VZCZCXYZ0002
RR RUEHWEB

DE RUEHNE #0880/01 0530919
ZNR UUUUU ZZH
R 220919Z FEB 07
FM AMEMBASSY NEW DELHI
TO RUCPDOC/USDOC WASHDC
RUEAHLC/HQ ICE IAO WASHINGTON DC
INFO RUEHC/SECSTATE WASHDC 3297

UNCLAS NEW DELHI 000880 
 
SIPDIS 
 
SIPDIS 
 
USDOC FOR 532/OEA/M. NICKSON-D/J. BANKINES/J. HATFIELD 
USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL 
USDOC FOR 4530/MAC/ANESA/OSA 
ICE HQ FOR STRATEGIC INVESTIGATIONS 
STATE FOR EB/ESP 
 
E.O. 12958: N/A 
TAGS: ETTC ETRD BEXP IN
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: SABERO ORGANICS 
GUJARAT LTD., DIST. BULSAR, GUJARAT 
 
REF: USDOC 00258 
 
¶1. Unauthorized disclosure of the information provided below is 
prohibited by Section 12(c) of the Export Administration Act. 
 
¶2. Acting Export Control Officer (ECO) David Nardella and BIS FSN 
Prem Narayan conducted a Post-shipment Verification (PSV) at Sabero 
Organics Gujarat Ltd. (Sabero)), Dist. Bulsar, Gujarat, on February 
13, 2007.  Sabero's Corporate Office is in Mumbai and plant is 
located approximately 200 kilometers north of Mumbai. 
 
¶3. BIS requested a PSV at Sabero, a private sector company, located 
at: Plot No. 2102, GIDC, Sarigam 396155, Dist. Bulsar, Gujarat, Tel. 
91-260-278-0395, Fax: 91-260-278-0853, Email: mp.desai@sabero.com, 
Website: www.sabero.com.  The PSV was requested under EAR99/NLR. 
Sabero was listed as Ultimate Consignee for three (3) transactions 
of Lignin Pitch (Lignin Sulfonic Acid and its salts).  The exporter 
was Meadwestvaco Corp., Garden Grove, CA. 
 
¶4. ECO along with FSN Narayan met with J.S. Sethi (Sethi), 
Director-Corporate Affairs, V.K. Behl (Behl), Chief Operating 
Officer, M.P. Desai (Desai), Senior General Manager and Rajendra 
Neogi (Neogi), Chief Manager-Stores & Supply Chain, Sabero.  Behl 
stated that the company is managed by two brothers, namely, Mohit 
Chuganee and Sumit Chuganee who are U.S. citizens. 
 
¶5. Sabero executives had not previously been aware of the BIS export 
regulations.  This was the first USG or BIS official visit to 
Sabero.  They stated that Sabero regularly imports Lignin Sulfonic 
acid and its salts from Meadwestvaco.  Behl stated that Reax 80D is 
the commercial name of this chemical.  Neogi provided a set of 
documentation for one of the three shipments made to Sabero in 
August 2006.  However, he provided complete consignment details of 
Reax 80D imported by Sabero from Meadwestvaco between April 2004 and 
February 2007.  This included quantities in kilograms, B/E numbers, 
B/L numbers, and invoice numbers. The documentation pertaining to 
the Meadwestvaco shipment contained the Sabero Receipt Note, Receipt 
for customs duties paid at the Mumbai Port, Transporters Receipt for 
carrying the commodity from Mumbai Port to Sabero Plant, and Sabero 
Store Receipt. 
 
¶6. Behl made a comprehensive slide presentation on the various 
agro-chemicals and specialty chemicals that Sabero manufactures. 
Included within this slide show was a detailed explanation of the 
usage and inventory control process for Reax 80D, the subject of 
this check.  His presentation included the total quantity of Reax 
80D that Sabero imported from Meadwestvaco from June 2005 to 
February 2007.  He stated that the Reax 80D is a dispersing agent 
and is one of the raw materials used for producing various types and 
standards of Mancozeb, an agro-chemical.  Mancozeb is a dithio 
carbamate fungicide which is widely used against several crop 
diseases.  It is applied prior to the fungus infestation. The 
particular uses of Mancozeb include control of early and late blight 
of potatoes and tomatoes, Rhizoctania solani and Streptomyces 
scabies on sweet potatoes, leaf spot disease on celery, cucurbits, 
beet, berries, currants, rusts on cereal, vegetables, roses, 
carnations, asparagus, beans, apples and plums, vines, onions, 
tobacco, and banana. 
 
