February 05, 2020

New Antidumping Petition on Corrosion Inhibitors From China

By Douglas J. Heffner and Richard P. Ferrin

On February 5, 2020, Wincom Incorporated (petitioner) filed antidumping (AD) and countervailing duty (CVD) petitions on imports of certain corrosion inhibitors from China.

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” The U.S. 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 U.S. government must determine not only that dumping and/or subsidies are 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 corrosion inhibitors.

Scope

The merchandise covered by this petition is tolyltriazole and benzotriazole. This includes tolyltriazole and benzotriazole of all grades and forms, including their sodium salt forms. Tolyltriazole is technically known as Tolyltriazole IUPAC 4,5 methyl benzotriazole. It can also be identified as 4,5 methyl benzotriazole, tolutriazole, TTA, and TTZ.

Benzotriazole is technically known as IUPAC 1,2,3-Benzotriazole. It can also be identified as 1,2,3-Benzotriazole, 1,2-Aminozophenylene, 1H-Benzotriazole, and BTA.

All forms of tolyltriazole and benzotriazole, including but not limited to flakes, granules, pellets, prills, needles, powder, or liquids, are included within the scope of these petitions.

The scope includes tolyltriazole/sodium tolyltriazole and benzotriazole/sodium benzotriazole that are combined or mixed with other products. For such combined products, only the tolyltriazole/sodium tolyltriazole and benzotriazole/sodium benzotriazole component is covered by the scope of these investigations. Tolyltriazole and sodium tolyltriazole that have been combined with other products is included within the scope, regardless of whether the combining occurs in third countries.

Tolyltriazole, sodium tolyltriazole, benzotriazole and sodium benzotriazole that is otherwise subject to these investigations is not excluded when commingled with tolyltriazole, sodium tolyltriazole, benzotriazole, or sodium benzotriazole from sources not subject to these investigations. Only the subject merchandise component of such commingled products is covered by the scope of these investigations.

Tolyltriazole has the Chemical Abstracts Service (CAS) registry number 299385-43-1. Tolyltriazole is classified under Harmonized Tariff Schedule of the United States (HTSUS) subheading 2933.99.82.20.

Sodium Tolyltriazole has the CAS registry number 64665-57-2 and is classified under HTSUS subheading 2933.99.82.90.

Benzotriazole has the CAS registry number #95-14-7 and is classified under HTSUS subheading 2933.99.82.10.

Sodium Benzotriazole has the CAS registry number 15217-42-2. Sodium Benzotriazole is classified under HTSUS subheading 2933.99.82.90.

Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

Alleged Dumping Margins

The petitioner alleges a dumping margin of 388.28 to 420.32 percent.

While the petitioner does not allege a specific subsidy rate, the petitioner alleges that the Chinese industry has benefited from preferential lending programs, grants, export credit insurance, tax credits, import duty exemptions, and the provision of manufacturing inputs by the government for less than adequate remuneration.

Estimated Schedule of Investigations

  • February 5, 2020 — Petition is filed
  • February 25, 2020 — DOC initiates investigation
  • February 26, 2020 — ITC staff conference
  • March 23, 2020 — Deadline for ITC preliminary injury determinations
  • April 30, 2020 — Deadline for DOC preliminary CVD determination, if not postponed
  • July 6, 2020 — Deadline for DOC preliminary CVD determination, if fully postponed
  • July 14, 2020 — Deadline for DOC preliminary AD determination, if not postponed
  • September 2, 2020 — Deadline for DOC preliminary AD determination, if fully postponed
  • January 15, 2021 — Deadline for DOC final AD and CVD determinations, if both preliminary and final determinations are fully postponed
  • March 1, 2021 — Deadline for ITC final injury determinations, assuming fully postponed DOC deadlines
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