On May 28, 2025, the Lysine Fair Trade Coalition and its individual members (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of L-lysine from the People’s Republic of China (“China”).
SCOPE OF THE INVESTIGATION
The scope of this investigation covers animal feed grade L-lysine (“lysine”). Lysine is an essential amino acid added to animal feed that is used in the biosynthesis of proteins. The scope covers lysine regardless of form, including lysine monohydrochloride, also referred to as lysine HCL, lysine sulfate, and liquid lysine. The scope includes lysine that has been coated or encapsulated for use with ruminants to ensure bioavailability.
Lysine HCL in the dry form has the molecular formula C6Hi4N202HC1. The Chemical Abstracts Service (CAS) registry number for lysine HCL is 657-27-2. Lysine HCL contains a minimum of 78 percent lysine by weight, as well as additional amino acids, carbohydrates, mineral salts, and organic acids. Lysine sulfate is the sulfate salt of lysine, and in the dry form it has the molecular formula C6Hi6N206S. The CAS registry number for lysine sulfate is 60343-69-3. Lysine sulfate typically contains approximately 40-70 percent lysine by weight, as well as additional amino acids, carbohydrates, mineral salts, and organic acids. Liquid lysine is a concentrated form of lysine in an aqueous solution with the molecular formula C6Hi4N202. The CAS registry number for liquid lysine is 56-87-1. Liquid lysine contains normally contains at least 50 percent lysine by weight, as well as additional amino acids, carbohydrates, mineral salts, and organic acids.
The scope includes lysine that is combined with other products, including for example, by mixing, blending, compounding, or granulating (e.g., base mixes, premixes, and concentrates). For such combined products, only the lysine component is covered by the scope of this investigation.
Subject merchandise also includes lysine that has been processed in a third country, including by commingling, diluting, adding or removing additives, refining, converting from liquid to dry or dry to liquid form, coating or encapsulating, or performing any processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the subject country.
The merchandise covered by this investigation is properly classified under Harmonized Tariff Schedule of the United States (HTSUS) subheading 2922.41.0090. Lysine may also be classified under HTSUS subheadings 2922.41.0010, 2922.49.4950, and 2309.90.9500. Although the HTSUS subheadings and the CAS registry numbers are provided for convenience and customs purposes, the written description of the scope of the investigation is dispositive.
PETITIONERS
Members of the Lysine Fair Trade Coalition
| Archer Daniels Midland Company 77 West Wacker Drive, Suite 4600 Chicago, IL 60601 Phone: (312) 634-8476 Contact: Rebecca Jones Email: Rebecca.Jones@adm.com Website: https://www.adm.com/en-us/ Production facility: Decatur, Illinois | CJ Bio America, Inc., an Iowa corporation 1946 Harvest Ave. Fort Dodge, IA 50501 Phone: (213) 338-2631 Contact: Lance Choi Email: lance.choi@cj.net Website: https://www.cjamerica.com Production facility: Fort Dodge, Iowa |
| Evonik Corporation 2 Turner Place Piscataway, NJ 08854 Phone: (732) 981-5000 Contact: Martin Steffan Email: martin.steffan@evonik.com Web site: www.evonik.com Production facility: Blair, Nebraska |
COUNSEL FOR PETITIONER
Paul C. Rosenthal
John M. Herrmann
Elizabeth C. Johnson
Matthew G. Pereira
Kelley Drye & Warren LLP
3050 K Street, N.W., Suite 400
Washington, DC 20007
(202) 342-8400
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 Petitioner, please see Attachment II.
ESTIMATED SCHEDULE
Below is an estimated schedule. Please note that Commerce deadlines are likely to be extended for the AD investigation as authorized by statute.
| Event | Earliest Date | Extended Date |
| Petition Filed | May 28, 2025 | |
| DOC Initiation | June 17, 2025 | |
| ITC Preliminary Investigation: | ||
| Questionnaires Due | June 11, 2025 | |
| Request to appear at hearing | June 16, 2025 | |
| Hearing | June 18, 2025 | |
| Briefs | June 23, 2025 | |
| ITC Vote | July 12, 2025 | |
| DOC Investigation Schedule: | ||
| DOC Preliminary Antidumping Determination | November 4, 2025 | December 24, 2025 |
| DOC Final Antidumping Determination | January 18, 2026 | May 8, 2026 |
| DOC Preliminary Countervailing Determination | August 21, 2025 | October 25, 2025 |
| DOC Final Countervailing Determination | November 4, 2025 | January 8, 2026 |
| ITC Final Investigation: | ||
| ITC Final AD Determination | March 4, 2026 | June 22, 2026 |
| ITC Final CVD Determination | December 19, 2025 | February 22, 2026 |
ALLEGED DUMPING MARGINS
China : 197.1%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis.
IMPORTS OF SUBJECT MERCHANDISE
| 2022 | 2023 | 2024 | |
| U.S. Imports from: | |||
| China | |||
| Quantity (Metric Tons) | 29,066 | 56,120 | 77,934 |
| Value (Customs, USD) | 47,105,231 | 66,288,213 | 95,953,899 |
| AUV ($/MT) | 1,620.63 | 1,181.18 | 1,231.23 |
ALLEGED SUBSIDIES
For a list of alleged subsidies the Petitioner, please see Attachment III.
CONTACT US For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan, or Stephen Brophy.