U.S. Producers File New Trade Case Against Imports of Citric Acid and Certain Citrate Salts from Canada and India

The Petitions

Archer-Daniels-Midland Company; Cargill, Incorporated; and Primary Products Ingredients Americas LLC (“Petitioners”) have 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 citric acid and certain citrate salts thereof imported from Canada and India.

The Petitioners allege that imports of citric acid and citrate salts 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 citric acid and certain citrate salts – including sodium citrate, potassium citrate, and crude calcium citrate – as well as blends containing citric acid, sodium citrate, and potassium citrate.

Citric acid, sodium citrate, and potassium citrate are used in the production and formulation of a wide variety of foods, beverages, pharmaceuticals, and cosmetics as well as commercial and household products including detergents and cleaners. Citric acid and certain citrate salts products can also be used in industrial applications, including metal finishing and cleaning, textile finishing treatments, production of plasticizers, and water treatment, among other industrial applications.

Scope of the Investigation

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

All grades and granulation sizes of citric acid, sodium citrate, and potassium citrate in their unblended forms, whether dry or in solution, and regardless of packaging type. The scope also includes blends of citric acid, sodium citrate, and potassium citrate, as well as blends with other ingredients, such as sugar, where the unblended form(s) of citric acid, sodium citrate, and potassium citrate constitute 40 percent or more, by weight, of the blend.

The scope also includes all forms of crude calcium citrate, including dicalcium citrate monohydrate, and tricalcium citrate tetrahydrate, which are intermediate products in the production of citric acid, sodium citrate, and potassium citrate.

The scope includes the hydrous and anhydrous forms of citric acid, the dihydrate and anhydrous forms of sodium citrate, otherwise known as citric acid sodium salt, and the monohydrate and monopotassium forms of potassium citrate. Sodium citrate also includes both trisodium citrate and monosodium citrate which are also known as citric acid trisodium salt and citric acid monosodium salt, respectively.

The scope does not include calcium citrate that satisfies the standards set forth in the United States Pharmacopeia and has been mixed with a functional excipient, such as dextrose or starch, where the excipient constitutes at least 2 percent, by weight, of the product.

Citric acid and sodium citrate are classifiable under 2918.14.0000 and 2918.15.1000 of the Harmonized Tariff Schedule of the United States (HTSUS), respectively. Potassium citrate and crude calcium citrate are classifiable under 2918.15.5000 and, if included in a mixture or blend, 3824.99.9397 of the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are classifiable under 3824.99.9397 of the HTSUS. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise is dispositive.

Key Facts

• Petitioners:  Archer-Daniels-Midland Company; Cargill, Incorporated; and Primary Products Ingredients Americas LLC
• 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:
  • Canada: AD margin from 62.75% to 97.39%, ad valorem, and a CVD margin above de minimis.
  • India: AD margin from 58.99% to 253.37%, 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 16, 2026 (CVD) and June 30, 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 practice 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	01/21/2026
DOC Initiation Date	20	2/10/2026
DOC Separate Rate Applications	41	3/3/2026
DOC Q&V Questionnaires	44	3/6/2026
ITC Preliminary Determination	45	3/7/2026
DOC Preliminary AD Determination	160	6/30/2026
DOC Final AD Determination	235	9/13/2026
ITC Final AD Determination	280	10/28/2026
DOC AD Publication of Order	287	11/4/2026
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	01/21/2026
DOC Initiation Date	20	2/10/2026
DOC Q&V Questionnaires	44	3/6/2026
ITC Preliminary Determination	45	3/7/2026
DOC Preliminary CVD Determination	85	4/16/2026
Request for a DOC Hearing	122	5/23/2026
DOC Final CVD Determination	160	6/30/2026
ITC Final CVD Determination	205	8/14/2026
DOC CVD Publication of Order	212	8/21/2026

* 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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