Thai spray-foam dodging China ester duties? Another Commerce circumvention hunt begins
Published Date: 9/1/2026
Notice
Summary
In response to a request from ICL-IP America, Inc. (the requester), the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether spray-foam systems from Thailand, which are completed or assembled with components produced in the People's Republic of China (China), are circumventing the antidumping duty (AD) and countervailing duty (CVD) orders on certain alkyl phosphate esters (esters) from China.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 2 costs, 2 mixed.
Suspension of Liquidation Continues
Commerce will notify U.S. Customs and Border Protection to continue suspending liquidation of entries covered by this inquiry and to apply the cash deposit rate that would apply if the products were covered by the Orders. Commerce may also direct CBP to begin suspension and require cash deposits for unliquidated entries entered on or after the publication date.
Questionnaires and Respondent Selection
If Commerce's ongoing scope inquiry finds spray-foam systems are within the Orders, Commerce intends to issue quantity-and-value and other questionnaires to producers and exporters in Thailand and will select respondents based on Q&V responses. Companies that fail to fully answer Commerce's requests may face facts available or adverse inferences under section 776 of the Act.
Commerce Opens Country‑Wide Inquiry
Commerce has started a country-wide circumvention inquiry into spray-foam systems from Thailand that are completed or assembled using components produced in China. The initiation was published on September 1, 2026 and applies to spray-foam systems containing the Chinese-origin "B" side ester component.
Statutory Timetable for Determinations
Commerce intends to issue a preliminary circumvention determination within 150 days and a final determination within 300 days from the date of the notice of initiation in the Federal Register. These deadlines start from the September 1, 2026 publication date unless the inquiry is rescinded, extended, or otherwise changed.
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Previous: 2026-17794, Certain Choline Salts From the People's Republic of China: Postponement of Preliminary Determination in the Countervailing Duty Investigation
The U.S. is investigating certain choline salts from China to see if unfair government help is involved. The first big decision on this is delayed from September 17 to a later date because the case is tricky and needs more time. This affects companies importing these salts and could lead to extra fees if unfair support is found.
Next: 2026-17796, Certain Alkyl Phosphate Esters From the People's Republic of China: Initiation of Circumvention Inquiry on the Antidumping and Countervailing Duty Orders
In response to a request from ICL-IP America, Inc. (the requestor), the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether certain alkyl phosphate esters (esters), which are completed or assembled in Thailand with intermediate chemicals produced in the People's Republic of China (China), are circumventing the antidumping duty (AD) and countervailing duty (CVD) orders on esters from China.