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On April 21, 2026, Advancion Corporation (“Petitioner”) filed companion antidumping and countervailing duty petitions for the imposition of antidumping and countervailing duties on U.S. imports of tris(hydroxymethyl)aminomethane (Tris) from the People’s Republic of China (“China”).

The AD/CVD investigations will now proceed before the U.S. International Trade Commission (“ITC”) and the U.S. Department of Commerce (“Commerce”).  The ITC will determine whether the domestic Tris industry is suffering material economic injury by reason of subject imports.  Commerce will determine whether, and if so, to what extent, the imports are being dumped and/or subsidized.  As reflected in the detailed schedule below, these cases will move quickly.  Preliminary duty deposits will be imposed if Commerce and the ITC both make affirmative preliminary determinations, with a possibility for retroactive duties if there is a surge in imports in response to the petition being filed.

SCOPE OF THE INVESTIGATION

The proposed scope of these investigations is as follows:

The merchandise subject to these investigations is tris(hydroxymethyl)aminomethane, also commonly referred to as tromethamine or THAM, and its derivative, tris(hydroxymethyl)aminomethane hydrochloride (“Tris HCl”), also commonly referred as Tris hydrochloride or tromethamine HC1 (collectively, “Tris”). Tris and Tris HC1 are organic compounds with molecular compositions of C4EIHNO3 and C4HiiNO3.C1H, respectively. The scope includes all grades, purities, and forms of Tris and Tris HC1, which vary based on the raw materials (nitromethane and formaldehyde) used in the production process and the end use application required. Tris and Tris HC1 are packaged and sold in different forms and sizes, however, all Tris and Tris HC1 are covered regardless of form or packaging.

The Tris and Tris HC1 covered by these investigations are chemical compounds with the Chemical Abstract Service (“CAS”) numbers 77-86-1 and 1185-53-1, respectively. The country of origin of the subject merchandise in these investigations is based on the country where the Tris molecule is manufactured. As a result, Tris HC1 manufactured in a third country using Tris produced in China is subject to the investigations. In addition, reprocessing Tris or Tris HC1 in a third country by, for example, recrystallizing, retesting, or repackaging the merchandise does not remove the product from the scope of these investigations.

Tris and Tris HC1 covered by the scope of these investigations are currently classified under Harmonized Tariff Schedule of the United States (“HTSUS”) subheading 2922.19.9690. Although the HTSUS subheading is provided for convenience and customs purposes, the written description of the scope is dispositive.

PETITIONERS

Advancion Corporation
1500 E. Lake Cook Road
Buffalo Grove, IL 60089
Phone: (847) 215-8600
Fax: N/A
Contact: Scott C. Johnson, Senior Vice President, Global Corporate and Marketing Communications
Email: scjohnson@advancionsciences.com
Website: https://www.advancionsciences.com
 

COUNSEL FOR PETITIONERS

KELLEY DRYE & WARREN LLP
670 Maine Avenue, SW, Suite 600
Washington, DC 20024
(202) 342-8400
 

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 21, 2026
DOC InitiationMay 11, 2026
ITC Preliminary Investigation:
Questionnaires DueMay 5, 2026
Request to appear at hearingMay 10, 2026
HearingMay 12, 2026
BriefsMay 15, 2026
ITC VoteJune 5, 2026
  
DOC Investigation Schedule: 
DOC Preliminary Antidumping DeterminationSeptember 28, 2026
DOC Final Antidumping DeterminationDecember 12, 2026
DOC Preliminary Countervailing DeterminationJuly 15, 2026
DOC Final Countervailing DeterminationSeptember 28, 2026
  
ITC Final Investigation: 
ITC Final AD DeterminationJanuary 26, 2027
ITC Final CVD DeterminationNovember 12, 2026

ALLEGED DUMPING MARGINS

China:                43.89%% – 965.62%

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

 202320242025  
China   
Volume (Kilograms)945,508838,0621,532,002
Import Value (USD)3,647,7123,103,0695,146,383
AUV (USD/kg)$3.86$3.70$3.36

CONTACT US

For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.

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Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

Photo of Stephen Brophy Stephen Brophy

Stephen brings more than 20 years of international trade experience to Husch Blackwell. His practice focuses on trade relief and regulation, representing clients in antidumping, countervailing duty and safeguard proceedings. He has assisted clients with these and other related matters before the U.S.

Stephen brings more than 20 years of international trade experience to Husch Blackwell. His practice focuses on trade relief and regulation, representing clients in antidumping, countervailing duty and safeguard proceedings. He has assisted clients with these and other related matters before the U.S. Department of Commerce and U.S. International Trade Commission. Stephen is also experienced with customs issues, including tariff classification, valuation and country of origin marking matters.