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$lTYl Phone :0481 -257 1 243 {-iau e-mail : secretary@rubberboard. org.

*-w+l Fax'.0481-2s7 i3lo q q g t 9 c/ rn

(ilFrw vq sairr q-[d-q, qr{fl rr{qrr)
(Ministry of Commerce & Industry, Government of India) lr2z, sq +d qls, o]-erfi - 686002
PB No.l 122. SLrb Jail Road, Kottayatr- 686 002

Ref.No.Secy1312019 6'n March 2019

Shri.Chandrasekharan Nair,
SANRA 82, Perukavu,
Peyad PO
Thiruvananthapuram 695573


Sub : Grievance No.DOCOM/E/2019/00176 dated 10.02.2019

regarding anomaly in Indian Rubber Statistics - reg.
Ref : Ministry's email d1.21.02.2019

With reference to the above, the following facts are forwarded. The error
reported is on the stock of natural rubber estimated using formula approach. The
globally accepted formula for estimating and verifying NR production,
consumption, trade and stock is as follows.

Opening Stock + Production + lmport = Consumption + Export + Closing Stock

Hence, the following formula can be used to estimate Closing Stock.

Closing Stock = (Opening Stock + Production + lmport) - (Consumption + Export)

Closing Stock can also be alternatively estimated based on survey approach by

collecting and collating data on stock with small growers, estates, processors,
dealers and product manufacturers. Rubber Board has been using survey
method for arriving at NR stock estimates as reliability is higher for such

Closing stock estimated through formulae method and survey method showed
wide variations during the period from 2009-10 to 2013-14. This mismatch could
be due to overestimation of NR production or underestimation of consumption or
a combination of both. Consumption, import and export of NR are objective
estimates as they are primarily based on returns and documents. NR production
is a subjective estimate as it is mainly based on monthly sample survey and any
error in production is reflected in stock of rubber as well. Hence, NR production
statistics during 2009-10 to 2013-14 were reviewed by an Expert panel and
recommended for revision based on a statistical regression model.

With regard to stock of NR, the Expert Panel recommended that it should include
rubber with growers, dealers, processors and manufacturers based on surveys
and returns collected and that the standard equality between (opening stock +
production + import) and (consumption + export + closing stock) should be
maintained as far as possible.

In commodity modelling, a certain percentage of allowable error will always exist

due to the estimation procedure. Production, consumption and stock are
estimates and' there can be some extent of permissible error. This error was
pointed out by you as mismatch.

It may be noted that the error in estimates has been considerably reduced after
revision of statistical methodology in 2015-16 based on the recommendations of
the Expert Panel. For the year 2016-17 and 2017-18, error levels are only 1.2o/o
and 1.7% respectively of the total NR consumption in the country which is less
than the permissible error of up Io S%.

A Statistics Consultative Panel (SCP) was constituted in April 2016 comprising

representatives of rubber producing, processing, trading and consuming sectori
for facilitating regular consultations and discuslions with different segments of
rubber sector on statistics related matters. The statistics published byihe Board
and.methodology are regularly discussed in SCP and the last meeting was held
on 4tn January 2019.

The unavoidable error in statistics on stock has no link with volume of rubber
imported as there have been no QRs on import from April 2001. Volume
rubber imported depends mainly on price differences between domestic and
international markets, deficit in NR production and regularity of market arrivals.

Copy to : Shri.M.S.Banerjee
Under Secretary to Government of India
Dept. of Commerce
Ministry of Commerce & lndustry
New Delhi