U.S. producers file new trade case against imports of Chromium Trioxide from India and Türkiye
American Chrome & Chemical, Inc. (“Petitioner”) filed new petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) seeking the imposition of antidumping duties (“AD”) on imports of chromium trioxide (dry and solution forms, also known as chromic acid) from India and Türkiye, and a countervailing duty (“CVD”) on imports from India. Petitioner alleges that these imports are being dumped in the U.S. market and are also unfairly subsidized by the Indian government.
Chromium trioxide is typically (but not exclusively) used for wood preservation, metal finishing, and plating. Secondary applications include catalyst manufacturing, use as an oxidizing agent, glass and ceramic manufacturing, plastic plating, and laboratory use. Chromium trioxide may also be used in the manufacture of trivalent chrome products (i.e., chromium nitrate, chromium chloride, chromium phosphate, chromium sulfate, and specialty chrome oxide) as well as hexavalent chrome products (i.e., barium chromate). It is most often imported and sold in dry form (flakes, pellets, or powder) because transporting it as a liquid is hazardous, though it must be mixed into a solution before use.
Please see below for the full text of the proposed scope for investigations.
Key facts
Petitioner: American Chrome & Chemical, 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: Petitioner alleged the following AD and CVD margins:
- Türkiye: AD margin is 40.93 % ad valorem.
- India: AD margins is 14.70 % ad valorem, and a CVD margin above de minimis.
The investigation
The U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) will conduct the investigations. The ITC will determine if there is a reasonable indication that the imports are injuring or threatening to injure the U.S. industry. The DOC will then determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD margins that importers will need to pay on their entries.
Importers will be required to deposit the calculated 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 Dec. 23, 2025 (CVD) and March 9, 2026 (AD). Importers should be aware that entries may be subject to cash deposits before these dates if the DOC finds that there is a surge of imports after the petitions were filed.
Next steps
All U.S. importers and foreign producers are advised to prepare as soon as possible due to the strict statutory deadlines in these cases. If this product is of interest to you, please contact Clark Hill’s international trade team so that we can provide you with additional information.
A schedule of approximate key dates is attached below.
The scope
Petitioner requested that the scope of the merchandise subject to investigation be defined as follows:
The merchandise subject to these investigations is chromium trioxide (Chemical Abstracts Services (“CAS”) registry number 1333-82-0), regardless of form (dry or solution). Chromium trioxide is an inorganic compound with the molecular formula CrO3 in dry form.
The product in dry form is generally referred to as chromium trioxide, which is the acidic anhydride of chromic acid. Chromium trioxide in solution form may be referred to as chromic acid. However, the dry form may also be marketed under the name chromic acid.
A non-exhaustive list of other names used for the subject merchandise includes: chromic anhydride, chromic trioxide, chromium (VI) oxide, monochromium trioxide, chromia, chromium (VI) trioxide, trioxochromium, and chromtrioxid. A non-exhaustive list of trade names for the subject merchandise includes: 11910080KROMSAV-ANHIDRID IP, Aktivkohle, imprägniert, Typ PLWK, Chromsaure, and Chroomzuur.
All chromium trioxide is covered by the scope of these petitions irrespective of purity, particle size, or physical form. Chromium trioxide is generally imported in dry form, including in the form of pellets, flakes, powders, or beads, but the scope includes chromium trioxide in solution form.
Chromium trioxide that has been blended with another product or products is included in the scope if the resulting mix contains 90 percent or more of chromium trioxide by total formula weight. If chromium trioxide is imported blended with another product, only the chromium trioxide content of the blend is included within the scope.
Subject merchandise also includes chromium trioxide that has been processed in a third country into a product that otherwise would be within the scope of this investigation, i.e., if any such further processing would not otherwise remove the merchandise from the scope of the investigation it is included in the scope of the investigation. For example, the dry form of the subject merchandise may be imported into a third country and then processed into a solution before shipment to the United States. Such a solution would be subject to the scope.
The subject merchandise is provided for in subheading 2819.10.0000 of the Harmonized Tariff Schedule of the United States (“HTSUS”). In addition to 1333¬82-0, import documentation may also reflect CAS registry numbers 12324-05-9, 12324-08-2, and 1362947-20-3. Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the scope is dispositive.
Approximate Key Dates*
| Antidumping Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 9/29/2025 |
| DOC Initiation Date | 20 | 10/19/2025 |
| DOC Separate Rate Applications | 41 | 11/10/2025 |
| DOC Q&V Questionnaires | 44 | 11/12/2025 |
| ITC Preliminary Determination | 45 | 11/13/2025 |
| DOC Preliminary AD Determination | 160 | 3/9/2026 |
| DOC Final AD Determination | 235 | 5/22/2026 |
| ITC Final AD Determination | 280 | 7/6/2026 |
| DOC AD Publication of Order | 287 | 7/13/2026 |
| Countervailing Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 9/29/2025 |
| DOC Initiation Date | 20 | 10/19/2025 |
| DOC Q&V Questionnaires | 44 | 11/12/2025 |
| ITC Preliminary Determination | 45 | 11/13/2025 |
| DOC Preliminary CVD Determination | 85 | 12/23/2025 |
| Request for a DOC Hearing | 122 | 1/29/2026 |
| DOC Final CVD Determination | 160 | 3/9/2026 |
| ITC Final CVD Determination | 205 | 4/22/2026 |
| DOC CVD Publication of Order | 212 | 4/29/2026 |
* 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 any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680), Kevin Williams (kwilliams@clarkhill.com; 312-985-5907), Aristeo Lopez (alopez@clarkhill.com; 202-552-2366), Kelsey Christensen (kchristensen@clarkhill.com; 202-640-6670), Laura M. Quesada (lquesada@clarkhill.com; 202-240-0170), or other members of Clark Hill’s International Trade Business Unit.
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