New Trade Petitions Target China’s Certain Amine Compounds, Alleging Dumping Margins of Up to 476%

New Antidumping and Countervailing Duty Petitions

On September 29, 2026, U.S. producers filed antidumping (AD) and countervailing duty (CVD) petitions on certain amine compounds (CACs) from China with the Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“ITC”). The petitions allege dumping margins ranging from 261.34% to 476.13% and subsidies above the de minimis level. These figures are allegations; Commerce has not calculated any duty or cash deposit rates. If the investigations proceed and Commerce issues an affirmative preliminary determination, U.S. importers could face cash deposit requirements on covered entries as early as December 2026 for CVD and March 2027 for AD. These dates are preliminary and may change.

The subject merchandise elements—certain amine compounds—are used as catalysts in polyurethane foam systems. They may be used to control and/or balance both the gelling reaction and the gas-forming or foaming reaction responsible for polyurethane foam formation. CACs are most commonly used in rigid polyurethane foam products, particularly in spray foam used as an insulation material in residential and commercial buildings. CACs have chemical properties that can make downstream polyurethane spray foam products efficient insulation materials, and amine compounds impact air sealing and sound dampening properties.

Importers, retailers, distributors, and their Chinese suppliers should promptly compare their merchandise and supply chains now with the proposed scope. An affirmative preliminary finding could change landed costs and cash flow while orders and shipments are still in the pipeline. The agencies have not yet determined whether the domestic industry is injured or whether the alleged dumping and subsidies exist.

Proposed Product Scope

The petitions propose the following scope language. Commerce may revise the scope during the investigations:

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 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 as 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.

Alleged Margins and Potentially Affected Companies

The petitions identify certain Chinese producers and exporters and U.S. importers. Being named does not establish that a company’s products are covered; being absent from the lists does not establish that they are excluded. Companies should review their merchandise and supplier relationships against the proposed scope. Clark Hill can provide the lists identified in the petitions.

The petitioners allege the following margins. Commerce will calculate any applicable deposit rates during its investigations:

• China: alleged AD margins of 261.34% to 476.13%; alleged CVD subsidies above de minimis, without a proposed numerical CVD rate.

How the Investigations Proceed

The ITC will first decide whether there is a reasonable indication of material injury or threat of material injury to the U.S. industry. A negative preliminary injury determination would terminate the investigations. If the ITC’s finding is affirmative, Commerce will investigate dumping and subsidization and calculate any AD and CVD rates. Final duties require affirmative final determinations from both agencies.

If the investigations continue, Commerce’s preliminary CVD and AD determinations are estimated for December 23, 2026, and March 8, 2027, respectively. Following an affirmative preliminary determination, cash deposits generally begin on covered entries as of publication of that determination in the Federal Register. If critical circumstances are found, suspension of liquidation and cash deposit requirements may apply retroactively to entries made up to 90 days before that publication. The dates are estimates and may be extended; the petitioners’ alleged margins are not the deposit rates.

What Importers and Chinese Suppliers Can Do Now

U.S. importers should compare specifications, species, dimensions, and processing history for each product with the proposed scope, identify the manufacturer and exporter, and map open orders and expected entry dates. Review landed cost and cash flow scenarios using possible AD and CVD deposits, without treating the petitioners’ estimates as the eventual rates.

Chinese producers and exporters should preserve product, sales, production, and subsidy records, identify related companies, and prepare for possible Commerce questionnaires. In a AD investigation for China, timely separate rate applications may be important for exporters seeking a rate distinct from the China-wide rate. The agency’s initiation notice and subsequent questionnaires will set actual filing deadlines.

Both sides should review pricing and duty allocation terms in supply contracts and decide promptly whether to present product scope or injury arguments. The indicative schedule below is subject to agency notices and extensions.

Approxímate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/29/2026
DOC Initiation Date	20	10/19/2026
DOC Separate Rate Applications	To be set	To be announced
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	11/13/2026
DOC Preliminary AD Determination	160	3/8/2027
DOC Final AD Determination	235	5/23/2027
ITC Final AD Determination	280	7/6/2027
DOC AD Publication of Order	287	7/13/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/29/2026
DOC Initiation Date	20	10/19/2026
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	11/13/2026
DOC Preliminary CVD Determination	85	12/23/2026
DOC Hearing Request Deadline (if applicable)	To be set	To be announced
DOC Final CVD Determination	160	3/8/2027
ITC Final CVD Determination	205	4/22/2027
DOC CVD Publication of Order	212	4/29/2027

 

* All deadlines are approximate and are subject to change throughout the course of an investigation. Deadlines that fall on a weekend or Federal holiday are extended to the next business day, as shown above. Contact Clark Hill for current updates and details.