MINISTRY OF COMMERCE & INDUSTRY
DEPARTMENT OF COMMERCE
(DIRECTORATE GENERAL OF ANTI-DUMPING & ALLIED DUTIES)
NOTIFICATION
NEW DELHI, the 21st September, 2002
PRELIMINARY FINDINGS
Sub: Anti-Dumping Investigation concerning imports of Caustic Soda from People’s Republic of China and Korea RP.
No.14/10/2002-DGAD - Having regard to the Customs Tariff Act 1975 as amended in 1995 and the Customs Tariff (Identification, Assessment and Collection of Anti-Dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995, thereof:
A. PROCEDURE
2. M/s Shanghai Chlor Alkali Chemical Co. Ltd., PR China
3. M/s Tricon Energy Limited, USA
Response/information to the questionnaire/notification was filed by the following exporters/producers:-
Response/information to the questionnaire/notification was filed by the following Importers/user Associations.
Additional information from M/s Hanwha Chemical Corporation, Korea RP was also sought, which was provided.
xiv) The Authority kept available non-confidential version of the evidence presented by various interested parties in the form of a public file maintained by the Authority and kept open for inspection by the interested parties as per Rule 6(7).
Cost investigation was also conducted to work out optimum cost of production and cost to make and sell the subject goods in India on the basis of Generally Accepted Accounting Principles (GAAP) and the information furnished by the petitioner. The cost of production data of the following companies were considered and examined appropriately:--
B . VIEWS OF EXPORTERS, IMPORTERS AND OTHER INTERESTED PARTIES
1. PETITIONER’S VIEWS
(i) The name of the product being dumped into the Indian market is Sodium Hydroxide generally known as Caustic Soda. Caustic Soda is chemically known as NaOH. It is an Inorganic Chemical classified under Chapter 28 of the Custom Tariff Act. Caustic Soda is a soapy, strongly alkaline odourless liquid widely used in diverse industrial sectors, either as a raw material or as an auxiliary chemical. It is mainly used in the manufacture of pulp and paper, newsprint, viscose yarn, staple fibre, aluminum, cotton, textiles, toilet and laundry soaps, detergents, dyestuffs, drugs and pharmaceuticals, vanaspati, petroleum refining etc. Caustic soda is produces in two forms- lye and solids. Solids can be in the form of flakes, prills, granules or any other form. All forms of caustic soda are the subject matter of the present petition.
Caustic Soda causes burn on contact with body tissues. Contact with eyes causes severe damages, swallowing results in severe injury. Caustic soda mist causes momentary stinging sensation in nose and throat. It reacts with strong acid very violently under boiling phenomena.
.(ii) Caustic Soda is a basic product very widely used in diverse industrial sectors, either as a raw material or as an auxiliary chemical. It is mainly used in the manufacture of pulp and paper, newsprint, viscose yarn, staple fiber, aluminum, cotton, textiles, toilet and laundry soaps, detergents, dyestuffs, drugs and pharmaceuticals, vanaspati, petroleum refining.
(iii) Three technologies are available world over for production of Caustic Soda. The Indian industry is producing Caustic Soda using all the three processes. The three processes are:
(iv) Even though all three technologies are being used in India for manufacturing Caustic Soda, Mercury Cells technology and Membrane Cells technology are being widely used in India.
(v) Indian Caustic Soda industry has been largely able to meet entire requirement of Caustic Soda in India. The Indian industry was self-sufficient in its requirement ever since 1975. As mentioned in previous para, Caustic Soda has been in the list of imports permitted under OGL particularly for actual users since 1980-81. The imports were, however, limited because of the pricing policy of the Indian industry. The capacities installed by the producers in China and Korea are far higher than the requirement in their own country. Further, with the imposition of anti-dumping duties on a number of other countries, the producers in the subject countries are finding it lucrative to export to India. The excess capacities in these Countries have put tremendous pressure on the producers to look for markets outside their country. Resultantly, the exporters from China and Korea have quoted very low prices for exports to India. It would also be relevant to point out that the producers in these countries have at times not directly offered for supplies to India. Substantial volumes have been offered by traders in third countries for supply of Caustic Soda originating in these Countries. The offers being by traders, naturally, these traders have taken care of their margins also. The prices quoted by the producers in these Countries are, therefore, still lower. The petitioners believe that the prices offered are far below the associated cost of production. Thus, the exporter from China and Korea has resorted to dumping of Caustic Soda in the Indian market.
b) DOMESTIC INDUSTRY
(i) DCW Limited a multi product company involved in production of various products such as Soda Ash, Caustic Soda (Lye, Solid and flakes), Calcium Chloride, Soda Bicarbonate, Aluminum Bicarbonate, Salt etc.
(ii) Gujarat Alkalies & Chemicals Limited is also a multi- product company involved in production of wide range of products which include Caustic Soda, Chlorine Gas, Hydrochloric Acid, Hydrogen gas, Sodium Cyanide, Sodium Hydrochloride, Sodium Ferrocyanide, Methyl Chloride, Chloroform, Carbon Tetrachloride, Potassium Hydroxide, Potassium carbonate, Phosphoric Acid, Hydrogen Peroxide etc.
(iii) Search Chem. is a subsidiary of United Phosphorus Limited. SCIL is a multi product company involved in production of various chemicals such as Yellow Phosphorus, Iso Propyl Bromide, Thio di Phenol, Methylene Gluotaronirite, Acetyl Bromide, Para Nitro Benzyl Alcohol and Triphenyl Phosphorus Thionate etc. The company is also involved in production for Power i.e. Electricity.
(iv) Grasim Industries Limited is a flagship company of Aditya Vikram Birla Group. Grasim Industries Limited is a multi product, multi location and well diversified company involved in production of various products such as Viscose Staple fibre, White Cement, Sulphuric Acid, Carbon Domestic industry Sulphate, Rayon grade pulp, Paper, Stable Bleaching Powder, Man Made Fibre Fabrics, Man Made Fibre Yarn, Gray Cement, Articles of Cement Concrete, Industrial Machinery, Poly Aluminum Chloride, Chloro Sulphonic Acid, and Sponge iron, etc.
(v) Andhra Sugars Limited is a multi product, multi location company involved in production of Sugar, Acetic Acid, Industrial Alcohol’s, Sulphuric Acid, Superphosphate, Chlorosulphonic Acid, Oleum, Aspirin, Carbon Dioxide, Alum, Diffusers, Chemical Equipment, Sugar Factory Boiling House Equipment’s, Unsymmetrical Dimethyl Hydrazine, Cotton Seeds etc, Richburn and oil cakes processing, Refinery, Hydrogenation of oils, cattle and poultry feed, wind power, electricity, etc.
