Published: 14 Sep 2026
DGTR Confirms Scope in Hot-Rolled Steel Anti-Dumping Investigation Against China, Japan and Russia
Omega QMS Compliance Insights
Omega QMS
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 DGTR’s decision not to exclude specific steel grades from the Product Under Consideration (PUC), after the domestic industry showed that it already produces, or can produce, the grades or equivalent grades for which exclusions were requested. The Authority also retained the original three-parameter PCN methodology covering product type, thickness and width.
This notification is a scope and methodology clarification. It is not a final determination on dumping, injury or causal link.
Background of the Anti-Dumping Investigation
DGTR initiated the investigation through notification F. No. 6/26/2026-DGTR dated 25 June 2026. Known interested parties were invited to submit questionnaire responses, comments on the scope of the PUC and proposals on the PCN methodology. Several parties made submissions on both product scope and classification.
The latest notification records the Authority’s examination of these submissions and clarifies the scope and PCN methodology for the investigation.
DGTR Rejects Requests for Specific Steel Grade Exclusions
Certain interested parties had asked for specific steel grades to be excluded from the PUC. The domestic industry, however, placed evidence on record showing that it had already produced, or had the manufacturing capability to produce, the grades or equivalent grades concerned.
Based on this evidence, DGTR has maintained the PUC scope as defined in the initiation notification. The requested steel grades have not been carved out at this stage.
Can Further Exclusion Requests Still Be Made?
Yes. DGTR has expressly stated that interested parties may continue to provide additional and relevant information and evidence to support product-specific exclusion requests during the investigation. The Authority will consider such evidence when determining the PUC scope for any measures it may ultimately recommend.
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. It covers hot-rolled flat products not further worked than hot-rolled, supplied in prime or non-prime condition, and supplied both in coils and in cut-to-length form. The products may have different edge configurations:
- 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
Production processes include as-rolled, thermo-mechanically rolled, thermo-mechanically controlled rolled, controlled rolled, normalized rolled and normalized processes, among others.
Processing Forms Covered by the Investigation
DGTR 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
Industries Using the Subject Hot-Rolled Steel
According to the notification, the subject products are used across a wide range of industries and applications:
- 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 makes the investigation relevant to manufacturers, importers, exporters and downstream users across several sectors.
Relevant Customs Tariff Headings
The PUC is classified under Customs Tariff Headings 7208, 7211, 7225 and 7226.
DGTR has expressly clarified that the customs classification is indicative only and does not bind the scope of the investigation. Businesses should not rely solely on the HS classification to decide 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. These products remain outside the scope of this anti-dumping investigation.
DGTR Retains the Original PCN Methodology
Some interested parties proposed changes to the PCN methodology. According to DGTR, however, they did not provide evidence of cost and price differences that would justify modifying it. The Authority therefore adopted the PCN methodology from the initiation notification without changes. The PCN has three parameters:
Product Type
| Type | Code |
|---|---|
| Alloy | A |
| Non-Alloy | N |
Thickness
| Range | Code |
|---|---|
| Up to and including 5 mm | C |
| More than 5 mm and up to 25 mm | D |
Width
| Range | Code |
|---|---|
| Up to and including 1500 mm | U |
| More than 1500 mm and up to 2100 mm | M |
Together, the three parameters give a structured basis for classifying the subject hot-rolled steel products for the investigation.
What Does the PCN Methodology Mean for Exporters and Importers?
Retaining the original PCN methodology gives greater clarity to businesses 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 product descriptions, transaction data and supporting technical information are consistent with the applicable PCN.
15-Day Deadline for Questionnaire Responses
Questionnaire responses due within15 days of the notification
DGTR has 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 start reviewing their product portfolio and transaction-level information without delay.
Key Implications for Businesses
Review Product Scope Carefully
Assess whether your hot-rolled flat alloy or non-alloy steel meets the PUC description, rather than relying solely on the customs tariff heading.
Map Products Against the PCN
Assess each product by product type, thickness and width to ensure accurate classification in the questionnaire response.
Do Not Assume Specific Grades Are Excluded
Exclusion requests were rejected at this stage because of evidence of domestic production capability. Businesses seeking exclusion should prepare product-specific technical and commercial evidence.
Check Whether the Product Is Stainless Steel
Stainless steel hot-rolled flat products are outside the PUC, but still assess product characteristics carefully against the complete scope.
Prepare Questionnaire Responses Within the Deadline
The 15-day deadline, with no further extension, 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. It does not determine that dumping has occurred or that the domestic industry has suffered injury.
Interested parties may still submit evidence on product-specific exclusion requests during the investigation. Businesses should distinguish between this scope and methodology clarification and any eventual findings or recommendations later in the investigation.
Key Takeaways
Hot Rolled Flat Products of Alloy or Non-Alloy Steel from China PR, Japan and Russia, with thickness up to 25 mm and width up to 2100 mm.
The scope remains as in the initiation notification. Grade exclusion requests were not accepted at this stage because the domestic industry demonstrated production or manufacturing capability.
Stainless steel hot-rolled flat products are outside the PUC.
The PUC includes coil and cut-to-length forms and a wide range of processing and edge conditions.
Headings 7208, 7211, 7225 and 7226 do not independently determine PUC coverage.
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, not a finding 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 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 product characteristics and PCN classification can help ensure your response is accurate and on time.
Affected by the Hot-Rolled Steel Investigation?
Need help with PUC scope, 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. 6/26/2026-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, DGTR.
Disclaimer: This article is 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.
