, other buyers sought exemptions for procuring the product concerned due to performance, technical and patent licensing issues. This highlights the supply constraints in India. 7/13/2025-DGTR I/131696/2026

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xiv. The United States of America separately define and impose duties on OCTG pipes and standard seamless pipes. xv. The SLXD process fundamentally alters the functional capability of the tube. OCTG pipes were not produced during the original period of investigation. xvi. Jindal SAW Limited secured a contract to manufacture OCTG pipes post the period of investigation. xvii. The claim that ONGC has been a regular and consistent buyer from Indian producers is false. ONGC and OIL procurement records before and during the period of investigation show imports citing non-availability of the required product from domestic sources. xviii. The DGTR recommends anti-dumping duties if there exists dumping and injury to the domestic industry.

tion show imports citing non-availability of the required product from domestic sources. xviii. The DGTR recommends anti-dumping duties if there exists dumping and injury to the domestic industry. Since the product concerned was not produced in India during the period of investigation no duty should be imposed on the same. xix. The inclusion of OCTG within the scope would allow for monopoly by the single domestic producer, this is not the intent of trade remedial measures. xx. The HS classification for both products is different. The HS Code for subject goods covered by the original investigation is HS 7304 11, pipe of a kind used for oil and gas pipelines”, while the product concerned falls under HS 7304 22, “casing, tubing and drill pipe, of a kind used in drilling for oil or gas”.
xxi. Contrary to the submissions of the domestic industry, commercial importers of the product concerned include oil field operators which are large and regulated entities and there are only remote possibility of wrongful declaration and circumvention of duties by them.

C.2. Submissions made by the domestic industry and Indian Stainless Seamless Pipes Manufacturers Association

The submissions made by the domestic industry and Indian Stainless Seamless Pipes Manufacturers Association are as follows:

i. The product concerned is a stainless-steel pipe and tube and hence, covered under the scope of the product under consideration.
ii. The definition of the product under consideration does not distinguish between threaded and non-threaded product.

tube and hence, covered under the scope of the product under consideration.
ii. The definition of the product under consideration does not distinguish between threaded and non-threaded product. Thus, the scope of the product under consideration is clear and includes both threaded and no threaded products.
iii. The definition of the product under consideration as per the initiation notification in the original investigation shows that the product is used to transfer liquids and gases, thus, the product concerned is included within the scope of the product under consideration.
iv. Jindal Saw Limited is producing and selling the product concerned since 2020-21, that is, the period of investigation of the original investigation. Further, Jindal Saw Limited has produced and sold the subject goods continuously till 2025-26.
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v. Jindal Saw Limited received license from Hunting PLC to undertake Seal Lock XD threading process in 2019, that is prior to the period of investigation of the original investigation.
vi. The product concerned is not mass produced and inventories of the same are not maintained. The product has been produced by Jindal Saw Limited based on the orders received.
vii. The applicant has failed to demonstrate that the demand of the product concerned was higher in the past as compared to the supply by the domestic industry.
viii. ONGC is the largest consumer of the product concerned and has continuously bought the product concerned from the Indian industry.

the past as compared to the supply by the domestic industry.
viii. ONGC is the largest consumer of the product concerned and has continuously bought the product concerned from the Indian industry. ONGC has not imported the product concerned at all.
ix. The Indian industry has also sold to Oil India Limited.
x. The brochure issued by the domestic industry shows that the product is being offered in India.
xi. The domestic industry has offered the product concerned to the applicant as well. However, the applicant has not replied to the offer made by Jindal Saw Limited and instead opted to import the said product from the subject country.
xii. Even in the present period, Jindal Saw Limited holds purchase order for the product concerned.
xiii. During the oral hearing, Vedanta had relied upon certain minutes of the meeting but failed to share the same with the domestic industry.
xiv. Seal Lock XD is not a production process for manufacturing of pipes and is merely a threading process. Even OCTG pipes are manufactured using hot extrusion or hot piercing process; and hence, there is no difference in the basic production process of the product concerned and the product under consideration.
xv. Threading is being done by the Indian industry also using the same process as stated by the applicant. xvi. While the applicant submitted in the oral hearing that threading is being undertaken by Jindal Saw Limited in a joint venture with Chinese entity, the same is incorrect.

