This piece was written by China Trade Monitor intern Khushi Kumar

Introduction:

India is the biggest user of Trade Remedy measures such as Anti-Dumping Duties (“ADD”) and Countervailing Duties (“CVD”), and it uses them against China most frequently. This piece maps and analyses India’s behaviour in terms of imposing ADDs and CVDs against China over the past decade or so.

As part of this, the piece looks at what may be driving these ADD and CVD orders. Factors include: economic pressures such as Chinese overcapacity, the kinds of industries that get targeted, geopolitical events such as border tensions and US tariffs, and the way India’s own decision-making turns a complaint into an order.

A key focus of the piece is why the number of orders has moved in waves, and how much of that movement each of these factors can explain. One part of the puzzle is the apparent contrast between improving diplomatic relations and the continued imposition of adversarial orders. It is worth noting that India and China have taken several steps to repair their relationship over the last two years. In October 2024, the two countries agreed on patrolling arrangements at Depsang and Demchok, the last two friction points on the Line of Actual Control, which the government said completed the disengagement of troops (the agreement was later reported as implemented, though de-escalation is still under discussion). Narendra Modi and Xi Jinping then met on the sidelines of the BRICS summit in Kazan, Russia, in October 2024, where they endorsed the agreement. In August 2025, Modi visited China for the SCO summit in Tianjin, his first visit to China in seven years, and the two leaders reaffirmed that India and China are development partners, not rivals. Direct flights, suspended for five years, resumed on 26 October 2025 with IndiGo’s Kolkata–Guangzhou service. In September 2026, Xi arrived in New Delhi for the BRICS summit hosted by India, his first visit to India in about seven years.

In terms of ADD and CVD orders, India has imposed about 150 ADD and 10 CVD orders between January 2016 and July 2026, including 20 ADD and 2 CVD orders in 2025 alone. The thaw dates from 2024, whereas the orders analysed here begin in January 2016, so most of the dataset predates it.

Each lens is applied to five periods in the data (2016–18, 2019–20, 2021, 2022–23 and 2024–25), because the factors that matter appear to differ from one period to the next.

The five periods do not share a single explanation. As the sections below show, the weight of each factor shifts between periods, and the data can show only that order counts move together with these factors, not that any one of them caused a particular year’s count.

So the real question is less “why did India impose these orders?” than “why did it impose them when it did?”

What the Data Shows:

Firstly, it is important to understand that India has a two-stage framework for imposition of Trade Remedy measures. The Directorate General of Trade Remedies (“DGTR”) established under the Ministry of Commerce, Government of India is the Designated Authority that investigates any complaints (applications) raised either by the Domestic Industry (“DI”) or suo motu. Upon considering the DI as well as the exporters’ arguments, it issues Final Findings that are recommendatory in nature. The second-stage consists of the Ministry of Finance, Government of India (“MOF”) adopting these recommendations and ultimately imposing any duty upon the exporters. Thus, there have been differing trends over the years in the number of investigations initiated and the number of orders finally imposed upon the subject country’s exporters.

This  piece largely consists of analysis on statistics related to investigations that definitively imposed duties upon China. It is important to understand that the number of investigations initiated each year is much higher than these final orders. There is a constant change in the trends of the MOF adopting the recommendations of the DGTR. This has led to various appeals and petitions to the Appellate Courts of the country to clarify the legal status of the DGTR recommendations and the requirement of the MOF’s justification on adoption of the same, currently pending adjudication.

As per the notifications released by the MOF, India has undertaken about 160 ADD/CVD investigations against China that have definitively resulted in imposition of duties. It can be observed that the trends have risen and dipped over the years, considering various factors discussed later in the piece.

The overall trend depicted by the data shows that the years 2016–18 saw 18, 23 and 19 orders respectively imposing duties against China, which is a high number as compared to subsequent years (wave). 2019–20 experienced a dip with 10 and 5 orders imposed respectively (trough), after which 2021 experienced a sudden high spike by imposition of duties on 23 products (spike). 2022–23 laid low with 9 orders each (trough), and 2024–25 went back to pre-COVID trends of 15+ orders per year (rebound).

Source: CBIC website
* 2026 data is limited to orders published through 27 July, 2026.

I have compiled a dataset containing further details regarding these orders imposed upon China in the past decade, along with orders currently active against China, which is linked here.

