Commerce sniffs out Chinese esters sneaking tariffs through Thailand rerouting trick
Published Date: 9/1/2026
Notice
Summary
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.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
Countrywide Circumvention Inquiry Initiated
Commerce has started a country-wide inquiry, effective September 1, 2026, to decide whether alkyl phosphate esters finished or assembled in Thailand using Chinese-origin intermediates (for example, PCl3, POCl3, or Propylene Oxide) are circumventing U.S. antidumping and countervailing duty orders on esters from China. Commerce intends to issue a preliminary determination within 150 days and a final determination within 300 days from the publication of this notice.
Suspension of Liquidation and Cash Deposits
Commerce has instructed U.S. Customs and Border Protection to continue suspending liquidation of entries of the covered esters and to apply the cash deposit rate that would apply if the products were determined to be circumventing the AD/CVD orders. Commerce also may direct CBP to begin suspension of liquidation and application of cash deposits for unliquidated entries entered on or after September 1, 2026.
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