Report of the Working Group to Review of the

Guidelines for Hedging of Commodity Price

Risk by Residents in the Overseas Markets

RESERVE BANK OF INDIA

MUMBAI
Table of Contents

Chapter Title Page no.

no.
1 Introduction, Terms of Reference and Acknowledgements 3
2 Commodity Hedging in Practice 10
3 Nature of Hedging 18
4 Proposed Commodity Hedging Framework 22
5 Role of Banks 29
6 Summary of recommendations 31
Annex: An Overview of the Domestic Commodity Derivatives 34
Exchanges

2
 Chapter 1
Introduction, Terms of Reference and Acknowledgements
1.1 Amongst the various tradable assets classes, commodity prices generally tend to be
more volatile compared to say, currencies or equities. Commodity price risk is the risk of
loss in an underlying exposure (real or financial) associated with the volatility of
commodity prices. It affects different agents in the commodity value chain differently.
Broadly, participants would fall into the following categories: -
a. Producers – These could be miners (for metals), other extractors (crude oil,
natural gas) or farmers (agricultural produce) with a naturally long price risk
position. They usually make significant capital investment upfront. Their hedging
is thus guided by the need to generate adequate returns to service capital
invested.
b. Processors – Processors are typically exposed to the spread between input
cost and output price and not to outright price movements, e.g., jewelers, oil
refiners etc.
c. Consumers – They constitute the majority of participants exposed to commodity
risk. Firms/companies using commodities as inputs would fall under this category.
Consumers’ hedging requirement is dependent on their ability to pass on price
changes of inputs to their customers and whether or not they have long-term
pricing contracts with producers/customers.
d. Traders – Commodity traders’ exposure to price risk depends on whether
they act as agents or principals. Even when they act as principals, they may act as
canalizing agencies that pass through price risk or they may internalize a degree
of price risk.
e. Investors – They could be financial investors seeking exposure to commodity
prices purely as an investment asset, or they may be investors that use
commodities (precious metals like gold, silver) as a type of savings. The latter
type, usually retail, is common in economies characterized by high inflation or the
absence of financial savings instruments with desired real returns.
1.2 Commodities whose price risk is sought to be managed can be broadly divided into four
categories – (i) Base metals (aluminum, copper, zinc, lead etc) typically used as inputs in
various industries; (ii) precious metals (gold, silver, platinum etc) that are largely used as
store of value but also as industrial inputs; (iii) energy products primarily used as fuel to

3
 run industries (crude oil, natural gas, coal etc), particularly shipping and transport
industries, and also as industrial inputs; and, (iv) agricultural output, including cash
crops, that are used as input in food and agro industries.
1.3 Hedging of commodity risk is difficult and complicated. It is difficult primarily due to the
inherent basis risk in all commodities that arises from the differences in grade between
the physical underlying and the hedging derivative. Many commodity markets,
particularly agricultural products, are typical to their geographical setting, further adding
to product differentiation. The market structure of every commodity market is unique,
based on its historical evolution and its relative significance in the production process.
1.4 Hedging activity in a commodity is also a function of the availability of liquid pricing
benchmarks and the internationalization of the benchmark. Generally, the more
internationalized the pricing benchmark (e.g., Brent for crude oil or LBMA London Gold
price), the easier it is to hedge and therefore the more is the hedging activity. Since
liquid benchmarks enable hedging even for large sizes, typically there are not more than
a few benchmarks in a commodity. Crude oil, for example, is dominated by Brent in
Europe and WTI in US. Most base metal benchmarks are those on London Metal
Exchange.
1.5 With commodity benchmarks trading in very few trading centers, and with greater
globalization leading to more price equalization across the globe users are subject to
global commodity price fluctuations. This generates the need for access to international
markets for effective hedging, even for producers who largely source and sell
domestically. India, too, felt the need to give domestic producers, processors and
consumers access to international markets for their commodity hedging needs in the
late 1990s. A brief account of the developments is given below.
1.6 The basic regulatory framework was laid down based on the Report in 1997 of a
committee headed by Shri R V Gupta, then Deputy Governor. India at that time lacked a
well-developed domestic commodity derivatives market. Indian entities, with genuine
underlying commodity price risk exposures, therefore, needed access to off-shore
markets. Accordingly, the regulatory framework governing hedging by residents in the
overseas markets had been formulated in terms of the provisions of the Foreign
Exchange Management Act (FEMA), 1999 (Act 42 of 1999) since hedge transactions
required remittance of foreign exchange for the purposes of initial margin, variation
margin, mark-to-market settlement etc. Under the framework, Authorized Dealer (AD)
banks were envisioned as facilitators, not trade counterparts, for resident hedgers.

4
1.7 As per the Gupta Committee report, successful commodity hedging requires that two
pre-conditions must be satisfied - (a) the hedge transaction should address a
genuine/authentic underlying risk, and (b) the hedge transaction should be correctly
executed and monitored. In the event either or both these conditions are not met,
hedging will acquire a speculative hue and in the process may increase the firm's
exposure to risk. The Committee was of the view that there is clear justification on
balance for regulatory focus to remain firmly fixed on helping Indian corporates with
authentic price exposures to achieve risk-reduction, and not speculation. Regarding
hedging instruments, the Committee felt that where effective hedging may not be
possible with the help of exchange traded instruments, Over-the-Counter (OTC)
products could be availed of. However, the relative OTC markets must necessarily have
some depth, liquidity, transparency and equitable access.

