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New Trade Case on Imports of R-125 (Pentafluoroethane) from China

January 13, 2021

New U.S. antidumping (“AD”) and countervailing (“CVD”) duty investigations were filed on Jan. 12, 2021, by Honeywell International (“Petitioner”) against imports of R-125 (Pentafluoroethane) from China.

The merchandise covered by this petition is Pentafluoroethane, more commonly referred to as R-125. R-125 is a hydrofluorocarbon (“HFC”) gas component for blended refrigerants in residential and commercial applications.

The petition includes AD (less than fair value) and CVD (unfair subsidy) allegations against China. 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 standard is met, then the cases will move to the DOC which will calculate the preliminary AD and CVD duty margins.

The DOC’s preliminary determinations are currently scheduled for April 7, 2021 (CVD) and June 21, 2021 (AD), which are the dates when importers will be required to post cash deposits per the calculated duties upon the products’ entry in 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:

Petitioners:  Honeywell International Inc. (sole domestic manufacturer)

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

AD margins:  Petitioners have alleged the following AD and CVD margins:

  • China: a calculated AD margin of 155.78 – 230.52 percent
  • China: CVD margin above de minimis.

Merchandise covered by the scope of the case:

The merchandise covered by this investigation is pentafluoroethane (“R-125”), or its chemical equivalent, regardless of form, type, or purity level. R-125 has the Chemical Abstracts Service (“CAS") registry number of 354-33-6 and the chemical formula C2HF5. R-125 is also referred to as Pentafluoroethane, Genetron HFC 125, Khladon 125, Suva 125, Freon 125, and Fc-125. Subject merchandise includes R-125, whether or not incorporated into a blend. Subject merchandise also includes R-125 and unpurified R-125 that is processed in a third country or otherwise outside the customs territory of the United States, including, but not limited to, purifying 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 R-125.

Excluded from the current scope is merchandise covered by the scope of the antidumping order on Hydrofluorocarbon Blends from the People's Republic of China. See Hydrofluorocarbon Blends from the People's Republic of China, 81 Fed. Reg. 55436 (Aug. 19, 2016) (the "Blends Order").

R-125 is classified under Harmonized Tariff Schedule of the United States (HTSUS) subheading 2903.39.2035. Other merchandise subject to the current scope, including the above-mentioned blends that are outside the scope of the Blends Order, may be classified under subheadings 2903.39.2045 and 3824.78.0020, HTSUS. The HTSUS subheadings and CAS registry number are provided for convenience and customs purposes. The written description of the scope of the petition is dispositive.

The DOC and the ITC are also already investigating imports of R-32.  Should an order be issued in that investigation, it is Petitioner’s intent to exclude from the current scope of this investigation merchandise covered by the scope of any eventual R-32 antidumping order.

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

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