On June 24, 2026, BCP Ingredients, Inc. (“Petitioner”) filed petitions requesting the imposition of antidumping and countervailing duties on imports of certain choline salts (“choline salts”) from the People’s Republic of China.
SCOPE OF THE INVESTIGATION
The proposed scope of these investigations is as follows:
The merchandise covered by this investigation is certain choline salts, in all forms and purities. Subject choline salts may or may not contain additives such as a carrier or an anti-caking agent and may or may not be coated or encapsulated. For choline salts that contain non-choline components, such as a carrier or coating, the entire article is covered, including the non-choline content, provided that the choline content constitutes at least 30% by weight.
Choline salts are organic compounds and quaternary ammonium salts. Subject merchandise includes, but is not limited to: (1) choline chloride (CAS No. 67-48-1); (2) choline bitartrate (CAS No. 87-67-2); and (3) choline dihydrogen citrate (CAS No. 77-91-8). This investigation covers choline salts for which the reaction of trimethylamine and ethylene oxide occurs in the subject country. The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including but not limited to refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation.
Excluded from the scope of this investigation is choline hydroxide (CAS No. 123-41-1) and choline salicylate (CAS No. 2016-36-6).
The choline salts subject to this investigation are classified under HTSUS subheading 2923.10.0000. Subject choline salts may also be classified under HTSUS subheading 2106.90.9998, and dried choline chloride subject to this investigation may be classified under HTSUS subheadings 2309.90.1005, 2309.90.1015, 2309.90.1020, 2309.90.1030, 2309.90.1032, 2309.90.1035, 2309.90.1045, 2309.90.1050, 2309.90.9500, and 3824.99.9397. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.
PETITIONERS
| BCP Ingredients, Inc. 5 Paragon Drive Montvale, New Jersey 07645 Robyn Parenti, Global Trade Compliance Director Phone: (845) 326-5600 Website: www.balchem.com |
COUNSEL FOR PETITIONERS
| PICARD KENTZ & ROWE LLP 1155 Connecticut Ave., NW, Suite 700 Washington, DC 20036 (202) 331-5040 |
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 | June 24, 2026 |
| DOC Initiation | July 14, 2026 |
| ITC Preliminary Investigation: | |
| Questionnaires Due | July 8, 2026 |
| Request to appear at hearing | July 13, 2026 |
| Hearing | July 15, 2026 |
| Briefs | July 18, 2026 |
| ITC Vote | August 8, 2026 |
| DOC Investigation Schedule: | |
| DOC Preliminary Antidumping Determination | December 1, 2026 |
| DOC Final Antidumping Determination | February 14, 2027 |
| DOC Preliminary Countervailing Determination | September 17, 2026 |
| DOC Final Countervailing Determination | December 1, 2026 |
| ITC Final Investigation: | |
| ITC Final AD Determination | March 31, 2027 |
| ITC Final CVD Determination | January 15, 2027 |
ALLEGED DUMPING MARGINS
China: 112.43% – 300.71%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis
ALLEGED SUBSIDIES
For a list of alleged subsidies by the Petitioner, please see Attachment III.
IMPORTS OF SUBJECT MERCHANDISE
The following data are based on imports classified under HTSUS subheading 2923.10.0000 (“Choline and its salts”) as reported by the U.S. International Trade Commission’s DataWeb. These data cover a broad basket category and are simultaneously over- and under-inclusive, but are intended to show the trend in import volumes and average unit values.
| 2023 | 2024 | 2025 | Q1 2025 | Q1 2026 | |
| Volume (Kilograms) | 1,305,810 | 1,420,200 | 4,099,932 | 534,517 | 1,156,366 |
| Value (USD) | $6,121,518 | $6,672,449 | $8,225,416 | $1,561,720 | $1,860,506 |
| Average Unit Value ($/kg) | $4.69 | $4.70 | $2.01 | $4.03 | $2.58 |
Based on subscription-based import data (Datamyne.com), petitioner estimates in-scope choline salt import volumes from China (and countries associated with potential transshipment) as follows:
| Quantity (MT) | 2023 | 2024 | 2025 | Q1 2025 | Q1 2026 |
| China | 4,845.78 | 6,976.68 | 8,658.26 | 2,357.68 | 2,648.17 |
| Possible China (transshipment) | 761.48 | 525.33 | 722.87 | 48.79 | 183.05 |
| Total | 5,607.26 | 7,482.35 | 9,381.13 | 2,406.47 | 2,831.22 |
CONTACT US
For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.