New AD/CVD Petitions: Hexamine from China, Germany, India, Saudi Arabia

On September 30, 2024, a new antidumping (AD) and countervailing duty (CVD) petition was filed against imports of Hexamine from China, Germany, India and Saudi Arabia. Due to its reactive nature, hexamine is used primarily as an input to produce explosives and energy products, a curing agent or catalyst in the plastics and resin industries, and as a precursor to foaming agents in the rubber industry.

The petition was filed on behalf of Bakelite LLC, the sole U.S. supplier of hexamine in the U.S. market. This case was brought because there was a significant shift in the global market for hexamine in the past three years. Russia, formerly a significant supplier of hexamine to the U.S. and global market, significantly reduced their exports to the United States. In the military buildup to Russia’s invasion of Ukraine in 2022, Russia used their own hexamine to produce RDX, an explosive used in artillery shells. Russia’s largest hexamine producer was taken over by Russian authorities in late 2023. With Russia’s exit from the U.S. market, hexamine imports from Germany, India, and Saudi Arabia surged significantly over the past few years. Bakelite alleges that this surge of subject imports from the four countries have caused injury as Bakelite was not able to take advantage of Russia’s exit from the U.S. market as they had expected.

These AD/CVD investigations will be conducted by two federal agencies. The International Trade Commission (“ITC”) will investigate whether the subject imports have materially retarded the establishment of the domestic industry. The U.S. Department of Commerce (“DOC”) will investigate whether the subject imports are being sold to the United States at less than fair value (“dumping”) or benefit from unfair government subsidies. Both agencies have to make affirmative findings of material retardation (ITC) or of dumping or subsidies (DOC) in order for AD/CVD duties to be imposed on the subject imports.

Scope

The petition proposes the following scope definition for the subject merchandise:

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 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.

Alleged AD/CVD Margins.

Petitioner calculated estimated dumping margins for the subject imports as follows:

China – 723.50%

Germany – 99.96% – 106.33%

India – 33.66% – 43.27%

Saudi Arabia – 482.29%

Petitioner did not provide any specific subsidy margin calculations.

Named Exporters/ Producers

Petitioner included a list of companies that it believes are producers and exporters of the subject merchandise. See attached list here.

Named U.S. Importers

Petitioner included a list of companies that it believes are U.S. importers of the subject merchandise. See attached list here.

Estimated Schedule of Investigations.