Petition Summary: Methylene Diphenyl Diisocyanate from the People’s Republic of China

On February 12, 2025, the Ad Hoc MDI Fair Trade Coalition (“Coalition” or “Petitioner”), filed a petition for the imposition of antidumping duties on U.S. imports of Methylene Diphenyl Diisocyanate (“MDI”) from the People’s Republic of China (“China”).

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from China:

The merchandise subject to this petition is aromatic polyisocyanate material whose composition includes two or more isocyanate groups (i.e., functional group containing a nitrogen atom, a carbon atom, and an oxygen atom bonded together (- NCO)) attached to one or more benzene rings (i.e., flat, symmetrical molecule made up of six carbon atoms arranged in a hexagonal ring and has the chemical formula C6H6) that are joined by methylene bridges (i.e., a carbon atom bound to two hydrogen atoms (−CH2− ) and connected by single bonds to two other distinct atoms in the rest of the molecule). These products are commonly called Polymeric, Monomeric, or Modified Methylene Diphenyl Diisocyanate (“MDI”) and also known as Methylene bisphenyl isocyanate, 4,4’-Diphenylmethane diisocyanate, Methylene di-p-phenylene ester of isocyanic acid, Methylene bis(4-phenyl isocyanate), among others. MDI is normally associated with Chemical Abstracts Service (“CAS”) registry numbers 9016-87-9, 101-68-8, 5873-54-1, 2536-05-2, 1689576-89-3, 25686-28-6, 26447-40-5, and 39310-05-9, but several others are also used.

MDI ranges in physical form from low viscosity liquids to solids. MDI is covered by the scope of this petition irrespective of whether it has gone through a distillation process and regardless of acid content, reactivity, functionality, freeze stability, physical form, viscosity, grade, purity, molecular weight, or packaging.

MDI may contain additives, such as catalysts, solvents, plasticizers, antioxidants, fire retardants, colorants, pigments, diluents, thickeners, fillers, softeners, toughening agents. The scope does not include mixtures of MDI with other materials, when the combined MDI component comprises less than 40 percent of the total weight of the mixture.

MDI may be partially reacted with itself, polyol, or polyamines, and retain MDI component that has not fully chemically reacted so as to convert it into a different product no longer containing isocyanate groups. These products are known ashomopolymer, uretonimine MDI, carbodiimide MDI, or prepolymers. The scope does not include partially reacted MDI when its NCO content is less than 10 weight percentage.

For MDI that enter as part of a system with separately packaged polyol, only the MDI portion of the system is included in the scope. The scope does not include an separately packaged polyol that would not fall within the scope if entered on its own.

The scope includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, introducing 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.

The scope also includes MDI that is commingled or blended with MDI from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigations.

This merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 2929.10.8010 and 3909.31.0000. Subject merchandise may also be entered under subheadings 3506.91.5000, 3815.90.5000, 3824.99.2900, 3824.99.9397, 3909.50.5000, 3911.90.4500, 3920.99.5000, and 3921.13.5000. The HTSUS subheadings are provided for convenience and customs purposes only; the written description of the scope is dispositive.

PETITIONER

Ad Hoc MDI Fair Trade Coalition

BASF Corporation

1000 Park Avenue

Florham Park, NJ 07042

(973) 914-2834

Catherine A. Trinkle, Vice President & Deputy General Counsel

catherine.trinkle@basf.com

The Dow Chemical Company

2211 H.H. Dow Way

Midland, MI 48674

(989) 638-7554

mcmcculloch@dow.com

COUNSEL FOR PETITIONER

KING AND SPAULDING

1700 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

(202) 737-0500

NAMED PRODUCERS/EXPORTERS

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

NAMED IMPORTERS

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

ESTIMATED SCHEDULE

Below is an estimated schedule. Please note that the Commerce Department deadlines are likely to be extended for the AD investigation as authorized by statute.

ALLEGED DUMPING MARGINS

China: 305.81% to 507.13%

Period of Investigation: The antidumping duty period of investigation will be July 1, 2024, through December 31, 2024.

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis.

IMPORTS OF SUBJECT MERCHANDISE

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