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On April 2, 2024, U.S. Epoxy Resin Producers Ad Hoc Coalition (hereinafter the “Coalition,” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of certain epoxy resins from China, India, South Korea, Taiwan, and Thailand.

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from China, India, South Korea, Taiwan, and Thailand that is within the scope of this Petition:

The merchandise subject to these petitions are epoxy resins, also known as epoxide resins or polyepoxides, which are polymers or prepolymers containing epoxy groups. Epoxy resins range in physical form from low viscosity liquids to solids and are used in a wide range of applications such as coatings, paints, adhesives, composite materials, wind blade systems, insulating materials, civil engineering materials, and electronics. All epoxy resins are covered by the scope of these petitions irrespective of physical form, viscosity, grade, purity, molecular weight, or molecular structure and regardless of packaging.

Epoxy resins may contain modifiers or additives, such as hardeners, curatives, colorants, pigments, diluents, solvents, thickeners, fillers, plasticizers, softeners, flame retardants, toughening agents, catalysts, Bisphenol F, and ultraviolet light inhibitors, so long as the modifier or additive has not chemically reacted so as to cure the epoxy resin or convert it into a different product no longer containing epoxy groups. Such epoxy resins with modifiers or additives are included in the scope where the epoxy resin component comprises at least 30 percent of the total weight of the product. The scope also includes blends of epoxy resins with different types of epoxy resins, with or without the inclusion of modifiers and additives, so long as the combined epoxy resin component comprises at least 30 percent of the total weight of the blend.

Epoxy resins are characterized by the presence of reactive epoxy groups that allow them to be readily cross-linked at the time of use. Epoxy resins may be reacted (cross-linked) either with themselves or with a wide range of co-reactants, often referred to as hardeners, curatives, or curing agents. The cross-linking reaction is commonly referred to as curing. The epoxy resins and blends thereof covered by this scope have not been cured.

Epoxy resins that enter as part of a system or kit with separately packaged coreactants, such as hardeners or curing agents, are within the scope. For such entries, both the epoxy resin and the co-reactant are covered by the scope of these petitions when entered together.

The scope includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, introducing, or removing modifiers or 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 epoxy resin that is commingled with epoxy resin from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigations.

Excluded from the scope are phenoxy resins, which are polymers weighing more than 11,000 Daltons and containing no epoxy groups other than at the terminal ends of the molecule. Phenoxy resins’ Melt Flow Index (“MFI”) at 200°C (392°F) range from 4 to 70 grams per 10 min and its Glass-Transition Temperatures (“Tg”) range from 80 to 100°C (176 to 212°F).

Excluded from the scope are certain paint and coating products, which are blends, mixtures, or other formulations of epoxy resin, curing agent, and pigment, in any form, packaged in one or more containers, wherein (1) the pigment represents a minimum of 10 percent of the total weight of the product, (2) the epoxy resin represents a maximum of 80 percent of the total weight of the product, and (3) the curing agent represents 5 to 40 percent of the total weight of the product.

Excluded from the scope are preimpregnated fabrics or fibers, often referred to as “pre-pregs,” which are composite materials consisting of fabrics or fibers (typically carbon or glass) impregnated with epoxy resin.

This merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheading 3907.30.0000. Subject merchandise may also be entered under subheadings 3907.29.0000, 3824.99.9397, 3214.10.0020, 2910.90.91, 2910.90.9000, 2910.90.2000, and 1518.00.4000. The HTSUS subheadings are provided for convenience and customs purposes only; the written description of the scope is dispositive.

PETITIONERS

Olin Corporation

190 Carondelet Plaza # 1530

Clayton, MO 63105

Phone: (314) 480-1494

Fax: N/A

Contact Name and Title: J. Matthew Martin, VP & General Counsel – Strategic

Partnerships & Initiatives

Contact Email: jmmartin@olin.com

Website: https://olin.com/

Westlake Corporation

2801 Post Oak Boulevard #600

Houston, TX 77056

Phone: (614) 519-7866

Fax: N/A

Contact Name and Title: Aaron VanderKaay, Senior Counsel

Contact Email: avanderkaay@westlake.com

Website: https://westlake.com/

COUNSEL FOR PETITIONERS

King & Spaulding LLP

1700 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

202-737-0500

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

EventEarliest Date
Petition FiledApril 2, 2024
DOC InitiationApril 22, 2024
ITC Preliminary Investigation:
Questionnaires DueApril 16, 2024
Request to appear at hearing                                     April 21, 2024
HearingApril 23, 2024
BriefsApril 28, 2024
ITC VoteMay 17, 2024
  
DOC Investigation Schedule: 
DOC Preliminary Antidumping DeterminationSeptember 9, 2024
DOC Final Antidumping DeterminationNovember 23, 2024
DOC Preliminary Countervailing DeterminationJune 26, 2024
DOC Final Countervailing DeterminationSeptember 9, 2024
  
ITC Final Investigation: 
ITC Final AD Determination                 January 7, 2025
ITC Final CVD Determination              October 24, 2024

ALLEGED DUMPING MARGINS

China:              264.87% – 351.97%   

India:               11.43% – 17.50%

South Korea:   30.01% – 43.09%

Taiwan:           87.19% – 136.02%

Thailand:         163.94% – 205.63%

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

 201820192020202120222023
China      
Quantity (Pounds)6,864,4282,097,9923,886,5298,422,9436,325,1214,084,046
CIF Value (US $)9,414,3724,074,5455,746,41918,155,28013,115,5396,953,117
Value Per Pound1.371.941.482.162.071.70
India      
Quantity (Pounds)2,735,748703,272776,3721,989,2354,481,0964,720,313
CIF Value (US $)4,849,8282,114,6781,131,3785,171,95512,684,1398,129,122
Value Per Pound1.773.011.462.602.831.72
South Korea      
Quantity (Pounds)96,874,679104,444,41383,551,254149,812,303183,972,047124,718,706
CIF Value (US $)138,053,639137,765,42096,932,465353,926,868520,600,797217,069,374
Value Per Pound1.431.321.162.362.831.74
Taiwan      
Quantity (Pounds)27,453,82425,383,50216,786,25916,525,47432,454,68840,026,645
CIF Value (US $)39,117,89331,924,17619,497,74036,874,25371,498,38056,786,479
Value Per Pound1.421.2614.162.232.201.42
Thailand      
Quantity (Pounds)30,278,59626,233,93518,134,28112,354,75510,480,61312,718,384
CIF Value (US $)41,323,60132,320,04220,574,23126,200,84827,758,17321,731,991
Value Per Pound1.361.231.132.122.651.71

CONTACT US For more information concerning this petition and how it may affect your business, please contact Jeffrey Neeley, Nithya Nagarajan, Stephen Brophy, or Dan Wilson.