On September 29, 2026, Evonik Corporation and Huntsman International LLC (“Petitioners”) filed petitions requesting the imposition of antidumping and countervailing duties on imports of certain amine compounds (“CACs”) from the People’s Republic of China.
SCOPE OF THE INVESTIGATION
The proposed scope of these investigations is as follows:
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: 6711-48-4 (1,3-Propanediamine, N’-[3-(dimethylamino)propyl]-N,N-dimethyl-, C10H25N3); 2212-32-0 (2-[[2-(Dimethylamino)ethyl]methylamino]ethanol, C7H18N2O); 1704-62-7 (Ethanol, 2-[2-(dimethylamino)ethoxy]-, C6H15NO2); 3030-47-5 (bis(2-dimethylaminoethyl)(methyl)amine, C9H23N3); 3033-62-3 (N,N,N’,N’-tetramethyl-2,2′-oxybis(ethylamine), C8H20N2O); and 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 and 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 antidumping 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.
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.
PETITIONERS
| Evonik Corporation 2 Turner Place Piscataway, NJ 08854 Contact: Matthew Aldag, Vice President Phone: 732-981-5060 Email: matthew.aldag@evonik.com |
| Huntsman International LLC 10003 Woodloch Forest Drive The Woodlands, TX 77380 Contact: Lewis Craft, Associate General Counsel Phone: 281-719-6000 Email: lewis_craft1@huntsman.com |
COUNSEL FOR PETITIONERS
| MAYER BROWN LLP 1999 K Street, N.W. Washington, DC 20006-1101 (202) 263-3235 |
NAMED PRODUCERS/EXPORTERS
For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.
NAMED IMPORTERS
For a list of importers alleged by the Petitioners, please see Attachment II.
ESTIMATED SCHEDULE
| Event | Earliest Date |
| Petition Filed | September 29, 2026 |
| DOC Initiation | October 19, 2026 |
| ITC Preliminary Investigation: | |
| Questionnaires Due | October 13, 2026 |
| Request to appear at hearing | October 18, 2026 |
| Hearing | October 20, 2026 |
| Briefs | October 23, 2026 |
| ITC Preliminary Vote | November 13, 2026 |
| DOC Investigation Schedule: | |
| DOC Preliminary Countervailing Determination | December 23, 2026 |
| DOC Preliminary Antidumping Determination | March 8, 2027 |
| DOC Final Countervailing Determination | March 8, 2027 |
| DOC Final Antidumping Determination | May 22, 2027 |
| ITC Final Investigation: | |
| ITC Final CVD Determination | April 22, 2027 |
| ITC Final AD Determination | July 6, 2027 |
ALLEGED DUMPING MARGINS
China: 261.34% – 476.13%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis.
ALLEGED SUBSIDIES
For a list of alleged subsidies by the Petitioners, please see Attachment III.
IMPORTS OF SUBJECT MERCHANDISE
U.S. imports of CACs from China are set forth below, based on data from Datamyne and USITC Trade DataWeb for HTSUS subheadings 2909.11.0000, 2921.29.0055, 2922.19.9690, and 2934.99.9001, as reported in Exhibit I-12 to Volume I of the Petition.
| 2023 | 2024 | 2025 | Jan.-Jun. 2026 | |
| Quantity (1,000 lbs.) | 31,763 | 45,447 | 42,104 | 24,502 |
| Value (USD, LDPV) | $315,122,427 | $407,463,195 | $277,130,659 | $143,633,056 |
| China’s Share of Total Import Quantity | 29% | 33% | 31% | 32% |
| China’s Share of Total Import Value | 24% | 36% | 22% | 24% |
| Total U.S. Imports, Quantity (1,000 lbs.) | 108,418 | 138,439 | 134,690 | 77,565 |
Note: Interim period figures cover January through June 2026 (quantity/value) or January through July 2026 (China’s monthly share data), as reported in the underlying exhibit. Source: Datamyne (quantity/value by country) and USITC Trade DataWeb (HTSUS subheadings identified above).
CONTACT US
For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.
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