(vi) Bihar Caustic, Jayshree Chemicals, and SIEL (Chemical Complex) are involved in production of Caustic Soda and it’s by-products only.
c) LIKE ARTICLE
(i) There is no difference in the Caustic Soda produced by the Indian industry and imported from China and Korea. Caustic Soda produced by the Indian industry in general and the participating companies in particular is comparable in terms of characteristics such as physical & chemical characteristics, raw material composition, functions & uses, product specifications, pricing, distribution & marketing and tariff classification of the goods. The two are technically and commercially substitutable. The consumers have used the two interchangeably. Caustic Soda produced by the domestic industry should be treated as like article to Caustic Soda imported from subject countries within the meaning of the anti-dumping Rules.
(ii) As discussed earlier in this petition, world-over, Caustic Soda is being produced by three processes. Indian industry is also producing Caustic Soda using all the three processes. However, difference in process does not mean difference in the product in terms of its physical & chemical properties, product specifications, marketing, pricing, consumer perceptions, tariff classification, etc.
(i) Producers in from China and Korea are involved in dumping the goods in India. The dumping has been largely resorted through traders in third Countries. However, the supplies were planned directly from these Countries.
(ii) Caustic Soda is a basic inorganic chemical and is used by a number of industries as raw material. It is primarily traded in bulk quantity and, therefore, the shipments are normally directly from the countries of origin. However, in the instant case and particularly in the tender floated by NALCO for purchase of very significant volumes, traders in third Countries have participated wherein the supplies have to be made directly from the subject countries.
(iii) NALCO had recently floated a tender for 100000 MT of Caustic Soda. A number of exporters participated in the tender floated by NALCO. The quantity of the tender floated is very significant.
(iv) Exporters from subject countries as well as other country against which investigation is under progress or which are now attracting duties participated in the tender. Details of the tender floated, exporter’s name, agent’s name, quantity offered, price offered, revised price offered, negotiated price at which order has placed by NALCO, landed value of imported material etc. are given in the "tender detail"..
(v) It may be seen that NALCO has placed its orders for 87000 MT, which is more than combined imports of Caustic Soda in a year in India.
(vi) In addition to China and Korea RP, exporters and producers from Indonesia are also dumping Caustic Soda in the Indian market. It is the market information of the domestic industry that around 3500 MT material is shortly landing the custom port in India. It would be worthy to mention here that earlier the domestic industry had filed a petition for imposition of Anti Dumping Duty inter-alia on Indonesia. However, the investigations were not initiated against Indonesia. Getting benefit of the situation i.e. imposition of Anti Dumping Duty against some other countries and no duty on imports from Indonesia, the producers and exporters from Indonesia have now found this a good opportunity to dump the material at times of serious decline in the export price from several countries and faced with surplus unutilized capacity.
(vii) Efforts were made to get information on prices at which Caustic Soda is being sold by the exporters from Korea RP in their domestic market. We have also made efforts to get price lists of the exporters or price evidence for their exports to other countries or any other information from the published sources. We have been able to get information about the prices in domestic market of Korea RP from a leading international Journal. Reliance is being placed on the information published in the Chlor Alkali in this regard.
(viii) Chlor alkali regularly reports the prices of Caustic Soda in the domestic market in Korea . Thus, considering the prices given in the Chlor Alkali, calculation of normal value in Korea RP have been done.. The normal value on this basis comes to US $ 227 pmt in case of Korea RP.
(ix) Massive dumping of Caustic Soda in the Indian market is causing material injury to the domestic industry. Further, the order placed by NALCO would cause further material injury to the domestic industry, as may be seen from the para on "Evidence of Injury".
e) INJURY
(iii) Our market intelligence suggests that a lot of dumped material is under transit and shipment is expected very shortly. Should the present trend of order booking continue, the domestic industry would loose significant sales.
(viii) The Sales volumes of the participating companies as provided to the Authority indicate that sales of the participating companies, which has been increasing till 2000-01 declined in the April-December 2001. Further, the sales volumes are likely to remain low, considering the significant volume of sales lost by the domestic industry.
(ix) The imports of Caustic Soda from the subject countries have increased dramatically. From a situation of off-and-on imports, the imports made by NALCO alone would be more than the combined volume of imports from all the countries and capacities of many a producers in the Country. The volume of imports is contained in Proforma IV-A. Further, dramatic increase in imports has resulted in significant increase in share of imports in (a) imports of Caustic Soda in India; and (b) demand of Caustic Soda in India.
(x) Production of the participating companies are given in Proforma IV A. It may be seen that the production of the participating companies, which has been increasing till 2000-01 declined in the April-December 2001. Moreover, the petitioners submit that the change in the production level alone may not indicate injury to the domestic industry. More important parameter is the price at which offers for sale have been made by the exporters from the subject countries and the prices at which the domestic industry has been forced to sell or may be forced to sell in view of the dumped imports from the subject countries.
(xi) Caustic Soda industry has provided very large-scale employment in the Country. Any sickness in the industry would have crippling effect on the employment.
(xii) The petitioners have lost significant sales due to the dumped imports. The NALCO order lost is a significant loss of sales for the domestic industry.
(xiii) Profitability of the participating companies is given in Proforma A. It may be seen that the domestic industry is making huge losses.
(xiv) Imports of Caustic Soda from Other Countries (excluding countries already attracting anti-dumping duties or countries against which investigation is under progress), are de-minimus or are at a price not causing any injury to Indian industry.
(xv) Demand of the Caustic Soda is increasing continuously. In fact, the demand has registered significant growth over the past five years. The domestic industry has sufficient capacity to meet the requirement of the Country. The changes in the demand have, therefore, not contributed to any injury to the domestic industry.
(xvi) Material injury has been caused to domestic industry from dumped imports from the subject countries. As stated elsewhere in the petition also, the domestic industry is producing Caustic Soda for the several years. The technology adopted by the domestic industry is comparable to the technology adopted by the exporters. There is no significant difference in the manufacturing process. . It is submitted that the lowering of prices by the exporter from the subject countries alongwith the dumped imports from Other Countries (which are already attracting duties are against which the investigations are in progress) is the reason for the present injury to the domestic industry.
