Published: 14 Sep 2026
DGTR Adopts Detailed Battery-Based Classification for Electric Tractor Anti-Dumping Investigation Against China
Omega QMS Compliance Insights
Omega QMS
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, sets up 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 from interested parties on the scope of the Product Under Consideration (PUC), requests for product exclusions, and the appropriate PCN methodology. The notification is not a final determination on dumping, injury or causal link. It sets the product scope and classification methodology for the ongoing investigation.
What Is the Product Under Consideration?
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 (CKD) and Semi-Knocked Down (SKD) forms. The goods are used in logistics and goods-transportation operations and are, among others, classifiable under HS Codes 87012400 and 87049012. 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 together constitute a complete or essentially complete electric tractor in CKD or SKD form, the goods may remain within scope. This depends on the facts of each transaction.
Battery Capacity Does Not Determine Product Exclusion
Electric tractors will not be excluded from the investigation merely because their battery capacity exceeds a particular threshold. DGTR specifically noted that capacities such as 282 kWh, 302 kWh, 376 kWh, 400 kWh or any other stated capacity do not by themselves lead to exclusion. Differences in battery capacity are instead addressed through the new PCN methodology.
Electric tractors with five-level regenerative braking, or built on either born-electric or converted vehicle platforms, also remain within scope provided they satisfy the overall product description.
DGTR’s Four-Parameter PCN Methodology
DGTR has established a four-parameter PCN system to allow more precise comparison of different electric tractor configurations during the investigation.
Axle Configuration (Position 1)
| Configuration | Code |
|---|---|
| 6×4 | A |
| 4×2 | B |
Power-Transmission Architecture (Position 2)
| Architecture | Code |
|---|---|
| E-axle / integrated electric drive axle | P |
| Gearbox / central motor with mechanical transmission | Q |
| Other transmission architecture | R |
Rated Battery Energy Capacity (Position 3)
| Capacity (kWh) | 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 |
Traction Battery Included (Position 4)
| Battery included | Code |
|---|---|
| Yes | Y |
| No | N |
DGTR has clarified that the battery-capacity unit should be read as kWh, correcting the reference to volts (V) in the PCN methodology proposed at initiation.
Examples of the New Electric Tractor PCN Codes
DGTR has given examples to show how the methodology works.
- 6×4 electric tractor
- E-axle / integrated electric drive axle
- Battery up to and including 300 kWh
- Traction battery supplied with the tractor
- 4×2 electric tractor
- Gearbox / central motor with mechanical transmission
- Battery above 400 kWh and up to 500 kWh
- Supplied without the traction battery
- 6×4 electric tractor
- Other transmission architecture
- Battery above 500 kWh
- Traction battery supplied with the tractor
How Will Battery-Less Electric Tractors Be Classified?
For tractors imported without the traction battery, the battery-capacity code will not be treated as having no capacity. Classification will instead be based on the battery capacity for which the tractor is designed. The designed capacity must be established with reliable technical documentation, such as:
- Vehicle homologation or type-approval documents
- Contracts
- Other verified technical records
This matters particularly for exporters and importers supplying tractors without the battery pack, as the supporting documentation may determine the applicable PCN.
Extensive Transaction-Wise Information Must Be Reported
Besides the applicable PCN, interested parties must submit transaction-wise technical information. 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 for verification
- Details of any adjustment claimed
Exporters and importers will need to align their commercial, technical and transaction-level records before preparing their questionnaire responses.
15-Day Deadline for Questionnaire Responses
Questionnaire responses due within15 days of publication
DGTR has directed all interested parties to submit questionnaire responses under the new PCN methodology within 15 days of publication, and has expressly stated that no further extension of time will be granted, citing the time-bound nature of anti-dumping investigations.
Businesses importing, exporting or selling covered electric tractors should begin reviewing product and transaction data immediately.
What This Means for Importers and Exporters
The new PCN methodology gives DGTR a more granular basis for comparing electric tractor configurations. Immediate priorities for businesses:
Map Each Model Against the PCN
Identify the axle configuration, power-transmission architecture, rated battery capacity and battery-inclusion status for every relevant model or transaction.
Review Battery Documentation
For tractors imported without batteries, verify that the designed capacity is clearly supported by homologation, type-approval, contractual or other technical records.
Prepare Transaction-Level Data
Consolidate battery chemistry, motor power, GCW, charging configuration, CBU/CKD/SKD status and type approval data.
Assess CKD/SKD Transactions Carefully
Where components are imported, examine whether together they constitute a complete or essentially complete electric tractor, which may bring the transaction within the PUC.
Meet the Questionnaire Deadline
With no further extension available, timely preparation and submission of the questionnaire response is critical.
Can Product-Specific Exclusions Still Be Requested?
Yes. 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 on the evidence placed on record.
The Authority has not granted exclusion merely on the basis of battery capacity or certain technical characteristics at this stage, but parties may still put appropriate product-specific evidence on record.
Why the DGTR’s PCN Methodology Matters
Electric tractors can differ significantly in drivetrain architecture, axle configuration, battery capacity and battery supply arrangements. A broad product comparison could involve technically different configurations. The PCN lets DGTR classify these variations systematically and obtain more detailed transaction-wise information.
The methodology is therefore significant for Chinese exporters, Indian importers, and companies preparing questionnaire responses, transaction data and supporting technical documentation.
Key Takeaways
The PUC covers electric tractors in 6×4 and 4×2 axle configurations in any form, including CBU, CKD and SKD.
They 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 product exclusions.
Axle configuration, power-transmission architecture, battery capacity and battery-inclusion status. Capacity has four bands, from up to 300 kWh to above 500 kWh.
Classification is based on the designed battery capacity, supported by verified technical records.
Detailed technical and commercial information must be reported with the questionnaire response.
Questionnaire responses are due within 15 days of publication, with no further extension.
The notification is a methodology clarification, not a finding 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 investigation, our team can assist with:
- PCN classification
- Regulatory assessment
- Transaction-level data review
- Questionnaire response preparation
- Supporting documentation
If you are an electric tractor manufacturer, exporter, importer or other interested party, timely assessment of the applicable PCN and supporting technical information can help ensure your response follows the Authority’s prescribed methodology.
Affected by the Electric Tractor Investigation?
Need help with PCN classification or your questionnaire response?
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 for general informational purposes only and should not be treated as legal or professional advice. The DGTR investigation remains subject to further proceedings and determinations by the Authority.
