Skip to content

New Trade Case on Imports of Dioctyl Terephthalate From Taiwan, Turkey, Malaysia, and Poland

April 8, 2024

On March 26, the Eastman Chemical Company (“Petitioner”) filed U.S. antidumping (“AD”) petitions alleging less-than-fair-value imports of Dioctyl Terephthalate (“DOTP”) from Taiwan, Turkey, Malaysia, and Poland.

The subject merchandise, DOTP, is a non-phthalate plasticizer that is used primarily in manufacturing plastics. A plasticizer is a chemical substance that, when added to a plastic, produces a product that imparts softness, viscosity, and flexibility, and makes it easier to handle. Plasticizers can be divided into phthalates and non-phthalates. DOTP specifically is a non-phthalate plasticizer. Please see below for the full text of the proposed scope for the investigations.

The Department of Commerce (“DOC”) and the U.S. 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 or threatening to injure the U.S. industry. If the ITC finds that this standard is met, the cases will move to the DOC, which will calculate the preliminary AD duty margins.

The DOC’s preliminary determinations are currently expected by Sept. 3. On the date of publication of DOC’s preliminary determinations, importers will be required to deposit the calculated duties upon the products’ entry into the U.S. market.

Importers should also be aware that entries may be subject to cash deposits 90 days before the DOC preliminary determinations if the DOC issues a finding of “critical circumstances,” meaning that imports increased by at least 15 percent following the filing of the petition compared to a similar period (typically three months) before the petition.

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. A schedule of approximate key dates is attached below.

The following are key facts about this trade case:

Petitioner: Eastman Chemical Company

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

AD margins: Petitioner alleged the following AD margins:

  • Taiwan: dumping margins from 83.70% to 136.20%, ad valorem;
  • Turkey: dumping margins from 34.83% to 70.97%, ad valorem;
  • Malaysia: dumping margin of 59.33%, ad valorem; and
  • Poland: dumping margin of 60.10%, ad valorem.

Merchandise covered by the scope of the case:

The proposed scope of this investigation describes the subject merchandise as:

The merchandise covered by this Petition is dioctyl terephthalate (DOTP), regardless of form. DOTP that has been blended with other products is included within this scope when such blends include constituent parts that have not been chemically reacted with each other to produce a different product. For such blends, only the DOTP component of the mixture is covered by the scope of these investigations.

DOTP that is otherwise subject to these investigations is not excluded when commingled with DOTP from sources not subject to these investigations. Commingled refers to the mixing of subject and non-subject DOTP. Only the subject component of such commingled products is covered by the scope of these investigations.

DOTP has the general chemical formulation C6 H4 (C8 H17 COO)2 and a chemical name of “bis (2-ethylhexyl) terephthalate” and has a Chemical Abstract Service (CAS) registry number of 6422–86–2. Regardless of the label, all DOTP is covered by these investigations.

Subject merchandise is currently classified under subheading 2917.39.2000 of the Harmonized Tariff Schedule of the United States (HTSUS). Subject merchandise may also enter under subheadings 2917.39.7000 or 3812.20.1000 of the HTSUS. While the CAS registry number and HTSUS classification are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

Approximate Key Dates*
Antidumping Duty Investigation
Event No. of Days Date of Action
Petition Filed 0 3/26/2024
DOC Initiation Date 20 4/15/2024
ITC Preliminary Investigations**
Questionnaires Due 14 4/9/2024
Request to appear at Conference 18 4/15/2024
Conference 21 4/16/2024
Post-Conference Briefs 26 4/22/2024
ITC Vote 43 5/8/2024
ITC Preliminary Determination 45 5/10/2024
DOC Investigations
DOC Preliminary AD Determination 160 9/3/2024
DOC Final AD Determination 235 11/18/2024
ITC Final Investigations
ITC Final AD Determination 280 12/31/2024
DOC Final Investigations
DOC AD Publication of Order 287 1/7/2025

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (; 202-640-6680), Kevin Williams (; 312-985-5907), Aristeo Lopez (; 202-552-2366), Kelsey Christensen (; 202-640-6670), Sally Alghazali (; 202-572-8676), or other members of Clark Hill’s International Trade Business Unit.

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.

Subscribe For The Latest