1. M/S NALCO
a) PRODUCT UNDER CONSIDERTION
(i.) MANUFACTURE OF VALUABLE BY PRODUCTS ALONGWITH CAUSTIC SODA - The Petition deliberately does not disclose the fact that the process of manufacturing Caustic Soda also leads to the manufacture of Chlorine and Hydrochloric Acid. The Petition itself admits that the Petitioner is engaged in protecting the interests of the domestic producers of not only Caustic Soda but also Chlorine, which goes on to show that there is a substantial monetary benefit obtained from the production of Chlorine. This is neither reflected in the particulars furnished by the Petition with respect to the cost of production being apportioned between the two products nor is the realisation resulting from the Chlorine mentioned therein. It is submitted that the cost realisation of the Chlorine is substantial and any Petition with respect to Caustic Soda would be incomplete without the examining the Chlorine production as regards both determination of dumping and injury. This fact is also important as the description of the domestic industry expressly specifies that all the companies are multi product companies or are engaged in the production of Caustic Soda by products. The implications on the cost of production are dealt with in greater detail subsequently in the present response.
(ii) NALCO verily believes that the Petitioner has also filed a petition for imposing Anti Dumping Duty on Chlorine. It is further verily believed that the domestic industry has sought to make out a case of dumping and injury therein by attributing the entire production cost towards production of Chlorine. In light of the aforesaid, it is respectfully submitted that the Hon'ble Authority in accordance with its powers under R. 8 of the Anti Dumping Rules, 1995 should seek a declaration on affidavit with respect to Chlorine petition or through such other appropriate means from the Petitioner, in order to verify the accuracy of the information furnished the in present Petition. The Hon'ble Authority has in the past sought such an assurance in the investigations initiated with respect to the import of Iso Propyl Alcohol, Case No. 12/1/ 2000 DGAD.
(i). The inclusion and support of the domestic producers mentioned in the Petition does not disclose the true factual picture with respect to the act solely responsible for the present Petition i.e. the NALCO tender. An examination of the NALCO tender in question (the Tender) and the other tenders of NALCO in the past would clearly disclose the absence of any cause of action in favour of the domestic producers specifically supporting in the Petition. The industries expressly supporting the present Petition have not in past participated in the tenders of NALCO due the cost logistics arising from their geographical location. The members of the domestic industry who have participated in the tender process have either insufficient quantities to satisfy the tender quantity or have expressed their inability to transport the quantity. A detailed description of the logistical problems is set out hereinbelow.
(ii) NALCO’s annual requirement of Caustic Soda for manufacture of Alumina is approx. 100,000 DMT on 100% NaOH basis. The Caustic Soda is purchased in lye form with approx. 50% NaOH content. As such, total quantity of Liquid Caustic Soda required by NALCO works out to 200,000 MT
(iii) The problem associated with supply of caustic soda to NALCO is that its alumina plant is located at Damanjodi, which is at a higher altitude. Therefore the railway does not allow 4 wheel wagons for dispatch to Damanjodi and thus supply can only be made through 8 wheel wagons with air break system. Such wagons being not available with railway, therefore none of the Caustic Soda domestic manufacturers can supply NALCO by rail.
(iv) Given the peculiar nature of Caustic Soda and as also admitted in Petition i.e. a quantity of Caustic Soda supplied would be twice the amount needed under a tender, at 50% NaOH basis, even supply by road tankers is not an economically viable option. A road tanker can carry only limited quantity of approximately 5 – 6 DMT (10 – 12 Liquid MT Caustic Soda). Therefore, only industries, which are geographically proximate from Damanjodi like M/s. Andhra Sugar, M/s. Rayalaseema (in Andhra Pradesh) and M/s. Jayshree Chemicals in Orissa, are able to use the road route option. Even with respect to the aforesaid industries the quantity supplied are small for reasons mentioned above.
(v) Accepting larger quantity by road is problematic for unloading at plant given the quantity supplied in a tanker. For supply of 2,000 DMT in a month number of tankers to be handled works out to 400 nos. i.e. 16 – 20 tanker a day. As such, accepting more tankers will be physically improbable because for supply by tankers, samples are required to be collected from each tanker and analysed for specification confirmation and weighment. The process of verification is time consuming and involves additional cost for testing.
(vi) The major supply to NALCO comes through the Vizag port from sea, where it has its own Caustic Soda storage tanks to store approx. 30,000 Liquid MT. NALCO uses its own railway tank wagon for transporting Caustic Soda from Vizag to Damanjodi. As regards supply by sea only 2 domestic suppliers namely M/s. DCW and M/s. SPIC had offered to use the sea route. It is stated that none of the domestic manufacturers on western coast of India including but not limited to those supporting the Petition have offered to supply Caustic Soda using the sea route to NALCO due to high freight element. M/s. IPCL had once offered to sell Caustic Soda to NALCO subject to the condition that NALCO should arrange for lifting the same from the IPCL plant, which was not acceptable to NALCO given the logistic problems in transportation mentioned above. It is further stated manufacturers on the western coast either do not have arrangements for shipment by sea or sea freight to Vizag and are unable to supply Caustic Soda to NALCO.
(vii) In light of the aforesaid the Petitioner's true motivation of seeking the support of the domestic producers mentioned is adequately borne out, namely to ride on the shoulders of the industries not actually supplying NALCO and to ensure that the Petition does not suffer from the lack of numbers required to fall within the definition of domestic industry under R. 2(b) of the Customs Tariff (Identification, Assessment and Collection of Duty or Additional Duty on Dumped Articles and for Determination of Injur) Rules, 1995 (the Anti Dumping Rules). The aforesaid rule sets out the definition of "domestic industry" and requires that the domestic producers filing the Petition should constitute a major proportion of the total domestic production. Though the domestic producers constitute a major proportion of the domestic production the definition of domestic industry in the facts and circumstances of the present case would have to be determined in accordance with the proviso to the aforesaid rule under sub clause (ii), which reads as follows:
"Provided that in exceptional circumstances referred to in sub rule (3), of Rule 11, the domestic industry in relation to the article in question shall be deemed to comprise two or more competitive markets and the producers within each of such market would constitute a separate industry if-
(i) the demand in the market is not in any substantial degree supplied by the producers of the said article located elsewhere in the industry"
(viii) Therefore the investigation of the Hon'ble Authority should be confined to the domestic producers actually participating in the NALCO tenders in the past i.e. from 1994-95 to 2001-2002. The capacity utilisation, cost of production and injury determination should be sought specifically from the aforesaid producers. A table listing out the various domestic producers who have supplied/offered to supply NALCO alongwith the quantity offered is provided on confidential basis.
