Final Findings issued in anti-dumping investigation (material retardation) on imports of N, N’-Dicyclohexyl Carbodiimide (DCC) from China (24.02.2022)

Product description – Dicyclohexylcarbodiimide, which is also known as N, N’- Dicyclohexyl Carbodiimide, DCC and 1, 3- Dicyclohexylcarbodiimide (DCC). It is an organic compound with chemical formula (C6H1 1N)2C.

HS Codes – 2921 2990, 2924 1900, 2924 2990, 2925 1900, 2925 2910, 2925 2990, 2933 3990 and 2941 9090.

Uses – DCC is the key raw material in antiretroviral drugs like Valaliclovir and Amikacin. It is used to couple amino acids during artificial peptide synthesis. It is also used in glutathione dehydrants as well as in the synthesis of acid anhydride, aldehyde, ketone and isocyanate.

Country involved – China

Applicant – Clean Science and Technology Limited

Date of Initiation – 25th February 2021

Period of Investigation – 1st January 2020 to 31st December 2020 (12 months).

Injury Period – 2017-18, 2018-19, 2019-20 and the period of investigation.

Margin and Proposed Duty –

Country Producers Dumping Margin (Range) Injury Margin (Range) Proposed Duty (US$/MT)
China Shandong Huihai Pharmaceutical and Chemical Co., Ltd 0-10 10-20 493.73
Non-cooperative / residual exporters 10-20 20-30 826.75

Key Findings-

  1. Clean Science and Technology Limited is the first producer of DCC in India and started production in January 2020.
  2. Since the consumers were majorly dependent upon imports from China prior to commencement of production of DCC in India, the entry and existence of CSTL will establish fair competition in the market.
  3. The Authority has determined that CSTL is not an established industry in India for production of DCC based on four factors, that are, overlap of existing facilities, time of establishment, size of the industry and stability of production.
  4. Material retardation is required to be examined with reference to the product and not with reference to the company. While CSTL is an established company, it is a new and nascent industry for production of DCC.
  5. Subject imports have caused material retardation to establishment of domestic industry in India as the volume of imports have remained high even after domestic industry started production, domestic industry was forced to sell at low prices due to dumped imports in India and it was unable to fetch its target prices, the inventories have increased during the period of investigation, the domestic industry has incurred losses and recorded a negative return on investment.
  6. Even though the performance of the domestic industry was positive in certain parameters, it was much adverse as compared to what it could have been in the absence of dumping in the country.
  7. In the absence of dumping, the domestic industry could have sold to the extent of production, would not have faced accumulation of inventories and would have been able to earn profits, cash profits and return on investment.
  8. The injurious effect of dumping is evident from the fact that CSTL has been in existence for 17 years and is well established for production of other products in the pharmaceutical market. However, it is unable to find a remunerative market for its newly developed product.
  9. Non-injurious price for the company could have been higher in case it would have been a new company at a new location and without any other past history of production. In such a case, the level of protection determined could have been higher.
  10. The domestic industry has the capacity to cater to entire demand in India. However, even if there is a demand-supply gap in the country, it does not justify dumping.