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New Trade Case on Imports of Raw Honey From Argentina, Brazil, India, Ukraine, and Vietnam

April 22, 2021

A new U.S. antidumping (“AD”) duty petition was filed on April 21 by the American Honey Producers Association and Sioux Honey Association against imports of raw honey from Argentina, Brazil, India, Ukraine, and the Socialist Republic of Vietnam.

The merchandise covered by this petition is raw honey, a sweet, viscous fluid produced from the nectar of plants and flowers which is collected by honeybees, transformed and combined with substances of their own, and stored and left in honeycombs to mature and ripen. Honey originates from plants and flowers such as white clover, thistle, and alfalfa, to produce predominantly white honeys. Honey is principally categorized by its color and is generally classified into four different color categories: (1) white; (2) extra-light amber; (3) light amber; and (4) amber. The variety of flower from which the nectar is gathered affects the raw honey’s color and flavor, and raw honey may be typed according to whether it has a predominant floral source (mono-floral honey) or whether it results from a multitude of floral sources (poly-floral honey). The value of raw honey varies depending on its floral source and color, with lighter colored and mild flavored honeys generally being more valuable in the U.S. market than darker and more strongly flavored honeys. For a full description of the scope of the petition, please see the Scope section below.

The petition includes AD (less than fair value) allegations against Argentina, Brazil, India, Ukraine, and Vietnam. 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 duty margins.

The DOC’s preliminary determinations are currently scheduled for Sept. 28 which is the date when importers will be required to deposit the calculated duties upon the products’ entry into the U.S. market.

The honey industry has been engaged in several trade actions since the mid-1970s, including a Section 201 (global safeguard), Section 406 (trade with communist countries), and in 2000 AD and countervailing duty (CVD) investigations targeting imports from China and Argentina. In 2012 the DOC revoked the AD and CVD orders on imports from Argentina. The AD order covering Chinese honey remains in effect.

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: The American Honey Producers Association and Sioux Honey Association

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 margins:

  • Argentina: calculated dumping margins ranging from 16.83 to 22.60 percent, ad valorem,
  • Brazil: a calculated dumping margin of 114.50 percent, ad valorem,
  • India: calculated dumping margins ranging from 34.22 percent to 99.16 percent, ad valorem,
  • Ukraine: calculated dumping margins ranging from 10.56 percent to 94.84 percent, ad valorem,
  • Vietnam: an estimated dumping margin of 207.08 percent ad valorem.

Merchandise covered by the scope of the case:

The merchandise covered by these petitions is raw honey. Raw honey is honey as it exists in the beehive or as obtained by extraction, settling and skimming, or coarse straining. Raw honey has not been filtered to a level that results in the removal of most or all of the pollen. The subject products include all grades, floral sources, and colors of raw honey and also includes organic raw honey.

Excluded from the scope is comb honey or honey that is packaged for retail sale (e.g., in bottles or other retail containers of five lbs or less).

The merchandise subject to this order is currently classifiable under statistical subheading 0409.0000.05, 0409.0000.35, 0409.0000.45, 0409.0000.56, and 0409.0000.65 of the Harmonized Tariff Schedule of the United States (“HTSUS”). Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this order is dispositive.

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), Matthew Goldstein (, 202-772-0917), Courtney Gayle Taylor (; 202-552-2350); Dennis Devaney (, 313-309-9454); or another member of Clark Hill’s International Trade Business Unit.

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