ted by the applicant. xvi. While the applicant submitted in the oral hearing that threading is being undertaken by Jindal Saw Limited in a joint venture with Chinese entity, the same is incorrect. Jindal Saw Limited has a joint venture with Hunting PLC which is an American company.
xvii. Contrary to the submissions of the applicant, there are a number of products for which there is only a single producer in the country and the DGTR has recommended and MOF has imposed anti-dumping duty. Further, product concerned is only one of the grades of the product under consideration. There are multiple producers of the product under consideration in India.
xviii. Imposition of anti-dumping duty does not lead to monopoly and does not restrict imports into India, the users are free to import the product at fair prices.
xix. As opposed to the submissions of the other interested parties, there is no obligation on each Indian producer to supply each grade of the product under consideration.
xx. The applicant itself has submitted documents showing that the request filed by ONGC for exemption for procuring the product concerned was withdrawn during 7/13/2025-DGTR I/131696/2026

tion.
xx. The applicant itself has submitted documents showing that the request filed by ONGC for exemption for procuring the product concerned was withdrawn during 7/13/2025-DGTR I/131696/2026

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the meeting of the standing committee under DMI&SP Policy due to availability of domestic capacity in India. xxi. Certain minutes submitted by the applicant are for the products not made out of stainless steel but for products of carbon steel.
xxii. Contrary to the submissions by the applicant, the decision of the US investigating authority does not impact the decision of the Authority in the Indian anti-dumping investigation. There is no fixed definition of the product under consideration and the same is decided in each investigation separately.
xxiii. Since the product concerned is available in India, there is no justification to exclude the same from the scope of the product under consideration based on incremental process.
xxiv. The present is a review under Rule 23 and the Authority is not re-examining the correctness of the decision taken at the time of original investigation as the Authority has become functus officio at this stage and cannot revisit its own final findings. Since the present review is under rule 23, the Designated Authority can only examine the request on the basis of changed circumstances and whether the product is being produced in India during the present period.
xxv.

ew is under rule 23, the Designated Authority can only examine the request on the basis of changed circumstances and whether the product is being produced in India during the present period.
xxv. Request for clarification of product scope under Rule 23 is not maintainable and a product grade cannot be excluded based on clarification request under Rule 23. By filing an application under Rule 23, the applicant itself admits that the product concerned is included in the scope of the product under consideration. xxvi. The applicant has failed to show that there are any changed circumstances of lasting nature due to which there is a need for exclusion of the product concerned.
xxvii. The present application has been filed by Vedanta to seek clearance for shipment already at port. The Ministry of Steel has questioned on the necessity of imports when such product was available and being produced by the domestic producers. The Authority may seek inputs from Ministry of Steel. xxviii. Merely because the price of the product concerned is higher, the same does not establish absence of dumping.
xxix. The incidence of anti-dumping duty on the product concerned is only 1.1%.
xxx. Any exclusion in the name of product concerned is likely to lead to widespread abuse and avoidance of anti-dumping duty in force. The importers are likely to import the product under consideration under the name of product concerned.
xxxi.

ed is likely to lead to widespread abuse and avoidance of anti-dumping duty in force. The importers are likely to import the product under consideration under the name of product concerned.
xxxi. Contrary to the submissions of the applicant, the Authority had considered HS Code at 4-digit level, that is, 7304 for imposition of anti-dumping duty. Hence, the product concerned is not excluded from the scope of the product under consideration.

C.3. Examination by the Authority

The Authority considered the following scope of the product under consideration at the time of issuance of the final findings in the original investigation.
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“3. The product under consideration is stainless-steel seamless tubes and pipes with diameter up to and including 6 inches, whether manufactured using hot extrusion process or hot piercing process and whether sold as hot finished or cold finished pipes and tubes, including subject goods imported in the form of defectives, non-prime or secondary grades.
4. Stainless-steel seamless tubes and pipes are used for structural purposes and to transfer liquids and gases. The product under consideration is used in application relating to oil and gas; petrochemicals and refineries; atomic energy; power generators including nuclear and thermal power; and aerospace and defence applications. 5. The product under consideration can be manufactured using either hot extrusion process or hot piercing process, which is also known as cross roll piercer process.

ace and defence applications. 5. The product under consideration can be manufactured using either hot extrusion process or hot piercing process, which is also known as cross roll piercer process. The scope of product under consideration includes product manufactured using both processes. 6. The product under consideration is classified under Chapter 73 under tariff headings 7304. The customs classification is only indicative and is not binding on the scope of the present investigation.”

