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New Trade Case on Imports of Granular Polytetrafluoroethylene Resin From India and Russia

A new U.S. antidumping (“AD”) and countervailing (“CVD”) duty petition was filed on Jan. 27 by Daikin America, Inc. against imports of granular polytetrafluoroethylene (“PFTE”) resin from India and Russia.

Granular PTFE is used in seals, bearings, gaskets, bushings, corrosion-resistant linings, lab equipment, piping components, piston rings, and diaphragms. Producers of PTFE use specific trade names for their products, including Polyflon™, a registered trademark of Daikin, and Teflon©, a registered trademark of The Chemours Company FC LLC.

The merchandise covered by this petition is granular PTFE. Granular PTFE is a white powder of various particle sizes, with a high melting point and melt viscosity. As a result of this high melting point and melt viscosity, granular PTFE is processed by compression molding or ram extrusion, followed by sintering. Those compression molded products are then fabricated into basic shapes, such as cylinders and cubes (stock shapes). The stock shapes can then be machined or cut into moldings such as seals. For a full description of the scope of the petition, please see the Scope section below.

The petition includes AD (less than fair value) and CVD (unfair subsidies) allegations against India and Russia. The Department of Commerce (“DOC”) and the International Trade Commission (“ITC”) will conduct the investigations. Within the next 45 days, the ITC will determine if there is a reasonable indication that the imports are injuring the U.S. industry. If the ITC finds that the standard is met, then the cases will move to the DOC which will calculate the preliminary AD duty margins.

The DOC’s preliminary determinations are currently scheduled for April 22(CVD) and July 6 (AD), which are the dates when importers will be required to deposit the calculated duties upon the products’ entry into the U.S. market.

There are strict statutory deadlines associated with these proceedings and affected companies are advised to prepare as soon as possible. If this product is of interest to you, please let us know so that we can provide you with additional information as it becomes available.

The following are key facts about this trade case:

Petitioner: Daikin America, Inc.

Prior Import Relief: In 1987, E.I. du Pont de Nemours & Co., Inc., filed AD petitions on imports of granular PTFE from Italy and Japan. AD orders on imports from those countries were in place until Dec. 22, 2010, when they were revoked through a “sunset” review.

In 2017, Chemours filed AD petitions on imports from China and India, as well as a CVD petition on imports from India. The ITC determined that the domestic industry was not injured by imports of PTFE from those countries and the investigations were terminated.

Foreign Producers/Exporters and US Importers:  Please contact us for a listing of individual companies named in the petition.

AD margins:  Petitioner has alleged the following AD and CVD margins:

  • India: a calculated AD margin of 214.77 ad valorem and a CVD margin above de minimis; and
  • Russia: a calculated AD margin of 71.01 percent ad valorem and a CVD margin above de minimis.

Merchandise covered by the scope of the case:

The product covered by this investigation is granular polytetrafluoroethylene (PTFE) resin. PTFE is covered by the scope of this investigation whether filled or unfilled, whether or not modified, and whether or not containing co-polymer, additives, pigments, or other materials. Also included is PTFE wet raw polymer. The chemical formula for PTFE is C2F4, and the Chemical Abstracts Service Registry number is 9002-84-0.

Subject merchandise includes material matching the above description that has been finished, packaged, or otherwise processed in a third country, including by filling, modifying, compounding, packaging with another product, or performing any other finishing, packaging, or processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the country of manufacture of the granular PTFE.

The product covered by this investigation does not include dispersion or coagulated dispersion (also known as fine powder) PTFE.

PTFE further processed into micro-powder, having particle size typically ranging from 1 to 25 microns, and a melt-flow rate no less than 0.1 gram/10 minutes, is excluded from the scope of this investigation.

Granular PTFE is classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 3904.61.0010. Subject merchandise may also be classified under HTSUS subheading 3904.69.5000. Although the HTSUS subheadings and CAS Number are provided for convenience and Customs purposes, the written description of the scope is dispositive.

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680), Kevin Williams (kwilliams@clarkhill.com; 312-985-5907); William Sjoberg (wsjoberg@clarkhill.com; 202-772-0924), Courtney Gayle Taylor (cgtaylor@clarkhill.com; 202-552-2350); Dennis Devaney (ddevaney@clarkhill.com); or another member of Clark Hill's International Trade Business Unit.