At a Glance
- Advancion Corporation filed antidumping and countervailing duty petitions on Tris(hydroxymethyl)aminomethane (Tris) from China.
- An investigation related to this petition could result in increased prices and/or decreased supply of Tris.
- The US Department of Commerce is expected to begin investigation on May 11, 2026.
On April 21, 2026, antidumping (AD) and countervailing duty (CVD) petitions were filed on Tris(hydroxymethyl)aminomethane (Tris) from China. The petitions were filed by Advancion Corporation.
Tris is an organic compound that is highly soluble in water and is used as a buffer, pH adjuster, and stabilizer in a wide range of applications, including (but not limited to) monoclonal antibodies, COVID and other diagnostic kits, mRNA and novel vaccines developed to fight the COVID virus, and many GLP-1s. Tris is also used on personal care and cosmetic applications, such as facial cleansers, skin care products, deodorants, and hand and body lotions. Tris is also used as an odor control agent in fabric care, as well as formaldehyde scavenger neutralizing agents in industrial applications such as paint and concrete.
The US AD law imposes special tariffs to counteract imports that are sold in the United States at less than "normal value." The US CVD law imposes special tariffs to counteract imports that are sold in the United States with the benefit of foreign government subsidies. For AD/CVD duties to be imposed, the US government must determine not only that dumping and/or subsidization is occurring, but also that there is "material injury" (or threat thereof) by reason of the dumped and/or subsidized imports. Importers are liable for any potential AD/CVD duties imposed. In addition, these investigations could impact purchasers by increasing prices and/or decreasing supply of Tris..
Scope
Please note that this section was not written by our authors but is taken verbatim from the petition.
The merchandise subject to these investigations is tris(hydroxymethyl)aminomethane, also commonly referred to as tromethamine or THAM, and its derivative, tris(hydroxymethyl)aminomethane hydrochloride (“Tris HCl”), also commonly referred as Tris hydrochloride or tromethamine HCl (collectively, "Tris"). Tris and Tris HCl are organic compounds with molecular compositions of C4H11NO3 and C4H11NO3.ClH, respectively. The scope includes all grades, purities, and forms of Tris and Tris HCl, which vary based on the raw materials (nitromethane and formaldehyde) used in the production process and the end use application required. Tris and Tris HCl are packaged and sold in different forms and sizes, however, all Tris and Tris HCl are covered regardless of form or packaging. The Tris and Tris HCl covered by these investigations are chemical compounds with the Chemical Abstract Service ("CAS") numbers 77-86-1 and 1185-53-1, respectively. The country of origin of the subject merchandise in these investigations is based on the country where the Tris molecule is manufactured. As a result, Tris HCl manufactured in a third country using Tris produced in China is subject to the investigations. In addition, reprocessing Tris or Tris HCl in a third country by, for example, recrystallizing, retesting, or repackaging the merchandise does not remove the product from the scope of these investigations. Tris and Tris HCl covered by the scope of these investigations are currently classified under Harmonized Tariff Schedule of the United States ("HTSUS") subheading 2922.19.9690. Although the HTSUS subheading is provided for convenience and customs purposes, the written description of the scope is dispositive.
Estimated Dumping Margins
The petitioner alleges dumping at margins of up to 965.62%.
The petitioner also alleges subsidies with respect to subject imports from China, although the CVD petition does not quantify the alleged net subsidy margins.
Estimated Schedule of Investigations
The following is an estimated schedule of investigations by the US Department of Commerce (DOC) and the US International Trade Commission (ITC):
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April 9, 2026 |
Petitions are filed. |
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April 29, 2026 |
DOC initiates investigations. |
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April 30, 2026 |
ITC staff conference (estimated). |
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May 25, 2026 |
Deadline for ITC preliminary injury determinations. |
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July 6, 2026 |
Deadline for DOC preliminary CVD determination, if deadline is NOT postponed. |
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September 8, 2026 |
Deadline for DOC preliminary CVD determination, if deadline is fully postponed. |
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September 16, 2026 |
Deadline for DOC preliminary AD determinations, if deadline is NOT postponed. |
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November 5, 2026 |
Deadline for DOC preliminary AD determinations, if deadline is fully postponed. |
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March 22, 2027 |
Deadline for DOC final AD/CVD determinations, if all deadlines are fully postponed. |
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May 6, 2027 |
Deadline for ITC final injury determinations, if all DOC deadlines are fully postponed. |