Published: 14 Sep 2026
DGTR Confirms Scope in Hot-Rolled Steel Anti-Dumping Investigation Against China, Japan and Russia
The Directorate General of Trade Remedies (DGTR) has confirmed the product scope and retained the existing Product Control Number (PCN) methodology in India’s ongoing anti-dumping investigation concerning imports of Hot Rolled Flat Products of Alloy or Non-Alloy Steel originating in or exported from China PR, Japan and Russia.
The clarification was issued under F. No. 6/26/2026-DGTR, SETU Case ID AD/OI/028/2026, dated 24 August 2026, following the initiation of the investigation on 25 June 2026.
A key development is the DGTR’s decision not to exclude specific steel grades from the Product Under Consideration (PUC), after the domestic industry submitted evidence demonstrating that it already produces, or has the manufacturing capability to produce, the grades or equivalent grades for which exclusions were requested.
The Authority has also retained the original three-parameter PCN methodology, covering product type, thickness and width.
Importantly, this notification is a scope and methodology clarification and does not constitute a final determination on dumping, injury or causal link.
Background of the Anti-Dumping Investigation
The DGTR initiated the present anti-dumping investigation through notification F. No. 6/26/2026-DGTR dated 25 June 2026.
Following initiation, known interested parties were invited to submit questionnaire responses as well as comments on the scope of the PUC and proposals regarding the PCN methodology. Various interested parties subsequently made submissions concerning both the product scope and classification methodology.
The latest notification records the Authority’s examination of these submissions and clarifies the scope and PCN methodology applicable to the ongoing investigation.
DGTR Rejects Requests for Specific Steel Grade Exclusions
One of the most significant aspects of the notification is the treatment of requests for product-specific or grade-specific exclusions.
Certain interested parties had requested that specific steel grades be excluded from the PUC.
However, the domestic industry placed evidence on record demonstrating that it had already produced, or possessed the requisite manufacturing capability to produce, the grades or equivalent grades for which exclusion had been sought.
Based on this evidence, the DGTR has maintained the scope of the PUC as defined in the initiation notification.
This means that the requested steel grades have not been carved out from the investigation at this stage.
Can Further Exclusion Requests Still Be Made?
The clarification does not completely close the door on product-specific exclusion requests.
The DGTR has expressly stated that interested parties may continue to provide additional and relevant information and evidence to substantiate requests for exclusion for particular products during the course of the investigation.
The Authority will consider such evidence when determining the scope of the PUC for any measures that may ultimately be recommended.
Product Scope Confirmed by DGTR
The PUC has been confirmed as:
“Hot Rolled flat products of alloy or non-alloy steel, not clad, plated or coated, of a thickness upto 25 mm and width upto 2100 mm.”
The scope is broad and covers hot-rolled flat products that are not further worked than hot-rolled and are supplied in prime or non-prime condition.
The products may have different edge configurations, including:
- As-rolled edges
- Trimmed edges
- Slit edges
- Milled edges
- Sheared edges
- Laser-cut edges
- Gas-cut edges
- Other types of edges
The products may also be:
- Pickled or non-pickled
- With or without skin-pass or tempering
- Slit or non-slit
- Normalized or un-normalized
- Ultrasonically tested or untested
- Oiled or non-oiled
They may also be produced through processes including as-rolled, thermo-mechanically rolled, thermo-mechanically controlled rolled, controlled rolled, normalized rolled and normalized processes, among others.
Processing Forms Covered by the Investigation
The DGTR’s clarification further confirms that the PUC may have undergone various processing steps, including:
- Pickling
- Oiling
- Rewinding
- Recoiling
- Temper rolling
- Heat treatment
- Sand blasting
- Shot blasting
- Similar processing
The PUC covers hot-rolled flat products supplied both in coils and in cut-to-length form.
Industries Using the Subject Hot-Rolled Steel
According to the DGTR notification, the subject products are used across a wide range of industries and applications, including:
- Automotive manufacturing
- Oil and gas line pipes and exploration
- Cold-rolled steel products
- Pipe manufacturing
- General engineering and fabrication
- Construction
- Capital goods
- Process equipment
- Cement industry
- Fertilizer industry
- Refineries
- Earth-moving equipment
This broad end-use profile highlights the potential relevance of the investigation to manufacturers, importers, exporters and downstream users across several industrial sectors.
Relevant Customs Tariff Headings
The PUC is classified under the following Customs Tariff Headings:
- 7208
- 7211
- 7225
- 7226
However, the DGTR has expressly clarified that the customs classification is indicative only and is not binding on the scope of the investigation. Therefore, businesses should not rely solely on the HS classification when determining whether a product falls within the PUC.
Stainless Steel Hot-Rolled Flat Products Excluded
The notification expressly states that the PUC does not cover hot-rolled flat products of stainless steel.
Accordingly, stainless steel hot-rolled flat products remain outside the scope of this particular anti-dumping investigation.
DGTR Retains the Original PCN Methodology
Some interested parties proposed modifications to the PCN methodology.
However, according to the DGTR, the parties proposing changes did not provide evidence demonstrating differences in cost and price that would justify modification of the existing methodology.
The Authority therefore decided to adopt the PCN methodology proposed in the original initiation notification without changes.
