New Trade Case Could Raise Costs for Certain Choline Salts from China

The Petitions

BCP Ingredients, Inc. has filed petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) seeking the imposition of antidumping (“AD”) and countervailing duties (“CVD”) on imports into United States certain choline salts (“choline salts”) from China. The petitions allege that imported choline salts from China are being sold in the United States at unfairly low prices and, in some cases, benefit from unfair government subsidies, causing material injury to the domestic industry. If the federal agencies agree, imports of choline salts could become subject to significant additional duties.

Currently, imports of choline salts from China are subject to tariffs that have been imposed on imports from China since 2018 under Section 301 of the Trade Act of 1974, 19 U.S.C. § 2411, and they may be subject to tariffs imposed under Section 122 of the Trade Act of 1974, 19 U.S.C. § 2132, since February 2026. Imports of the subject merchandise were also subject to tariffs imposed under the International Emergency Economic Powers Act throughout most of 2025.

The current petitions are not the first trade remedy proceedings involving choline products. In 1983, a U.S. producer, Syntex Agribusiness, Incorporated, filed an antidumping petition covering choline chloride from Canada. The U.S. International Trade Commission and the Department of Commerce ultimately issued an antidumping duty order in 1984, which remained in place until its revocation in 1989. More recently, Balchem Italia Srl, an affiliate of U.S. producer Balchem Corporation, successfully petitioned the European Commission to impose antidumping duties on choline chloride from China. The European Commission initiated its investigation in October 2024 and imposed definitive antidumping duties ranging from 90 to 115.9 percent in December 2025.

The subject merchandise—certain choline salts—is used to supplement choline, an essential nutrient for both animals and humans. Choline salts, including choline chloride and choline bitartrate, are commonly added to animal feed, infant formula, dietary supplements, fortified foods, and other nutraceutical products. In the United States, choline chloride is used primarily in animal nutrition applications. Choline chloride and choline bitartrate are also widely used in human nutrition products.

For importers, distributors, purchasers, and companies across the animal nutrition, feed, dietary supplement, and nutraceutical supply chains, this filing is important because these cases move quickly. If Commerce issues affirmative preliminary determinations, U.S. importers of choline salts from China may be required to post cash deposits on covered imports within months, potentially affecting pricing, sourcing decisions, and product availability.

Scope of the Investigations

The following language describes the imported merchandise that Petitioner intends to cover in these investigations:

The merchandise covered by this investigation is certain choline salts, in all forms and purities. Subject choline salts may or may not contain additives such as a carrier or an anticaking agent and may or may not be coated or encapsulated. For choline salts that contain noncholine components, such as a carrier or coating, the entire article is covered, including the noncholine content, provided that the choline content constitutes at least 30% by weight.

Choline salts are organic compounds and quaternary ammonium salts. Subject merchandise includes, but is not limited to, the following choline salts:

• Choline chloride, which exists as a colorless aqueous solution and as a white, crystalline powder which may or may not be mixed with vegetable, inorganic, or fat-based carriers. It has the molecular formula [(CH3)3NCH2CH2OH]+Cl- and may also be referred to as (2-hydroxyethyl) trimethylammonium chloride. The Chemical Abstracts Service (CAS) registry number for choline chloride is 67-48- 1; the Flavoring Extract Manufacturers’ Association (FEMA) number is 4500; the PubChem number is 6209; and the European Community (EC) number is 200- 655-4.
• Choline bitartrate, which is a white crystalline powder with the molecular formula [(CH3)3NCH2CH2OH]+ HOOC− CH(OH)− CH(OH)− COO− and may be referred to as (2-hydroxyethyl) trimethylammonium-L-(+)-tartrate salt. Choline bitartrate has the CAS registry number 87-67-2; the PubChem number 6900; and the EC number 201-763-4.
• Choline dihydrogen citrate, which is a white crystalline powder with the molecular formula C11H21NO8 and may be referred to as (2-hydroxyethyl) trimethylammonium citrate. Choline dihydrogen citrate has the CAS registry number 77-91-8; the PubChem number 66170; and the EC number 201-068-6.

This investigation covers choline salts, for which the reaction of trimethylamine and ethylene oxide occurs in the subject country. The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including but not limited to: refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation if performed in the country of manufacture of the in-scope choline. Liquid or dried choline salts subject to this investigation are not excluded when commingled with choline salts from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigation.

