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