c) LIKE ARTICLE
d) INJURY
vii. The Alkali Association represents the Association of Indian Manufacturers of Caustic Soda and Chlorine. Most of these manufacturers have multi-product plant and part of the Chlorine and in some cases 100% Chlorine is utilized by them for manufacture of value added products and they get larger margins by selling Chlorine. For them, Caustic Soda is only a by-product. The very purpose of Anti Dumping Petition by the Alkali Manufacturers is to increase the indigenous price of Caustic Soda in the country. Through Alkali Manufacturers Association these manufacturers have conspired to keep Caustic Soda price at a level, which will be just lower than the imported price of Caustic Soda with Anti Dumping Duty. It may be mentioned here that out of the countries, who are capable of exporting Caustic Soda to India due to Petition by these Alkali Manufacturers Association and due to non-participation of the countries on whom Dumping was alleged, Anti Dumping Duty have been levied in respect of 5 countries i.e. USA, France, Saudi Arabia, Iran and Japan. Provisionally Anti Dumping Duty has also been imposed from imports from Qatar. With imposition of Anti Dumping Duty from Korea and China almost 90% of exporting countries of the world that can export Caustic Soda will get covered. It may be seen that in March, 2002 when the whole world can buy Caustic Soda at the prevailing market price of US$ *** FOB and considering average freight of US$ *** from most of the countries of the world to India the landed price would have been US$ *** C&F. Against this with Custom Duty of 35% then applicable, the landed price works out to US$ ***. Against this the Hon’ble Authority should consider the landed price as US$ *** which is arrived at by taking into account the Anti Dumping Duty applicable now. The additional implication per MT over normal international price works out to approx. US$ *** per MT with an exchange rate of Rs.48.38 this works out to Rs. *** per MT. For NALCO’s requirement of 100,000 DMT the additional implication will be Rs. ***. When any Aluminum Manufacturers in the world can buy at a price of US$ *** per DMT with the imposition of Anti Dumping Duty in India, NALCO will be forced to buy at US$ ***. This will only make Indian Aluminum Industry non-competitive and will give rise to increase in indigenous price of Aluminum, which will result in import of Aluminum. The Indian Alkali Industries who are already producing almost to the full capacities and their productions are increasing their profit margin are increasing, but inspite of above, they want further profit by imposition of Anti Dumping Duty which is against the object and spirit of India’s commitments to the WTO. There is no injury to indigenous industries and on the contrary this Anti Dumping Duty is solely motivated by the desire of the indigenous manufacturers to join hands and increase the price of Caustic Soda much above their cost of production and gain supra competitive profits. The Designated Authority should look into this game plan of Alkali Association and should reject their Petition in view of misrepresentation, suppression and submission of distorted facts.
d) DUMPING
2. M/S Grasim
(i) M/s Grasim has submitted that they have never imported Caustic Soda from any country till now rather have purchased Caustic Soda from Indian manufacturers.
a) INJURY & OTHER ISSUES
4. M/s Deepak Nitrite Limited, Nandesari
a) INJURY & OTHER ISSUES
While announcing the Normal Value of China, the Authority has considered the price of Caustic Soda Lye only and the prices of other products such as chlorine, hydrochloric acid and hydrogen does not appear to have considered.
3. EXPORTER’S VIEWS
1. M/S TRICON ENERGY LIMITED, USA
a) STANDING OF THE PETITIONER
(i) The petitioners claim that the petition is being filed by M/s Alkaline Manufacturers Association of India. Further in the petition, "participating companies" data is produced for the injury analysis.
(ii) It is respectfully submitted that this is contrary to the Anti Dumping laws and practice in India. All the supporting petitioners must provide full and complete data for this proceeding. Clearly data of "participating companies cannot be the basis for injury to the industry as a whole. In fact it may well be the case that the data of the "non "participating companies" might indicate that there is no injury at all.
b) PRODUCT UNDER CONSIDERATION
The product under consideration as defined by the petitioners is "Sodium Hydroxide" generally known as Caustic Soda. Caustic Soda is chemically known as NaOH. It is an organic chemical classified under Chapter 28 of the Customs Tariff act. Caustic Soda is produced in two forms –lye and solids. Solids can be used in the form of flakes, prills, granules or any other form. All forms of Caustic Soda are the subject matter of the present petition.
The high purity characteristic is descriptive of the very low concentrations of contaminants in the product. Salt, or NaCI, is typically less than 10 ppm, with a maximum of 30 ppm. Sodium Chlorates, or NaCIO3 are typically 0.5 ppm, with a maximum limit of 1 ppm. Sodium Carbonates, or Na2CO3, are typically 0.02 weight %, with a maximum limit of 0.06 weight %, Sodium Sulfates, or Na2SO4, are typically 10 ppm, with a maximum of 20 ppm.
The mercury cell produced Caustic Soda is typically referred as Mercury Cell Grade, or more commonly, Rayon Grade. Most product of rayon fiber is dependent on the availability of the high purity Rayon Grade Caustic Soda solution. Another very common use of this high purity caustic solution is for Domestic Industry water exchangers. The Domestic Industry unit resin literature often specified Rayon Grade Caustic Soda only for regeneration. One must remember that this literature was published prior to the availability of membrane cell produced solution.
The quality considerations with respect to the diaphragm cell produced Caustic solutions include relatively high salt, chlorates, carbonates, and sulfates. Salt as NaCI, concentrations are typically 1.0% with maximums raning from 1.1 to 1.3 weight %, depending on producer. Sodium Chlorates are typically 0.15 weight %, with a maximum of 0.3 weight %. Sodium Carbonates are typically 0.1 weight %, with a maximum of 0.2 weight %. Sodium Sulfates are typically 0.01 weight %, with a maximum of 0.02 weight %.
The diaphragm cell produced Caustic Soda is often referred to as Diaphragm Cell Grade. It is also called Commercial Grade. Technical Grade, and occasionally Technical Diaphragm or other similar combinations.
An additional ‘Grade’ of Caustic Soda produced by the diaphragm cell process is the purified Grade. The production of Purified Grade involves the further evaporationof the 50% Diaphragm Grade Caustic Soda solution to reduce the salt concentration. The higher Caustic Soda concentration forces precipitation of the salts, which are soluble in Caustic Soda solution in an inverse relationship. The higher concentration solution is then re-diluted to the 50% concentration that is commercially available as Purified Grade Caustic Soda.
