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Petition Summary: Certain Choline Salts from the People’s Republic of China

By Nithya Nagarajan & Stephen Brophy on June 30, 2026
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On June 24, 2026, BCP Ingredients, Inc. (“Petitioner”) filed petitions requesting the imposition of antidumping and countervailing duties on imports of certain choline salts (“choline salts”) from the People’s Republic of China.

SCOPE OF THE INVESTIGATION

The proposed scope of these investigations is as follows:

The merchandise covered by this investigation is certain choline salts, in all forms and purities. Subject choline salts may or may not contain additives such as a carrier or an anti-caking agent and may or may not be coated or encapsulated. For choline salts that contain non-choline components, such as a carrier or coating, the entire article is covered, including the non-choline content, provided that the choline content constitutes at least 30% by weight.

Choline salts are organic compounds and quaternary ammonium salts. Subject merchandise includes, but is not limited to: (1) choline chloride (CAS No. 67-48-1); (2) choline bitartrate (CAS No. 87-67-2); and (3) choline dihydrogen citrate (CAS No. 77-91-8). This investigation covers choline salts for which the reaction of trimethylamine and ethylene oxide occurs in the subject country. The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including but not limited to refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation.

Excluded from the scope of this investigation is choline hydroxide (CAS No. 123-41-1) and choline salicylate (CAS No. 2016-36-6).

The choline salts subject to this investigation are classified under HTSUS subheading 2923.10.0000. Subject choline salts may also be classified under HTSUS subheading 2106.90.9998, and dried choline chloride subject to this investigation may be classified under HTSUS subheadings 2309.90.1005, 2309.90.1015, 2309.90.1020, 2309.90.1030, 2309.90.1032, 2309.90.1035, 2309.90.1045, 2309.90.1050, 2309.90.9500, and 3824.99.9397. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.

PETITIONERS

BCP Ingredients, Inc.
5 Paragon Drive
Montvale, New Jersey 07645
Robyn Parenti, Global Trade Compliance Director
Phone: (845) 326-5600
Website: www.balchem.com

COUNSEL FOR PETITIONERS

PICARD KENTZ & ROWE LLP
1155 Connecticut Ave., NW, Suite 700
Washington, DC 20036
(202) 331-5040
 

NAMED PRODUCERS/EXPORTERS

For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.

NAMED IMPORTERS

For a list of importers alleged by the Petitioner, please see Attachment II.

ESTIMATED SCHEDULE

EventEarliest Date
Petition FiledJune 24, 2026
DOC InitiationJuly 14, 2026
  
ITC Preliminary Investigation: 
Questionnaires DueJuly 8, 2026
Request to appear at hearingJuly 13, 2026
HearingJuly 15, 2026
BriefsJuly 18, 2026
ITC VoteAugust 8, 2026
  
DOC Investigation Schedule: 
DOC Preliminary Antidumping DeterminationDecember 1, 2026
DOC Final Antidumping DeterminationFebruary 14, 2027
DOC Preliminary Countervailing DeterminationSeptember 17, 2026
DOC Final Countervailing DeterminationDecember 1, 2026
  
ITC Final Investigation: 
ITC Final AD DeterminationMarch 31, 2027
ITC Final CVD DeterminationJanuary 15, 2027

ALLEGED DUMPING MARGINS

China:              112.43% – 300.71%

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis

ALLEGED SUBSIDIES

For a list of alleged subsidies by the Petitioner, please see Attachment III.

IMPORTS OF SUBJECT MERCHANDISE

The following data are based on imports  classified under HTSUS subheading 2923.10.0000 (“Choline and its salts”) as reported by the U.S. International Trade Commission’s DataWeb. These data cover a broad basket category and are simultaneously over- and under-inclusive, but are intended to show the trend in import volumes and average unit values.

 202320242025Q1 2025Q1 2026
Volume (Kilograms)1,305,8101,420,2004,099,932534,5171,156,366
Value (USD)$6,121,518$6,672,449$8,225,416$1,561,720$1,860,506
Average Unit Value ($/kg)$4.69$4.70$2.01$4.03$2.58

Based on subscription-based import data (Datamyne.com), petitioner estimates in-scope choline salt import volumes from China (and countries associated with potential transshipment) as follows:

Quantity (MT)202320242025Q1 2025Q1 2026
China4,845.786,976.688,658.262,357.682,648.17
Possible China (transshipment)761.48525.33722.8748.79183.05
Total5,607.267,482.359,381.132,406.472,831.22

CONTACT US

For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.

Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

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Photo of Stephen Brophy Stephen Brophy

Stephen brings more than 20 years of international trade experience to Husch Blackwell. His practice focuses on trade relief and regulation, representing clients in antidumping, countervailing duty and safeguard proceedings. He has assisted clients with these and other related matters before the U.S.

Stephen brings more than 20 years of international trade experience to Husch Blackwell. His practice focuses on trade relief and regulation, representing clients in antidumping, countervailing duty and safeguard proceedings. He has assisted clients with these and other related matters before the U.S. Department of Commerce and U.S. International Trade Commission. Stephen is also experienced with customs issues, including tariff classification, valuation and country of origin marking matters.

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  • Posted in:
    Administrative and Regulatory, Antitrust, Competition and Trade
  • Blog:
    International Trade Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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