Petition Summary: Hexamine (Hexamethylenetetramine) from the People’s Republic of China, the Federal Republic of Germany, the Republic of India, and the Kingdom of Saudi Arabia

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On September 30, 2024 Bakelite LLC (“Bakelite” or “Petitioner”), filed a petition for the imposition of antidumping on U.S. imports of hexamine (Hexamethylenetetramine) from the People’s Republic of China (“China”), the Federal Republic of Germany (“Germany”), the Republic of India (“India”), and the Kingdom of Saudi Arabia (“Saudi Arabia”) and countervailing duties on imports of hexamine from China and India.

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from China, Germany, India and Saudi Arabia that is within the scope of this Petition:

The scope of the Order covers hexamine in granular form or powder, regardless of particle size, or as a slurry, stabilized or unstabilized, whether or not blended, mixed, pulverized, or grounded with other products, containing more than 50 percent hexamine by weight.

Hexamine is the common name for hexamethylene tetramine (Chemical Abstract Service # 100-97-0), and is also referred to as 1,3,5,7- tetraazaadamantanemethenamine; HMT; HMTA; 1,3,5,7-tetraazatricyclo {3.3.1.13,7} decane; 1,3,5,7-tetraaza adamantane; hexamethylenamine. Hexamine has the chemical formula C6H12N4.

Granular hexamine that has been blended with other product(s) is included in this scope when the resulting mix contains 50 percent or more of hexamine by weight, which include but are not limited to, (1) inert additives that do not react with hexamine; (2) co-reactants that react with hexamine when heated; and (3) additives that undergo self-condensation or reaction with other components when utilized in a mixture. Examples of such inert additives include, but are not limited to:

precipitated silica, benzoic acid, aluminum silicate, diisodecyl phthalate (DIDP), calcium carbonate, magnesium stearate, citric acid, and metal oxides. Examples of such co-reactants include, but are not limited to: phenolic resins, alkylphenol novolacs, boron-modified novolac, phosphorous-modified novolac, rubber modified novolac, CNSL-novolac, tannin, lignin, tung oil, limonene-phenol condensate, resorcinol novolac, aniline-PF condensate, dicy-UF condensate, and and 1,3-dihydroxybenzene. Examples of such additives that undergo self-condensation or reaction with other components when utilized in a mixture include, but are not limited to polyvinyl alcohol, urea, ammonium nitrate, and zinc dinitramide.

Subject merchandise includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, adding or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the subject country.

Hexamine that has been blended with other products is included within this scope when such blends include constituent parts that have been intermingled, but that have not been chemically reacted with each other to produce a different product.

Excluded from this scope is pharmaceutical hexamine in tablet or capsule form.

Merchandise covered by the scope of this petition can be classified in the Harmonized Tariff Schedule (“HTS”) of the United States under the subheadings 2933.69.5000. This tariff classification is provided for convenience and customs purposes; however, the written description of the scope is dispositive.

PETITIONERS

BAKELITE LLC

1040 Crown Pointe Parkway Suite 700

Atlanta, GA 30338

T: +1 937-741-8734

W: https://www.bakelite.com/

Contact: Jesse Neese, Director of Strategy and Regulatory Affairs

COUNSEL FOR PETITIONERS

GREENBERG TRAURIG LLP

2101 L Street, NW

Washington, D.C. 20037

(202) 331-3100

NAMED PRODUCERS/EXPORTERS

For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.

NAMED IMPORTERS

For a list of importers alleged by the Petitioner, please see Attachment II.

ESTIMATED SCHEDULE

Event Earliest Date
Petition Filed September 30, 2024
DOC Initiation October 20, 2024
   
ITC Preliminary Investigation:  
Questionnaires Due October 14, 2024
Request to appear at hearing October 19, 2024
Hearing October 21, 2024
Briefs October 26, 2024
ITC Vote November 14, 2024
   
DOC Investigation Schedule:  
DOC Preliminary Antidumping Determination March 9, 2025
DOC Final Antidumping Determination May 23, 2025
DOC Preliminary Countervailing Determination December 24 2024
DOC Final Countervailing Determination March 9, 2024
   
ITC Final Investigation:  
ITC Final AD Determination July 7, 2025
ITC Final CVD Determination April 23, 2025

ALLEGED DUMPING MARGINS

China: 723.50%

Germany: 99.96% – 106.33%

India: 33.66% – 43.27%

Saudi Arabia: 482.29%

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis

 

ALLEGED SUBSIDIES

For a list of alleged subsidies the Petitioner, please see Attachment III.

IMPORTS OF SUBJECT MERCHANDISE

  2021 2022 2023 2023 Jan-June 2024 Jan-June
China          
Quantity (lbs) 429,284 352,080 881,152 594,902 293,250
Value ($) 88,404 83,691 318,323 193,889 68,800
AUV ($/lbs) 0.21 0.24 0.36 0.33 0.23
Germany          
Quantity (lbs) 2,039,275 2,961,471 1,784,522 1,157,138 957,212
Value ($) 1,209,028 797,336 601,504 303,614 335,799
AUV ($/lbs) 0.59 0.27 0.34 0.26 0.35
India          
Quantity (lbs) 535,988 3,377,124 47,069 5,181 584,225
Value ($) 130,188 938,818 49,909 21,454 396,976
AUV ($/lbs) 0.24 0.28 1.06 4.14 0.68
Saudi Arabia          
Quantity (lbs) 256,838 221,983 2,880,037 188,753 2,368,436
Value ($) 165,429 46,410 762,628 66,158 1,139,964
AUV ($/lbs) 0.64 0.21 0.26 0.35 0.48


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