Evolution of the regulatory framework: 2003 till date

1.8 Following the Gupta Committee recommendations, RBI initially followed a cautious
approach – through special dispensations for hedging to acclimatize all stakeholders –
but gradually eased overseas access for commodity hedging. The facilities as they have
evolved over the years is given below in a chronological order.
a. July 1, 2003 - Residents in India, engaged in import and export trade were
permitted to hedge the price risk of all commodities in the international
commodity exchange/ markets on a specific approval from RBI.
b. May 31, 2007 - Hedging for domestic transactions of select metals and aviation
turbine fuel: AD banks with specific authorization from Reserve Bank were
permitted to allow:
• Domestic producers/ users to hedge their price risk on aluminum, copper,
lead, nickel, and zinc in international exchanges up to the average of previous
three financial years’ actual purchases/ sales or the previous years’ actual
purchases/ sales turnover, whichever is higher.
• Actual users of Aviation Turbine Fuel (ATF) to hedge their economic
exposures in the international commodity exchanges based on their domestic
purchases.
c. November 6, 2007 - Hedging for Domestic Oil Refining and Marketing Companies:
Domestic oil marketing and refining companies were permitted to hedge their

5
 commodity price risk to the extent of 50 per cent of their inventory based on the
volumes in the quarter preceding the previous quarter.
d. June 3, 2008
• Hedging of domestic purchases of crude oil and sales of petro-products and
anticipated imports of crude oil: Domestic crude oil refining companies were
permitted to hedge their commodity price risk
a. On domestic purchases of crude oil and sale of petroleum products on
the basis of underlying contracts linked to international prices on
overseas exchanges/ markets.
b. On crude oil imports in overseas exchanges/ markets up to 50% of the
average of previous three financial years’ actual purchases/ sales or 50%
of the previous years’ actual purchases/ sales turnover, whichever is
higher.
• Remittance related to Commodity Derivative Contracts – Issuance of Bank
Guarantee (BG)/ Standby Letter of Credit (SBLC)
a. Banks were permitted to issue guarantees/ standby letters of credit to
cover the specific payment obligations arising out of commodity
derivative transactions entered into by customers with overseas
counterparties.
e. January 17, 2012 - Liberalization in Commodity Hedging guidelines: Banks were
delegated the power to grant permissions to:
i. Hedge the price risk in respect of any commodity in the international
commodity exchanges/ markets as specified under the delegated route.
ii. Hedge the price risk, by unlisted companies, on import/ export of any
commodity in the international exchanges/ markets.
In a nutshell, the current hedging arrangement is as follows –
a. Price risk on any commodity that is being exported/imported can be hedged in
overseas commodity derivative market without any restriction.
b. Price risk arising from domestic sale/purchase can be hedged in overseas
commodities derivatives market only for specified commodities, viz., Aluminum,
Copper, Lead, Nickel, Zinc, Air Turbine Fuel and Crude Oil.

1.9 Over the years, commodity hedging interest of Indian corporates has been growing, not
just for the commodities specified but for various other commodities under the approval

6
route. Apart from the hedging done by corporates under the delegated route, the hedging
under the approval route itself has been rather high (Table 1 1). Most of the requests for
approval pertain to commodities that have not been delegated for hedging to AD Banks.
Clearly, there is a need for opening up the commodity hedging for a wider range of
commodities. Besides, too much reliance on case-by-case approvals does not augur too well
for efficient and timely hedging, which highlights the need for a more liberalized regulatory
dispensation.

Table 1 - Share of Approval Route

2007-08 2008-09 2009-10 2010-11 2011-12 2012-13 2013-14 2014-15 2015-16 Total
Copper (1000 MT) 0% 0% 0%
Aluminium (1000 MT) 0% 0% 0% 0% 0% 0%
Lead (1000 MT) 0% 2% 0%
Zinc (1000 MT) 100% 88% 78% 69% 55% 43% 11% 3% 2% 99%
Tin (MT) 100% 8%
Iron Ore (MT) 100% 100%
Nickel (MT) 0%

Gold (1000 Tr oz) 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%
Silver (mn Tr Oz) 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%
Platinum (1000 TrOz) 100% 100% 100% 100% 100% 100%
Palladium (1000 TrOz) 100% 100% 100% 100% 100%
Rhodium (1000 TrOz) 100% 100% 100% 100%

Coal (MT) 100% 100% 100% 100% 100%

Crude Oil (mn barrels) 100% 100% 100% 100% 100% 99% 99% 95% 100% 99%
ATF (MT) 100% 100% 100% 100%
HSFO (000 mt) 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%
Bunker Fuel (000 MT) 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%

Sugar 100% 100% 100% 91%

Cotton 100% 100% 26% 15% 62%
Rubber 100% 100% 100%
Edible Oil
Coffee 100% 100% 100% 100% 100%

1.10 Reserve Bank of India constituted this working group on Sep 14, 2016 to review the
guidelines for hedging of commodity price risk by residents in the overseas markets during
the development phase of our domestic commodity derivative market. The group had
members drawn from RBI, Securities and Exchange Board of India (SEBI), commercial banks
and corporates.
Composition of the Working Group:
• Shri Chandan Sinha, Ex-Executive Director, RBI (Chairman)
• Shri T. Rabi Sankar, Chief General Manager, RBI

1
Based on data collected from large user banks.
7
 • Shri P. K. Bindlish, Chief General Manager, SEBI
• Shri Venkat Nageshwar, Deputy Managing Director, State Bank of India
• Shri Ajit Ranade, Chief Economist, Aditya Birla Group
• Shri Ashish Parthasarathy, Treasurer, HDFC Bank
• Shri A Sondhi, Director (Marketing), MMTC
• Shri Siddhartha Misra, Deputy General Manager, RBI (Convener)

Terms of reference for the working group:

• Assess the risks faced by resident entities and their hedging requirements,
• Identify gaps in the existing regulatory framework in relation to the hedging
requirements viz. coverage of commodities, participants and products,
• Suggest the broad principles for guiding the regulatory regime for overseas hedging
of commodity risks,
• Recommend a modified framework for residents hedging commodity risk overseas,
• Any other related matter.

1.11 The Working Group held three meetings between October 14, 2016 and February 27,
2017. During its deliberations, the Group had the benefit of interacting with external
experts from the corporate sector, commercial banks and advisory firms. The Group would
like to acknowledge the valuable contributions of Shri Anil Mathews and Shri Vikram Sondhi
of Hindalco, Shri Johnson Lewis and Shri Manish Goyal of Bank of Nova Scotia. The Group
would like to particularly acknowledge the contribution of Shri Muzammil Patel of Deloitte
Touche Tohmatsu India LLP for sharing his considerable expertise. The Group would also
like to acknowledge the valuable support and assistance extended by the officers of the
Financial Markets Regulation Department viz., Shri Nitin Daukia, Shri Deepak Kundu and
Smt. Zenobia Kargutkar.

