Product Control Number (PCN) is a methodology followed in trade defence investigations to compare identical types of Product under Consideration (PUC). Defining PCN facilitates dumping and injury margin calculations. PCN enables comparison of different types of PUC with much ease, and is therefore widely used by various countries in anti dumping, anti subsidy and other trade defence actions.

In investigations, PUC types’ cost/ price may vary significantly. In such circumstances, it becomes important to compare identical types. Article 2.4 mandates that a fair comparison shall be made between the export price and the normal value. This comparison shall be made at the same level of trade, normally at the ex‐factory level, and in respect of sales made at as nearly as possible the same time. Due allowance shall be made in each case, on its merits, for differences which affect price comparability, including differences in conditions and terms of sale, taxation, levels of trade, quantities, physical characteristics, and any other differences which are also demonstrated to affect price comparability. Therefore in order to ensure fair comparison, the product needs to be compared type to type basis in a situation where the cost and price of different product types vary significantly.

Cost/ Price of different types vary due to certain intrinsic and extrinsic characteristics of PUC, which are implicit in Product specifications. Certain products might have more than one specification‐ creating difficulty in comparing PUC types with domestic alike article of exporting country and PUC types with domestic alike article of importing country. And therefore, to simplify comparison “Product Control Number” is defined. Under PCN, each specification due to which cost/ price of types vary by more than ~ 5 to 10% are assigned a digit. Same combination of digits (PCN) means identical types.

Product Control Number is of significance to interested parties, as it can make a great difference in dumping and injury margins and final duty. Also, it is highly effective given its simplistic nature, and therefore, followed by many investigating authorities across the globe. European Commission uses PCN in virtually every anti dumping investigation1.

Indian trade defence action investigation authorities have used PCN in quiet a few investigations like anti dumping investigation concerning imports of Viscose Filament Yarn originating in or exported from China PR2. Its use has increased over a period of time, due to accuracy of results which cannot be achieved otherwise.

About Author:
Mr. Nihit Gupta
Adviser (BI & Analytics)

1 Anti Dumping in the WTO, the EU and China by Yan Luo
2 Review Investigation Final Findings No. 15/23/2010‐DGAD