Provisional Assessment Ordered for Insoluble Sulphur Imports from China During Anti-Absorption Review
The Central Government has directed that imports of Insoluble Sulphur originating in or exported from the People’s Republic of China will now be subject to provisional assessment pending the outcome of an anti-absorption review investigation. This measure has been introduced following a recommendation by the Directorate General of Trade Remedies (DGTR), which found prima facie evidence suggesting possible absorption of the existing anti-dumping duty.
It is important to note that this order does not suspend or replace the existing anti-dumping duty. Instead, it introduces an additional compliance mechanism to safeguard revenue until the review is completed.
What is the Background of the Case?
The anti-dumping framework relating to Insoluble Sulphur has evolved through multiple regulatory actions.
Existing Anti-Dumping Duty
The DGTR, through its Final Findings dated 7th March 2025, recommended the imposition of anti-dumping duty on imports of Insoluble Sulphur originating in or exported from:
- People’s Republic of China
- Japan
Based on these recommendations, the Ministry of Finance issued Notification No. 13/2025-Customs (ADD) dated 6th June 2025, imposing anti-dumping duty on these imports.
Why Has a New Review Been Initiated?
On 20th March 2026, the DGTR initiated an Anti-Absorption Review Investigation concerning imports from China.
Purpose of the Anti-Absorption Review
An anti-absorption review examines whether exporters have effectively neutralized the impact of anti-dumping duties by reducing export prices or adopting pricing practices that absorb the duty instead of passing it on to buyers.
The DGTR observed prima facie evidence indicating possible absorption of the anti-dumping duty by Chinese exporters, warranting further investigation.
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What Has the Government Ordered?
Importers will also need to comply with an additional requirement.
Guarantee for Differential Anti-Dumping Duty
The proper officer of Customs may require importers to furnish an appropriate guarantee covering any differential anti-dumping duty that may become payable after completion of the review investigation.
If the review ultimately results in an increase in the anti-dumping duty, the guarantee will protect the Government’s ability to recover the additional amount.
Requirement to Furnish a Customs Guarantee
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Importers will also need to comply with an additional requirement.
Guarantee for Differential Anti-Dumping Duty
The proper officer of Customs may require importers to furnish an appropriate guarantee covering any differential anti-dumping duty that may become payable after completion of the review investigation.
If the review ultimately results in an increase in the anti-dumping duty, the guarantee will protect the Government’s ability to recover the additional amount.
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What Does This Mean for Importers?
Importers sourcing Insoluble Sulphur from China should carefully evaluate the compliance implications.
Key Practical Impact
- Imports will undergo provisional assessment instead of final assessment.
- Customs authorities may insist on furnishing a financial guarantee.
- Final anti-dumping liability may change after completion of the review.
- Importers should retain complete documentation for future assessments.
- Businesses should consider the potential financial exposure arising from any differential anti-dumping duty.
Note
The existing anti-dumping duty imposed under Notification No. 13/2025-Customs (ADD) dated 6th June 2025 continues without any change on imports of Insoluble Sulphur originating in or exported from China and Japan.
The present notification merely introduces provisional assessment for imports from China during the pendency of the anti-absorption review. It does not withdraw, suspend, or modify the existing anti-dumping duty.
Key Takeaways
Importers should note the following:
- Provisional assessment applies only to imports from China.
- The anti-absorption review has been initiated based on prima facie evidence.
- Customs may require guarantees for potential differential duty.
- Existing anti-dumping duty remains fully applicable.
- The arrangement will continue until the Government issues its final decision after completion of the review.
Conclusion
The Government’s decision to introduce provisional assessment reflects a precautionary approach while the anti-absorption review is underway. Although the existing anti-dumping duty remains unchanged, importers of Insoluble Sulphur from China should prepare for additional compliance requirements, including provisional assessments and possible financial guarantees.
Businesses involved in importing the subject goods should closely monitor the progress of the DGTR review, maintain adequate documentation, and assess the potential impact of any future revisions to anti-dumping duties to ensure smooth customs clearance and regulatory compliance.
Notification Reference: 13/2026-Customs (ADD)
03/07/2026
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