1.12 The structure of this report is as follows. Chapter 2 reviews the commodity price risk
hedging activity in all its dimensions. Chapter 3 lays down a model regulatory framework
for identification of commodity price risks arising from variable input and output prices
taking in to account the Indian commodity profile and state of development and
sophistication of domestic markets and participants, respectively. Chapter 4 describes
various regulatory issues in the context of commodity price risk management that were
examined by the Working Group and makes related recommendations. These include
8
hedging of risks arising out of domestic trade in commodities versus cross-border trade,
approach for identifying commodities for hedging price risk, listing as an eligibility criteria
for access to hedging markets overseas, inventory hedging, use OTC versus exchange traded
products, currency risk arising out of hedging commodity price risk and role of domestic
stock exchanges in offering commodity derivatives. Chapter 5 examines the potential role
of commercial banks in both encouraging their constituents to hedge their commodity price
risk and ultimately to act as market-makers. Chapter 6 summarizes the recommendations
of the Working Group. The annexure to the report provides an overview of select domestic
commodity exchanges and their products.

***

9
 Chapter 2
Commodity Hedging in Practice

2.1 As briefly explained in Chapter 1, the Gupta Committee stressed the need for existence
of genuine underlying risk to preempt speculative use of overseas derivative markets. It
recognized the need for access to both exchange markets and OTC markets but required
that OTC markets must necessarily have some depth, liquidity, transparency and
equitable access. Based on the sample data collected from Authorized Dealer banks
active in facilitating commodity derivative transactions of residents in the overseas
markets, the following broad picture emerges.
2.2 Most hedging activity is in base metals but a reasonably wide variety of products are
hedged offshore by Indian corporates. (Table 2.1).

Table 2.1: Commodities hedged by residents overseas

Precious Metals Metals Energy Agro

Gold Aluminum Crude Cotton

Silver Copper ATF Palm Oil

Platinum Lead Bunker Fuel Sugar

Palladium Zinc Coal Cocoa

Rhodium Tin HSFO Edible Oil

Iron Propane

2.3 Table 2.2 provides a snapshot of hedging activities in these commodities 2. For energy
and precious metals, hedging is entirely in OTC segment. Iron ore (100%) and lead (75%)
are the two metals with large OTC hedging. For all other metals as well as agricultural
products, hedging is done on established exchanges. Within exchanges, apart from LIFFE
(coffee), NYMEX and ICE (Cotton) and SGX (rubber), all hedging is in the London Metal
Exchange (LME).

2
The table is based on data collected from large user banks and is only indicative.
10
11
2.4 Hedging is almost entirely under the approval route in energy and precious metal
products. Base metal hedging is largely under the delegated route while for agricultural
products, hedging is mainly under the approval route for coffee and sugar while it is
under the delegated route for cotton and rubber.
2.5 Most hedging interest is for exposure of commodity risk in international trade of
importers/exporters. Virtually all hedging is by importers/exporters for agricultural
goods and energy products. Significant hedging interest by domestic users (producers
and consumers) is visible in both precious metals as well as base metals. A more detailed
presentation of category-wise hedging behavior is presented below.

Precious metals
2.6 As can be seen in Chart 2.1 below, Gold and silver constituted the majority by volume of
the precious metals hedged. All such hedges were booked on the OTC market and under
the approval route. Hedging volumes in all precious metals has seen a significant pickup
since 2013-14.

Chart 2.1 Hedging of precious metals

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Energy
2.7 Amongst energy products, crude oil emerges as the commodity against which the
maximum hedges have been booked followed by High Sulphur Fuel Oil (HSFO) (Chart
2.2). A majority of such hedges have been booked under the approval route (Chart 2.3)
and all hedges have been booked through the OTC route.
Chart 2.2 Hedging of Energy

Chart 2.3 Hedging of Energy under delegated (D) & approval (A) route

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Metals
2.8 Aluminum, followed by Copper and Tin were the most hedged commodities in the
metals basket (Chart 2.4). Most of the hedging was under the delegated route (Chart
2.5). Hedging activity was predominantly on exchanges except for lead (Chart 2.6)

Chart 2.4 Hedging of Metals

Chart 2.5 Hedging of Metals under delegated (D) & approval (A) route

14
 Chart 2.6 Hedging of Metals through exchanges and OTC

Agro commodities
2.9 Sugar dominated the list of agro-commodities hedged till 2012-13. For the last 2 years
coffee, rubber and sugar have been the more actively hedged commodities (Chart 2.7).
Cotton and rubber are largely hedged under the delegated route while coffee and sugar
are hedged under the approval route (Chart 2.8). Agriculture commodity hedges are
spread across exchanges – LIFFE for coffee, SGX for rubber, ICE/LME/NYMEX for cotton
etc. (Chart 2.9)

Chart 2.7 Hedging of Agro commodities

15
Chart 2.8 Hedging of Agro commodities under delegated (D) & approval (A) route

Chart 2.9 Hedging of Agro commodities on various exchanges

16
Domestic Commodity Exchanges: Role of Securities and Exchange Board of India (SEBI)
2.10 There have been significant advances made by the Government and Securities
Exchanges Board of India (SEBI) to foster the development of the domestic commodity
exchanges. Today, residents can hedge the price risk on a wide range of commodities in
domestic commodity exchanges. A brief overview of the domestic commodity exchanges
is given in Annex. In 2015-16, the Indian commodity derivatives market witnessed a
significant transition when the erstwhile commodities market regulator, Forward
Markets Commission (FMC) was merged with SEBI with effect from September 28, 2015
with an aim, “to strengthen regulation of commodity forward markets and reduce wild
speculationi”. The Central Government repealed the Forward Contracts (Regulation) Act,
1952 (FCRA) with effect from September 29, 2015 paving the way for the merger of the
FMC with SEBI.