The sections that follow therefore test four possible explanations of the waves, namely economic pressure, industry structure, geopolitical events and institutional factors, and treat each as a possible contributor, not as a proven cause.

Economic Drivers:

Chinese overcapacity is one of the possible drivers of the rise in orders, and it is treated here as a background pressure, not as a complete explanation.

In the mid-2010s, state-led overinvestment in steel, aluminium, cement and glass left excess capacity that was never fully written off. That fits India’s 2016–18 orders. In March 2016, the Steel Ministry told Parliament that producers were complaining of an import surge, falling prices and shrinking profits. Nine of the 58 ADD orders in 2016–18 were on steel, all in 2017–18, though chemicals were larger at 21.

Because overcapacity pushes surplus output toward markets that remain open to it, India, as a large import market with a sizeable trade deficit with China, is a natural destination for diverted Chinese exports. This is a plausible channel, not a demonstrated one, because the dataset records orders and contains no import volumes or prices.

Secondly, it must be noted that there exists a theoretical rationale behind why such export pressures have arisen amongst the Chinese manufacturing industry. The body of literature referred to as “The China Shock” provides an insight into the consequences that arise due to such pressures faced by the importing countries. According to Autor et al., it was observed that between 1990 and 2007, there were sharp surges in imports coming from China into the United States, causing significant harm to local industries competing directly against them. For this reason, this framework shall only serve as a basis for understanding this phenomenon.

A new set of pressures arising again in 2020s is termed “China Shock 2.0”, wherein pressures exist in capital-intensive industries like chemical products and steel, along with low domestic demand. The Federal Reserve dates this second shock from about 2018 and describes export growth concentrated in capital and technology-intensive goods such as electric vehicles, batteries and machinery, so it forms a continuing backdrop to the whole period studied here, not only to its recent years.

Developing economies and the Global South, in general, face this pressure too. Reports indicate that a flood of inexpensive Chinese goods has contributed to the closure of more than 2,000 factories in Thailand, while Indonesia’s textile sector has reportedly lost tens of thousands of jobs to excess Chinese exports. Several other Global South economies, including Mexico, South Africa and Brazil, have responded with trade-restricting measures of their own. Anti-dumping use is widespread globally, and the OECD counted 395 steel measures in 2025 worldwide, 113 of them on China.

In 2019–20, global trade was weak, with volume down 0.1% in 2019 and 5.3% in 2020. India’s imports from China fell from $76.38bn (2017–18) to $65.26bn (2019–20) and held flat in 2020–21, but mostly because phone imports dropped from $15.59bn to $6.48bn. That says little about chemicals or steel. Only 11 ADD orders were imposed in these two years. It remains unclear what caused the 2019–20 trough. The pandemic does not obviously explain it: the 2019 dip came before COVID-19, and orders imposed in 2019–20 stem from cases initiated roughly 15 to 21 months earlier, that is, before the pandemic. Weak global trade, the start of the MOF’s higher rejection rate from 2020 and ordinary variation in the number of cases decided are possible contributors, but the dataset cannot separate them.

In 2021, pandemic supply-chain disruption may have amplified price pressure. That year, 15 out of 23 orders were chemical-related. However, owing to policy changes in 2022 due to input-cost worries, the government suspended trade remedies on several steel products, and only 18 orders were imposed across the two years. Taken together, the 2021 spike and the 2022–23 trough are better explained by how many recommendations the MOF adopted (see Institutional factors) than by import pressure alone.

The 2024–25 pattern is consistent with China Shock 2.0. China’s steel exports rose 21% in volume but fell 5% in value in the first three quarters of 2024, and 51% of firms surveyed in China saw overcapacity looming in chemicals. India imposed 41 total orders in these two years, and chemicals are half of 2024–26 orders.

It can thus be said that in relation to the Indian situation, this theoretical understanding helps identify how increased import surges and lower prices cause adverse effects on Indian industries. Consequently, they make their complaints known to the DGTR. Whether or not such findings are accepted by the MOF is something that cannot be determined beforehand. All the orders present within the linked dataset correspond to the above-explained trend, especially that concerning an increase in orders on chemicals which make up around half of the orders passed for 2024–2026. However, conclusive evidence cannot be generated owing to restrictions posed by the data itself.

