The Rubber Duty DGTR Recommended, Then Never Charged

India's Directorate General of Trade Remedies holds an oral hearing today, 14 August 2026, in a new anti-dumping investigation into Halo-Isobutene-Isoprene Rubber (HIIR) - halogenated butyl rubber, used in tyre inner liners, hoses, seals and conveyor belts - imported from China, Singapore and the United States. Anyone tracking this case only through 2025 headlines could be forgiven for thinking India already protects this industry: DGTR investigated the same rubber from Singapore and the US once before, alongside Japan, Russia and the UK, and recommended anti-dumping duty on all five countries back in December 2024.

That recommendation is not the same as a duty. According to the domestic industry's own submission - recorded in DGTR's notification opening this second investigation - the December 2024 duty was never actually imposed. Singapore- and US-origin HIIR has apparently been trading duty-free the entire time since. A fresh, multi-month process is now under way to get a duty in place a second time, and today's hearing is part of it.

What today's hearing is actually about

The case is F. No. 6/59/2025-DGTR (Case No. AD(OI)-51/2025), initiated on 31 October 2025 after an application from Reliance Sibur Elastomers Private Limited, the sole Indian producer of HIIR. The product covers both Bromobutyl Rubber (BIIR) and Chlorobutyl Rubber (CIIR) - made by halogenating Isobutylene-Isoprene Rubber (IIR) - and is classified under HS Code 4002 3900, though DGTR's own notification records it has also entered India under three other HS codes during the injury period and states plainly that the customs classification is "indicative" only and "not binding on the scope" of the investigation. An importer relying on a single tariff line to decide whether a shipment is in scope is reading the wrong document.

The oral hearing itself has already moved once: DGTR's Designated Authority originally scheduled it for 3:30 PM, then issued a notice on 11 August preponing the start time to 12:00 Noon.

The 2024 recommendation that didn't become a duty

DGTR's prior HIIR case - F. No. 6/19/2023-DGTR, initiated 30 September 2023 - covered the same product from Japan, Russia, Singapore, the United Kingdom and the United States. Its Final Findings, dated 28 December 2024, concluded that dumping from all five countries was retarding the establishment of India's only domestic HIIR plant, and recommended duty "for a period of 5 years from the date of notification to be issued in this regard by the Central Government" - duty running as high as $1,487 per tonne on some Singapore-origin shipments and reflecting dumping margins DGTR itself described as ranging from 10% to 70% across the subject countries.

That five-year clock depends on a Central Government notification actually being issued. The same recommendation-to-notification gap surfaced two days earlier, in Phthalic Anhydride's anti-dumping case. This second investigation's own initiation notice, filed roughly ten months after the December 2024 recommendation, records the applicant's account of what happened in between: "since anti-dumping duty was not imposed pursuant to the findings, the domestic industry has continued to suffer retardation to its establishment." Whatever the reason on the government's side, the practical result the applicant describes is a recommendation that sat unconverted for the better part of a year, by the applicant's own account as of the date it filed this second case.

Why the country list changed

The new investigation's subject countries are China PR, Singapore and the United States - not the five from 2023. Singapore and the US carry over from the earlier case; Japan, Russia and the UK drop out entirely; China PR appears for the first time. For China specifically, the applicant is separately asking DGTR to apply non-market-economy treatment under Article 15(a)(i) of China's WTO Accession Protocol when constructing normal value - a distinct legal question the 2023 case never had to address, since China wasn't a subject country then.

None of this is a sunset review or a continuation of the 2023 case. It is a fresh original investigation, with its own period of investigation (1 July 2024 to 30 June 2025) and its own injury-analysis window running back to April 2021. Two of the three countries under scrutiny are being investigated for the second time on the same allegation, without the first investigation's recommendation ever having taken legal effect in between.

What a well-run import operation checks now

The practical exposure sits with anyone sourcing HIIR from China, Singapore or the US, or downstream buyers of tyres, hoses or conveyor belting made with it. DGTR's notification is explicit that a party who does not respond within the prescribed time limit - or whose response is incomplete - risks having findings recorded against it on the basis of "facts available," the adverse-inference standard that applies when an interested party stays outside the process rather than inside it.

Two checks follow directly from what is actually in the record, rather than from how the 2024 case was reported at the time. First, HS Code 4002 3900 is a starting point, not a boundary - DGTR has already said so in writing, and a customs classification review is not a substitute for checking the investigation's own product description. Second, nothing in the public record from this investigation states that a duty on Singapore- or US-origin HIIR is currently in force; the domestic industry's own account is that the opposite has been true since December 2024. A compliance calendar that logged "HIIR duty imposed" after the 2024 recommendation was reported is logging a step that, on the applicant's own telling, never happened.

Source note: This article is based on DGTR's initiation notification for Case No. AD(OI)-51/2025 (F. No. 6/59/2025-DGTR, dated 31 October 2025), its oral hearing notices (7 August and 11 August 2026), and the Final Findings in the earlier related case (F. No. 6/19/2023-DGTR, dated 28 December 2024) - all published on the Directorate General of Trade Remedies' own site, dgtr.gov.in.