The highest estimated dumping margin is 352.32%! The U.S. initiates an investigation into polyurethane additives from China

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On October 26, the U.S. Department of Commerce published in the Federal Register the notice of initiation of anti-dumping and countervailing duty investigations against certain amine compounds from China. The products involved in the case are mainly amine catalysts used in polyurethane production.

The current investigation was filed by U.S. companies Evonik Corporation and Huntsman International LLC on September 29. The petitioners allege that relevant Chinese items are sold at low prices in the U.S. market and receive government subsidies, causing harm to the U.S. domestic sector.

The U.S. Department of Commerce officially announced the initiation of the investigations on October 20. The start date of both investigations is October 19, and the case numbers are A-570-245 (anti-dumping) and C-570-246 (countervailing duty) respectively.

The product categories involved in the case are clear, covering main raw materials, mixed materials and polyurethane systems

The product list of this investigation includes amine compounds such as pentamethyldiethylenetriamine (CAS 3030-47-5), bis(dimethylaminoethyl) ether (CAS 3033-62-3), and dimorpholinodiethyl ether (CAS 6425-39-4), with core applications as polyurethane catalysts.

The scope of the investigation extends to mixtures containing the above substances and polyurethane systems: mixtures with an amine component weight ratio of ≥1% are included in the investigation; to independently packaged polyurethane items, the verification limit targets the B component to which the amine catalyst is added.

The petitioners claimed high dumping margins, and the relevant figures are only estimated values from the petition

The dumping margin range given in the petition is 244.94%–352.32%. The U.S. Department of Commerce included this data in the initiation documents however clearly stated that this figure is not equivalent to the duty rate determined in the preliminary or final ruling and is only the unilateral claim of the petitioners. The countervailing duty investigation focuses on verifying various government subsidy programs obtained by domestic producers.

The import value under the corresponding tariff codes in 2025 is approximately USD 235 million, and there are discrepancies in the statistical scope

U.S. trade statistics show that in 2025, the value of U.S. imports from China under the corresponding tariff codes was approximately USD 235 million, involving tariff codes such as 2922.19.9690, 2921.29.0055, and 2934.99.9001. The notice notes that the above tariff codes also include other goods not covered by this investigation, so this amount cannot be immediately equated to the import scale of the items involved in the case.

Investigation milestones are clear, and multiple ruling timelines are scheduled

The U.S. International Trade Commission (ITC) is expected to issue a preliminary injury ruling around November 13. If the preliminary injury ruling is affirmative and the investigation proceeds, the U.S. Department of Commerce plans to issue a preliminary countervailing duty ruling on December 24 and a preliminary anti-dumping ruling on March 9, 2027; the relevant time points might be extended in accordance with legal procedures.

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