The applicant has filed an application for mid-term review of the scope of the product under consideration and has requested clarification that “Casing & Tubing with premium threading (known as OCTG in market parlance) manufactured by using Seal-Lock XD process patented by HESPL” is not included in the scope of the product under consideration. The applicant has further claimed that such product is not being manufactured by the domestic industry in India and the manufacturing process and end use of the product concerned is different form the product under consideration in the original investigation. The Authority has noted the arguments and counter arguments by all parties in the present investigation and accordingly examined the following.

The Authority notes that SEAL Lock XD which a process patented by Hunting PLC, is a process for undertaking threading on the product under consideration during the manufacturing process. Stainless steel tubes and pipes are not manufactured using the said process.

unting PLC, is a process for undertaking threading on the product under consideration during the manufacturing process. Stainless steel tubes and pipes are not manufactured using the said process. All stainless-steel tubes and pipes are manufactured using either hot extrusion process or hot piercing process. Further, this is the primary production process for making product under consideration. Thereafter, threading process is undertaken, which may be done using SEAL Lock XD process or any other process. Thus, the submission that the product concerned is itself manufactured using SEAL Lock XD process is not appropriate.

The Authority further notes that the scope of product under consideration as defined in the original investigation does not distinguish between threaded and non-threaded product. Further, the product concerned is a stainless-steel tubes and pipes manufactured 7/13/2025-DGTR I/131696/2026

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using either hot extrusion process or hot piercing process and squarely falls within the definition of the product under consideration. The applicant has not provided any evidence with regard to the fact that the definition of the product under consideration does not include the product concerned. It has not been shown by the applicant that this product was imported in the period of investigation of the original investigation. Nor it has been shown that like article has not been supplied by Indian industry.

shown by the applicant that this product was imported in the period of investigation of the original investigation. Nor it has been shown that like article has not been supplied by Indian industry. On the contrary, the domestic industry has submitted that there were no imports of this type during the POI of the original investigations.

The applicant has submitted that the domestic industry does not manufacture the said product in India and had no manufacturing of the product concerned in the period of investigation of the original investigation. However, the data on record shows that Jindal Saw Limited has produced and sold the product concerned in India continuously since 2020-21, that is the period of investigation of the original investigation.

Year
Unit Production Domestic Sales 2020-21 MT

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2020-21 Indexed 100 100 2021-22 MT

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2021-22 Indexed 85 85 2022-23 MT

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2022-23 Indexed 29 29 2023-24 MT

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2023-24 Indexed 664 664 2024-25 MT

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2024-25 Indexed 1043 1043 (Source: Submissions made by the Domestic Industry)

The domestic industry has established that it is holding technical qualifications and capabilities, as required by the applicant, to produce the product. The company also holds the license to do threading from the very same company as has been referred by the applicant, and does threading using the same process as stated by the applicant.

e product. The company also holds the license to do threading from the very same company as has been referred by the applicant, and does threading using the same process as stated by the applicant. The Authority also notes that threading is not the primary production process and is merely an incremental production process after production of pipes.

As regard the submission that there are supply constraints of the product concerned in India and only limited quantities are being supplied by Jindal Saw Limited, the Authority notes that the domestic industry has submitted that the product concerned is manufactured based on orders in hand and not manufactured and stored as inventory.

The domestic industry has submitted that there are two other consumers of the product concerned namely, Oil and Natural Gas Corporation (ONGC) and Oil India Limited 7/13/2025-DGTR I/131696/2026

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(OIL). ONGC is the largest buyer of the product concerned in India. And only one consumer, that is, Vedanta has filed the present application.

The applicant has submitted that the end application for the product concerned is different from the product under consideration in the original investigation as the same is used for oil and gas purposes. In this regard, the Authority notes that para 4 of the initiation notification of the original investigation states that the product under consideration is used for structural purposes as well as for applications relating to oil and gas.

para 4 of the initiation notification of the original investigation states that the product under consideration is used for structural purposes as well as for applications relating to oil and gas. Thus, there is no difference between the applications considered for product under consideration at the time of the original investigation and the applications listed by the applicant for the product concerned.

“4. Stainless-Steel seamless tubes and pipes are used for structural purposes and to transfer liquids and gases. The product under consideration is used in applications relating to oil and gases; petrochemicals and refineries; atomic energy; power generators including nuclear and thermal power; and aerospace and defence applications.”