¶7. Sabero produces Mancozeb in various forms that include: wettable 
powder (WP) 75 and 80 percent concentration; water dispersible 
granules (WDG) 75 percent concentration; suspension concentrate 
(SC); suspo-emulsion (SE); and oil suspension (OS).  He then 
described the manufacturing process of Mancozeb.  First, carbon 
disulphide is reacted with ethylenediamone in the presence of sodium 
hydroxide; this results in sodium salt formation.  The sodium salt 
formed is further reacted with manganese sulphate in an aqueous 
medium.  In this reaction sodium ion is replaced by manganese.   The 
product formed is separated from the acqeous by filtration.   This 
initial product is called Maneb.  The resultant wet cake of Maneb is 
mixed with water to form slurry before reacting with zinc sulphate, 
whereby crude product is formed.   Further to this additives like 
HMTA (hexamethylenetetramine) and SLS (sodium lignosulphonate) are 
added.  The crude product is then dried to get Mancozeb Technical. 
It once again goes through various manufacturing processes and 
subsequently Reax 80D along with other additives are added to make 
the end product Mancozeb WDG 75 percent concentration. A technical 
product is one that is the base from which a consumer product is 
made, through the addition of chemicals such as the Reax 80D. 
 
¶8. His presentation highlighted that the other dispersing agents, 
such as Morwet D-425, are used to produce Mancozeb WDG 75 percent, 
Mancozeb SE 500 standard, Mancozeb SE 455 standard, Mancozeb SE 430 
standard, Mancozeb SC 420, 430, 455 and 600 standards and Tergitol 
is used to make Mancozeb OS 600.  ECO asked that why there are these 
 
different standards.  Behl stated that there is no difference except 
that every country has a different set of standards for Mancozeb. 
In order to match their customers' requirements they prepare 
Mancozeb standards accordingly. He confirmed that the application is 
the same for all of the different standards of Mancozeb. 
 
¶9. Behl also produced a reconciliation statement for Reax 80D, for 
ECO and Narayan to review; this document reflected the opening and 
closing stocks, and amount consumed.  After the meeting, ECO and 
Narayan were given a tour of the Sabero plant.  ECO and Narayan were 
shown the manufacturing process of Mancozeb.  They were also taken 
to two different lockable sheds where ECO and Narayan examined Reax 
80D stock, and where the end product Mancozeb 75 percent WDG was 
stored.  Sabero runs in three shifts and is guarded 24 hours a day. 
As stated by Behl, Sabero's operation and records are transparent, 
open to viewing and inspection at any time. 
 
¶10. Incorporated in 1991, Sabero started manufacturing in 1994.  It 
is a public limited company listed on the Bombay and the National 
Stock exchanges in India.  Sabero manufactures agricultural 
chemicals that include acephate-tech & formulation, glyphosate-Tech 
and formulation, CPP-Tech & formulation, cypermethrin tech & 
formulation, monocroto-phos tech and formulation, dichlorovos tech & 
formulation, mancozeb technical, moncozeb 80 percent, mancozeb 75 
percent, mancozeb WDG, red mancozeb, blue-green mancozeb, OS 
formulations, SE formulations and SC formulations.  It also 
manufactures specialty chemicals that include phosphorus 
trichloride, phosphorus thiophosphorylchloride, trimethyl phosphate 
(TMP), triethyl phosphate (TEP), phosphorus oxychloride, hydroxyl 
ethyledane phosphate, dimethyl methyl phosphate, diethyl ethyl 
phosphate and tri butyl phosphate (TBP).  Sabero executives claim 
that they are the global leader in TEP (very high purity), the 
Global leader in TMP (very high purity), and the third largest in 
the world in Mancozeb and largest in India in glyphosate.  Sabero 
has subsidiaries in Netherlands, Australia, Brazil and Argentina. 
Of total production, 70 percent of its products are exported and 30 
percent are sold in the domestic market.  Sabero exports its 
products to approximately 62 countries including Australia, France, 
Italy, Russia, South Africa, Switzerland, U.K. and the U.S.  Sabero 
employs 400 personnel including 102 engineers, 142 chemists, 3 Ph.D. 
 Sabero's sales for FY 2006 were approximately $50 million. 
 
¶11. Recommendation: Post recommends Sabero Organics Gujarat Limited 
as a reliable user of U.S.-origin commodity.  All indications are 
that the listed commodity is being used for its manufacturing 
process, and in accordance with the Export Administration 
Regulations. (DNARDELLA/PNARAYAN) Mulford