New Trade Case Could Raise Costs for Perfluoroalkoxy Alkane from India
The Petitions
Antidumping (“AD”) and countervailing duty (“CVD”) petitions have been filed with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) concerning imports into the United States of perfluoroalkoxy alkane (“PFA”) from India. The petitions allege that imported PFA from India are being sold in the United States at unfairly low prices and, in some cases, are benefiting from unfair government subsidies, causing material injury to the domestic industry. If the federal agencies agree, imports of PFA could become subject to significant additional duties.
The subject merchandise—perfluoroalkoxy alkane—is a high-performance fluoropolymer used in demanding applications where reliability, purity, and chemical resistance are critical. PFA is essential to the manufacture of tubing, molded and extruded parts, films, coatings, wire and cable insulation, and other components used in semiconductor fabrication, chemical processing equipment, pharmaceutical manufacturing, medical device production, laboratory equipment, food processing, aerospace applications, and various other environments.
For importers, distributors, purchasers, and companies throughout the semiconductor, chemical processing, pharmaceutical, medical device, electronics, food-processing, and industrial manufacturing supply chains, this filing is important because these cases move quickly. If Commerce issues affirmative preliminary determinations, U.S. importers of PFA from India 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 these investigations is perfluoroalkoxy alkane (“PFA”), a copolymer of tetrafluoroethylene and perfluoroalkoxy side chains. Its chemical structure is represented as a repeating chain of tetrafluoroethylene units with perfluoroalkoxy side chains (-(CF2-CF2)n-(CF2-CF(ORf))m-) where Rf is a perfluorinated alkyl group (e.g., -CF3,-C2F5, -C3F7). PFA is normally associated with Chemical Abstracts Service (“CAS”) registry number 26655-00-5 or 31784-04-0.
The scope includes PFA resin provided in primary forms (including, but not limited to pellets, granules, powder, flakes, or aqueous dispersions). PFA has a minimum melting endotherm peak temperature of 265 degrees Celsius and a melt flow rate of greater than 1 g/10 min.
The scope also includes merchandise matching the above description that has been finished, packaged, or otherwise processed in a third country, including by packaging with another product, or any other finishing, packaging, or processing that would not otherwise remove the merchandise from the scope of the investigation. The scope also includes PFA that is commingled or blended with PFA from sources not subject to the investigations. Only the subject component of such commingled products is covered by the scope of these investigations.
Excluded from the scope of these investigations is PFA that has a minimum melting endotherm peak temperature of less than 265°C and a melt flow rate of less than 1 g/10 min.
Also excluded from the scope of these investigations are PFA products compounded with fillers or reinforcing materials, including, but not limited to, glass fiber, carbon fiber, carbon black, graphite, mineral fillers, or similar reinforcing additives. This exclusion does not apply to unfilled PFA resin containing only minor processing aids, stabilizers, pigments, or other nonreinforcing additives.
The subject merchandise is currently properly classifiable under the Harmonized Tariff Schedule of the United States (“HTSUS”) subheading 3904.69.50. Products subject to these petitions may also enter under HTSUS subheadings 3904.61.00 and 3904.69.1000. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of the investigations is dispositive.
Key Facts
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:
- India: AD Margin from 47.93% to 56.57% 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 October 29, 2026 (CVD) and January 12, 2027 (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
Given the strict statutory deadlines, governing AD and CVD investigations, U.S. importers and foreign producers are advised to prepare as soon as possible.
If this product is of interest to your business, 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 | 8/5/2026 |
| DOC Initiation Date | 20 | 8/25/2026 |
| DOC Separate Rate Applications | 41 | 9/15/2026 |
| DOC Q&V Questionnaires | 44 | 9/18/2026 |
| ITC Preliminary Determination | 45 | 9/21/2026 |
| DOC Preliminary AD Determination | 160 | 1/12/2027 |
| DOC Final AD Determination | 235 | 3/29/2027 |
| ITC Final AD Determination | 280 | 5/12/2027 |
| DOC AD Publication of Order | 287 | 5/19/2027 |
| Countervailing Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 8/5/2026 |
| DOC Initiation Date | 20 | 8/25/2026 |
| DOC Q&V Questionnaires | 44 | 9/18/2026 |
| ITC Preliminary Determination | 45 | 9/21/2026 |
| DOC Preliminary CVD Determination | 85 | 10/29/2026 |
| Request for a DOC Hearing | 122 | 12/5/2026 |
| DOC Final CVD Determination | 160 | 1/12/2027 |
| ITC Final CVD Determination | 205 | 2/26/2027 |
| DOC CVD Publication of Order | 212 | 3/5/2027 |
* 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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