New Antidumping Duty and Countervailing Duty Petitions on Vanillin From China

At a Glance

• Solvay USA LLC filed both antidumping duty petitions and countervailing duty petitions on vanillin from China.
• The U.S. Department of Commerce is expected to begin investigations on June 26, 2024.

On June 5, 2024, antidumping duty (AD) and countervailing duty (CVD) petitions were filed on vanillin from China. The petitioner is Solvay USA LLC (Solvay).

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” The U.S. CVD law imposes special tariffs to counteract imports that are sold in the United States with the benefit of foreign government subsidies. For AD/CVD duties to be imposed, the U.S. government must determine not only that dumping and/or subsidization is occurring, but also that there is “material injury” (or threat thereof) by reason of the dumped and/or subsidized imports. Importers are liable for any potential AD/CVD duties imposed. In addition, these investigations could impact purchasers by increasing prices and/or decreasing supply of vanillin.

Scope

Please note that this section was not written by our authors but is taken verbatim from the petition.

The merchandise covered by the investigation is vanillin, with the molecular formula C8H8O3 or C9H10O3. For purposes of this investigation, vanillin consists of natural vanillin, synthetic vanillin (also known as 4-Hydroxy-3-methoxybenzaldehyde), bio-sourced synthetic vanillin (biovanillin), and ethylvanillin (also known as 3-Ethoxy-4-hydroxybenzaldehyde). Vanillin covered by this investigation is a chemical compound with the Chemical Abstracts Service (“CAS”) number 121-33-5 or 121-32-4. Products with the chemical formula C9H10O3 (ethylvanillin) are also included within the scope. Vanillin is covered by the investigation regardless of whether it is in a crystalline powder or crystal form. Vanillin is covered by the scope of the investigations, irrespective of purity, particle size, physical form, packaging, or production process.

Merchandise subject to the investigations are specified within the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 2912.41.0000 and 2912.42.0000. The HTSUS subheadings are provided for convenience and customs purposes only. The written description of the merchandise covered by the investigations is dispositive.

Estimated Dumping Margins

Solvay alleges dumping margins ranging from 520.08 to 551.06%.

Solvay also alleges significant subsidies, although the petitions do not quantify the alleged net subsidy margins.

Estimated Schedule of Investigations

The following is an estimated schedule of investigations by the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC):