A petition filed Feb. 12 alleges that methylene diphenyl diisocyanate from China is being sold at less than fair value in the U.S. and benefiting from countervailable subsidies. The alleged average dumping margins range from 305.81 percent to 507.13 percent.
The product subject to this petition is used the production of polyurethanes for many applications, including the manufacture of rigid polyurethane foams used for home and refrigerator insulation, coatings, adhesives, binders and sealants. It is commonly called polymeric, monomeric, or modified MDI and is also known as methylene bisphenyl isocyanate, 4,4’-diphenylmethane diisocyanate, methylene di-p-phenylene ester of isocyanic acid, and methylene bis(4-phenyl isocyanate), among others.
MDI consists of an aromatic polyisocyanate material whose composition includes two or more isocyanate groups (i.e., functional groups containing a nitrogen atom, a carbon atom, and an oxygen atom bonded together) attached to one or more benzene rings (i.e., flat, symmetrical molecules made up of six carbon atoms arranged in a hexagonal ring) that are joined by methylene bridges (i.e., a carbon atom bound to two hydrogen atoms and connected by single bonds to two other distinct atoms in the rest of the molecule).
The petition covers MDI (1) irrespective of whether it has gone through a distillation process, (2) regardless of acid content, reactivity, functionality, freeze stability, physical form, viscosity, grade, purity, molecular weight, or packaging, (3) that has been processed in a third country, including by commingling, diluting, introducing or removing additives, or performing any other processing that would not otherwise remove the MDI from the scope if performed in the subject country, and (4) that is commingled or blended with MDI from sources other than China.
The petition does not cover (1) mixtures of MDI with other materials when the combined MDI component comprises less than 40 percent of the total weight of the mixture, (2) partially reacted MDI when its nitrogen-carbon-oxygen content is less than 10 weight percentage, or (3) any separately packaged polyol that would not fall within the scope if entered on its own.
MDI is currently classifiable under HTSUS subheadings 2929.10.8010 and 3909.31.0000 and may also be entered under subheadings 3506.91.5000, 3815.90.5000, 3824.99.2900, 3824.99.9397, 3909.50.5000, 3911.90.4500, 3920.99.5000, and 3921.13.5000.
The Department of Commerce and the International Trade Commission will next determine whether to launch AD and CV duty and injury investigations, respectively, on this product. There are strict statutory deadlines associated with these proceedings, so affected companies that wish to protect their interests should contact Sandler, Travis & Rosenberg as soon as possible.
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