More precisely, the dataset is consistent with the import-surge explanation but cannot confirm it, because it records orders and contains no import volumes, prices or injury findings. Since the Federal Reserve dates China Shock 2.0 from about 2018, it accounts for the backdrop and for the chemical share of recent orders, but not for the troughs of 2019–20 and 2022–23, which are examined under Institutional factors.

Industry factors:

Chemicals make up the largest proportion of products upon which duties are imposed. Combined with Pharmaceutical products, chemicals constitute about 47% of the total 150 ADD orders. Monoisopropylamine (MIPA) serves as a building block for pesticides and solvents, which makes it relevant to both farming and drug manufacturing. Toluene Diisocyanate (TDI) is a core raw material for foams and insulation, so its price feeds into the construction and automotive sectors, and Untreated Fumed Silica is a functional additive in paints, coatings and adhesives.

These chemicals are vital for several downstream industries, and the public-interest argument in investigations becomes highly relevant here. These dumped chemicals do not merely hamper the competitiveness of the Domestic Industries, but also make them more reliant on the whims of Chinese policies, further decimating India’s goals of Atmanirbharta, i.e. self-reliance.

The Steel industry has also invited a lot of trade-remedy measures against China in the past decade. Although the duty-imposing orders make up only about 11% of the dataset presented here, it can be observed that fresh investigations have repeatedly been initiated on products such as seamless tubes, flat-rolled steel etc., with a permutation of different subject-countries and differing rates of duties imposed. Apart from these ADDs, safeguard duties on steel have also been imposed from 2015, which have extended up to 2018. A fresh 12pc provisional safeguard duty on flat steel imports had also been recommended by the DGTR in 2025.

There was also an imposition of Minimum Import Price (“MIP”), a form of variable duty imposed as a policy-measure by the Directorate General of Foreign Trade (“DGFT”), without any quasi-judicial enquiry, in February 2016 on about 173 steel products. This was further extended in August 2016 to cover a trimmed list of 66 products. Right at the same time, several anti-dumping investigations against steel products from China and other countries were initiated. MIP ensures that imports fulfil a pre-determined floor-level price, and any imports falling below this price are restricted. This essentially filters out dumped products at a vast level. Although this measure has been argued to not be WTO-compliant, and in essence, qualify as a non-tariff barrier under GATT Article XI, however, these measures explain India’s treatment of imported steel in the concerned period.

Besides Chemicals and Metals such as Steel and Aluminium making up the predominant proportion of the orders, other products mainly consist of Plastics and Polymers, Automotive Components and Textiles. Repetition of some products like aluminium foil in 2017, 2021, 2025, and also R-134a and PVC paste resin in 2016 and 2025 suggest either entry of new exporters into the industry, or the lack of a deterrent effect upon these exporters’ trade-distortive practices.

Geopolitical factors:

It is important to analyse any correlation certain geopolitical factors may have with the present dataset, even if they may not have a direct impact on these duty-imposing orders. The impact of any geopolitical event would likely only be visible about 12-18 months afterwards, owing to the duration of the investigation as per the statutory rules, and the consequent adoption of the findings.

In 2016–17, China and other WTO members raised concerns about India’s use of anti-dumping, and China said India had opened 18 investigations against it in 2016. The Doklam standoff ran from mid-June to late August 2017, but the 22 ADD orders imposed in 2017 stem from cases initiated before it, so the standoff could have an impact only in later years. From 2018, US tariffs on Chinese goods redirected Chinese exports toward other markets, including South and South-East Asia. DGTR itself later cited the 2018 US Section 232 steel restrictions as having diverted trade flows to India, a channel economists call trade deflection. That evidence concerns steel, and applying the theory to India’s chemical, glass and machinery orders is an extension.

India’s decision not to join RCEP in November 2019, partly over the trade deficit with China, Press Note 3 in April 2020 and the Galwan clash in June 2020 mark a hardening of economic posture. Yet the filings were made by the domestic industry, and the MOF rejected 74 of about 130 recommendations from 2020 to mid-2023 and then accepted 22 of 24. That alone could produce the 2022–23 trough and the 2024–25 rebound, whatever the diplomatic climate. US tariffs on India reached 50% in August 2025 before easing in February 2026, but this was general pressure on India, not a request that it act against China. Because most 2025 orders stem from cases initiated in 2023–24, the 2025 tariffs cannot explain them. No comparable geopolitical trigger stands out for 2019–2020, when orders were among the lowest. In 2024–25, the thaw coincided with 41 orders, most of which stem from cases initiated before it.

