On January 21, 2026, Archer-Daniels-Midland Company, Cargill, Incorporated, and Primary Products Ingredients Americas LLC (“Petitioners”), filed a petition for the imposition of Antidumping Duties and Countervailing Duties on Imports of Citric Acid and Certain Citrate Salts from Canada and India.
SCOPE OF THE INVESTIGATION
The following describes the imported merchandise that is included within the scope of these investigations:
All grades and granulation sizes of citric acid, sodium citrate, and potassium citrate in their unblended forms, whether dry or in solution, and regardless of packaging type. The scope also includes blends of citric acid, sodium citrate, and potassium citrate, as well as blends with other ingredients, such as sugar, where the unblended form(s) of citric acid, sodium citrate, and potassium citrate constitute 40 percent or more, by weight, of the blend.
The scope also includes all forms of crude calcium citrate, including dicalcium citrate monohydrate, and tricalcium citrate tetrahydrate, which are intermediate products in the production of citric acid, sodium citrate, and potassium citrate. The scope includes the hydrous and anhydrous forms of citric acid, the dihydrate and anhydrous forms of sodium citrate, otherwise known as citric acid sodium salt, and the monohydrate and monopotassium forms of potassium citrate. Sodium citrate also includes both trisodium citrate and monosodium citrate which are also known as citric acid trisodium salt and citric acid monosodium salt, respectively.
The scope does not include calcium citrate that satisfies the standards set forth in the United States Pharmacopeia and has been mixed with a functional excipient, such as dextrose or starch, where the excipient constitutes at least 2 percent, by weight, of the product.
Citric acid and sodium citrate are classifiable under 2918.14.0000 and 2918.15.1000 of the Harmonized Tariff Schedule of the United States (HTSUS), respectively. Potassium citrate and crude calcium citrate are classifiable under 2918.15.5000 and, if included in a mixture or blend, 3824.99.9397 of the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are classifiable under 3824.99.9397 of the HTSUS. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise is dispositive.
PETITIONERS
| Archer-Daniels-Midland Company 4666 Faries Parkway Decatur, IL 62526 Website: http://www.adm.com | Cargill, Incorporated 15407 McGinty Road West, P.O. Box 5674 Wayzata, MN 55391 Website: https://www.cargill.com/ |
| Primary Products Ingredients Americas LLC 20 N. Martingale Road, Suite 350 Schaumburg, IL 60173 Website: http://www.primient.com/ |
COUNSEL FOR PETITIONERS
King & Spalding LLP
1700 Pennsylvania Avenue, N.W.
Washington, DC 20006
NAMED PRODUCERS/EXPORTERS
For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.
NAMED IMPORTERS
The list of importers has been marked confidential by the Petitioner, should this information become available, we will update accordingly.
ESTIMATED SCHEDULE
| Event | Earliest Date |
| Petition Filed | January 21, 2026 |
| DOC Initiation | February 10, 2026 |
| ITC Preliminary Investigation: | |
| Questionnaires Due | February 4, 2026 |
| Request to appear at hearing | February 9, 2026 |
| Hearing | February 11, 2026 |
| Briefs | February 14, 2026 |
| ITC Vote | March 7, 2026 |
| DOC Investigation Schedule: | |
| DOC Preliminary Antidumping Determination | June 30, 2026 |
| DOC Final Antidumping Determination | September 13, 2026 |
| DOC Preliminary Countervailing Determination | April 16, 2026 |
| DOC Final Countervailing Determination | June 30, 2026 |
| ITC Final Investigation: | |
| ITC Final AD Determination | October 28, 2026 |
| ITC Final CVD Determination | August 14, 2026 |
ALLEGED DUMPING MARGINS
Canada:
62.75% to 97.39%
India:
58.99% to 252.37%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis
ALLEGED SUBSIDIES
For a list of alleged subsidies by the Petitioner, please see Attachment II.
IMPORTS OF SUBJECT MERCHANDISE
| 2022 | 2023 | 2024 | Jan. – Sept. 2025 | |
| Canada | ||||
| Quantity (1,000 lbs) | 109,116 | 181,752 | 251,303 | 165,762 |
| CIF Value ($1,000) | 121,967 | 174,317 | 201,678 | 119,387 |
| AUV ($/lbs.) | 1.12 | 0.96 | 0.80 | 0.72 |
| India | ||||
| Quantity (1,000 lbs) | 21,235 | 34,092 | 27,637 | 35,579 |
| CIF Value ($1,000) | 38,965 | 31,517 | 23,388 | 26,412 |
| AUV ($/lbs.) | 1.83 | 0.92 | 0.85 | 0.74 |
CONTACT US For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.