VZCZCXYZ0003
RR RUEHWEB

DE RUEHNE #0881/01 0530920
ZNR UUUUU ZZH
R 220920Z FEB 07
FM AMEMBASSY NEW DELHI
TO RUCPDOC/USDOC WASHDC
RUEAHLC/HQ ICE IAO WASHINGTON DC
INFO RUEHC/SECSTATE WASHDC 3299

UNCLAS NEW DELHI 000881 
 
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 one transaction of 
Tergitol 15-S-5 and S-7 Surfactant.  The exporter was The Dow 
Chemical Company (Dow), Freeport TX. 
 
¶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 Tergitol 15 - S-5 
and S-7 Surfactant from Dow.  Neogi provided a set of documentation 
pertaining to the Dow shipment that 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 Tergitol 15 - S-5 and S-7, 
the subject of this check.  His presentation included the total 
quantity of both types of Tergitol that Sabero imported from Dow in 
June 2005.  He stated that the Tergitol is a surfactant for emulsion 
or oil suspension, is one of the raw materials used for producing 
various types and standards of Mancozeb, an agro-chemical.  Morwet 
D-425 is used for producing water dispersible granules whereas both 
types of Tergitols are used for producing oil spray Mancozeb OS. 
Each 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 Tergitol 15 S-5, S-7 and other additives are added to 
make the end product Mancozeb OS.  A technical product is one that 
is the base from which a consumer product is made, through the 
addition of chemicals such as the Tergitol 15-S-5 and S-7 
surfactants. 
 
¶8. Behl also produced reconciliation statement for Tergitol 15-S-5 
and S-7 for ECO and Narayan to review that reflected the opening and 
closing stocks and its consumption.  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 
Tergitol 15-S-5 and S-7 stock, and where the end product Mancozeb OS 
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. 
 
¶9. 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. 
 
¶10. Recommendation: Post recommends Sabero Organics Gujarat Limited 
as a reliable user of U.S.-origin commodities.  All indications are 
that the listed commodities are being used for its manufacturing 
process, and in accordance with the Export Administration 
Regulations. (DNARDELLA/PNARAYAN) Mulford