Product description – The product under consideration (‘PUC’) is ‘Sulphenamides Accelerators’. The scope of the product under consideration only includes CBS (N-cyclohexyl-2-benzothiazolesulfenamide) and NS (N-tert-butyl-2-benzothiazolesulfenamid) form of the PUC. The scope of the product under consideration excludes MOR (N-oxydiethylene-2-benzothiazolesulphenamide) and DCBS (N,N’-Dicyclohexyl-2-benzothiaz esulfonamides) Sulphenamides Accelerators.

HS Codes – The product under consideration is classified under Chapter 38, Heading 3812 under the HS code 3812 10 00. The product under consideration is also imported under the HS codes, 2921 51 90, 2930 30 00, 2931 90 90, 2934 20 00, 3812 31 00 and 3812 39 90.

Countries involved – China PR, EU and USA

Applicant – NOCIL Limited

Period of investigation – 1^st April 2023 to 30^th June 2024

Injury period – 1^st April 2020 to 31^st March 2021, 1^st April 2021 to 31^st March 2022, 1^st April 2022 to 31^st March 2023 and the period of investigation.

Margins and recommended duties –

Key findings –

• The product under consideration is ‘Sulphenamides Accelerators’. The scope of PUC includes only CBS and NS forms of the PUC.
• CBS and NS can be considered as a single PUC since they have similar raw materials, manufacturing process, physical and technical characteristics, function and end users. Further, their cost structures also exhibit a parallel movement.
• CBS and NS have been considered two separate PCNs for the PUC.
• The product produced by the domestic industry is a like article to the imported product.
• Apart from the applicant, there is one other producer of the subject goods in India, viz., Finorchem Limited.
• NOCIL Limited is an eligible domestic industry within the meaning of Rules and satisfies the criteria of standing.
• The adoption of fifteen-month period of investigation is appropriate since the selected period facilitated ease of data preparation and verification without causing any distortion or skewness in the analysis, given the comparable volume and value of imports during the relevant period.
• The rules do not prescribe for reasons to be provided for adopting a period shorter or longer than twelve months, specifically within the initiation notification.
• Dumping margin is above de minimis and significant.
• Imports from subject countries in absolute terms have increased over the injury period.
• Imports in relation to production and consumption increased in the period of investigation in comparison to immediately preceding year.
• Landed price for each of the subject countries is significantly below the selling price of the domestic industry.
• The imports are undercutting the prices of the domestic industry.
• The landed price is significantly below the cost of sales of both the PCNs in the period of investigation.
• The imports are suppressing the prices of the domestic industry.
• Capacity utilization of the domestic industry declined in the period of investigation.
• Despite increase in demand in the period of investigation, the production of the domestic industry declined.
• The domestic sales of the domestic industry declined in the period of investigation. The sales volumes of the domestic industry are materially lower than it could have achieved.
• The domestic industry’s market share has reduced in the period of investigation, and that of the subject countries have increased.
• Average inventory of the domestic industry increased in the period of investigation.
• Profitability parameters, cash profit and ROI of the domestic industry have declined in 2021-22, turned negative in 2022-23, and continued to remain negative despite improvement in the period of investigation.
• While the growth of the domestic industry in the period of investigation has been positive in price parameters, the domestic industry continues to suffer losses. The production and domestic sales have recorded a negative growth in the period of investigation.
• The ability of the domestic industry to raise capital investment has been severely impacted.
• Material injury caused to the domestic industry is due to dumping of the PUC from subject countries.
• The injury margin is positive and significant.
• Since the share of PUC in the overall raw material cost, total cost and sales value of the tyre producers is 0.54%, 0.36% and 0.32% respectively, impact of anti-dumping duty on the downstream industry will be negligible. 
• The cumulative impact of anti-dumping duty on all products (either attracting duty or where duty has been recommended by the Authority) on the downstream tyre industry is negligible.
• Barring the subject countries and the domestic industry, there is one other producer in India, namely Finorchem Limited. Therefore, the anti-dumping duty will not lead to any monopoly for the domestic industry.