Product description – The product under consideration includes all physical forms and concentrations, excluding salts, formulations and derivatives of –

1. HEDP Acid or Etidronic Acid having chemical name 1-Hydroxy Ethylidene-1, 1 Diphosphonic Acid, having chemical formula – C₂H₈O₇P₂ and CAS number 2809-21-4. The product is also known as Hydroxyethylidene-1,1-diphosphonic acid, 1 Hydroxyethylidenediphosphonic Acid and Hydroxyethylidene Diphosphonic acid.
2. ATMP Acid or Aminotrimethylene phosphonic acid, having chemical formula -N(CH₂PO₃H₂)₃ and CAS number 6419-19-8. The product is also known as Amino Tri(Methylene Phosphonic Acid ) and Tris(Methylene Phosphonic Acid) Amine.

HS Codes – 2918 2910, 2922 1990, 2931 4990, 2931 5900, 2931 9019, 2931 9090, 2942 0090, 3809 9200 and 3824 9900.

Uses – The product is used as follows –

1. HEDP Acid – It is used as an anti-scalant in detergents, water treatment, oilfield, textile, paper, personal care, RO membrane and thermal desalination.
2. ATMP Acid – It is used in various chemical formulations for industrial water treatment, oilfield, industrial cleaners, paper & pulp, textile industry, metal treatment, electroplating, inks and construction chemicals as a scale inhibitor and a complexing agent.

Country involved – China PR

Applicants – Aquapharm Chemical Limited and Excel Industries Limited

Period of investigation – 1^st April 2024 to 31^st March 2025

Injury period – 2022-23, 2023-24, 2024-25 and the period of investigation

Margins and recommended duties –

Country	Product	Producer	Dumping Margin	Injury Margin	Duty
China	HEDP Acid	All producers	30-40%	10-20	USD 200 / MT
	ATMP Acid	All producers	40-50%	15-25	USD 214 / MT

Key findings –

• The application was filed seeking imposition of duties on imports of subject goods from China PR. However, no interested party has participated and cooperated in the present investigation.
• The applicants jointly account for the entire total Indian production and constitute the domestic industry as defined under Rule 2(b).
• The exporters in China PR have dumped the product under consideration in India, and such dumped imports have caused material injury to the domestic industry.

Imports of HEDP Acid from China –

1. While the volume of imports declined up to 2023-24, it had increased in absolute and relative terms during the period of investigation as compared to the previous year.
2. Landed price declined at a higher rate than the decline in the major raw material (Yellow Phosphorous) prices, over the injury period and exerted significant pressure on the domestic industry, forcing it to reduce its prices lower than its costs.
3. The subject imports have suppressed and depressed the prices of the domestic industry.

Imports of ATMP Acid from China –

1. Volume of imports declined in 2022-23 and thereafter remained constant; however, subject imports accounted for 100% share in total imports.
2. Landed price declined at a higher rate than the decline in the major raw material (Yellow Phosphorous) prices over the injury period and exerted significant pressure on the domestic industry, forcing it to reduce its prices lower than its costs.
3. The subject imports have undercut, suppressed and depressed the prices of the domestic industry.

Impact on performance of the domestic industry –

1. While the volume parameters of the domestic industry improved on account of expansion of capacities, its profitability deteriorated over the injury period.
2. The domestic industry incurred financial losses, cash losses and continued to record negative returns on capital employed. While the losses reduced in the period of investigation, the losses persisted as compared to the base year.
3. The subject imports adversely impacted the ability of the domestic industry to generate returns and mobilize further capital investments.

• The Authority noted that imposition of duties will be in the interest of the public at large.
• Since the product is not a major input and is merely used as specialty additives in chemicals, it does not constitute a significant share in costs for users. Thus, any increase in costs due to imposition of duties will have a negligible impact on downstream users, comprising of large-scale corporations.
• Non-imposition of duties may increase the dependency of users on imports, resulting in increased influence of subject imports in the market despite no demand-supply gap in the country and exploitation of users.