Antidumping and Countervailing Duty Petitions for L-Lysine from China
Introduction
On May 28, 2025, new antidumping (AD) and countervailing duty (CVD) petitions were filed against imports of L-lysine from China. The petitions were filed by the Lysine Fair Trade Coalition and its individual members: Archer Daniels Midland Company, CJ Bio America, Inc., and Evonik Corporation. L-lysine is an essential amino acid used primarily as a nutrient additive in animal feed.
These petitions initiate an AD/CVD investigation, which will be conducted by two key U.S. federal agencies: the International Trade Commission (ITC) and the Department of Commerce (DOC). This blog post explores the details of the investigation, the scope of the products covered, and the potential impact on the U.S. lysine market.
Purpose of the Investigation
The goal of these AD/CVD investigations is to determine whether imports of L-lysine from China are being sold at unfairly low prices (dumping) or benefiting from unfair government subsidies. Both agencies must make affirmative findings for antidumping and countervailing duties to be imposed on Chinese imports. Here’s how the investigation will proceed:
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The ITC will assess whether these imports have materially harmed or threatened to harm the U.S. industry.
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The DOC will examine whether Chinese producers are selling L-lysine in the U.S. market at less than fair value or if they are receiving unfair government subsidies.
Both agencies must reach affirmative conclusions for AD/CVD duties to be imposed.
Scope of the Investigation
The petition defines the scope of this investigation to include L-lysine in various forms used as an additive in animal feed. Specifically, the scope covers the following:
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Animal feed grade L-lysine, including lysine monohydrochloride (HCL), lysine sulfate, and liquid lysine.
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Lysine that is coated or encapsulated for use with ruminants to ensure bioavailability.
The different forms of lysine covered in this investigation include:
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Lysine HCL (dry form) with the molecular formula C6H14N2O2HCl, containing a minimum of 78% lysine by weight.
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Lysine sulfate, with the molecular formula C6H16N2O6S, typically containing 40-70% lysine by weight.
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Liquid lysine, with the molecular formula C6H14N2O2, containing at least 50% lysine by weight.
The scope also includes:
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Blended or combined lysine products, such as base mixes, premixes, and concentrates, where only the lysine component is considered part of the investigation.
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Lysine that has undergone processing in a third country, such as commingling, diluting, refining, coating, or converting from one form to another.
The Harmonized Tariff Schedule of the United States (HTSUS) subheading for this merchandise is 2922.41.0090, though it may also be classified under 2922.41.0010, 2922.49.4950, and 2309.90.9500 for customs purposes.
Alleged AD/CVD Margins
The petitioner has calculated an estimated dumping margin of 197.1% for subject merchandise from China. However, the petitioner has not provided specific subsidy margin calculations at this time.
Named Exporters/ Producers
Petitioner included a list of companies that it believes are producers and exporters of the subject merchandise. See attached list of Chinese exporters/ producers of lysine 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 of US importers of lysine here.
Estimated Schedule of Investigations
The schedule for the investigation is as follows:
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May 28, 2025: Petitions filed
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June 17, 2025: DOC initiates investigation
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June 18, 2025: ITC Staff Conference
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July 12, 2025: ITC preliminary determination
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October 25, 2025: DOC CVD preliminary determination (assuming extended deadline; unextended date: August 21, 2025)
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December 24, 2025: DOC AD preliminary determination (assuming extended deadline; unextended date: November 4, 2025)
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May 8, 2026: DOC AD/CVD final determinations (extended)
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June 22, 2026: ITC final determination (extended)
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June 29, 2026: DOC AD/CVD orders issued (extended)
This schedule reflects the timeline for key determinations and actions in the investigation process.
Likely Impact
This investigation could lead to new antidumping and countervailing duties on L-lysine imports from China, which would affect U.S. buyers and consumers of this essential amino acid. The outcome of the investigation will have a significant impact on the global lysine market, particularly in the U.S., where demand for animal feed additives is substantial.
If the DOC and ITC make affirmative findings, the U.S. will impose additional duties on L-lysine imports from China. This could affect prices and availability of L-lysine for U.S. manufacturers and animal feed producers. As the investigation progresses, it is essential for industry stakeholders to stay informed about developments.
How to Prepare
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Monitor the investigation closely: Be sure to track updates on the investigation and its determinations.
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Consider the impact on your supply chain: U.S. companies importing lysine from China should prepare for potential changes in pricing and availability.
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Engage with legal and trade experts: If you are a stakeholder in the animal feed or lysine industry, consulting with trade experts can help you navigate the complexities of the investigation and its potential outcomes.
For updates and expert insights on this investigation, contact our international trade law team today. We can help you understand the potential impact on your business and advise on the next steps to safeguard your interests.