***

17
 Chapter 3
Nature of Hedging

Commodity price risk management: A holistic examination

3.1 To enable a holistic examination of the problem of commodity price risk management, it
is imperative to study the specific nature of commodity price risk. The first issue is the
nature of the hedging entity, specifically, what is its position in the value chain:
a. Producers (i.e., those involved in exploration, production and farming) are faced
with the risk of fall in absolute prices, either because it affects the return on
their investment or because it affects their inventory value.
b. For commodity processors and refiners, the nature of commodity risk assumes
multiple forms viz., margin risk, timing risk, inventory risk and fixed price risk.
i. Refiners or processers seek to earn a margin i.e. the difference in price of
output produced and input used for production. While they are not impacted
by absolute fall or rise in prices, the fall in the output price relative to the
input price leads to a lower earning.
ii. In many cases, margin erosion may occur due to difference in timing of
pricing of input and output. Accordingly, even where margin risk is locked in
through hedging, timing differences between pricing of input and output can
impact earnings.
iii. Refiners or processors carry priced-in inventory (inventory for which price is
fixed) as part of their regular supply chain. This inventory can be of the input
or output. Fall in absolute prices of either input or output can impact the
reported earnings. While it may be assumed that a certain level of inventory
will always be carried to facilitate regular operations, fall in inventory prices
between reporting dates is required to be reported in financials of an
organization.
iv. Refiners or processors may offer fixed price contracts to their customers i.e.
consumers in the value chain. As a result of this, refiners are exposed to price
risk on account of increase in the price of the commodity.
c. Another key player in the value chain i.e. marketing companies who offer fixed
price contracts to their customers are exposed to price risk on account of
increase in the price of the commodity.

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 d. Finally, the end customers are exposed to the risk of rise in absolute prices.
There is generally little correlation between the price of commodities used by
consumer industries and the price of the final product they sell. At times, they
may be unable to pass on price increases to the end customer. Accordingly,
increase in absolute prices directly impact margins of consumer industries.
3.2 There is also the problem of basis risk in commodity price risk management. Basis arises
on account of benchmark differential risk, where the benchmark used for settlement of
the paper transaction and the benchmark on which the physical transaction is priced are
different. Whereas the benchmarks may be closely linked and highly correlated, there is
always the possibility of the benchmarks not being identical on settlement of the paper
transaction. This is referred to as benchmark differential risk and can make the hedge
ineffective. Benchmark differential risk arises mainly due to variations in grades of the
commodity.
3.3 Thus, commodity price risk managment is a multi-dimensional problem. Keeping this in
view and balancing it with the state of the development of the domestic commodity
exchanges, the Group recognised the need for a principle based regulatory framework
to meet most, if not all, of the commodity price risk management needs of Indian
commodity users including the less sopshiticated ones. Such a framework is set out
below.
3.4 The basic principle involved in hedging the commodity price risk is that the hedging
activity should be undertaken to offset the impact on the profit margin of an entity on
account of fluctuation in the commodity prices. In general, a risk framework can be
outlined based on the exposure of a company to variability of commodity prices either
in raw materials used by the company or in the final product. Based on the variability in
prices faced by the company, the commodity price risk of the company can be
categorized under four categories. The categorization is illustrated in the following
figure and each of the categories are discussed in the following paragraphs.

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 Commodity Input Prices
Price Risk

Fixed Floating

Fixed No Risk Risk of input prices going

Output Prices

higher
Floating

Risk of output prices Risk on inventory

going lower
Figure 3.1 Categorisation of Commodity Price Risk

a. Input price is fixed and output price is fixed – A company in the top left
quadrant of figure 3.1 will have fixed input prices and fixed output prices of the
commodities consumed or produced by company. The fixing in the prices may
be done contractually with customers and suppliers of the company. In such
cases the company is not exposed to any commodity price risk and
consequently does not have to absorb any loss on account of price fluctuation
of the commodity. In this case no hedging is required.
b. Input price is variable and output price is fixed – A company in the top right
quadrant of figure 3.1 will be exposed to variability in the price of input
commodity, whereas the price of finished product is fixed contractually or is
inelastic in the near term. In this case the company will have to absorb the
financial impact due the variability in the price of the input commodity.
Therefore, the appropriate hedging requirement for such a company would be
to convert the variable input prices into fixed input prices using financial
derivatives. An example of a company in this quadrant could be a company
bidding for or servicing a fixed price contract.
c. Input price is fixed and output price is variable – A company in the bottom left
quadrant of figure 3.1 will be exposed to variability in the price of output
commodity, whereas the price of input commodity is fixed contractually or is
inelastic in the near term. In this case the company will have to absorb the
financial impact due the variability in the price of the output commodity.

20
 `Therefore, the appropriate hedging requirement for such a company would be
to convert the variable output prices into fixed output prices using financial
derivatives. An example of a company is this quadrant could be a mining
company which has purchased the rights to the mine at a fixed price.
d. Input price is variable and output price is variable – A company in the bottom
right quadrant of figure 3.1 will be exposed to variability in the price of output
commodity as well the input commodity. In such cases the entity does not have
to absorb losses on account of price fluctuation, unless it has no control (or
limited control) on output pricing because it is linked to an external benchmark.
In the latter case, the entity would need to hedge price movement during the
working capital cycle, i.e., it would need to hedge its inventory. An example of
this case could be a crude refining company or a gold jewellery company.
3.5 The risk profile of a company is defined by its position in the input-output prices matrix
(Figure 3.1). The following inferences can be drawn:
a. A company having fixed prices of input commodity and output commodity will
not be facing any risk and therefore there is no requirement for hedging in this
case.
b. A company having fixed prices of input commodity and variable prices of output
commodity or vice versa will be exposed to commodity price risk. The
appropriate hedging requirement in this case would be price fix hedges. Price
fix hedges fix the price of a commodity over a period of time in future.
c. A company having variable prices of input commodity and variable prices of
output commodity will be exposed to commodity price risk only on the
inventory held by the company. The appropriate hedging requirement in this
case would be offset hedging to offset the financial impact of inventory
valuation on the valuation date.
***

21
 Chapter 4
Proposed Commodity Hedging Framework

4.1 Based on the commodity risk hedging behavior of Indian businesses examined in
Chapter 2, and in the light of the hedging framework set out in Chapter 3, this chapter
highlights the major features of a comprehensive hedging framework for commodity
price risk with appropriate recommendations.

