Treasury Eyes Tax on MDI Chemical (n=2.0-3.0)
Published Date: 8/26/2026
Notice
Summary
This notice of filing announces that a petition has been filed requesting that methylene diphenyl diisocyanate ((C<INF>8</INF>H<INF>6</INF>NO)(C<INF>8</INF>H<INF>5</INF>NO)<INF>n-2</INF> (C<INF>7</INF>H<INF>4</INF>NO); n=2.0-3.0), also known as "MDI," be added to the list of taxable substances. This notice of filing also requests comments on the petition. This notice of filing is not a determination that the list of taxable substances is modified.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 0 costs, 2 mixed.
Petition to Add MDI to Superfund List
A petition was filed asking that methylene diphenyl diisocyanate (MDI; CAS 101-68-8, 9016-87-9; n = 2.0–3.0) be added to the list of taxable substances under Internal Revenue Code section 4672(a). The petitioner is Huntsman International LLC and the petition filing date for making a determination is November 21, 2025. This notice is a request for comment and is not a determination that the taxable list is modified.
Public Comment Deadline and Filing Options
The IRS requests public comments or requests for a public hearing on the MDI petition, with written comments and requests for a hearing due on or before October 26, 2026. Comments may be submitted electronically at https://www.regulations.gov (docket IRS-2026-1028) or mailed to Internal Revenue Service, Attn: CC:PA:01:PR (Notice of Filing for Methylene Diphenyl Diisocyanate), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
Petitioner's Estimated Tax Rate Listed
The petition includes the petitioner's calculated tax rate for MDI of $10.20 per ton and lists conversion factors (benzene 0.62; nitric acid 0.50; methane 0.13; chlorine 0.56). The petition uses n = 2.0 to demonstrate more than 20% of the substance is made from taxable chemicals and uses a midpoint n = 2.5 to calculate the tax rate for the range.
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