With regard to the submissions that inclusion of product concerned within the scope of the product under consideration will lead to monopoly in India as there is only one producer of the product concerned in India, the Authority notes that imposition of anti- dumping duty does not lead to monopoly as it does not restrict imports into India. Anti- dumping duty only ensures that the product is being imported into India at fair prices. Further, product concerned is merely a grade of the product under consideration and there are multiple producers of the product under consideration in India. In any case, if Jindal Saw Limited engages in monopolistic practices, the applicant may reach to appropriate authorities under the relevant laws and rules.

uct under consideration in India. In any case, if Jindal Saw Limited engages in monopolistic practices, the applicant may reach to appropriate authorities under the relevant laws and rules.

As regard the submissions that ONGC and other buyers of the product concerned sought exemption for procuring the product concerned due to supply constraints in India, the Authority notes that the documents submitted by the applicant shows that such request was withdrawn by ONGC during the meeting of standing committee under DMI&SP Policy. Further, the evidence on record shows that ONGC has actually procured the product concerned from Jindal Saw Limited.

With regard to the minutes of meeting of standing committee under DMI&SP Policy dated 15th April 2024, submitted by Vedanta, the Authority notes that the discussion was held on 11-3/4" OD Size, N-80, 60 PPF Flush Joint; 7" P-110, 35 PPF for HPHT application; and 7" OD Size Q 125 35 PPF for HPHT application. The domestic industry has submitted that such products are not stainless-steel tubes and pipes but tubes and pipes which are made out of carbon steel.
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T application. The domestic industry has submitted that such products are not stainless-steel tubes and pipes but tubes and pipes which are made out of carbon steel.
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As regard the fact that the product concerned is a higher priced product than the product under consideration, the Authority notes that there are multiple grades of the product under consideration which entail a different cost and price. The Authority had formulated a PCN methodology for this purpose in the original investigation. Merely because one product grade is priced higher than average price of imports in India, does not mean that the same is not being dumped in India.

The applicant has submitted that the HS code for the product concerned at 6-digit level is different from the HS code of the product under consideration at 6-digit level. The Authority notes that the product under consideration is imported under various HS codes and for this purpose, the anti-dumping duty has been imposed at 4-digit level. The HS code for the product concerned is covered with the HS Code which entails the anti- dumping duty.

DI has also annexed licences with their written submissions which show that the licence was with them during the period of investigation. The identical product to the product being imported by Vedanta Limited is being manufactured and supplied in India as Jindal SAW Limited holds licences from Hunting PLC for threading process. A copy of this licence has also been submitted.

imported by Vedanta Limited is being manufactured and supplied in India as Jindal SAW Limited holds licences from Hunting PLC for threading process. A copy of this licence has also been submitted. In such a case, the product produced by Jindal SAW Limited is identical to the product being imported from the subject country.

In light of the examination made above and the evidence placed on record, the Authority
holds that there is no need to change the scope of the product under consideration as determined in the original investigation and the product concerned is included within the definition of the product under consideration.

D. POST DISCLOSURE COMMENTS

D.1 Submissions by the applicant

The applicant has reiterated its submissions regarding scope of product under consideration in the original investigation, end use of product concerned, manufacturing process, higher landed price of the product concerned, lack of manufacturing of product concerned during the original period of investigation, lack of technology and licenses to manufacture product concerned and difference in HS Codes. In addition, the other applicant has made the following submissions post issuance of the disclosure statement: 7/13/2025-DGTR I/131696/2026

anufacture product concerned and difference in HS Codes. In addition, the other applicant has made the following submissions post issuance of the disclosure statement: 7/13/2025-DGTR I/131696/2026

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i. Seal Lock XD is a critical process to manufacture the product concerned as threading enhances the sealing performance of the product under consideration which makes it capable to withstand high pressure in drilling operations.
ii. The product concerned cannot be replaced by regular stainless steel tubes and pipes and entire oil and gas industry relies upon product concerned for extraction. iii. While the product under consideration is used for transporting oil and gas, the product concerned is used for extraction of the same. Hence, there is difference in usage of the product concerned.
iv. The product concerned is technically non substitutable by the product under consideration due to threading process which changes the identity and characteristics of the final product.
v. The manufacturing facility for the product concerned was started by Jindal Saw Limited post September 2023.
vi. The US Authority imposed anti-dumping duty on imports of product under consideration and product concerned separately.
vii. Negligible quantity of the product concerned was imported into India during the period of investigation of the original investigation and such quantities cannot be considered to cause any injury to the domestic industry.
viii.