Common uses include process and wastewater neutralization, textiles production, soaps and detergents and aluminum production. These uses and applications generally will refer to the Caustic Soda as any of the various grades previously addressed, dependent on supplier’s terminology.
The high purity characteristic is descriptive of the low concentrations of contaminants in the product. Salt, or NaCI, is typically less than 30 ppm, with a maximum of 75 ppm. Sodium Chlorates, or NaCIO3 are typically 3 ppm, with a maximum limit of 5 ppm. Sodium Carbonates, or Na2CO3 are typically 0.03 weight %,, with a maximum limit of 0.05 ppm. Sodium Carbonates, or Na2SO4, are typically 15 ppm, with a maximum of 20 ppm. Note that these limits are Olin specific, with some slight deviation to be expected amongst the various membrane cell operation.
The Caustic soda produced by the membrane cell process is most commonly referred to as Membrane Grade.
c) INJURY AND CAUSAL LINK
Without any prejudice to the aforesaid, it is respectfully submitted that the Domestic Industry could not have been injured by the minimal supplies made by M/s Hanwha Chemical Corporation and M/s Tricon Energy Limited pursuant to the NALCO tender.
a) PRODUCT UNDER CONSIDERATION
+ the price movements of EDC > VCM >PVC
(v) For all the above two factors one of the basic raw materials is Chlorine –
now, if the international market demands more PVC, it means that the demand of Chlorine is high, now to produce more Chlorine, more of Caustic Soda will be generated. So, while looking into the pricing factors, the other related factors may kindly be looked into before coming to any conclusion and determination of prices.
(vi) Further the global practice is to produce primarily Chlorine and thus Caustic Soda as by-product, whereas in India it seems to be otherwise.
b) INJURY
3. CHLOR SHANGHAI CHEMICAL CO. LTD. , PR CHINA
C. EXAMINATION BY AUTHORITY
The foregoing submissions made by the exporter, petitioner and other interested partiesw, to the extent these are relevant as per Rules and have a bearing upon the case, have been examined, considered and dealt with at appropriate places in these findings.
The product under consideration in the present investigation is Sodium Hydroxide (chemical nomenclature NaOH), commonly known as Caustic Soda originating in or exported from Korea RP and PR China. Caustic soda is an inorganic, soapy, strongly alkaline and odourless chemical and finds application in various fields like manufacture of pulp and paper, newsprint, viscose yarn, staple fibre, aluminium, cotton, textiles, toilet and laundry soaps, detergent, dyestuffs, drugs and pharmaceuticals, petroleum refining etc.
Caustic soda is classified under chapter 28 of the customs Tariff Act, 1975 under Customs Head 2815.11 and 2815.12. As per ITC Eight Digit classification, the product is classified under the Custom Heading 2815.1101, 2815.1102 and 2815.1200. The classification, is however, indicative only and is in no way binding on the scope of the present investigation.
Caustic soda is produced in two forms, i.e. lye and solids by three technology processes, i.e mercury cell process, diaphragm process and membrane process.
Caustic Soda can be imported under OGL and attracts a basic customs duty of 35%. The present investigation covers all forms of caustic soda.
The Authority notes that it has been mentioned by various interested parties that the three different types of production process of caustic soda produces different quality of caustic soda. It has also been indicated that the Membrane type process is used by a very few producers in India. Further it has been mentioned that 99% caustic soda be excluded from the purview of the scope of the investigation.
The Authority however notes that both M/s Tricon Energy Ltd., USA and M/s Hanwha Chemical Corporation, Korea RP have indicated an adjustment of 5 $/MT on the basis of the membrane technology as indicated in the NALCO’s tender. The Authority therefore notes that M/s NALCO has loaded an adjustment of 5$/MT for such a technology depending on its own requirements and the Authority has appropriately considered this adjustment while evaluating the dumping margin for M/s Hanwha Chemical Corporation. Therefore the Authority notes that the difference in terms of quality can best be addressed by way of appropriate adjustment as and when evidenced and claimed. The adjustment granted to M/s Hanwha Chemical Corporation has been for the purpose of preliminary determination pending final determination. The Authority also notes that the investigation covers all forms of caustic soda both Lye and flakes and all that are different forms of the same subject goods and are used substitutably depending on the requirement of the user. The two forms in various concentrations are therefore the subject matter of the investigation. The Authority further for the purposes of dumping margin has made appropriate comparisons on DMT basis only.
2. LIKE ARTICLE
The Authority notes that the petitioner has claimed that the goods produced by them are like article to the goods produced, and exported from the subject country. Also both are technically and commercially substitutable and the consumers are using the domestically produced and imported goods interchangeably. It has been indicated that the Caustic soda is processed by three processes viz. Mercury cells process, diaphragm process and membrane process world over. The difference in these processes does not mean difference in product in terms of various characteristics. Also there is no significant difference in the cost of production for the three processes. The petitioner has claimed that the goods produced by them and those exported from the subject countries are like article within the meaning of the Rules. The Authority in view of submissions made by other interested parties and keeping in view the substitutability and interchangeability of the goods exported from subject countries and those produced by the Domestic Industry, considers the subject goods exported and the domestically produced subject goods as like article as per Rule 2(d) for the purpose of preliminary determination pending final determination.
3. DOMESTIC INDUSTRY
The petition has been filed by M/s Alkali Manufacturers Association of India on behalf of the domestic industry. The petition has been supported by M/s DCW Limited, Mumbai, M/s Gujarat Alkalis & Chemicals Limited, Vadodara Gujarat, M/s Gujarat Alkalies, Dahej, M/s Search Chem Industries Limited, Mumbai, M/s Indian Rayon and Industries Ltd., Veraval, Gujarat, M/s Grasim Industries, Nagda, M.P, M/s SIEL Chemical Complex, Patiala, Punjab, M/s Bihar Caustic & Chemicals, Ltd., Jharkhand, M/s Jayshree Chemicals Limited, Orissa, M/s Andhra Sugars Limited, Tanaku , Bilt Chemicals, DCM Sriram, New Delhi and Punjab Alkalies & Chemicals, Chandigarh. None of the domestic producers has opposed the petition.
