Published: 28 Sep 2026
DGTR Initiates Anti-Circumvention Investigation into CPVC Resin Exports from Malaysia, Japan and Thailand
Omega QMS Compliance Insights
Omega QMS
The Directorate General of Trade Remedies (DGTR), Department of Commerce, has initiated an anti-circumvention investigation concerning imports of Chlorinated Polyvinyl Chloride (CPVC) Resin, whether or not further processed into compound, exported to India from Malaysia, Japan and Thailand.
The investigation examines allegations that the existing anti-dumping duty on CPVC Resin originating in or exported from China PR and Korea RP may be circumvented through exports by three specifically named companies in Malaysia, Japan and Thailand.
It was initiated through F. No. 7/29/2026-DGTR, SETU Case ID AD/AC/006/2026, dated 16 September 2026, and published in the Gazette of India, Extraordinary. Initiation does not constitute a final finding that circumvention has occurred; DGTR will examine the allegations and evidence before reaching its findings.
What Has Changed?
The investigation follows an application by DCW Limited, Epigral Limited and Lubrizol Advanced Materials India Private Limited, representing the domestic industry. DGTR initiated it under Section 9A(1A) of the Customs Tariff Act, 1975, read with Rules 25 and 26 of the Customs Tariff (Identification, Assessment and Collection of Anti-Dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995.
The investigation is specifically concerned with exports by:
| Country | Exporter |
|---|---|
| Malaysia | Sasia Chlorine Polymers Sdn. Bhd. |
| Japan | EBC Corporation |
| Thailand | Sekisui Specialty Chemicals (Thailand) Co. Ltd. |
The investigation is limited to these three named exporters. It does not automatically extend to all CPVC Resin producers or exporters from Malaysia, Japan or Thailand.
What Is the Product Under Investigation?
The product is “Chlorinated Polyvinyl Chloride (CPVC) Resin – whether or not further processed into compound”, the same product covered by the original anti-dumping investigation on China PR and Korea RP. CPVC Resin is used in:
- Hot- and cold-water plumbing
- Residential and commercial plumbing systems
- Fire-protection systems
- Reclaimed-water piping
- Chilled-water piping
- Hydronic piping and distribution
- Industrial piping applications
The product is classified under Customs Tariff Items 3904 90 10 and 3904 90 90. DGTR has clarified that the customs classification is indicative only and does not determine the scope of the investigation.
Existing Anti-Dumping Duty on CPVC Resin
The investigation relates to an existing anti-dumping measure on CPVC Resin from China PR and Korea RP.
| Stage | Details |
|---|---|
| Original investigation | Initiated in 2019 |
| Duty imposed | Notification No. 05/2020-Customs (ADD), 7 March 2020 |
| Sunset review | Initiated in December 2023 |
| Duty continued with modification | Notification No. 15/2024-Customs (ADD), 23 August 2024 |
The current investigation seeks to determine whether the remedial effect of this measure is being undermined by exports of the product from Malaysia, Japan and Thailand by the three named exporters.
What Is the Alleged Circumvention?
The domestic industry has presented evidence alleging changes in the trade pattern involving CPVC Resin. According to the application:
Malaysia and Japan Route
CPVC Resin is allegedly exported from China to Malaysia and Japan, and subsequently exported to India as CPVC Resin.
Thailand Route
CPVC Resin or compound is allegedly exported from China to Thailand, and subsequently exported to India by the named Thai exporter.
Alleged Dumping
The applicants have submitted prima facie evidence alleging that the product under investigation is being dumped.
Imports and Idle Capacity
The applicants point to increased imports alongside idle capacity in the domestic industry.
Based on the prima facie evidence, DGTR has noted a change in the pattern of trade, including an increase in imports from Japan, Malaysia and Thailand to significant levels without sufficient cause or economic justification, which may undermine the remedial effect of the existing duty on China PR.
Important: these are allegations under investigation. They form part of the prima facie assessment at the initiation stage. The notification is not a final determination that the three exporters have circumvented the duty.
Period of Investigation
| Period | Coverage |
|---|---|
| Period of Investigation | 1 April 2025 to 31 March 2026 (12 months) |
| Injury period | 2022–23, 2023–24 and 2024–25 |
Who Is Covered by the Investigation?
The investigation is limited to CPVC Resin exported to India by Sasia Chlorine Polymers Sdn. Bhd. (Malaysia), EBC Corporation (Japan) and Sekisui Specialty Chemicals (Thailand) Co. Ltd. (Thailand). Other producers or exporters in these countries are not automatically covered merely because of their location.
Indian importers should identify their actual overseas supplier before determining whether their imports are directly connected with this investigation.
SETU Portal Filing Is Mandatory
All information, questionnaire responses and submissions must be filed through the DGTR SETU Portal. Submissions sent by email or any other mode may not be considered. Interested parties must register on the portal and file under SETU Case ID AD/AC/006/2026. DGTR also specifies the following formats:
- Narrative submissions in searchable PDF or MS Word format
- Data files in MS Excel format
- Properly linked calculations
- Separate confidential and non-confidential versions, wherever confidentiality is claimed
Questionnaire Response Deadline: 37 Days
Known producers and exporters, governments of the subject countries, Indian importers and users, and other interested parties must submit information within the timelines in the initiation notification. Confidential and non-confidential versions of Questionnaire Responses must be uploaded within 37 days from the date the Authority sends the notice calling for information, or transmits it to the diplomatic representatives of the concerned countries.