Risk of domestic business entities vis-à-vis risk of exporters/importers

4.2 The current guidelines differentiate facilities based on the geographic location of
procurement of the commodity, i.e. domestic sale/purchase or export/import.
Exporters/importers can hedge the price risk of any commodity they export or import,
respectively. Domestic entities, on the other hand, can only hedge price risk of a limited
set of commodities. From a pure risk perspective, such distinction may not be justifiable.
Besides, this has led to a relative lack of hedging activity from entities sourcing/selling in
domestic markets. Nearly three quarters of all hedging is done by exporters/importers,
who account for 100% hedging in energy and agricultural commodities (Table 4.1).
Activity of domestic businesses is limited to the metals segment – both base metals and
precious metals. To encourage hedging by all businesses facing commodity price risk,
such distinction needs to be removed. The downside risk of such removal would be an
increase in exchange rate risk of domestic businesses as entities who do not currently
hedge commodity risk overseas start hedging in international markets. This aspect if
discussed in para 4.10. It may hence be preferable to do away with such differentiated
access based on whether an entity is engaged in domestic or international trade and
move to a risk based framework, as outlined in the previous chapter. From a risk
management perspective, domestic buyers/sellers exposed to commodity risk should be
treated on the same footing as exporters/importers. The Group, therefore, is in favour of
a uniform approach in extending facilities to hedge commodity price risk in overseas
markets that is agnostic to the place of procurement of the commodity, by doing away
with the differences in treatment of importer/exporter on the one hand, and domestic
buyers/sellers on the other.

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 Table 4.1 - Categorization of Commodity Price Hedgers
By exporters/ By local
Total
importers buyers/sellers
Coffee 100% 0% 100%
Cotton 100% 0% 100%
Rubber 100% 0% 100%
Sugar 8% 92% 100%
Copper 57% 43% 100%
Aluminium 48% 52% 100%
Lead 100% 0% 100%
Tin 100% 0% 100%
Nickel 100% 0% 100%
Iron Ore 88% 12% 100%
Zinc 100% 0% 100%
Coal 98% 2% 100%
Crude 100% 0% 100%
HSFO 100% 0% 100%
ATF 100% 0% 100%
Bunker Fuel 100% 0% 100%
Gold 32% 68% 100%
Silver 29% 71% 100%
Platinum 34% 66% 100%
Palladium 47% 53% 100%
Rhodium 100% 0% 100%

Commodities that can be hedged

4.3 Under current regulation importers/exporters can hedge the price risk of any
commodity which they import/export. On the other hand, domestic commodity
buyer/seller are permitted to hedge the price risk of only limited commodities. Since the
committee is of the view that the differentiation between entities involved in domestic
and international trade may be dispensed with (para 4.2), one approach would be to let
any resident entity hedge the price risk of any commodity to which it is exposed. While
this can be the approach eventually, it may not be prudent to make this jump from
limited commodities to all commodities, unless the foreign currency impact of the move
can be assessed. At this stage it may be advisable to continue with a positive list of
commodities, exposure to which can be hedged by both domestic entities and
importers/exporters. Based on the available information of production and consumption
of commodities and actual hedging oversees by Indian residents, such interest is based
around the commodities indicated in Table 4.2 below. The Group, therefore,

23
 recommends a ‘Positive List’ of commodities which can be hedged in the overseas
markets by all residents, i.e., by both domestic users and exporters/importers alike.
Reserve Bank could periodically review the list based on market feedback.

Table 4.2: Commodities eligible for hedging – Positive List

Precious Metals Base Metals Energy Agro
Gold Aluminium Crude oil and its Cotton
derivative fuels like
ATF, bunker oil, HSFO
etc.

Silver Copper Natural Gas and its Palm Oil and Palm
derivative products like Kernel Oil
propane etc.
Platinum Lead Sugar

Palladium Zinc Coal Coffee

Rhodium Nickel Soya complex

Tin Cocoa

Note: Commodities in bold added to the extant list.

Inventory Hedging

4.4 In terms of the hedging framework outlined in the previous chapter, companies falling in
the bottom-right quadrant will be exposed to price risk on the commodity held as
inventory during the processing cycle. In terms of present guidelines inventory hedging
is only permitted to domestic oil marketing and refining companies. The Group
recommends that this regulation may be liberalized and inventory hedging permitted to
entities exposed to price risk, for any commodity on the ‘positive list’, if they meet the
following conditions: -

 Both the cost of the input and the price of the output are variable, and,
 The output price is linked to international prices.
4.5 The Group deliberated on the issue of the amount of inventory that could be permitted
to be hedged under this recommendation. It was decided that amount could be based
on the average inventory maintained by the company as declared in its financial
statements or as certified by their statutory auditors. In respect of certain commodities
like precious metals, RBI may lay down additional conditions, if necessary.

24
 Price Fix hedge

4.6 A price fix hedge is a hedge designed to lock-in either an input price or an output price
for a period of time in future. In a price fix hedge, the hedger secures business margins
by locking in input or output prices. Price Fix hedges are different from offset hedges
(which are currently permitted), in that they are based on anticipated contracts
whereas offset hedges are based on existing contracts where the price is not fixed.
Under price fix hedging an important decision is how far into the future the input or
output prices are to be locked. Ideally, this decision should be left to the discretion of
the edging entity com. Price fix hedges will be appropriate for companies in the top-right
and bottom-left quadrant in figure 3.1. The Group, therefore, recommends that price fix
hedging be permitted in addition to offset hedging to entities that are faced with a
variable price on either input or output, but not both.

Over-the-Counter (OTC) vs Exchange

4.7 The Group was of the view that hedging in exchanges is more transparent as compared
to hedging in Over-the-Counter (OTC) markets. Current regulations permit hedging in
the OTC markets if the risk profile so warrants. In view of the large access to OTC
markets (Table 4.3) even in commodities that have active exchange contracts, the Group
felt that this avenue may not be amenable to regulatory/supervisory control. The Group
is of the view that in respect of OTC transactions, the permitted OTC counterparties may
be limited to regulated entities, preferably banks, operating in major financial centers
and/or acceptable jurisdictions specified by RBI. In particular, hedging transactions shall
not be undertaken with related parties in overseas markets. The Group, therefore,
recommends hedging in overseas commodity exchanges due to transparency in pricing.
However, if the risk profile so warrants hedging in the OTC market overseas may be
allowed but only with regulated entities, preferably banks, as counterparties operating in
acceptable jurisdictions specified by RBI.