The Authority notes that various interested parties have mentioned that only a limited number of domestic producers participated in the NALCO’s tender and that shipping the goods to NALCO by domestic producers is a costly affair because of the high inland freight. It has been indicated that the Domestic Industry definition be limited to these producers who have actually participated in NALCO’s tender. The Authority does not consider this argument appropriate since NALCO happens to be only one of the consumers of caustic soda. Also the Authority notes that inability to supply in a cost effective manner to NALCO is a matter to be appropriately considered under injury examination and not to be addressed for the scope of the Domestic Industry. Also the Authority notes that in any event of any displacement of the domestic producers situated in proximity to NALCO, the injury occurring to them would eventually be transmitted to the other domestic producers. However the dumping of goods and their imports by NALCO is to be appropriately addressed as per Anti Dumping Rules. Therefore the argument of the interested parties that suppliers and non-suppliers to NALCO form two different competitive market does not hold merit..
The Authority also notes that the domestic producers who have supported the petition constitute more than 50% of the total domestic production and therefore have the standing to file the petition on behalf of the domestic industry as per Rule 5 (3) (a) and (b) of the Anti-Dumping Rules and also represent Domestic Industry in terms of Rule 2(b)
4. NORMAL VALUE & EXPORT PRICE
Under Section 9A(1)(c), normal value in relation to an article means:
(i) the comparable price, in the ordinary course of trade, for the like article when meant for consumption in the exporting country or territory as determined in accordance with the rules made under sub-section (6); or
(ii) when there are no sales of the like article in the ordinary course of trade in the domestic market of the exporting country or territory, or when because of the particular market situation or low volume of the sales in the domestic market of the exporting country or territory, such sales do not permit a proper comparison, the normal value shall be either:-
(a) comparable representative price of the like article when exported from the exporting country or territory or an appropriate third country as determined in accordance with the rules made under sub-section (6); or
(b) the cost of production of the said article in the country of origin along with reasonable addition for administrative, selling and general costs, and for profits, as determined in accordance with the rules made under sub-section(6);
Provided that in the case of import of the article from a country other than the country of origin and where the article has been merely transshipped through the country of export or such article is not produced in the country of export or there is no comparable price in the country of export, the normal value shall be determined with reference to its price in the country of origin.
The normal value and ex-factory export price determination is illustrated below.
A. NORMAL VALUE
1. M/S SHANGHAI CHLOR CHEMICAL ALKALI CO. LTD. PR CHINA
The Authority notes that the exporter has provided details on sales in their home market of ion exchange Membrane Grade Caustic Soda (48%) during the Period of Investigation (POI). The ex-factory export price has been indicated as ****$/Dry Metric Tonne (DMT). The exporter has provided the cost of production of the subject goods during the POI as ****$/DMT. The weighted average domestic sales price has been shown to be making profits and thereby in the ordinary course of trade. In claim of market economy/individual treatment, the exporter has indicated that they are established in accordance with the Company Law of China and is a public listed company at the Shanghai Stock Exchange. The exporter independently operates business and production activities, freely selects suppliers and customers and develops sales markets in response to the signals of the market. The Authority in this regard notes the specific provisions in the notifications pertaining to Anti Dumping Rules No.28/2001 dated 31st May, 2001 and Notification No. 1/2001 dated 4th January, 2002 in which the conditions for ‘non-market economy’ country has been defined. In the Notification dated 4th January, 2002, a country would be presumed as non-market economy in case the country has been determined to be or has been treated as non-market economy for the purpose of an anti dumping investigation by the Designated Authority or by the competent Authority of any WTO member country during the three year period preceding the investigation.
The Authority also notes that information pertaining to various specified criteria has been sought for from the cooperative exporter in order to consider the rebuttal on the treatment as non-market economy. On perusal of the response provided by the exporter, it is noticed that only a broad statement of fact has been provided regarding the operation on the market signals but no specific information on various criterion as listed in the Custom Notification dated 4th January, 2002 has been provided with adequate evidence to justify treating the exporter to be operating on the market principles. The Authority therefore for the purpose of preliminary determination pending final determination does not propose to consider the broad statement provided by the exporter as a justification for their being operating on the market economy principles. The Authority also recalls that the China has been treated as non-market economy in Steel Concrete Reinforcing Bar by PR China to USA dated 22.6.2001, Bicycles by China to EU dated 30.6.2001 and Non-Frozen Apple Juice Concrete by China to EU dated 13.4.2000during the last three years. This has also been indicated in the preliminary finding pertaining to dumping of STPP from China and Chinese Taipei which have also been implemented by the Department of Revenue vide their Notification dated 17.6.2002. The cost data of the subject goods as available from the petitioners which has been duly normated by adopting the best practices on constructed cost of production with appropriate adjustments to arrive at the constructed Normal Value as per Annexure 1 to the Anti Dumping Rules and Section 9A(1)(c)(ii) (b) of the Customs Tariff Act, 1975 as amended in 1995. The constructed Normal Value of the subject goods has therefore been referenced as ****$/DMT for the POI. The Authority in this regard also notes that the data furnished by the exporter on the ex-factory domestic selling price and the ex-factory export price also indicates the incidence of dumping to an extent of ****$/DMT.
B. EXPORT PRICE
The Authority notes that the exporter has provided the ex-factory export price of the subject goods during the POI as ****$/DMT and have also claimed adjustments of ****$/DMT as discounts/commission and have provided the ex-factory export price as ****$/DMT. The Authority on the basis of the information provided by the exporter has correlated the exports made by the exporter with the response provided by M/s NALCO, the importer of the subject goods during the POI.
The Authority for the purpose of preliminary determination pending final determination has considered the ex-factory export price as provided by the exporter and allowed the adjustments on discounts/commission.
The ex-factory export price comes to ****$/DMT. The Authority in this regard also notes the submissions made by the exporter that the appropriate comparison for the purpose of dumping margin be made i.e. 48% subject goods should be compared with 48% of the subject goods and 100% concentration of the subject goods should be compared with 100% of the subject goods. In the instant case, the Authority notes that the export price has been provided on the DMT basis and that the Normal Value as indicated above has also been computed on the DMT basis for the purpose of comparison.
C. ASSESSMENT OF NON-COOPERATING PRODUCERS/EXPORTERS FROM PR CHINA
A. NORMAL VALUE
The Authority notes that none of the exporters other than M/s Shanghai Chlor Alkali Chemical Co. Lt.d, PR China has responded to the questionnaire sent by the Authority for the purpose of investigation. In view of this non-cooperation, the Authority upholds the claim of the petitioners for treating such producers/exporters on the non-market principle. Keeping in view the treatment as considered in various EU/ES cases cited above, the Authority has therefore constructed the normal value by adopting normated cost of production by benchmarking best practices.
