At a Glance
- Evonik Corporation and Huntsman International LLC filed antidumping and countervailing duty petitions on certain amine compounds from China.
- Investigation related to these petitions could result in increased prices and/or decreased supply of certain amine compounds.
- The US Department of Commerce is expected to begin investigation on October 19, 2026.
On September 29, 2026, antidumping (AD) and countervailing duty (CVD) petitions were filed on certain amine compounds from China. The petitions were filed by Evonik Corporation and Huntsman International LLC.
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 amine compounds.
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 includes certain amine compounds, which are catalysts for the reaction of isocyanates with hydroxy-containing substances such as polyols and/or water. Certain amine compounds are organic compounds containing one or more nitrogen atoms that may be bonded to two or three separate carbon atoms. One or more of these carbon atoms is part of an ethylene (-CH2CH2-) or propylene (-CH2CH2CH2-) bridge that separates the nitrogen from another nitrogen atom or an oxygen atom. One or more of the remaining carbon atoms will be part of a methyl (-CH3) group or other alkyl group. Products that are subject to the scope are listed below and typically have the following Chemical Abstracts Service ("CAS") numbers:
CAS Number |
Description |
Molecular Formula |
|
6711-48-4 |
1,3-Propanediamine, N'-[3-(dimethylamino)propyl]-N,N-dimethyl- or N,Ndimethyl-1,3-Propanediamine, N'-[3-(dimethylamino)propyl] |
C₁₀H₂₅N₃ |
|
2212-32-0 |
2-[[2-(Dimethylamino)ethyl]methylamino]ethanol |
C₇H₁₈N₂O |
|
1704-62-7 |
Ethanol, 2-[2-(dimethylamino)ethoxy]- or 2-[2-(dimethylamino)ethoxy]ethanol |
C₆H₁₅NO₂ |
|
3030-47-5 |
bis(2-dimethylaminoethyl)(methyl)amine |
C₉H₂₃N₃ |
|
3033-62-3 |
N,N,N',N'-tetramethyl-2,2'-oxybis(ethylamine) |
C₈H₂₀N₂O |
|
6425-39-4 |
2,2'-dimorpholinyldiethyl ether |
C₁₂H₂₄N₂O₃ |
Products subject to these investigations are liquids varying from clear to hazy. They have a viscosity at 25 degrees Celsius of between 1-100 mPa·s. Certain amine compounds covered by this scope have a density at 21 degrees Celsius of 0.82 to 1.05 g/cm³. Certain amine compounds covered by this scope have a molecular weight between 133 g/mol and 245 g/mol. The boiling point for subject merchandise covers a range from 200 degrees Celsius (392 degrees Fahrenheit) to 265 degrees Celsius (509 degrees Fahrenheit).
Certain amine compounds may be blended with each other or with other substances. Certain amine compounds in any blend or mixture are subject to the scope, so long as the blend or mixture contains at least 1 percent by weight of in-scope amine compounds. Any substances other than the certain amine compounds in a blend or mixture are not included in the scope.
For certain amine compounds that enter as part of a rigid or flexible polyurethane foam system that contains a separately packaged isocyanate mixture "A side" and a polyol-based "B side" blend containing certain amine compounds, the amine compounds in the system are included in the scope so long as the B side contains at least 1 percent by weight of in-scope amine compounds. Substances other than the certain amine compounds in the system are not included in the scope.
The scope includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, introducing, or removing ingredients, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the subject country. If any certain amine compounds produced in China are present in blended or processed merchandise, the country of origin of the amine compounds for purposes of this investigation will be China.
Excluded from the scope of these investigations is any in-scope amine compound that is subject to existing anti-dumping and countervailing duty orders by nature of being part of a subject blend or mixture under the Certain Alkyl Phosphate Esters from the People's Republic of China Orders. See Certain Alkyl Phosphate Esters from the People's Republic of China: Antidumping and Countervailing Duty Orders, 90 Fed. Reg. 24,579 (June 11, 2025).
This merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings, including 2909.11.00.00, 2922.19.96.90, 2921.29.00.55, and 2934.99.90.01. Subject merchandise may also be entered under subheadings 2921.21.00.00 and 3815.90.50.00. The HTSUS subheadings and CAS numbers are provided for convenience and customs purposes only; the written description of the scope is dispositive.
Estimated Dumping Margins
The petitioners allege dumping margins ranging from 261.34% to 476.13%.
The petitioners also allege subsidies with respect to subject imports from China, although the CVD petition does not quantify the alleged net subsidy margin.
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):
|
September 29, 2026 |
Petitions are filed. |
|
October 19, 2026 |
DOC initiates investigations. |
|
October 20, 2026 |
ITC staff conference (estimated). |
|
November 13, 2026 |
Deadline for ITC preliminary injury determinations. |
|
December 23, 2026 |
Deadline for DOC preliminary CVD determination, if deadline is NOT postponed. |
|
February 26, 2027 |
Deadline for DOC preliminary CVD determination, if deadline is fully postponed. |
|
March 8, 2027 |
Deadline for DOC preliminary AD determination, if deadline is NOT postponed. |
|
April 27, 2027 |
Deadline for DOC preliminary AD determination, if deadline is fully postponed. |
|
September 9, 2027 |
Deadline for DOC final AD/CVD determinations, if all deadlines are fully postponed. |
|
October 25, 2027 |
Deadline for ITC final injury determinations, if all DOC deadlines are fully postponed. |