25
 Table 4.3 - Hedging on Exchanges and OTC
By local
Exchanges Total
buyers/sellers
Coffee 100% 100%
Cotton 100% 100%
Rubber 100% 100%
Sugar 100% 100%
Copper 99% 1% 100%
Aluminium 99% 1% 100%
Lead 25% 75% 100%
Tin 100% 100%
Nickel 100% 100%
Iron Ore 100% 100%
Zinc 99% 1% 100%
Coal 100% 100%
Crude 100% 100%
HSFO 100% 100%
ATF 100% 100%
Bunker Fuel 100% 100%
Gold 100% 100%
Silver 100% 100%
Platinum 100% 100%
Palladium 100% 100%
Rhodium 100% 100%

Direct vs Indirect Exposure

4.8 An entity can be exposed to the price of a commodity directly or indirectly. An exposure
to a commodity on direct basis is when the entity is a direct user of the said commodity
and any fluctuation of the same has material impact on the profit margins of the
company. As an example, a tyre manufacturing company is directly exposed to the price
of raw rubber since rubber is a major raw material for production of tyres. On the other
hand, a car manufacturing company is only indirectly exposed to rubber prices as the
cost of tyres in a car is only a fraction of the overall car price and the price of tyres does
not fluctuate as frequently as that of raw rubber. However, the calculation of indirect
exposures can be complex and the impact of indirect exposures generally tends to be
low on overall profitability. The Group, therefore, recommends that in view of the
complexity involved in assessing the indirect commodity risk of the user, hedging of only
direct commodity price risk may be allowed for now.

26
 Hedging of Currency Risk

4.9 Hedging in international markets involves exchange rate exposure, as the price of
commodities is denominated in foreign currency. Since exporters/importers are
otherwise directly exposed to risk, there is no net additional currency risk from their
access to international commodity markets. Domestic buyers/sellers, on the other hand,
attain new exposure to currency risk in the process of hedging their commodity risk in
international markets and may, therefore, seek to hedge it in the domestic forex market.
The Group deliberated on the various aspects of the issue. Empirical evidence suggests
that commodity prices are, in general, more volatile than currencies and hence, hedging
of commodity price risk offsets a major part of the price risk faced by the user. Further,
if this facility is used widely, it could lead to a build-up of sizeable forex derivative
positions creating potential for forex market volatility. Besides, forex hedging in the
domestic OTC market are generally permitted on a deliverable basis. For the domestic
buyer/seller hedging his commodity risk overseas there is no corresponding cash flow in
foreign currency of the underlying commodity, hence hedge contracts have to be
necessarily cash-settled. On the other hand, some members felt that the impact on
domestic forex market may not be significant given current usage. Besides, the size of
foreign exchange reserves might comfortably absorb the resulting exchange market
pressure. In any case, a calibrated policy could also be adopted wherein initially
domestic buyers/sellers of commodities are allowed to hedge commodity price risk
overseas on a fully currency-hedged basis. This can be gradually relaxed over time as
such entities attain maturity in managing exchange rate risk and also depending on
regulatory comfort about the size of such exposure. On balance, the Group recommends
that hedging by domestic buyers/sellers of the currency risk resulting from their overseas
commodity hedging may be permitted as it will enable effective and complete hedging of
international commodity price risk.

Hedging on domestic commodity exchanges

4.10 Hedging of commodity price risk overseas involves taking on Rupee currency risk, as
discussed in para 4.10. While exporters/importers or large domestic corporates have
the necessary skill to undertake currency hedging, for the large number of less
sophisticated players like SMEs, currency risk could be material. In this context,
domestic exchanges could play an important role as hedging on local exchanges enables
hedging of both commodity and currency risk. While it may not be desirable to mandate

27
 hedging in the domestic commodity derivatives market, as these markets may not
provide the required depth and liquidity at his stage, there is a need to encourage
hedging commodity price risk on domestic exchanges. The Group, therefore,
recommends that residents who hedge their commodity price risk in overseas market
should be encouraged to partly and progressively hedge their risks on the domestic
exchanges. Awareness needs to be created by all stakeholders including the exchanges in
this regard.

Listing Requirement

4.11 At present, apart from exporters/importers, only those domestic companies which are
listed on stock exchanges are permitted to hedge commodity risk overseas. Presumably,
this requirement arises from a concern that unlisted entities may not have the right
attributes in terms of balance sheet size, risk management skills and adequate corporate
governance to be allowed direct access to overseas hedging markets. At the same time,
it excludes a large majority of small and medium enterprises from hedging their
commodity price risk. Apart from leading to potentially unequal market access, this
regulation does not stand scrutiny from a risk exposure perspective. The Group is in
favour of extending hedging facility to all entities, listed or not. However, to address the
concerns behind the current regulation, the group recommends that in respect of
domestic sale/purchase of commodities in the positive list, unlisted entities may be
permitted to hedge commodity risk overseas with the approval of their AD bank.
Subsequently, if and when AD banks are permitted by RBI to deal in commodity
derivatives, unlisted entities may hedge with the banks as the counterparty.

***

28
 Chapter 5
Role of Banks
5.1 The role of banks in commodity derivatives is limited. As authorized dealers, all
payments related to overseas commodity hedging by domestic entities is routed
through banks. Banks do not take part in such hedging in any other capacity. Banks
also provide clearing and settlement services for commodity derivative transactions
in domestic exchanges. However, banks have been financing commodity businesses
through their loan portfolios and providing fund and non-fund-based facilities to
commodity traders for their working capital requirements.
5.2 The Working Group on Warehouse Receipts and Commodity Futures (Chairman -
Shri Prashant Saran) set up by RBI (April 2005) had recommended that banks may
be permitted to deal in agricultural commodities and their derivatives on exchanges
as this would enable banks to offer such products to farmers. However, this
recommendation had not been implemented.
5.3 The Group discussed the role of banks and felt that a wider access for Indian
entities to overseas commodity derivative markets requires a more active role for
banks than they take on now. This should involve banks dealing in commodity
derivatives. One obvious advantage is that small entities, which may otherwise be
inhibited from accessing global markets directly will be encouraged to hedge their
risk if permitted to do so with local banks. Another advantage is that banks can act
as aggregators for such smaller entities which will reduce external access only to
net exposure at the level of a bank, leading to more efficient use of foreign
exchange. This activity would result in banks running a book in commodity
derivatives, which could be increased in a calibrated fashion based on regulatory
comfort.
5.4 At present, banks do not have direct exposure to commodities though they are
indirectly exposed to commodity risk through their loan book. Considering that the
role of banks is pivotal in the Indian financial sector, the Group felt that RBI may
consider enabling banks and/or their subsidiaries to offer commodity hedging
facility to their constituents. Such facilities can be provided on a back-to-back basis
to start with. Later, depending upon regulatory comfort and prudential limits, RBI
may consider allowing banks to run modest proprietary positions, subject to
prudential limits. The Group, therefore, recommends that domestic banks and/or