The Authority has referenced the Normal Value for such producers/exporters as ****$/DMT.
B. EXPORT PRICE
The Authority notes that the export price has been provided by the petitioners on the basis of the data collected by them from DGCI&S and other secondary prices. The petitioners have also claimed adjustments on ocean freight, ocean insurance, commission, inland freight, port expenses and credit cost to an extent of ****$/DMT, ****$/DMT, ****$/DMT, ****$/DMT, ****$/DMT and ****$/DMT respectively. The Authority notes that as per the DGCI&S data imports of subject goods to an extent of 8210 MT have been shown from PR China. As per the response of one of the cooperating importer viz. M/s NALCO, the imports from PR China are shown to an extent of 26505 MT. The DGCI&S data is therefore not exhaustive and complete and therefore cannot be referenced. Since NALCO is one of the importer, there would be other imports of the subject goods made by other importers which may not have been reflected in the DGCI&S data. Also no response has been received from the Customs regarding the details of the imports made during the POI. Since the best available information under such circumstances for the non-cooperating exporter could only be the information as available from the cooperating exporter, viz. M/s Shanghai Chlor Alkali Co. Ltd. whose export price also happens to be the lowest on the basis of the information as available with the Authority, the Authority considers it appropriate to reference this export price for the non-cooperating exporters from PR China. The adjustments allowed on the CIF on account of ocean freight, ocean insurance, commission, inland freight and port expenses to an extent of ****$/DMT, ****$/DMT, ****$/DMT, ****$/DMT and ****$/DMT respectively
The ex-factory export price is referenced as ****$/DMT.
KOREA RP
M/S HANWHA CHEMICAL CORPORATION, KOREA RP.
A. NORMAL VALUE
The Authority notes the response filed by the exporter regarding their domestic selling prices of subject goods during the POI. The Authority notes that the transaction wise details on the domestic selling price for the POI has been provided by the exporter during the POI. The exporter has claimed adjustments on the domestic sales on account of discounts, inland freight, inland insurance and others to an extent of ****$/DMT, ****$/DMT, ****$/DMT and ****$/DMT respectively. The exporter has also submitted that the domestic sales made during the period as near to the period of exports to India should be referenced for the purpose of appropriate comparison. The Authority notes that the sample evidence pertaining to the domestic selling price has been provided by the exporter. The exporter has claimed an adjustment on account of inland freight to an extent of ****$/DMT which has been substantiated by the exporter by way of expenses incurred on the freight component.
The Authority for the purpose of preliminary findings pending final determination has considered the adjustments as claimed on the inland freight. The Authority for the purpose of preliminary determination pending final determination also allows the other adjustments on inland insurance and commission. The Authority has referenced the domestic selling price for the period December, 2001-March, 2002 which is comparable to the period of exports made to India for the purpose of determination of the Normal Value. The Authority also notes that the cost of production of subject goods as claimed during the POI indicates that the domestic selling prices are in the ordinary course of trade. However the Authority has considered this cost of production for the purpose of preliminary findings pending final determination.
Therefore for the purpose of preliminary determination pending final determination, the Authority has referenced the Normal Value as ****$/DMT.
The Authority notes that the exporter has provided the ex-factory export price as ****$/DMT. The exporter has provided export price to M/s Tricon Energy Limited, USA who in turn have exported the subject goods to India during the POI. Further the exports have been made through M/s Hanwha Corporation, the trading arm of M/s Hanwha Chemical Corporation. The exporter has claimed adjustments on account of discounts/commission to M/s Hanwha Corporation to an extent of ****$/DMT. The Authority has also correlated the exports made by M/s Tricon Energy Limtied, USA to M/s NALCO, the importer of subject goods in India who have provided the CIF price of the subject goods during the POI to India. The Authority for the purpose of final determination pending final determination has considered the adjustments as claimed by the exporter on discounts, adjustment on terms of sales as per NALCO’s tender and adjustment on previous transaction sales to M/s Tricon to an extent of ****$/DMT.
The ex-factory export price comes to ****$/DMT.
C. ASSESSMENT OF NON-COOPERATING PRODUCERS/EXPORTERS FROM KOREA RP
A. NORMAL VALUE
The Authority notes that none of the exporters other than M/s Hanwha Chemical Corporation, Korea RP has responded to the questionnaire sent by the Authority for the purpose of investigation. In view of this non-cooperation, the Authority has constructed the normal value on the basis of the data provided by the petitioners by referencing the best normated cost of production.
The Authority has referenced the Normal Value for such producers/exporters as ****$/DMT.
B. EXPORT PRICE
The Authority notes that the DGCI&S data indicates the imports from Korea RP to an extent of 56 MT. The Authority notes that one of the importers viz. M/s NALCO has provided response indicating imports from Korea RP to an extent of 6270.43 MT whereas the exporter has during this period exported quantity to an extent of 12569 MT. Thus the information as provided by DGCI&S does not capture the import data fully and is being lowest and best available information. Therefore the CIF price of M/s Hanwha Chemical Corporation has been referenced for the non-cooperating exporters as well. The adjustments on the export price are considered on ocean freight, ocean insurance, commission, port and inland freight to an extent of ****$/MT, ****$/MT, ****$/MT, ****$/MT and **** $/DMT respectively on the basis of the information made available by the petitioners and the cooperative exporter.
The ex-factory export price comes to ****$/DMT.
5. DUMPING-Comparison of Normal Value & Export Price
The rules relating to comparison provides as follows:
"While arriving at margin of dumping, the Designated Authority shall make a fair comparison between the export price and the normal value. The comparison shall be made at the same level of trade, normally at ex-works level, and in respect of sales made at as nearly possible the same time. Due allowance shall be made in each case, on its merits, for differences which affect price comparability, including differences in conditions and terms of sale, taxation, levels of trade, quantities, physical characteristics, and any other differences which are demonstrated to affect price comparability."
The authority has carried out weighted average normal value comparison with the weighted average ex-factory export price in Period of Investigation, for evaluation of the dumping margin for all the exporter/producers of the subject country.