Other economies have adopted China-targeted measures after US action, and one framing sees countries choosing between collective retaliation and individual accommodation of Washington. Whether India’s orders reflect alignment of this kind is a hypothesis this data cannot test. The timing is consistent with a lagged geopolitical influence but does not prove one.

Institutional factors:

As explained above, the DGTR makes findings of a recommendatory nature and the final imposition of ADD/CVD or safeguard duties is carried out by the MOF. In 2018, DGTR was created in the Department of Commerce, by merging the Directorate General of Anti-Dumping and Allied Duties (“DGAD”), the Directorate General of Safeguards and the safeguards (QR) functions of the DGFT. It has been observed by industry experts that in the DGAD-era, the MOF had a minimal rate of rejection of recommendations. From 2020-onwards, the rejection-rates increased substantially with 74 out of approximately 130 recommendations rejected (more than a 50% rejection rate).  The Union of India’s challenge before the Delhi High Court to orders of the Customs, Excise and Service Tax Appellate Tribunal (“CESTAT”), on the ground that reasons for rejection were required to be provided, has itself been the subject of litigation. In September 2025, the Delhi High Court was set to examine whether the CESTAT can hear challenges to the MOF’s notifications. The legal position regarding this remains unsettled as of this writing.

A turnaround in the acceptance rates is visible 2024-onwards, which is the other largest explanation of the ‘rebound’ increase in duty-imposition, besides various economic drivers, while the High Court’s decision is still awaited. This has also led to the domestic producers seeking fresh investigation into products upon which duties were not imposed earlier on account of rejection by the MOF. Three orders in the dataset illustrate the refiling of rejected products: textured tempered glass (8 May 2025), aluminium foil up to 80 micron (19 June 2025) and plastic processing machinery (26 June 2025), which were imposed after earlier recommendations on these products were reportedly rejected.

The Paradox:

It is important to consider that despite these procedural aspects, the MOF’s adoption of the findings is where things get political. Along with a surface-level diplomatic thaw in India-China geopolitical relations, the economic drivers cannot be ignored. China’s overproduction and low domestic demand, coupled with India’s heavy import-reliance on both intermediary and finished goods ultimately paves the way for China to engage in these trade-distortive practices in order to capture a large market-presence. The after-effects of the improvement in diplomatic relations 2024-onwards may not be directly visible in the dataset of 2025 or recent months yet. Two points from the dataset bear on timing. First, the 22 orders of 2025 stem from cases initiated roughly 15 to 21 months earlier, that is, mostly before the October 2024 patrolling agreement, so they could not reflect the thaw. Second, cases initiated after the thaw could produce orders only from about 2026, and the three ADD orders imposed up to 27 July 2026 are too few to show any change. The apparent contrast is therefore a contrast of timing as much as of policy.

Synthesis and Conclusion:

Reading the four lenses together, the dominant driver differs by period, and no single factor explains the whole decade. In 2016–18, economic pressure and industry structure do most of the work. Mid-2010s overcapacity in steel, aluminium and glass coincided with the MOF that had rejected fewer than 1% of DGTR’s recommendations before 2019, so petitions largely became orders.

The 2019–20 trough is best read institutionally, since rejections began in 2020, with weak global demand as context. Even so, this is the least well explained period: the 2019 dip came before the MOF’s higher rejection rate and before COVID-19, so neither explanation accounts for the whole trough, and its cause is left open. 2021 is the hardest period to explain. The count peaks in a year when rejections were also high. In 2022–23, peak rejection and input-cost concerns point to the institutional lens, and there is no obvious new geopolitical trigger.

The 2024–25 rebound combines an ‘economic driver’ with an ‘institutional reversal’. The economic driver is China Shock 2.0, which is dated from about 2018 and which shows in chemicals reaching half of 2024–26 orders. The institutional reversal is the ministry’s reversion into high acceptance rates mid-2023 onwards. Geopolitics appears as a lagged background influence, weakest in 2022–23 and in 2024–25, when a diplomatic thaw coincided with record order counts. This attribution is interpretive. Taken together, economic pressure sets the baseline, India’s institutional machinery shapes the waves, and geopolitics plays a smaller, lagged role, a reading the evidence is consistent with but cannot prove.