On April 23, 2024, ICL-IP America, Inc., a subsidiary of the ICL Group (“ICL” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of certain alkyl phosphate ester from the People’s Republic of China.

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from China that is within the scope of this Petition:

Alkyl phosphate esters based exclusively on side chains with a length of two or three carbon atoms (also includes chlorinated alkyl chains) and with a phosphorus content of at least 6.5% (per weight) and a viscosity between 1 and 2000 mPa.s (at 20-25 °C). Alkyl phosphate esters include Tris (2-chloroisopropyl) phosphate (TCPP), Tris(1,3-dichloroisopropyl) phosphate (TDCP), and Triethyl Phosphate (TEP). TCPP is also known as Tris (1-chloro-2- propyl) phosphate, Tris(1-chloropropan-2-yl) phosphate, Tris (monochloroisopropyl) phosphate (TMCP), and Tris(2-chloroisopropyl) phosphate (TCIP). It has the chemical formula C9H18Cl3O4P and the CAS Nos. 1244733-77-4 and 13674-84-5. It may also be identified as CAS No. 6145-73-9. TDCP is also known as Tris (1,3-dichloroisopropyl) phosphate, Tris (1,3- dichloro-2-propyl) phosphate, Chlorinated tris, tris {2-chloro-1- (chloromethyl ethyl} phosphate, TDCPP, and TDCIPP. It has the chemical formula C9H15Cl6O4P and the CAS No. 13674-87-8. TEP is also known as Phosphoric acid triethyl ester, phosphoric ester, flame retardant TEP, Tris(ethyl) phosphate, Triethoxyphosphine oxide, and Ethyl phosphate (neutral). It has the chemical formula (C2H5O)3PO and the CAS No. 78-40-0. Also included in this investigation are isomers of the foregoing products and blends including one or more alkyl phosphate esters where the alkyl phosphate esters account for 20 percent or more of the blend by weight.

Alkyl phosphate esters are classified under subheading 2919.90.5050, HTSUS. Imports may also be classified under subheadings 2919.90.5010 and 3824.99.5500, HTSUS. References to the HTSUS classification are provided for convenience and customs purposes, and the written description of the merchandise under investigation is dispositive regarding the scope of the investigation.

PETITIONERS

622 Emerson Rd. #500

St. Louis, MO 63141

www.icl-group.com

Kathleen Molamphy

Vice President, General Counsel and Compliance Officer

Phone: (314) 983-7714

Email: Kate.Molamphy@icl-group.com

COUNSEL FOR PETITIONERS

Cassidy Levy Kent (USA) LLP

900 19th Street, NW, Suite 400

Washington, DC 20006

Tel.: 202-567-2300

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

ALLEGED DUMPING MARGINS

China:              119.52% – 145.43%   

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis

ALLEGED SUBSIDIES

For a list of alleged subsidies alleged to be countervailable by the Petitioner, please see Attachment III.

IMPORTS OF SUBJECT MERCHANDISE

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