Published: 14 Sep 2026
DGTR Adopts Detailed Battery-Based Classification for Electric Tractor Anti-Dumping Investigation Against China
The Directorate General of Trade Remedies (DGTR) has adopted a detailed Product Control Number (PCN) methodology for its ongoing anti-dumping investigation concerning imports of electric tractors in 6×4 and 4×2 axle configurations originating in or exported from China PR.
The methodology, issued under F. No. 6/20/2026-DGTR and dated 19 August 2026, establishes a four-parameter classification system based on axle configuration, power-transmission architecture, rated battery energy capacity, and whether the traction battery is included with the imported tractor.
The clarification follows comments received from interested parties concerning the scope of the Product Under Consideration (PUC), requests for product exclusions, and the appropriate PCN methodology.
Importantly, the notification does not constitute a final determination on dumping, injury, or causal link. It establishes the product scope and classification methodology to be followed during the ongoing investigation.
What Is the Product Under Consideration?
The DGTR has confirmed that the PUC covers:
Electric Tractors in 6×4 and 4×2 axle configuration in any form
The scope includes Completely Built Units (CBUs), Completely Knocked Down (CKDs), and Semi-Knocked Down (SKDs). The subject goods are used in logistics and goods-transportation operations and are, inter alia, classifiable under HS Codes 87012400 and 87049012.
However, the notification clarifies that these HS classifications are indicative only and do not determine the scope of the PUC.
Treatment of Standalone Parts
Standalone parts imported independently remain outside the PUC.
However, where imported components, taken together, constitute a complete or essentially complete electric tractor in CKD or SKD form, the goods may remain within the scope of the investigation. This determination will depend on the facts of each individual transaction.
Battery Capacity Does Not Determine Product Exclusion
One of the key clarifications is that electric tractors will not be excluded from the investigation merely because their battery capacity exceeds a particular threshold.
The DGTR specifically noted that capacities such as 282 kWh, 302 kWh, 376 kWh, 400 kWh, or any other stated capacity do not by themselves result in exclusion from the PUC.
Instead, differences in battery capacity are to be addressed through the newly adopted PCN methodology.
The Authority has also clarified that electric tractors incorporating five-level regenerative braking or manufactured on either born-electric or converted vehicle platforms remain within the scope, provided they satisfy the overall product description.
DGTR’s Four-Parameter PCN Methodology
The DGTR has established a four-parameter PCN system to facilitate more precise comparison of different electric tractor configurations during the anti-dumping investigation.
1. Axle Configuration
The first PCN parameter distinguishes between:
| Axle Configuration | Code |
|---|---|
| 6×4 | A |
| 4×2 | B |
The code occupies Position 1 of the PCN.
2. Power-Transmission Architecture
The second parameter identifies the tractor’s drivetrain architecture:
| Power-Transmission Architecture | Code |
|---|---|
| E-axle / integrated electric drive axle | P |
| Gearbox / central motor with mechanical transmission | Q |
| Other transmission architecture | R |
This forms Position 2 of the PCN.
3. Rated Battery Energy Capacity
The third parameter classifies the tractor according to its rated battery energy capacity, measured in kilowatt-hours (kWh):
| Rated Battery Energy Capacity | Code |
|---|---|
| Up to and including 300 kWh | 1 |
| Above 300 kWh and up to 400 kWh | 2 |
| Above 400 kWh and up to 500 kWh | 3 |
| Above 500 kWh | 4 |
This occupies Position 3 of the PCN.
The DGTR has also clarified that the battery-capacity unit should be read as kWh, correcting the reference to volts (V) that appeared in the PCN methodology proposed at the initiation stage.
4. Whether the Traction Battery Is Included
The fourth parameter identifies whether the traction battery is included with the imported subject goods:
| Traction Battery Included | Code |
|---|---|
| Yes | Y |
| No | N |
This forms Position 4 of the PCN.
Examples of the New Electric Tractor PCN Codes
The DGTR has provided examples to illustrate how the methodology will work.
AP1Y
- 6×4 electric tractor
- E-axle / integrated electric drive axle
- Battery capacity up to and including 300 kWh
- Traction battery supplied with the tractor
BQ3N
- 4×2 electric tractor
- Gearbox / central motor with mechanical transmission
- Battery capacity above 400 kWh and up to 500 kWh
- Tractor supplied without the traction battery
AR4Y
- 6×4 electric tractor
- Other transmission architecture
- Battery capacity above 500 kWh
- Traction battery supplied with the tractor
How Will Battery-Less Electric Tractors Be Classified?
A significant clarification concerns electric tractors imported without the traction battery.
In such cases, the battery-capacity code will not simply be treated as having no battery capacity. Instead, classification will be based on the battery capacity for which the tractor is designed.
The designed battery capacity must be established using reliable technical documentation, such as:
- Vehicle homologation/type-approval documents
- Contracts
- Other verified technical records
This requirement is particularly important for exporters and importers supplying tractors without the battery pack, as the supporting documentation may determine the applicable PCN classification.
Extensive Transaction-Wise Information Must Be Reported
In addition to providing the applicable PCN, interested parties are required to submit transaction-wise technical information.