29
their subsidiaries active in capital markets be allowed to offer commodity hedging
facility to their constituents for better risk management in the economy, initially on
a back-to-back basis, on both OTC and exchanges, including on domestic exchanges.
Later, when necessary risk management capability has been acquired, banks may be
allowed to run a book in commodity derivatives within the umbrella limit of 20% of
NOF applicable for investment in equities, venture capital funds (VCFs) & equity
linked mutual funds. Further, for this purpose, RBI may consider the necessary legal
enablement in the B.R. Act, 1949.

***

30
 Chapter 6
Summary of Recommendations

The recommendations made by the Group are listed below.

6.1 Recommendation #1: The Group is in favor of a uniform approach in extending facilities
to hedge commodity price risk in overseas markets that is agnostic to the place of
procurement of the commodity, by doing away with the differences in treatment of
importer/exporter on the one hand, and domestic buyers/sellers on the other.

6.2 Recommendation #2: The Group recommends a ‘Positive List’ of commodities (per Table
6.1) which can be hedged in the overseas markets by all residents i.e. by both domestic
users and exporters/importers alike. Reserve Bank could periodically review the list based
on market feedback. [Ref. para. 4.3]

Table 6.1: Commodities eligible for hedging – Positive List

Precious Metals Base Metals Energy Agro
Gold Aluminium Crude oil and its Cotton
derivative fuels like
ATF, bunker oil, HSFO
etc

Silver Copper Natural Gas and its Palm Oil and Palm
derivative products like Kernel Oil
propane etc
Platinum Lead Sugar

Palladium Zinc Coal Coffee

Rhodium Nickel Soya complex

Tin Cocoa

Note: Commodities in bold added to the extant list.

6.3 Recommendation #3: The Group recommends that inventory hedging be permitted to
entities exposed to commodity price risk, for any commodity on the ‘positive list’ to the
extent of the average inventory maintained, if they meet the following conditions: -

 Both the cost of the input and the price of the output are variable, and,
 The output price is linked to international prices. [Ref. para. 4.4 and 4.5]
6.4 Recommendation #4: The Group recommends that price fix hedging be permitted in
addition to offset hedging to entities that are faced with a variable price on either input
or output, but not both. [Ref. para. 4.6]
31
6.5 Recommendation #5: The Group recommends hedging in overseas commodity
exchanges due to transparency in pricing. However, if the risk profile so warrants,
hedging in the OTC market overseas may be allowed but only with regulated entities,
preferably banks, as counterparties operating in acceptable jurisdictions specified by RBI.
[Ref. para. 4.7]

6.6 Recommendation #6: The Group recommends that in view of the complexity involved in
assessing the indirect commodity risk of the user, hedging of only direct commodity price
risk may be allowed for now. [Ref. para. 4.8]

6.7 Recommendation #7: The Group recommends that hedging by domestic buyers/sellers of
the currency risk resulting from their overseas commodity hedging may be permitted as
it will enable effective and complete hedging of international commodity price risk. [Ref.
para. 4.9]

6.8 Recommendation #8: The Group recommends that residents who hedge their commodity
price risk in overseas market should be encouraged to partly and progressively hedge
their risks on the domestic exchanges. Awareness needs to be created by all stakeholders
including the exchanges in this regard. [Ref. para. 4.10]

6.9 Recommendation #9: The group recommends that in respect of domestic sale/purchase
of commodities in the positive list, unlisted entities may be permitted to hedge
commodity risk overseas with the approval of their AD bank. Subsequently, if and when
AD banks are permitted by RBI to deal in commodity derivatives, unlisted entities may
hedge with the banks as the counterparty. [Ref. para. 4.11]

6.10 Recommendation #10: The Group recommends that domestic banks and/or their
subsidiaries active in capital markets be allowed to offer commodity hedging facility to
their constituents, initially on a back-to-back basis, on both OTC and exchanges,
including on domestic exchanges. Later, when necessary risk management capability has
been acquired, banks may be allowed to run a book in commodity derivatives within the
umbrella limit of 20% of NOF applicable for investment in equities, venture capital funds
(VCFs) & equity linked mutual funds. For this purpose, RBI may consider the necessary
legal enablement in the B.R. Act, 1949. [Ref. para. 5.4]

***

32
 Annex

An Overview of the Domestic Commodity Derivatives Exchanges

At present, the Indian commodity futures market active eco-system comprises of three
national exchanges (NCDEX, MCX and NMCE) and three commodity specific regional
exchanges (Hapur Commodity Exchange, The Rajkot Commodities Exchange and IPSTA
Kochi). While 91 commodities have been notified by the Central Government to be eligible
for trading in the commodities futures market, contracts on around 39 commodities are
currently being traded at these exchanges, of which 29 are agricultural and 10 are non-
agricultural commodities. Futures in commodities shown in the table below are being
offered by the three national exchanges.

Commodity type Commodities

Precious Metals Gold & Silver
Metals Aluminium, Copper, Lead, Zinc, Nickel & Steel
Energy Crude & Natural Gas
Agricultural Cotton, Cotton seed oilcake, Soy bean, Refined soy oil, Crude
palm oil, Cardamom, Mustard seed, Kapas, Pepper, Mentha oil,
Turmeric, Guar seed & gum, Jeera, Chilli, Rubber, Coriander,
Castor seed, Copra, Bajra, Wheat, Barley, Maize, Isabgul, Raw
jute, Sacking & Coffee Robusta
Source: MCX, NCDEX and NMCE websites

ii
Turnover/Volume traded/Open Interest
The aggregate turnover at all the exchanges in the domestic commodity derivatives
segment increased by 9.1 per cent to ₹ 66,96,380 crore in 2015-16 from ₹ 61,35,672 crore in
2014-15. Further, the aggregate turnover at all the exchanges in the domestic commodity
derivatives segment for 2016-17 (till February 2017) was ₹ 59,83,146 crore. The highest
share in the all-India turnover of approximately 90.7 per cent was recorded at MCX,
followed by 8.9 per cent at NCDEX and 0.4 per cent at NMCE. The chart below shows the
respective share of exchanges in the consolidated volume traded across exchanges for FY
2016. In terms of the total volume traded in Commodity futures, MCX held the dominant
position with 80.1 per cent share, followed by NCDEX (19.1 per cent) and NMCE (0.5 per
cent).

