New Antidumping Duty and Countervailing Duty Petitions on Certain Choline Salts from China

At a Glance

• BCP Ingredients, Inc., filed antidumping and countervailing duty petitions on certain choline salts from China.
• An investigation related to this petition could result in increased prices and/or decreased supply of certain choline salts.
• The US Department of Commerce is expected to begin investigations on July 14, 2026.

On June 24, 2026, antidumping (AD) and countervailing duty (CVD) petitions were filed on certain choline salts from the People's Republic of China. The petitions were filed by BCP Ingredients, Inc.

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 certain choline salts.

Uses

According to the petition, choline is an organic chemical compound that is an essential nutrient for animals and humans. Moreover, supplementation of choline in animal and human diets is often required, thus it may be incorporated into various animal or human foods or dietary supplements. The petition identifies the three most common commercial forms of choline salts as Choline Chloride (CC), Choline Bitartrate (CBT), and Choline Dihydrogen Citrate (CDHC) and notes that these can be added to animal feed, infant formula, prenatal dietary supplements, fortified foods, and other nutraceutical products for human consumption. CBT can also be encapsulated, typically in a lipid coating, resulting in a granule presentation. This encapsulated CBT is most often sold to the fortified foods industry, as the coating protects the choline molecule from other ingredients in the food. Outside of health applications, choline salts can be used as a clay stabilizer for fracturing fluids in the oil and gas industry, although it is rarely used for this application.

Scope

Please note that this section was not written by our authors but is taken verbatim from the petition.

The merchandise covered by this investigation is certain choline salts, in all forms and purities. Subject choline salts may or may not contain additives such as a carrier or an anti-caking agent and may or may not be coated or encapsulated. For choline salts that contain non-choline components, such as a carrier or coating, the entire article is covered, including the non-choline content, provided that the choline content constitutes at least 30% by weight.

Choline salts are organic compounds and quaternary ammonium salts. Subject merchandise includes, but is not limited to, the following choline salts:

• Choline chloride, which exists as a colorless aqueous solution and as a white, crystalline powder which may or may not be mixed with vegetable, inorganic, or fat-based carriers. It has the molecular formula [(CH₃)₃NCH₂CH₂OH]⁺Cl^- and may also be referred to as (2-hydroxyethyl) trimethylammonium chloride. The Chemical Abstracts Service (CAS) registry number for choline chloride is 67-48-1; the Flavoring Extract Manufacturers' Association (FEMA) number is 4500; the PubChem number is 6209; and the European Community (EC) number is 200-655-4;
• Choline bitartrate, which is a white crystalline powder with the molecular formula [(CH₃)₃NCH₂CH₂OH]⁺HOOC⁻CH(OH)⁻CH(OH)⁻COO⁻ and may be referred to as (2-hydroxyethyl) trimethylammonium-L-(+)-tartrate salt. Choline bitartrate has the CAS registry number 87-67-2; the PubChem number 6900; and the EC number 201-763-4;
• Choline dihydrogen citrate, which is a white crystalline powder with the molecular formula C₁₁H₂₁NO₈ and may be referred to as (2-hydroxyethyl) trimethylammonium citrate. Choline dihydrogen citrate has the CAS registry number 77-91-8; the PubChem number 66170; and the EC number 201-068-6;

This investigation covers choline salts for which the reaction of trimethylamine and ethylene oxide occurs in the subject country. The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including, but not limited to, refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation if performed in the country of manufacture of the in-scope choline. Liquid or dried choline salts subject to this investigation are not excluded when commingled with choline salts from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigation.

Excluded from the scope of this investigation is choline hydroxide, which has the molecular formula C₅H₁₅NO₂, the CAS registry number 123-41-1, the PubChem number 31255, and the EC number 204-625-1. Also excluded is choline salicylate, which has the molecular formula C₁₂H₁₉NO₄, the CAS registry number 2016-36-6, the PubChem number 54686350, and the EC number 217-948-8.

The choline salts subject to this investigation are classified under the Harmonized Tariff Schedule of the United States (HTSUS) subheading 2923.10.0000. Subject choline salts may also be classified under HTSUS subheading 2106.90.9998, and dried choline chloride subject to this investigation may be classified under HTSUS subheadings 2309.90.1005, 2309.90.1015, 2309.90.1020, 2309.90.1030, 2309.90.1032, 2309.90.1035, 2309.90.1045, 2309.90.1050, 2309.90.9500, and 3824.99.9397. Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.

Downstream Implications

Please note that the wording of the proposed scope language suggests that the petitioner is attempting to include within the investigation a broad range of downstream products. For example, as noted above, the petition states that "[f]or choline salts that contain non-choline components, such as a carrier or coating, the entire article is covered, including the non-choline content, provided that the choline content constitutes at least 30% by weight." The proposed scope language also asserts as follows:

The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including, but not limited to, refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation if performed in the country of manufacture of the in-scope choline. Liquid or dried choline salts subject to this investigation are not excluded when commingled with choline salts from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigation.

The implication from the above scope language and certain other discussions in the petition suggests that the scope could potentially cover choline chloride and choline bitartrate that are added to infant formula, nutritional supplements, and multivitamins. Indeed, the petition explicitly discusses US Customs rulings outlining the HS codes for cat food and vitamins that contain choline salts as an ingredient and includes those HTSUS codes in the scope language.

Estimated Dumping Margins

The petitioner alleges dumping margins ranging from 112.43% to 300.71%.

The petitioner also alleges subsidies with respect to subject imports, 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):