Excluded from the scope of this investigation is choline hydroxide, which has the molecular formula C5H15NO2, the CAS registry number 123-41-1, the PubChem number 31255, and the EC number 204-625-1. Also excluded is choline salicylate, which has the molecular formula C12H19NO4, the CAS registry number 2016-36-6, the PubChem number 54686350, and the EC number 217-948-8.

The choline salts subject to this investigation are classified under the Harmonized Tariff Schedule of the United States (HTSUS) subheading 2923.10.0000. Subject choline salts may also be classified under HTSUS subheading 2106.90.9998, and dried choline chloride subject to this investigation may be classified under HTSUS subheadings 2309.90.1005, 2309.90.1015, 2309.90.1020, 2309.90.1030, 2309.90.1032, 2309.90.1035, 2309.90.1045, 2309.90.1050, 2309.90.9500, and 3824.99.9397. Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.

Key Facts

Petitioner: BCP Ingredients, Inc.

Foreign Producers/Exporters and U.S. Importers:  The petitions identify a number of companies. Businesses that may be affected should review the petitions carefully and assess whether they are named directly or implicated through supply-chain relationships. Please contact Clark Hill’s International Trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins: The Petitioner alleged the following AD and CVD margins:

• China: AD Margin from 156.79% to 300.71% ad valorem, and a CVD margin above de minimis.

The Investigations

The DOC and ITC will conduct parallel investigations. The ITC examines whether the domestic industry is materially injured or threatened with material injury. The DOC determines whether dumping or subsidization exists and, if so, calculates the duty rates that importers must deposit.

If the DOC issues an affirmative preliminary determination, importers will be required to deposit the estimated AD/CVD duties on their imports as of the date that the DOC publishes its affirmative preliminary determination in the Federal Register. In this case, the DOC’s preliminary determinations are currently expected by September 17, 2026 (CVD) and December 1, 2026 (AD), although the schedule is subject to change. Importers should also be alert to the possibility of a critical circumstances finding, which in some cases can allow duty liability to date back to before the preliminary determination if the DOC finds that there is a surge of imports after the petitions were filed.

Next Steps

AD/CVD investigations are front-loaded. Key decisions are made early, and companies that wait until duties are imposed may lose important opportunities to shape the record.

Companies that import, purchase, sell, distribute, or use potentially covered choline salts should begin assessing their exposure now. Practical steps include confirming whether imported products fall within the proposed scope, identifying the country of manufacture and any third-country processing or assembly, reviewing whether the company is listed in the petitions, preserving import and sales records, and coordinating internally among legal, finance, procurement, sales, logistics, and operations teams. If your company imports certain choline salts, purchases products containing certain choline salts, or may otherwise be affected by these investigations, please contact Clark Hill’s International Trade team for additional details and strategic guidance.

A schedule of approximate key dates is below.

Approximate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	6/24/2026
DOC Initiation Date	20	7/14/2026
DOC Separate Rate Applications	41	8/4/2026
DOC Q&V Questionnaires	44	8/7/2026
ITC Preliminary Determination	45	8/10/2026
DOC Preliminary AD Determination	160	12/1/2026
DOC Final AD Determination	235	2/15/2027
ITC Final AD Determination	280	3/31/2027
DOC AD Publication of Order	287	4/7/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	6/24/2026
DOC Initiation Date	20	7/14/2026
DOC Q&V Questionnaires	44	8/7/2026
ITC Preliminary Determination	45	8/10/2026
DOC Preliminary CVD Determination	85	9/17/2026
Request for a DOC Hearing	122	10/24/2026
DOC Final CVD Determination	160	12/1/2026
ITC Final CVD Determination	205	1/15/2027
DOC CVD Publication of Order	212	1/22/2027

 

* 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.

Contact Clark Hill

If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice:

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680)
• Kevin Williams (kwilliams@clarkhill.com; 312-985-5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202-230-9889)
• Aristeo Lopez (alopez@clarkhill.com; 202-552-2366)
• Laura M. Quesada (Lquesada@clarkhill.com; 202-240-0170)
• Amal Sheheen (asheheen@clarkhill.com; 202-552-2354)
• Onjoly Purification (Opurification@clarkhill.com; 202-552-2361)

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