uct concerned was imported into India during the period of investigation of the original investigation and such quantities cannot be considered to cause any injury to the domestic industry.
viii. The observation of the Authority that the said product was not imported during the period of investigation of the original investigation shows that no injury can be inflicted by such product type on the domestic industry.
ix. Jindal Saw Limited did not participate in the global tender floated by the applicant in 2022 as it did not have capacity to manufacture the same. x. Information submitted by Jindal Saw Limited regarding supply of the said product prior to September 2023 is factually incorrect and does not correlate to the product concerned.
xi. The data provided in the disclosure statement is indexed and does not provide an idea of the quantities produced and supplied by Jindal Saw Limited and whether such quantities pertain to Seal Lock XD threading or casing and tubing in general. The trend shows declining production and sales post the period of investigation.
xii. The Authority has not analysed the production and sales of the product concerned during 2017-19 which is the actual injury period.
xiii. The Authority did not establish a causal link between the injury to the domestic industry and imports of product concerned during the original anti-dumping investigation. Accordingly, no duties can be imposed on the product concerned.
xiv.

k between the injury to the domestic industry and imports of product concerned during the original anti-dumping investigation. Accordingly, no duties can be imposed on the product concerned.
xiv. It is a consistent practice of the Authority to exclude the product not manufactured by the domestic industry from the scope of the domestic industry.
xv. The Authority may provide actual user based exemption for imports of the product concerned as done in previous investigations.
xvi. The present case is similar to the anti-dumping investigation into imports of low ash metallurgical coke where the Authority has provided exemption for imports of product type on actual user conditions.
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D.2 Submissions by the domestic industry and Indian Stainless Seamless Pipes Manufacturers Association

24. The domestic industry and Indian Stainless Seamless Pipes Manufacturers Association have made the following new submissions post issuance of the disclosure statement: a. The present is not a case for imposition of anti-dumping duty. The anti-dumping duty is already in force and the applicant has not been able to demonstrate any monopoly created by Jindal Saw Limited.
    b. The Indian industry holds license from Hunting PLC for threading and has produced and supplied the identical product in the domestic market.
    c. There is no mandatory requirement for use of the product with threading done by SEAL Lock XD process patented by Hunting PLC.

roduced and supplied the identical product in the domestic market.
c. There is no mandatory requirement for use of the product with threading done by SEAL Lock XD process patented by Hunting PLC. There are number of different brands offering threading process and the product with such threading can also be used to meet the requirements of the applicant.
d. The present application appears to have been filed by Vedanta primarily to seek clearance for a shipment of the product concerned currently held at the port as the Ministry of Steel has questioned such imports.
e. The incidence of anti-dumping duty on the product concerned is negligible which shows that the application has been filed only due to a Customs issue.
f. Any exclusion in the name of product concerned is likely to lead to widespread circumvention of the anti-dumping duty in force.

D.3 Examination by the Authority

The Authority has examined the post disclosure submissions made by the applicant and the domestic industry and notes that a number of submissions are reiterations which have already been examined suitably and addressed adequately in the relevant paras of the final findings. The issues raised in the post-disclosure comments/submissions by the interested parties and considered relevant by the Authority are examined below.

With regard to the submissions that Seal Lock XD is an essential process to manufacture the product concerned, the Authority has already noted that the product is manufactured using hot piercing or hot extrusion process.

issions that Seal Lock XD is an essential process to manufacture the product concerned, the Authority has already noted that the product is manufactured using hot piercing or hot extrusion process. Threading process is only an incremental process. Further, as per the evidence on record, the Indian industry holds licenses and has been consistently supplying the product concerned (with Seal Lock XD threading) in the domestic market. Thus, identical article is being supplied in the domestic market by the Indian industry.

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With regard to the submission that threading process changes the identity as well as use of the product, the Authority notes that since the said product is being produced and supplied by the Indian industry and the same falls within the definition of the product under consideration defined in the original investigation, change in usage based on incremental process does not justify exclusion from the scope of the product under consideration.

The applicant has submitted that manufacturing facility for the product concerned was started by Jindal Saw Limited in September 2023, that is, post the period of investigation in the original investigation. The Authority notes that Jindal Saw Limited held license from Hunting PLC for manufacturing of the product concerned during the period of investigation of the original investigation. Jindal Saw Limited manufactured and supplied the product concerned even during the period of investigation of the original investigation.

iod of investigation of the original investigation. Jindal Saw Limited manufactured and supplied the product concerned even during the period of investigation of the original investigation.

