Dioctyl Terephthalate From Taiwan, Turkey, Malaysia, and Poland

On March 26, Eastman Chemical Company (Petitioner) filed antidumping duty (AD) petitions on dioctyl terephthalate (DOTP) from Taiwan, Turkey, Malaysia, and Poland.

The Petitioner alleges that imports of Taiwan, Turkey, Malaysia, and Poland have caused material injury and threaten additional material injury to the US domestic industry due to the recent increase in imports from these countries. The Petitioner alleges they have experienced material injury through declines in production, lost sales and revenue, lost market share, and lost profitability.

AD duties may be imposed if the US Department of Commerce (DOC) determines that dumping is occurring and if the US International Trade Commission (ITC) determines that there is “material injury” (or the threat thereof) by reason of the dumped imports.

If the investigations are affirmative, importers of Taiwan, Turkey, Malaysia, and Poland will be liable for any potential AD duties imposed.

Scope of Investigations

Per the petition, the merchandise covered by this Petition is dioctyl terephthalate, regardless of form. DOTP that has been blended with other products is included within this scope when such blends include constituent parts that have not been chemically reacted with each other to produce a different product. For such blends, only the DOTP component of the mixture is covered by the scope of these investigations.

DOTP that is otherwise subject to these investigations is not excluded when commingled with DOTP from sources not subject to these investigations. Commingled refers to the mixing of subject and non-subject DOTP. Only the subject component of such commingled products is covered by the scope of these investigations.

DOTP has the general chemical formulation C6 H4 (C8 H17 COO)2 and a chemical name of "bis (2-ethylhexyl) terephthalate" and has a Chemical Abstract Service (CAS) registry number of 6422–86–2. Regardless of the label, all DOTP is covered by these investigations.

Subject merchandise is currently classified under subheading 2917.39.2000 of the Harmonized Tariff Schedule of the United States (HTSUS). Subject merchandise may also enter under subheadings 2917.39.7000 or 3812.20.1000 of the HTSUS. While the CAS registry number and HTSUS classification are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

Estimated AD Margins

The Petitioner alleges the following dumping margins exist:

  • Taiwan: AD rates of 83.70% to 136.20% ad valorem;
  • Turkey: AD rates of 34.83% to 70.97% ad valorem;
  • Malaysia: AD rates of 59.33 % ad valorem; and
  • Poland: AD rates of 60.10% ad valorem.

Estimated Key Dates of Interest to Exporters and Importers

The following are estimated key dates for these investigations, once initiated by the DOC and the ITC:

First Deadlines:
ITC Preliminary Injury Phase

approx. April 9, 2024questionnaire responses will be due.
April 16, 2024 – ITC Preliminary Staff Conference
May 10, 2024 - ITC Preliminary injury determination
Commerce Initiation Date April 15, 2024
Commerce Preliminary AD Determinations

September 2, 2024 - AD preliminary determination

The preliminary results deadline can be extended.

Commerce Preliminary CVD Determinations

No CVD included.

Earliest Suspension of Liquidation (theoretical) June 7, 2024 (if there are critical circumstances; otherwise, approximately September 2, 2024)

For further information, please reach out to any of the authors of this alert, or any other member of our team. 


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