The DGTR requires reporting of:
- Exact battery capacity in kWh
- Battery chemistry
- CBU, CKD or SKD status
- Model/type approval
- Motor power
- Gross Combination Weight (GCW)
- Charging configuration
- Supporting documents required for verification
- Details of any adjustment claimed
This means exporters and importers will need to ensure that their commercial, technical and transaction-level records are aligned before preparing their questionnaire responses.
15-Day Deadline for Questionnaire Responses
The DGTR has directed all interested parties to submit their questionnaire responses in accordance with the newly adopted PCN methodology within 15 days of publication of the notification.
The Authority has expressly stated that no further extension of time will be granted, citing the time-bound nature of anti-dumping investigations.
Accordingly, businesses involved in the import, export or sale of electric tractors covered by the investigation should begin reviewing their product and transaction data immediately.
What This Means for Importers and Exporters
The new PCN methodology provides DGTR with a more granular basis for comparing different electric tractor configurations in the anti-dumping investigation.
For businesses, the immediate priorities should include:
1. Map Each Model Against the PCN Parameters
Importers and exporters should identify the applicable:
- Axle configuration
- Power-transmission architecture
- Rated battery energy capacity
- Battery-inclusion status
for every relevant model or transaction.
2. Review Battery Documentation
Where tractors are imported without batteries, businesses should verify that the designed battery capacity is clearly supported by homologation, type-approval, contractual or other technical records.
3. Prepare Transaction-Level Data
The notification requires information beyond the PCN itself. Companies should therefore consolidate data relating to battery chemistry, motor power, GCW, charging configuration, CBU/CKD/SKD status and type approval.
4. Assess CKD/SKD Transactions Carefully
Companies importing components rather than complete tractors should examine whether the components collectively constitute a complete or essentially complete electric tractor, as this may bring the transaction within the PUC.
5. Meet the Questionnaire Deadline
Given the DGTR’s explicit statement that no further extension will be granted, timely preparation and submission of the questionnaire response is critical.
Can Product-Specific Exclusions Still Be Requested?
The DGTR has clarified that the current PUC scope does not prevent interested parties from submitting relevant information and evidence in support of product-specific exclusion requests during the investigation.
Any such request will be examined based on the relevant information and evidence placed on record.
Therefore, while the Authority has not granted exclusion merely on the basis of battery capacity or certain technical characteristics at this stage, parties may still place appropriate product-specific evidence on record.
Why the DGTR’s PCN Methodology Matters
Electric tractors can differ significantly in terms of drivetrain architecture, axle configuration, battery capacity and battery supply arrangements.
A broad product comparison could therefore involve technically different configurations. The PCN methodology enables the DGTR to classify these variations systematically and obtain more detailed transaction-wise information during the investigation.
The methodology is consequently significant not only for Chinese exporters and Indian importers, but also for companies preparing questionnaire responses, transaction data and supporting technical documentation.
Key Takeaways
The DGTR’s 19 August 2026 notification establishes the following key points:
- The PUC covers electric tractors in 6×4 and 4×2 axle configurations in any form.
- The scope includes CBU, CKD and SKD forms.
- Standalone parts remain outside the PUC unless the components together constitute a complete or essentially complete tractor in CKD/SKD form.
- Battery-capacity differences are addressed through the PCN methodology rather than automatic product exclusions.
- The PCN uses four parameters: axle configuration, power-transmission architecture, battery capacity and battery-inclusion status.
- Battery capacity is classified in four bands ranging from up to 300 kWh to above 500 kWh.
- For tractors imported without batteries, classification is based on the designed battery capacity supported by verified technical records.
- Transaction-wise reporting of technical and commercial information is required.
- Questionnaire responses are due within 15 days of publication, with no further extension.
- The notification is a methodology clarification and does not represent a final determination on dumping or injury.
How Omega QMS Can Help
At Omega QMS, we assist businesses in navigating India’s evolving regulatory and trade compliance framework, including anti-dumping investigations, DGTR proceedings, import-export regulations, customs compliance, QCOs and product regulatory requirements.
For companies affected by the electric tractor anti-dumping investigation, our team can assist with PCN classification, regulatory assessment, transaction-level data review and preparation of questionnaire responses and supporting documentation.
If you are an electric tractor manufacturer, exporter, importer or other interested party affected by the DGTR investigation, timely assessment of the applicable PCN and supporting technical information can help ensure that your response is prepared in accordance with the Authority’s prescribed methodology.
Source
Directorate General of Trade Remedies (DGTR), Department of Commerce, Ministry of Commerce & Industry, Government of India
F. No. 6/20/2026-DGTR, dated 19 August 2026
Subject: PUC and PCN Methodology in the Anti-dumping investigation concerning imports of “Electric Tractors in 6×4 and 4×2 axle configuration in any form” originating in or exported from China PR.
The notification was issued by Vishal Sharma, Director (FT), DGTR.
Disclaimer: This article is intended for general informational purposes and should not be treated as legal or professional advice. The DGTR investigation remains subject to further proceedings and determinations by the Authority.