China amine compounds: Commerce initiates AD/CVD

Commerce initiated concurrent less-than-fair-value (AD) and countervailing duty (CVD) investigations on certain amine compounds from China, applicable October 19, 2026. Both notices were placed on public inspection October 23, 2026, and are scheduled for publication October 26, 2026 (91 FR 67294-67299; FR Doc. 2026-21766; A-570-245 and 91 FR 67290-67294; FR Doc. 2026-21767; C-570-246). The ITC already opened its preliminary phase; see amine compounds China ITC preliminary institution.

AD A-570-245 and CVD C-570-246 initiated Oct 19, 2026. Petitions Sept 29 by Evonik and Huntsman. Petition-based alleged AD margins ~245% to ~352% (initiation only). Q&V due Nov 2; scope comments Nov 9.

Petitions, industry support, and periods of investigation

• Petitioners: Evonik Corporation and Huntsman International LLC. Petitions filed September 29, 2026. Supplemental questionnaires October 2 to 14; responses October 7 to 15.
• Industry support: petitioners' supporters exceed 50 percent of total production of the domestic like product, so Commerce did not poll the industry.
• AD POI: January 1 through June 30, 2026 (China treated as an NME).
• CVD POI: January 1 through December 31, 2025.
• Producers named: the Petition identifies 36 Chinese producers/exporters.

Alleged dumping margins and CVD programs

For initiation only, Commerce compared export price to normal value using Brazil, Malaysia, and Türkiye as proposed surrogate countries. The petition-based estimated dumping margins are Brazil surrogate 249.86% to 352.32%; Malaysia surrogate 261.34% to 351.16%; Türkiye surrogate 244.94% to 345.96%. These are allegations supporting initiation, not determined rates. On the CVD side, Commerce initiated on 25 alleged subsidy programs. The Government of China filed consultation remarks in lieu of consultations on October 16, 2026.

Scope in brief

Covered merchandise is certain amine catalysts for the reaction of isocyanates with polyols and/or water. The appendix lists six CAS numbers: 6711-48-4 (3,3′-Iminobis(N,N-dimethylpropylamine)), 2212-32-0, 1704-62-7, 3030-47-5 (pentamethyldiethylenetriamine), 3033-62-3 (bis(dimethylaminoethyl) ether), and 6425-39-4 (dimorpholinodiethyl ether). Physical property ranges in the scope include viscosity at 25°C of 1-100 mPa·s, density at 21°C of 0.82 to 1.05 g/cm³, molecular weight 133 to 245 g/mol, and boiling point 185°C to 310°C.

Blends or mixtures with at least 1 percent by weight of in-scope amine compounds are covered (only the amine portion). Rigid or flexible polyurethane foam systems are covered when the polyol-based B side has at least 1 percent by weight of in-scope amines. Third-country processing is included; China origin of the amine compounds controls. Excluded: in-scope amines already subject to the Certain Alkyl Phosphate Esters from China AD/CVD orders (90 FR 24579, June 11, 2025). HTSUS convenience citations include 2922.19.9690, 2921.29.0055, and 2934.99.9001; merchandise may also enter 2909.11.0000, 2921.21.0000, and 3815.90.5000. The written scope is dispositive.

Deadlines and next steps

• Q&V questionnaires: due 5:00 p.m. ET November 2, 2026, for both cases (https://www.trade.gov/ec-adcvd-qv-questionnaire). For CVD, Commerce will use Q&V rather than CBP data because the main HTSUS subheadings are basket categories.
• Scope and product-characteristics comments: 5:00 p.m. ET November 9, 2026 (the 20-day date fell on Sunday November 8). Rebuttals November 19, 2026. File scope comments on both records.
• Prelim determinations (unless postponed): CVD no later than 65 days after initiation (by our count December 23, 2026, counting from October 19); AD no later than 140 days after initiation (by our count March 8, 2027).
• ITC: preliminary determination within 45 days after petition filing; a negative ITC result terminates. Contacts: David Duffeck (AD) (202) 482-3524; Alex DiCenso (202) 482-0689 and Roee Tenne (202) 482-3996 (CVD).

Action items

• Map SKUs and blends: polyurethane foam, coatings, and adhesives importers should map products to the six CAS numbers and the 1 percent by-weight rule, including foam-system B side content.
• Trace origin: gather supplier origin data, including third-country processing where China-origin amines remain in the blend.
• Budget for provisional deposits: track the CVD and AD preliminary windows; do not treat petition margins as determined rates.
• Watch the ITC prelim: a negative ITC determination ends both investigations.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.