ASL LAW's guide to India stainless steel anti-dumping investigation

India initiates anti-dumping investigation on cold rolled stainless steel 300–400 series imported from China, Indonesia, and Vietnam

According to information from the Vietnam Trade Office in India, on September 29, 2025, the Directorate General of Trade Remedies (DGTR) of India issued a notice initiating an anti-dumping investigation on cold rolled flat products of stainless steel 300 and 400 series originating in or imported from China, Indonesia, and Vietnam.

This is one of the large-scale anti-dumping investigations in the steel sector initiated by India in 2025, reflecting the intense competition between imports and domestic production in this market.

Case details

  • Product under investigation: Cold rolled stainless steel 300–400 series, under HS codes: 721990, 721911, 721912, 721913, 721914, 721921, 721922, 721923, 721924, 721931, 721932, 721933, 721934, 721935, 721990, 722011, 722012, 722020, 722090. (The HS codes are for reference purposes only; the specific product scope is defined in the initiation notice).
  • Petitioner: Indian Stainless Steel Development Association (ISSDA). The petitioner alleged that India’s domestic cold rolled stainless steel 300–400 industry has suffered significant injury due to large volumes of imports from China, Indonesia, and Vietnam being dumped at abnormally low prices.
  • Product Control Numbers (PCN): The petitioner proposed a PCN system to differentiate product types within the scope of investigation. DGTR requires interested parties to submit comments, with detailed explanations, on the product scope and PCN system within 15 days from the initiation date. This is a key factor in determining dumping margins, as it directly relates to the comparison between normal domestic prices and export prices.
  • Period of investigation:
    • For dumping practices: April 1, 2024 – March 31, 2025.
    • For injury assessment: the financial years 2021–2022, 2022–2023, 2023–2024, and the dumping investigation period.

Obligations and deadlines for Vietnamese enterprises

Vietnamese producers/exporters of cold rolled stainless steel 300–400 must submit comments and questionnaire responses to DGTR within 30 days from the date of the initiation notice. If an extension is needed, enterprises may submit a written request to DGTR before the deadline.

DGTR emphasizes that if enterprises fail to submit on time or do not cooperate, the investigating authority may use adverse facts available to calculate dumping margins, potentially resulting in high anti-dumping duties. In cases where DGTR does not select mandatory respondents, all exporters are still required to respond to the investigation questionnaire.

Recommendations from the Trade Remedies Authority of Vietnam (TRAV)

To support enterprises in timely responding to the case, TRAV recommends:

  • Reviewing export activities of cold rolled stainless steel 300–400 to India in order to identify potential risks.
  • Studying India’s anti-dumping investigation regulations thoroughly, particularly on documentation and submission procedures.
  • Proactively submitting comments regarding the product scope and PCN system to safeguard the interests of Vietnamese enterprises.
  • Preparing questionnaire responses that are complete, truthful, accurate, and submitted on time. Enterprises may consider engaging legal and international accounting advisory services to minimize risks.
  • Coordinating closely with TRAV for updates, guidance, and timely support during the course of the investigation.

To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnam Antidumping Law Firm specializing in anti-dumping and trade remedy for timely assistance.

Related documents can be accessed here.

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