The dumping margin for exporter/producers comes as under:
SI.No. |
Exporter/Producer |
Ex-factory Export Price ($/MT) |
Dumping Margin as % of EP |
1. |
KOREA RP 1. Hanwha Chemical Corporation. 2. Other producers/exporters |
**** **** |
Deminimis 53.22 |
2. |
PR CHINA 1.M/s Chlor Shanghai Chemical Co. Ltd. 2. Other producers/exporters
|
**** **** |
74.02 80.03 |
6. INJURY AND CAUSAL LINK
Under Rule 11 supra, Annexure-II, when a finding of injury is arrived at, such finding shall involve determination of the injury to the domestic industry, "…..taking into account all relevant facts, including the volume of dumped imports, their effect on prices in the domestic market for like articles and the consequent effect of such imports on domestic producers of such articles…." In considering the effect of the dumped imports on prices, it is considered necessary to examine whether there has been a significant price undercutting by the dumped imports as compared with the price of the like article in India, or whether the effect of such imports is otherwise to depress prices to a significant degree or prevent price increases, which otherwise would have occurred, to a significant degree.
For the examination of the impact of the dumped imports on the domestic industry in India, we may consider such indices having a bearing on the state of the industry as production, capacity utilisation, sales quantum, stock, profitability, net sales realisation, the magnitude and margin of dumping, etc. in accordance with Annexure II(iv) of the rules supra.
As regards the threat of injury, the Authority notes that the Anti-Dumping Rules states as follows:
"A determination of a threat of material injury shall be based on facts and not merely on allegation, conjecture or remote possibility. The change in circumstances, which would create a situation in which the dumping would cause injury, must be clearly foreseen and imminent. In making a determination regarding the existence of a threat of material injury, the DA shall consider, inter-alia, such factors and;
The Authority notes that various interested parties have mentioned that it is in totality that the price of chlorine and hydrochloric acid along with caustic should be considered. It has also been mentioned that the domestic producers of caustic soda in India are using obsolete technology and have high cost of production on account of electricity cost. The issue of high inland freight for supply to NALCO has also been indicated.
It has also been further mentioned that there is an excess capacity in India which is leading to injury to the domestic producers. Submissions have also been made that world over chlorine is the main product and whereas in India it is the caustic soda which is the main product. The Authority after noting the above submissions holds that the non-injurious price has been evaluated for the various domestic producers by appropriately considering the sales realisation from the related products. Also in order to eliminate inefficiencies, the Authority has normated and benchmarked the best practices on utilisation of raw materials, utilities etc..
As regards the injury which could happen on account of higher cost of production in India, the Authority notes that under the Indian Anti Dumping Rules it is the lesser duty rule which is applied. Further in any event the anti dumping duties cannot exceed the dumping margin. Therefore in any event if injury to Domestic Industry which could exceed the dumping margin it is certainly not addressed under the Rules of the Anti Dumping.
However despite the above, the Authority appropriately considers the cost of production of the domestic producers and normates the same for determination of Non-Injurious Price (NIP). As regards the injury on account of inland freight is concerned, the Authority holds that the comparison of landed value of dumped goods with NIP is made at the ex-factory level which does not include the inland freight. Therefore the importer viz. Ms NALCO could import the material at non-dumped price and thereby may not place order on to the domestic producers in India in case the freight was consideration for them.
As regards the submissions on usage of obsolete technology is concerned, the Authority notes that the various domestic producers in India are using all the three technology and that the inefficiencies in the cost of production are appropriately considered while determination of the Non-Injurious Price. As regards filing of separate petitions on chlorine by the Domestic Industry is concerned, the Authority notes that the related product if at all comes for anti dumping duty investigation, its cost of production and non-injurious price would be appropriately considered as per the general accounting and costing principles
The Authority notes and observes the following economic parameters in the case of the domestic producers who have supported the petition:-
1999-00 |
2000-01 |
2001-02 |
|
Capacity (MT) |
830000 |
830000 |
842500 |
Production (MT) |
712146 |
730625 |
711556 |
Capacity utilisation (%) |
85.8 |
88.03 |
84.46 |
Sales (MT) |
588455 |
583221 |
544046 |
Net Sales Realisation (Rs/MT) |
**** |
**** |
**** |
Cost of production (Rs/MT) |
**** |
**** |
**** |
Imports all countries (MT) |
86743 |
73622 |
93291 |
Imports from China (MT) |
19 |
17 |
26505 |
Imports from Korea (MT) |
21 |
33 |
12569 |
Market share of imports from subject countries (%) |
.05 |
.07 |
41.88 |
Demand (MT) |
1477061 |
1488052 |
1510619 |
It could be seen from the above that :
7. INDIAN INDUSTRY’S INTEREST & OTHER ISSUES
The Authority notes that it has been indicated by M/s NALCO that the anti dumping duties would affect their export competitiveness. The Authority in this regard holds that there are various schemes under the EXIM policy which permit imports of goods for export production without levy of anti dumping duty. Therefore there are appropriate schemes which an exporter could avail of for the purpose of export production. The Authority also holds that the purpose of anti-dumping duties, in general, is to eliminate injury caused to the Domestic Industry by the unfair trade practices of dumping so as to re-establish a situation of open and fair competition in the Indian market, which is in the general interest of the country.
The Authority also recognises that though the imposition of anti-dumping duties might affect the price levels of the products manufactured using the subject goods and consequently might have some influence on relative competitiveness of these products, however, fair competition in the Indian market will not be reduced by these anti-dumping measures. On the contrary, imposition of anti-dumping measures would remove the unfair advantages gained by the dumping practices and would prevent the decline of the domestic industry and help maintain availability of wider choice of the subject goods to the consumers. Imposition of anti-dumping measures would also not restrict imports from the subject country in any way, and, therefore, would not affect the availability of the products to the consumers.
The landed value of imports for the purpose shall be the assessable value as determined by the customs under Customs Tariff Act, 1962 and applicable level of custom duties except duties levied under Section 3, 3A, 8B, 9, 9A of the Customs Tariff Act, 1975.
It is seen, after considering the foregoing, that:
SI.No. |
Exporter/Producer |
Amount (US$/MT) |
1. |
KOREA RP All producers/exporters except M/s Hanwha Chemical Corporation |
353.4 |
2. |
PR CHINA 1.M/s Chlor Shanghai Chemical Co. Ltd. 2. Other producers/exporters
|
362.34 362.34 |
E. FURTHER PROCEDURE
The following procedure would be followed subsequent to notifying the preliminary findings:
(L V SAPTHARISHI),
Designated Authority