A petition filed Jan. 23 alleges that difluoromethane (R-32) from China is being sold at less than fair value in the U.S. market. The alleged dumping margin is 87.98 percent.

R-32 is a hydrofluorocarbon, a colorless, odorless gas used primarily as a component in HFC blends, which are used in refrigerant applications. This petition covers R-32 or its chemical equivalent, regardless of form, type, or purity level, as well as the following.

- R-32 and unpurified R-32 that are processed in a third country or the U.S., including purifying or any other processing that would not otherwise remove the R-32 from the scope if performed in the country of manufacture of the in-scope R-32

- R-32 blended with products other than pentafluoroethane (R-125) if such blends contain 85 percent or more by volume of R-32

- R-32 blended with any amount of R-125 if such blends contain more than 52 percent by volume of R-32

- R-32 commingled with R-32 from other sources

R-32 is classified under HTSUS 2903.39.2035. Other subject goods, including the above-mentioned blends, may be classified under HTSUS 2903.39.2045 and 3824.78.0020.

Excluded from the petition are goods covered by the AD duty order on HFC blends from China.

The Department of Commerce and the International Trade Commission will next determine whether to launch AD 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.

For more information please contact trade attorney Kristen Smith at (202) 730-4965.

Copyright © 2023 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.


Kristen S. Smith
Partner, Advisory Committee; Trade Remedies Practice Group Leader

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