33
Chart: Share of Exchanges in Total Volume Traded in Commodity Futures (FY 2016)

MCX
In 2015-16, the total turnover at MCX increased by 8.7 per cent to ₹ 56,34,194 crore
compared to ₹ 51,83,707 crore in 2014-15. Further, the total turnover at MCX in 2016-17
(till February end) is ₹ 54,25,289 crore. Bullion with the highest share in turnover witnessed
a decline of 3.9 per cent in 2015-16 over 2014-15. As compared to 2014- 15, turnover in
energy increased by 17.7 per cent in 2015-16. The metals segment recorded an 18.1 per
cent increase in turnover in 2015-16 while the agriculture segment witnessed a 10.4 per
cent increase in turnover. Open interest at the exchange increased from ₹ 8,715 crore in
2014-15 to ₹ 9,080 crore in 2015-16.

NCDEX
At NCDEX, the total turnover in 2015-16 was ₹ 10,19,588 crore, representing an increase of
12.8 per cent from ₹ 9,04,063 crore in 2014-15. Further, the total turnover at NCDEX in
2016-17 (till February end) is ₹ 5,32,775 crore which represents the sharp decline. Turnover
in the agriculture segment witnessed an increase of 14.7 per cent in 2015-16, while that in
bullion declined by 36.5 per cent in 2015-16 over the previous year. Open interest at the
exchange declined from ₹ 6,087 crore in 2014-15 to ₹ 4,703 crore in 2015-16.
NMCE
At NMCE, the total turnover in 2015-16, contributed entirely by agriculture segment was ₹
29,368 crore, a decrease of 18.5 per cent from ₹ 36,040 crore in 2014-15. Further, the total

34
turnover at NMCE in 2016-17 (till February end) is ₹ 25,083 crore. Open interest at the
exchange increased from ₹ 46 crore in 2014-15 to ₹ 61 crore in 2015-16.

Hapur Commodity Exchange

At Hapur Commodity Exchange, which is a commodity specific exchange for rape/mustard
seed, the total turnover in 2015-16 was ₹ 11,192 crore, an increase of 31.3 per cent from ₹
8,521 crore in 2014-15. Open interest at the exchange increased from ₹ 13 crore in 2014-15
to ₹ 23 crore in 2015-16.

Rajkot Commodity Exchange Ltd.

At the Rajkot Commodity Exchange Ltd., which is a commodity specific exchange for Castor
seed, the total turnover in 2015-16 was ₹ 1,976 crore, a decrease of 37.5 per cent from ₹
3,163 crore in 2014-15 (Table 2.54). At IPSTA, the commodity specific exchange for pepper,
the total turnover in 2015-16 was ₹ 62 crore, a decrease of 65.2 per cent from ₹ 178 crore in
2014-15.

Product Segment-wise Turnover/Volume traded

Of the aggregate all India turnover, 88.6 per cent was contributed by non-agri commodities
while the remaining 11.4 per cent was contributed by agri commodities. As against the
previous years, there has been a distinct shift in the relative shares of traded commodity
groups at MCX. The share of bullion, the dominant product segment, declined from 41.5 per
cent in 2014-15 to 36.7 per cent in 2015-16 and further to 35.5 percent in 2016-17 (till
February end). Energy contributed a 32.8 per cent share in turnover followed by metal at
29.3 per cent and agriculture at 2.3 per cent. At NCDEX, agriculture had the highest share in
turnover at 98 per cent followed by bullion at 2 per cent in 2015-16 and nearly 100 percent
in 2016-17 (till February end). At NMCE, the entire turnover was that of the agriculture
segment.

Agri Commodities

On the whole, 27 agri commodities were traded at the Indian commodities futures
exchanges, of which NCDEX traded 19, MCX (6) and NMCE (11) during 2016-17. A few
commodities like kapas, castor seed, mustard seed, cotton and guar seed, etc., were traded
at more than one exchange. In addition to the above, the regional exchanges are
commodity specific as the Rajkot Commodity Exchange Ltd. trades castor seed; the Hapur

35
Commodity Exchange, trades mustard seeds, and IPSTA trades pepper. At MCX, the share of
agri commodities in the total turnover for 2016-17 was a miniscule 2.3 per cent. Crude palm
oil (CPO) was the most traded agri commodity with a percentage share of 0.79 per cent in
the total turnover at the exchange. Apart from CPO, mentha oil, cotton, cardamom and
kapas were the only agri commodities traded at MCX during 2015-16. At NCDEX, the share
of agri commodities in the total turnover for 2015-16 was almost 100 percent. The top 10
agri commodities contributed 89.7 per cent of the turnover of the exchange. Chana was the
most traded agri commodity with a percentage share of 15.7 per cent in the total turnover
at the exchange. Soya oil with a share of 14.0 per cent and guar seed with a share of 11.3
per cent were the other most traded commodities at NCDEX during the year. At NMCE,
rape/mustard seed was the most traded agri commodity with 22.0 per cent share of per
cent in the total turnover, followed by isabgul seed at 20.7 per cent.

Non-Agri Commodities
At MCX, in 2016-17 the share of non-agri commodities in the total turnover was 97.7 per
cent. Crude oil was the most traded non-agri commodity with a percentage share of 29.8
per cent in the total turnover at the exchange. Gold was the other most traded commodity
with a share in turnover of 22.1 per cent followed by silver at 14.7 per cent. Trading in non-
agri commodities in NCDEX was negligible.

***

List of sources:

i SEBI PR No. 237/2015 dated September 28, 2015

ii Annual Report 2015-16 of Securities and Exchange Board of India (SEBI)

36