The PCN consists of three parameters:
1. Product Type
| Product Type | Code |
|---|---|
| Alloy | A |
| Non-Alloy | N |
2. Thickness
| Thickness | Code |
|---|---|
| Up to and including 5 mm | C |
| More than 5 mm and up to 25 mm | D |
3. Width
| Width | Code |
|---|---|
| Up to and including 1500 mm | U |
| More than 1500 mm and up to 2100 mm | M |
The three parameters therefore provide a structured basis for classifying the subject hot-rolled steel products for the purposes of the investigation.
What Does the PCN Methodology Mean for Exporters and Importers?
The retention of the original PCN methodology provides greater clarity to businesses participating in the investigation.
Exporters and importers should identify the applicable classification for each relevant product based on:
- Whether the steel is alloy or non-alloy;
- Its thickness; and
- Its width.
Businesses preparing questionnaire responses should ensure that their product descriptions, transaction data and supporting technical information are consistent with the applicable PCN.
15-Day Deadline for Questionnaire Responses
The DGTR has directed all interested parties to file their questionnaire responses within 15 days from the issuance of the notification.
The Authority has further stated that no further extension of time will be granted, citing the time-bound nature of anti-dumping investigations.
Given the short timeline, exporters, importers and other interested parties should begin reviewing their product portfolio and transaction-level information without delay.
Key Implications for Businesses
The latest DGTR clarification has several practical implications for businesses involved in the hot-rolled steel trade.
1. Review Product Scope Carefully
Companies importing or exporting hot-rolled flat alloy or non-alloy steel should assess whether their products meet the PUC description, rather than relying solely on the applicable customs tariff heading.
2. Map Products Against the PCN
Each relevant product should be assessed according to its:
- Product type
- Thickness
- Width
This will help ensure accurate classification in the questionnaire response.
3. Do Not Assume Specific Grades Are Excluded
The DGTR has rejected the exclusion requests raised at this stage because evidence was placed on record regarding domestic production or manufacturing capability for the grades or equivalent grades concerned.
Businesses seeking an exclusion should therefore prepare appropriate product-specific technical and commercial evidence to support their position.
4. Check Whether the Product Is Stainless Steel
Hot-rolled flat products of stainless steel are expressly outside the PUC.
Businesses should nevertheless assess the product characteristics carefully against the complete scope of the investigation.
5. Prepare Questionnaire Responses Within the Deadline
The 15-day deadline, coupled with the DGTR’s statement that no further extension will be granted, makes timely preparation particularly important.
What This Notification Does — and Does Not — Decide
The 24 August 2026 notification primarily clarifies the PUC scope and PCN methodology applicable to the ongoing investigation.
It does not represent a final determination that dumping has occurred or that the domestic industry has suffered injury.
The DGTR has also clarified that interested parties may continue to submit relevant evidence regarding product-specific exclusion requests during the investigation.
Therefore, businesses should distinguish between the current scope/methodology clarification and any eventual findings or recommendations that may arise later in the anti-dumping investigation.
Key Takeaways
The DGTR’s latest notification confirms the following:
- The investigation covers Hot Rolled Flat Products of Alloy or Non-Alloy Steel from China PR, Japan and Russia.
- The PUC covers products with thickness up to 25 mm and width up to 2100 mm.
- The scope remains unchanged from the initiation notification.
- Requests to exclude certain steel grades were not accepted at this stage because the domestic industry demonstrated existing production or manufacturing capability for the grades or equivalent grades.
- Stainless steel hot-rolled flat products are outside the PUC.
- The PUC includes products in both coil and cut-to-length form and covers a broad range of processing and edge conditions.
- Customs Tariff Headings 7208, 7211, 7225 and 7226 are indicative and do not independently determine PUC coverage.
- The original three-parameter PCN methodology has been retained:
- Product Type: Alloy (A) / Non-Alloy (N)
- Thickness: Up to 5 mm (C) / More than 5 mm up to 25 mm (D)
- Width: Up to 1500 mm (U) / More than 1500 mm up to 2100 mm (M)
- Interested parties must file questionnaire responses within 15 days, with no further extension.
- The notification is a scope and methodology clarification and not a final determination on dumping or injury.
How Omega QMS Can Help
At Omega QMS, we assist businesses in navigating India’s evolving trade and regulatory framework, including anti-dumping investigations, DGTR proceedings, customs regulations, import-export compliance and trade remedy matters.
For manufacturers, exporters, importers and downstream users affected by the hot-rolled steel investigation, our team can assist with:
- PUC scope assessment
- PCN classification
- Product-specific exclusion assessment
- Review of supporting technical and commercial documentation
- Questionnaire response preparation
- DGTR regulatory representation and compliance support
If your products are imported from or exported from China PR, Japan or Russia and may fall within the scope of this investigation, an early review of the product characteristics and PCN classification can help ensure that the required response is prepared accurately and within the prescribed timeline.
Source
Directorate General of Trade Remedies (DGTR), Department of Commerce, Ministry of Commerce & Industry, Government of India
F. No. 6/26/2026-DGTR
SETU Case ID: AD/OI/028/2026
Date: 24 August 2026
Subject: PUC and PCN Methodology in the Anti-dumping investigation concerning imports of “Hot Rolled Flat Products of Alloy or Non-Alloy Steel” originating in or exported from China PR, Japan and Russia.
The notification was issued by Onkar Nath Mishra, Assistant Director, Directorate General of Trade Remedies (DGTR).
Disclaimer: This article is intended for general informational purposes only and does not constitute legal or professional advice. The DGTR investigation remains subject to further proceedings and determinations by the Authority.