With regard to the submissions that negligible / no imports of the product concerned in the period of investigation of the original investigation shows that no injury was inflicted on the domestic industry, the Authority notes that the product concerned is only a grade of the product under consideration. The injury is examined based on the imports of the product under consideration and not grades of the product under consideration. The Authority conducted detailed PCN wise examination in the original anti-dumping investigation and held that the dumping of subject imports has caused injury to the domestic industry. Accordingly, anti-dumping duty was recommended and imposed on the imports of the product under consideration. A separate grade wise analysis of injury and causal link is not conducted in the anti-dumping investigation. Further, it is a consistent practice of the Authority that a product type not imported into India cannot be excluded from the scope of the product under consideration.

The applicant has submitted that the data provided in the disclosure statement issued is indexed. The Authority notes that such data is business proprietary information of the domestic industry and disclosure of the same would cause adverse impact on the domestic producer. Accordingly, the data has been shared on indexed basis.

ness proprietary information of the domestic industry and disclosure of the same would cause adverse impact on the domestic producer. Accordingly, the data has been shared on indexed basis.

As regard the submission that the Authority has not examined production and sales of the product concerned during 2017-2019 which was the injury period for the original investigation, the Authority notes that there is no evidence of imports of such product during this period. Therefore, the question of domestic industry having produced like article does not arise. In any case, once the Authority has found that the domestic industry has produced like article in the present period and original period of investigation, it is not relevant whether the industry was producing in another periods. The findings from the investigation show that the product was included in the product scope of the original 7/13/2025-DGTR I/131696/2026

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investigation. Further, there is no justifications for exclusion of the product based on facts as existing in the present period.

The applicant has requested for actual user based exemption for the product concerned and has submitted that the present case is similar to the anti-dumping investigation into imports of low ash metallurgical coke.

requested for actual user based exemption for the product concerned and has submitted that the present case is similar to the anti-dumping investigation into imports of low ash metallurgical coke. The Authority notes that in the anti-dumping investigation into imports of low ash metallurgical coke, the domestic industry had submitted that it does not manufacture a product type used by ferroalloy industry due to commercial considerations and accordingly agreed for exclusion of the same. However, in the present investigation, the domestic industry has manufactured and supplied the product concerned in the Indian market. Further, the applicant itself has acknowledged that Jindal Saw Limited has production facilities to manufacture the product concerned and has a joint venture with Hunting Plc. In such a case, an exclusion based on actual user condition is not justified in the present investigation.

With regard to the submission that exclusion of the product concerned will lead to circumvention of anti-dumping duty in force, the Authority notes that since the product concerned has not been excluded from the scope of the product under consideration, there can be no concerns on circumvention of duties.

E. CONCLUSION AND RECOMMENDATIONS

After examining the submissions made by all the applicant and the domestic industry and issues raised therein; and considering the facts available on record, the Authority concludes that:

i.

After examining the submissions made by all the applicant and the domestic industry and issues raised therein; and considering the facts available on record, the Authority concludes that:

i. The scope of the product under consideration defined in the original investigation does not distinguish between threaded and non-threaded product.
ii. The product concerned is manufactured using hot piercing or hot extrusion process, and hence, the same is included within the scope of the product under consideration.
iii. The domestic industry has produced and sold the product concerned in the domestic market in the period of investigation of the original investigation as well as in the current period.
iv. The domestic producer holds a license from Hunting PLC for threading and has produced identical article to that imported into India.
v. There is no difference between the applications considered for the product under consideration at the time of the original investigation and the applications listed by the applicant for product concerned.
vi. Product concerned is only a product type of the product under consideration. There are multiple producers of the product under consideration in India.
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ncerned.
vi. Product concerned is only a product type of the product under consideration. There are multiple producers of the product under consideration in India.
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vii. Merely because one product grade is priced higher than average price of imports in India, does not mean that the same is not being dumped in India.
viii. The HS Code pertaining to the product concerned is already included in the HS Codes on which anti-dumping duty has been imposed.
ix. There is no need to change the scope of the product under consideration as considered in the original investigation and product concerned is covered within the scope of the product under consideration.

F. FURTHER PROCURE

35. An appeal against the determination/review of the Authority in this final finding shall lie before the Customs, Excise and Service Tax Appellate Tribunal in accordance with the relevant provisions of the Act.

    Amitabh Kumar (Designated Authority)

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