Commerce Probes Chinese Spray-Foam Chemicals Under Trade Orders
Published Date: 7/23/2026
Notice
Summary
The U.S. Department of Commerce is checking if spray-foam systems from China fall under existing trade rules that add extra taxes on certain chemicals from China. This review pauses a related investigation about sneaky ways to avoid these taxes. Businesses importing these products should watch for updates starting July 23, 2026, as this could affect costs and trade rules.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 3 costs, 2 mixed.
Commerce opens scope inquiry on spray-foam
The Department of Commerce has started a scope inquiry to decide whether the esters-containing side of spray-foam systems from China is covered by the antidumping and countervailing duty orders. This inquiry was published on July 23, 2026 and may change whether imported spray-foam systems are treated as subject to those orders.
Suspension of liquidation and cash deposits apply
Commerce will notify U.S. Customs and Border Protection to continue suspending liquidation of entries already suspended and to apply the cash deposit rates that would apply if the spray-foam esters are covered by the Orders. Commerce will also direct CBP to begin suspension of liquidation and application of cash deposits for any unliquidated entries entered or withdrawn for consumption on or after July 23, 2026.
Circumvention inquiry deferred pending scope ruling
Commerce is deferring the circumvention inquiry it received about spray-foam systems from China while it completes the scope inquiry. The deferral means Commerce will decide the scope question first before pursuing the circumvention allegation.
Product tests for coverage: weight, phosphorus, viscosity
The Orders cover blends with one or more alkyl phosphate esters when the esters make up 20 percent or more of the blend by weight. The Orders also cover alkyl phosphate esters with a phosphorus content of at least 6.5 percent by weight and a viscosity between 1 and 2000 mPa·s (measured at 20–25 °C).
Final scope ruling timeline: 120-day deadline
Commerce intends to issue its final scope ruling within 120 days from the July 23, 2026 publication date, and may extend that deadline by up to 180 days. Interested parties should expect a final decision within those time limits unless extended.
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Key Dates
Department and Agencies
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