Continuation of Anti-Dumping Duty on TDI (80:20) Imports – Regulatory Analysis
The Government of India has continued the anti-dumping duty on imports of Toluene Di-Isocyanate (TDI) having isomer content in the ratio of 80:20, classified under tariff item 29291020, originating in or exported from the European Union and Saudi Arabia.
This decision follows a sunset review conducted by the Directorate General of Trade Remedies (DGTR), which concluded that discontinuation of the existing anti-dumping duty would likely result in continuation of dumping and consequent injury to the domestic industry.
The notification has been issued under Section 9A of the Customs Tariff Act, read with the Anti-Dumping Rules, 1995, and shall remain in force for five years unless revoked, amended, or superseded earlier.
Legal Framework and Statutory Basis
Section 9A – Authority to Impose Anti-Dumping Duty
Section 9A empowers the Central Government to impose anti-dumping duty where:
- Goods are exported to India at less than their normal value;
- Such dumping causes or threatens material injury to domestic industry;
- There exists a causal link between dumping and injury.
In the present sunset review, the Designated Authority concluded:
- There is a likelihood of continuation of dumping if duty is withdrawn.
- Domestic producers remain vulnerable to price suppression and undercutting.
- Injury margins justify continued trade remedial action.
The Government, after considering the final findings, has continued the measure to preserve fair trade conditions.
Scope of the Product Under Consideration
Product Description
- Toluene Di-Isocyanate (TDI)
- Isomer ratio: 80:20 only
- Tariff Item: 29291020
- Customs classification is indicative and not binding on scope.
Important Clarification
Only TDI with 80:20 isomer composition is covered.
All other grades and compositions of TDI are explicitly excluded.
Anti-Dumping Duty Structure – Producer-Specific Rates
The anti-dumping duty is imposed as a specific amount per Metric Ton (MT), denominated in USD but payable in Indian currency based on the exchange rate notified under Section 14 of the Customs Act, 1962.
S.No. | Tariff Item | Description of Goods | Country of Origin | Country of Export | Producer | Amount | Unit | Currency |
(1) | (2) | (3) | (4) | (5) | (6) | (7) | (8) | (9) |
1 | 29291020* | “Toluene Diisocyanate (TDI) having isomer content in the ratio of 80:20** | European Union | Any country including European Union | Covestro Deutschland AG | 221.04 | MT | US$ |
2 | -do- | -do- | -do- | -do- | BorsodChem Zrt | 102.05 | MT | US$ |
3 | -do- | -do- | -do- | -do- | Any producer other than mentioned in S. No. 1 & 2 above | 264.96 | MT | US$ |
4 | -do- | -do- | Any country other than countries attracting anti-dumping duty | European Union | Any | 264.96 | MT | US$ |
5 | -do- | -do- | Saudi Arabia | Any country including Saudi Arabia | Sadara Chemical Company | 217.55 | MT | US$ |
6 | -do- | -do- | -do- | -do- | Any producer other than mentioned in S. No. 5 above | 344.33 | MT | US$ |
7 | -do- | -do- | Any country other than countries attracting anti-dumping duty | Saudi Arabia | Any | 344.33 | MT | US$ |
Duration and Applicability
- Effective for five years from publication in the Official Gazette.
- Subject to earlier revocation, amendment, or supersession.
- Duty payable in Indian currency.
- Exchange rate applicable: As notified under Section 14 of the Customs Act, 1962.
- Relevant date: Date of presentation of Bill of Entry under Section 46.
Economic and Strategic Implications
Impact on Importers
Importers must:
- Factor in specific per-MT duty while calculating landed cost.
- Review long-term supply contracts.
- Validate producer-specific sourcing to optimize duty exposure.
- Ensure accurate product composition certification (80:20 ratio).
Failure to properly declare origin, producer, or isomer composition may trigger reassessment, penalties, and interest liabilities.
Impact on Domestic Industry
Continuation of the duty provides:
- Protection against price undercutting.
- Stability in domestic pricing.
- Incentive for capacity utilization and investment.
- Level playing field against subsidized or dumped imports.
From a policy perspective, the measure reinforces India’s commitment to calibrated trade defence rather than protectionism.
Compliance Advisory for Trade Stakeholders
Importers Should:
- Obtain manufacturer certificates confirming isomer ratio.
- Maintain origin documentation.
- Cross-check producer-specific duty rates before clearance.
- Monitor exchange rate notifications regularly.
- Conduct periodic internal customs audits.
CFOs and Trade Heads Should:
- Recalculate procurement cost models.
- Evaluate alternate sourcing geographies.
- Assess inventory stocking strategy.
- Incorporate duty exposure into pricing contracts.
Policy Perspective
The continuation of anti-dumping duty signals a strong enforcement posture by the Government in protecting domestic manufacturing against unfair trade practices.
At the same time, the structured producer-specific rate design ensures proportionality and avoids blanket trade restrictions.
The measure reflects a balanced trade defence mechanism aligned with WTO principles and domestic industrial priorities.
Conclusion
The continuation of anti-dumping duty on TDI (80:20) imports from the European Union and Saudi Arabia underscores the Government’s strategic approach to trade remedy enforcement.
For importers, the decision necessitates enhanced compliance vigilance and strategic sourcing. For domestic producers, it ensures continued market stability and protection from injurious dumping.
Stakeholders must proactively realign procurement, pricing, and compliance frameworks to mitigate risk and optimize trade efficiency under the extended anti-dumping regime.
Notification Reference: CBIC
Notification No:03/2026-Customs (ADD)
10-Feb-2026