Published: 28 Sep 2026

DGTR Initiates Anti-Circumvention Investigation into CPVC Resin Exports from Malaysia, Japan and Thailand

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 applicable to CPVC Resin originating in or exported from China PR and Korea RP may be being circumvented through exports by three specifically named companies in Malaysia, Japan and Thailand.

The investigation has been 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.

Importantly, the initiation of an anti-circumvention investigation does not constitute a final finding that circumvention has occurred. DGTR will examine the allegations and evidence during the investigation before reaching its findings.

What Has Changed?

1. DGTR Initiates Anti-Circumvention Investigation

The investigation follows an application filed by DCW Limited, Epigral Limited and Lubrizol Advanced Materials India Private Limited, the applicants representing the domestic industry.

DGTR has initiated the investigation 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.

A key point is that 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 under investigation is:

“Chlorinated Polyvinyl Chloride (CPVC) Resin – whether or not further processed into compound.”

This is the same product that was covered by the original anti-dumping investigation concerning imports originating in or exported from China PR and Korea RP.

CPVC Resin is used in a range of applications, including:

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 under investigation is classified under Customs Tariff Items 3904 90 10 and 3904 90 90. However, 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 present investigation relates to an existing anti-dumping measure on CPVC Resin originating in or exported from China PR and Korea RP.

The original anti-dumping investigation was initiated in 2019. Following the investigation, the Central Government imposed anti-dumping duty through Notification No. 05/2020-Customs (ADD) dated 7 March 2020.

A subsequent sunset review was initiated in December 2023. Following the final findings, the anti-dumping measure was continued with modification through Notification No. 15/2024-Customs (ADD) dated 23 August 2024.

The current anti-circumvention investigation seeks to determine whether the remedial effect of this existing measure is being undermined through the exports of the subject 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:

CPVC Resin in resin form is allegedly exported from China to Malaysia and Japan, and subsequently exported to India as CPVC Resin.
CPVC Resin or compound is allegedly exported from China to Thailand, and subsequently exported to India by the named Thai exporter.
The applicants have also submitted prima facie evidence alleging that the product under investigation is being dumped.
The applicants have pointed to increased imports alongside idle capacity in the domestic industry.

Based on the prima facie evidence placed on record, 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 anti-dumping measure on imports from China PR.

Important: These Are Allegations Under Investigation

The above circumstances form part of the allegations and prima facie assessment at the initiation stage.

The initiation notification does not constitute a final determination that the three exporters have circumvented the existing anti-dumping duty.

DGTR has initiated the investigation to determine the existence and effect of the alleged circumvention.

Period of Investigation

The investigation will examine a 12-month period:

1 April 2025 to 31 March 2026

The injury period covers:

2022–23
2023–24
2024–25
Period of Investigation

Who Is Covered by the Investigation?

The investigation is specifically limited to CPVC Resin exported to India by:

Sasia Chlorine Polymers Sdn. Bhd. – Malaysia
EBC Corporation – Japan
Sekisui Specialty Chemicals (Thailand) Co. Ltd. – Thailand

Other producers or exporters of the product from Malaysia, Japan or Thailand are not automatically covered merely because they are located in the subject countries.

This distinction is particularly important for Indian importers, who should identify their actual overseas supplier before determining whether their imports are directly connected with the present investigation.

SETU Portal Filing Is Mandatory

All information, questionnaire responses and submissions relating to the investigation must be filed through the DGTR SETU Portal.

DGTR has stated that submissions sent through email or any other mode may not be considered.

Interested parties are required to register on the SETU Portal and file their submissions under the relevant SETU Case ID: AD/AC/006/2026.

DGTR has also specified requirements concerning the format of submissions, including:

Narrative submissions in searchable PDF/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/exporters, governments of the subject countries, Indian importers and users, and other interested parties are required to submit the relevant information within the timelines prescribed by the initiation notification.

The confidential and non-confidential versions of Questionnaire Responses/submissions must be uploaded within 37 days from the date on which the notice calling for information is sent by the Authority or transmitted to the appropriate diplomatic representatives of the concerned countries.

Any request for an extension must be submitted through the SETU Portal at least three days before the original deadline. Requests submitted after this point will not be considered.

Confidentiality Requirements

Businesses participating in the investigation should pay particular attention to DGTR’s 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 submission, with confidential information appropriately indexed, blanked out or summarised where applicable.

DGTR also requires parties claiming confidentiality to provide a good-cause statement explaining why the information cannot be disclosed.

Failure to provide a meaningful non-confidential version or adequate justification for confidentiality may result in the relevant submission not being taken on record.

Other interested parties may also submit comments on confidentiality claims made by another party within seven days from circulation of the non-confidential version.

Risk of Non-Cooperation

Participation in the investigation is important for affected businesses.

DGTR has stated that where an interested party fails to provide necessary information within the prescribed period, refuses access to required information, or significantly impedes the investigation, the Authority may treat the party as non-cooperative.

In such circumstances, DGTR may record its findings on the basis of facts available on record and make recommendations to the Central Government as considered appropriate.

Accordingly, exporters and importers directly connected with the three named exporters should assess the notification promptly and ensure that required information is prepared and submitted within the prescribed timelines.

Business Impact

The initiation of this investigation is particularly relevant to businesses importing CPVC Resin from the three named exporters.

For Indian Importers

Importers should identify whether their CPVC Resin suppliers are among the three exporters specifically named in the notification.

They should also review their historical imports, commercial documentation and product information in preparation for any questionnaire or information request.

For the Three Named Exporters

The named exporters should assess the allegations and prepare the necessary 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 assess whether their supply chains involve any of the exporters under investigation.

For Other Exporters

Exporters from Malaysia, Japan and Thailand should note that the present investigation is not a blanket investigation covering every exporter from these countries. The notification specifically identifies the three exporters under investigation.

What Happens Next?

DGTR will examine the information and evidence submitted by interested parties during the investigation.

The Authority may issue further communications concerning matters such as:

Questionnaire responses;
PCN methodology, where applicable;
PCN discussions or meetings;
Oral hearings;
Disclosure statement;
Corrigenda or amendments;
Final findings.

Interested parties have been advised to regularly monitor the DGTR website and SETU Portal for further developments.

The present notification is therefore an initiation notice, and the final outcome of the investigation has not yet been determined.

Key Takeaways

DGTR has initiated an anti-circumvention investigation into CPVC Resin exported from Malaysia, Japan and Thailand.
The investigation concerns the existing anti-dumping measure applicable to CPVC Resin originating in or exported from China PR and Korea RP.
The investigation is limited to three named exporters:
- Sasia Chlorine Polymers Sdn. Bhd. – Malaysia
- EBC Corporation – Japan
- Sekisui Specialty Chemicals (Thailand) Co. Ltd. – Thailand
The product under investigation is CPVC Resin, whether or not further processed into compound.
Indicative tariff items are 3904 90 10 and 3904 90 90.
The Period of Investigation is 1 April 2025 to 31 March 2026.
All submissions must be made through the SETU Portal.
Questionnaire Responses must be submitted within 37 days from the prescribed date of communication.
Extension requests must be filed through SETU at least three days before the original deadline.
Confidential submissions must be accompanied by meaningful non-confidential versions and appropriate good-cause statements.
Non-cooperation may result in findings being made on the basis of facts available.
No final 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 scope of the investigation
Reviewing supplier and exporter exposure
SETU Portal registration and procedural assistance
Preparation and review of Questionnaire Responses
Compilation and review of supporting transaction-level data
Preparation of confidential and non-confidential submissions
Confidentiality and good-cause statement requirements
Monitoring DGTR proceedings and subsequent 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.

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.