Extension requests must be filed through the SETU Portal at least three days before the original deadline. Later requests will not be considered.
Confidentiality Requirements
Where confidential information is submitted, the party must simultaneously provide a non-confidential version.
- The non-confidential version should substantially replicate the confidential one, with information indexed, blanked out or summarised
- A good-cause statement must explain why information cannot be disclosed
- Other parties may comment on confidentiality claims within seven days of circulation
- A missing or inadequate non-confidential version may lead to the submission not being taken on record
Risk of Non-Cooperation
If an interested party fails to provide necessary information within the prescribed period, refuses access to required information, or significantly impedes the investigation, DGTR may treat the party as non-cooperative.
In such cases, DGTR may record findings on the basis of facts available on record and make recommendations to the Central Government as it considers appropriate. Exporters and importers connected with the three named exporters should assess the notification promptly and prepare their submissions in time.
Business Impact
For Indian Importers
Identify whether your CPVC Resin suppliers are among the three named exporters, and review historical imports, commercial documents and product information in preparation for any questionnaire.
For the Three Named Exporters
Assess the allegations and prepare questionnaire responses, transaction-level data and supporting documentation within the prescribed timelines.
For Indian CPVC Resin Users
Companies using CPVC Resin in plumbing, piping, fire protection or industrial applications should monitor the investigation and check whether their supply chains involve the exporters under investigation.
For Other Exporters
This is not a blanket investigation of every exporter from Malaysia, Japan and Thailand. The notification identifies the three exporters specifically.
What Happens Next?
DGTR will examine the information and evidence submitted during the investigation. It may issue further communications on:
- Questionnaire responses
- PCN methodology, where applicable
- PCN discussions or meetings
- Oral hearings
- Disclosure statement
- Corrigenda or amendments
- Final findings
Interested parties should regularly monitor the DGTR website and SETU Portal. This is an initiation notice, and the final outcome has not been determined.
Key Takeaways
DGTR has begun an anti-circumvention investigation into CPVC Resin exported from Malaysia, Japan and Thailand, relating to the existing duty on China PR and Korea RP.
Sasia Chlorine Polymers Sdn. Bhd. (Malaysia), EBC Corporation (Japan) and Sekisui Specialty Chemicals (Thailand) Co. Ltd. (Thailand).
CPVC Resin, whether or not further processed into compound. Indicative tariff items are 3904 90 10 and 3904 90 90.
1 April 2025 to 31 March 2026.
All submissions must be filed through the SETU Portal under Case ID AD/AC/006/2026.
Questionnaire Responses are due within 37 days of the prescribed communication date. Extension requests must be filed at least three days before the deadline.
Confidential submissions need meaningful non-confidential versions and good-cause statements. Non-cooperation may lead to findings on facts available.
No finding of circumvention has been made at the initiation stage.
How Omega QMS Can Help
At Omega QMS, we assist businesses in navigating India’s trade-remedy and regulatory framework, including anti-dumping investigations, anti-circumvention proceedings, customs regulations, import-export compliance and DGTR procedures. For businesses affected by the CPVC Resin investigation, our team can assist with:
- Assessing whether imports fall within the investigation’s scope
- Reviewing supplier and exporter exposure
- SETU Portal registration and procedural assistance
- Preparation and review of Questionnaire Responses
- Compilation and review of transaction-level data
- Confidential and non-confidential submissions
- Confidentiality and good-cause statements
- Monitoring DGTR proceedings and notifications
- Regulatory representation and trade-remedy support
If your business imports CPVC Resin from Sasia Chlorine Polymers, EBC Corporation or Sekisui Specialty Chemicals (Thailand), timely assessment of the notification and preparation of the required submissions should be prioritised.
Affected by the CPVC Resin Investigation?
Need help with SETU filings, Questionnaire Responses or assessing your exposure?
Source: Directorate General of Trade Remedies (DGTR), Ministry of Commerce & Industry, Department of Commerce, Government of India. F. No.: 7/29/2026-DGTR . SETU Case ID: AD/AC/006/2026. Date: 16 September 2026.
Subject: Initiation of an anti-circumvention investigation concerning alleged circumvention through Malaysia, Japan and Thailand of the anti-dumping duty imposed on imports of “Chlorinated Polyvinyl Chloride (CPVC) Resin – whether or not further processed into compound” originating in or exported from China PR and Korea RP. Designated Authority: Amitabh Kumar, DGTR.
Disclaimer: This article is for general informational purposes only and does not constitute legal or professional advice. The investigation is ongoing, and the allegations described above should not be treated as final findings. Businesses should review the applicable DGTR notifications and assess their position based on their specific products, suppliers and transactions.
