U.S. Producer Files New Trade Case Against Imports of Certain Fatty Acids from Indonesia and Malaysia

The Petitions

Vantage Specialty Chemicals, Inc. (“Petitioner”) has filed new 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 of certain fatty acids (“CFA”) from Indonesia and Malaysia.

The Petitioner alleges that imports of CFAs are being dumped in the U.S. market by being sold for less than fair value and that these imports are injuring the domestic producers. The imported products subject to these petitions are CFAs –  which are products of chemically transformed animal fat or vegetable oil, including their derivatives.

CFAs are used in a wide variety of products including and not limited to food additives, animal feed, candles, crayons, paints, coatings, asphalt, adhesives, industrial lubricants, and rubber processing. CFAs can also be used in personal and homecare products such as soaps, fabric softeners, pharmaceuticals, detergents, and cosmetics.

Scope of the Investigation

The following language describes the imported merchandise that Petitioners intend to cover in these investigations:

The merchandise subject to these Petitions is certain fatty acids (CFA), which are organic acids made of hydrocarbon chain with a carboxylic acid group (i.e., an organic acid that contains a carboxyl group ( —C(=O)—OH) attached to an R-group, sometimes also written as R-COOH, R—C(O)OH, or R-) at one end with a carbon chain length (i.e., the number of carbon atoms in the fatty acid chain) of C6, C8, C10, C12, C14, C16, or C18, with an iodine value below 105 g/100 g and with a ratio of free fatty acids to triglycerides (also known as the “degree of split” or “DoS”)) of at least 97 percent, including single fatty acid (also referred to as “pure cut”), and blends containing a combination of two or more carbon chain lengths.

CFA is also commonly called pure, pure cut, fractionated, or distilled fatty acid or mixed, mixed cut, or blended fatty acid, with the terms pure, pure cut, fractionated, and distilled typically referring to specific single-chain fatty acids that have been separated from a mixed natural source such as animal fat or vegetable oil using processes like hydrolysis (the breakdown of fat molecules by water, catalyzed by acid, base or enzymes (lipases) to yield glycerol and free fatty acids), distillation, and crystallization, and the terms mixed or mixed or mixed cut referring to combinations, blends or mixtures of different single-chain fatty acids also derived from a natural source as animal fat or vegetable oil using processes like hydrolysis, distillation, and crystallization. Common names for pure, pure cut, fractionated, or distilled fatty acids forms include stearic acid and oleic acid. Common names for mixed or mixed cut fatty acids include coconut fatty acid, hardened coconut fatty acid, topped coconut fatty acid, topped hardened coconut fatty acid, palm kernel fatty acid, hardened palm kernel fatty acid, topped palm kernel fatty acid, topped hardened palm kernel fatty acid, palm fatty acid, palm stearin fatty acid, palm fatty acid distillate, and palm olein fatty acid.

CFA is normally associated with Chemical Abstracts Service (CAS) registry numbers 57-11-4, 112-80-1, 61790-38-3, 67701-05-7, 67701-06-8, 67707-01-3, 68938-15-8, 101403-98-9, 91771-90-3, 90990-15-1, 68440-15-3,84238-17-5, 98106-66-2, 84238-17-5, 90990-08-1, and 90990-08-2 but several others may also be used.

CFA ranges in physical form from low viscosity liquids to solids. CFA is covered by the scope of these Petitions irrespective of whether it has gone through a distillation process and regardless of acid content, reactivity, functionality, freeze stability, heat stability, physical form, viscosity, grade, purity, molecular weight, or packaging.

CFA may contain additives, such as catalysts, solvents, antioxidants, fire retardants, colorants, pigments, diluents, thickeners, fillers, softeners, and toughening agents.

Specifically excluded from the scope are CFA containing 90 percent or more, by weight, of fatty acids with carbon chain lengths of C6, C8, or C10 (or any combination thereof).

The scope also does not include mixtures of CFA with other materials, when the combined CFA components comprises less than 80 precent of the total weight of the mixture.

The scope includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, introducing or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the Petitions if performed in the subject country.

The scope also includes CFA that is comingled or blended with CFA from sources not subject to these Petitions. Only the subject component of such comingled products is covered by the scope of these Petitions.

The merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 2915.70.01.20, 2915.70.01.50, 2915.90.10.50, 2916.15.10.00, 2916.15.51.00, 3823.11.00.00, 3823.12.00.00,3823.19.20.00, and 3823.19.40.00, and may also enter under 2915.70.01.10 and 2915.90.10.10.

The HTSUS subheadings set forth above are provided for convenience and customs purposes only. The written description of the scope is dispositive.

Key Facts

Petitioner: Vantage Specialty Chemicals, Inc.

Foreign Producers/Exporters and U.S. Importers:  Please contact Clark Hill’s international trade team for a listing of individual importers and exporters named in the petitions.

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

• Indonesia: AD margin from 20.08% to 72.03%, ad valorem, and a CVD margin above de minimis.
• Malaysia: AD margin from 64.67% to 94.41%, ad valorem, and a CVD margin above de minimis.

The Investigation

The DOC and the ITC will conduct parallel investigations. The ITC will first determine if there is a reasonable indication of material injury or threat of injury to the U.S. industry. The DOC will then determine whether the subject imports are being dumped, and, if so, calculate the applicable AD duty margin.

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 April 23, 2026 (CVD) and July 7, 2026 (AD), although the schedule is subject to change. Importers should be aware that cash deposits may apply earlier 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 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	01/28/2026
DOC Initiation Date	20	2/17/2026
DOC Separate Rate Applications	41	3/10/2026
DOC Q&V Questionnaires	44	3/13/2026
ITC Preliminary Determination	45	3/16/2026
DOC Preliminary AD Determination	160	7/7/2026
DOC Final AD Determination	235	9/20/2026
ITC Final AD Determination	280	11/4/2026
DOC AD Publication of Order	287	11/11/2026
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	01/28/2026
DOC Initiation Date	20	2/17/2026
DOC Q&V Questionnaires	44	3/13/2026
ITC Preliminary Determination	45	3/16/2026
DOC Preliminary CVD Determination	85	4/23/2026
Request for a DOC Hearing	122	6/1/2026
DOC Final CVD Determination	160	7/7/2026
ITC Final CVD Determination	205	8/21/2026
DOC CVD Publication of Order	212	8/28/2026

*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)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• 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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