The U.S. Department of Commerce has initiated antidumping and countervailing duty investigations covering certain amine compounds from China. Commerce initiated the investigations on October 19, 2026, following petitions filed September 29, 2026.
The antidumping petition alleges margins ranging from 244.94% to 352.32%. Commerce also found sufficient allegations that Chinese producers receive countervailable subsidies to initiate a separate countervailing duty investigation.
Although cash deposits have not yet been imposed, the alleged rates create substantial prospective exposure for chemical importers and manufacturers using covered compounds.
Which Products Are Under Investigation?
The investigations cover amine compounds that act as catalysts in reactions between isocyanates and hydroxy-containing substances such as polyols or water, a core step in making polyurethane foams. The scope names six specific compounds:
- 3,3′-Iminobis(N,N-dimethylpropylamine) (CAS 6711-48-4)
- 2-[[2-(Dimethylamino)ethyl]methylamino]ethanol (CAS 2212-32-0)
- 2-[2-(Dimethylamino)ethoxy]ethanol (CAS 1704-62-7)
- Pentamethyldiethylenetriamine (CAS 3030-47-5)
- Bis(dimethylaminoethyl) ether (CAS 3033-62-3)
- Dimorpholinodiethyl ether (CAS 6425-39-4)
The scope also covers blends containing at least 1% by weight of these compounds, including polyurethane foam systems whose “B side” meets that threshold. Merchandise processed in a third country remains covered if it contains the Chinese-origin compounds. Amine compounds already covered by the existing antidumping and countervailing duty orders on certain alkyl phosphate esters are excluded.
Commerce identified the following Harmonized Tariff Schedule classifications for customs purposes:
- 2921.29.0055
- 2922.19.9690
- 2934.99.9001
Covered merchandise may also enter under 2909.11.0000, 2921.21.0000 and 3815.90.5000.
These tariff provisions may include merchandise that is not covered by the investigations. Likewise, merchandise described by the written scope is covered even when entered under another classification, because the written scope controls.
Importers should therefore review the written product description, chemical composition, technical specifications and production history rather than relying exclusively on the HTSUS number or commercial product name.
The cases are identified as:
- Antidumping: A-570-245
- Countervailing duty: C-570-246
- ITC investigations: 701-TA-808 and 731-TA-1809 (Preliminary)
Alleged Rates Would Significantly Affect Landed Cost
The alleged dumping margins range from 244.94% to 352.32%. These are allegations submitted at the beginning of the proceeding, not current duty rates or final findings.
If Commerce later issues an affirmative preliminary determination, CBP may be instructed to suspend liquidation and collect estimated cash deposits on covered entries.
The final rates could be higher or lower than the alleged margins. The investigations may also end without an order if the International Trade Commission does not find the required injury or threat of injury to the U.S. industry.
Nevertheless, potential deposits approaching or exceeding three times the entered value could make affected sourcing commercially impractical.
Important Upcoming Dates
The International Trade Commission is currently scheduled to issue its preliminary injury determination on or around November 13, 2026.
If the ITC makes an affirmative preliminary determination, Commerce is currently scheduled to issue:
- Its preliminary countervailing duty determination on December 24, 2026
- Its preliminary antidumping determination on March 9, 2027
These deadlines may be extended under the applicable statutes.
The petitioners are Evonik Corporation and Huntsman International LLC.
Why Importers Should Review Their Exposure Now
Importers should not wait for preliminary deposits to begin evaluating their supply chains.
Companies should determine:
- Whether imported products match the written scope
- The identity of the Chinese producer and exporter
- Whether a third-country supplier uses Chinese-origin covered material
- Which open purchase orders could arrive after a preliminary determination
- Whether contracts assign responsibility for AD/CVD deposits
- Whether customs bonds remain sufficient for increased duty exposure
- Whether commercially viable alternative sources exist
Third-country processing does not automatically remove a product from an AD/CVD proceeding. Importers buying from distributors or processors outside China should trace the product’s manufacturing history and obtain technical documentation supporting any claim that the imported merchandise falls outside the scope.
Retrospective Liability Remains a Concern
Antidumping and countervailing duties operate under a retrospective assessment system. Cash deposits collected at entry are estimates rather than necessarily the importer’s final liability.
The amount ultimately assessed may increase after an administrative review. Importers generally remain responsible for additional duties even when a foreign supplier agreed to cover the cost or quoted a delivered price.
Companies should avoid reimbursement arrangements that are not structured and reported in accordance with Commerce’s requirements.
Steps Importers Should Take
Potentially affected importers should:
- Compare product specifications with the written scope.
- Identify the producer, exporter and country where each manufacturing step occurs.
- Review open purchase orders and projected entry dates.
- Model landed costs using multiple potential deposit rates.
- Review duty, reimbursement and price-adjustment language in supplier contracts.
- Evaluate bond sufficiency and working-capital requirements.
- Monitor the ITC’s preliminary injury determination and subsequent Commerce deadlines.
For additional information, review Commerce’s investigation summary and case schedule.
ASK Alba™ Contact the Alba team for assistance reviewing product scope, supplier documentation, potential duty exposure and entry requirements. Subscribe to the ASK Alba™ Trade Brief for updates on antidumping and countervailing duty investigations affecting U.S. importers.
References
- U.S. Department of Commerce, International Trade Administration: Initiation of AD/CVD Investigations of Certain Amine Compounds from the People’s Republic of China
- Federal Register: Certain Amine Compounds From the People’s Republic of China; Initiation of Countervailing Duty Investigation (91 FR 67290, October 26, 2026)
- Federal Register: Amine Compounds From China; Institution of Antidumping and Countervailing Duty Investigations and Scheduling of Preliminary Phase Investigations (U.S. International Trade Commission, October 5, 2026)
