U.S. Antidumping and Countervailing Duties on Alkyl Phosphate Esters from China (A-570-168 / C-570-169)
Alkyl phosphate esters from China may be affected by both a U.S. antidumping order (A-570-168) and a countervailing duty order (C-570-169).
| Product | Alkyl Phosphate Esters |
| Country | China |
| Case type | AD+CVD |
| Case number(s) | A-570-168 (AD) · C-570-169 (CVD) |
| Status | Active / continued |
| Scope control | Commerce written scope language |
| HTS role | Reference / screening only |
| Rate note | Varies by exporter/producer and administrative review |
| A-570-168 (AD) |
Federal Register: 2026-06 FR notice 2026-10938 (Opportunity to Request Review)
|
| C-570-169 (CVD) |
Federal Register: 2026-06 FR notice 2026-10938 (Opportunity to Request Review)
|
| Status as of | Active — 2026-07-03 |
| Expiration | No fixed expiration date. AD/CVD orders remain in place subject to five-year sunset reviews, and stay active unless revoked after Commerce/ITC review or other Commerce action. |
| Last checked by ETDETA | 2026-07-03 |
Alkyl phosphate esters imported from China may fall within the scope of two U.S. Department of Commerce trade-remedy orders: an antidumping duty order under case A-570-168 and a countervailing duty order under case C-570-169. Importers researching these goods should carefully verify scope, origin, and current deposit rates because both AD and CVD deposits may apply.
Scope — simplified screening examples, not full legal scope
The official written scope controls. The examples below are screening references only.
- •Certain alkyl phosphate ester chemicals that may include trialkyl phosphate esters
- •Phosphate ester flame-retardant compounds that may fall within the written scope
- •Alkyl phosphate esters used as plasticizers where they match scope descriptions
- •Certain aryl/alkyl phosphate ester blends where the alkyl phosphate ester component is described in the scope
- •Alkyl phosphate esters imported in bulk or drummed liquid form that may be covered
- •Alkyl phosphate ester products marketed under trade names but chemically matching the scope
- ?Phosphate compounds that are not alkyl phosphate esters (verify against scope)
- ?Inorganic phosphates or phosphoric acid, which are typically different products
- ?Finished downstream articles that merely contain trace phosphate esters, depending on scope
- ?Purely aromatic (aryl-only) phosphate esters that may fall outside the alkyl phosphate ester description
- ?Chemically distinct organophosphate products not described in the written scope
Who it affects
This typically matters for importers, distributors, and manufacturers sourcing alkyl phosphate esters or phosphate-ester chemical inputs from China, including those buying flame retardants, plasticizers, or specialty chemical intermediates.
What the duty means
If covered, imports generally require AD and CVD cash deposits at the time of entry; rates vary by exporter/producer and by administrative review and can be substantial. A 0% cash-deposit rate is NOT an exemption — the order still applies and entries must be declared. Because both an AD (A-570-168) and a CVD (C-570-169) order exist, both types of deposits may apply.
Importer checklist — how to assess your risk
- ☐Gather the commercial invoice and confirm the exact chemical description and grade.
- ☐Obtain product photos, spec sheets, and safety data sheets showing composition.
- ☐Document the material composition and CAS identity of the alkyl phosphate ester.
- ☐Record the intended end use (flame retardant, plasticizer, intermediate, etc.).
- ☐Collect country-of-origin support and manufacturing records to substantiate origin.
- ☐Identify the specific manufacturer/producer and exporter names, and confirm the exact producer/exporter combination.
- ☐Determine the proper HTS classification for screening, understanding it is not decisive on scope.
- ☐Confirm scope applicability with a licensed customs broker or qualified trade counsel; do not rely only on supplier statements.
- ☐Verify the applicable cash-deposit rate against current Commerce results and CBP AD/CVD messages before filing entry.
Risks to watch
- ⚠Circumvention or transshipment findings if goods are routed through third countries to disguise Chinese origin.
- ⚠Scope inquiries that could clarify whether specific blends or grades are within the orders.
- ⚠Using the wrong exporter/producer combination, which can trigger a higher all-others or China-wide rate.
- ⚠Misdeclaration or misclassification penalties, including potential retroactive duty liability.
FAQ
Official sources
These links are for source verification. Confirm the latest applicable rate and instructions with Commerce/CBP before entry.
- · Federal Register notice (2026-06 FR notice 2026-10938 (Opportunity to Request Review))
- · Commerce ACCESS — AD/CVD proceedings & scope rulings
- · CBP ACE AD/CVD case search & messages
- · USITC sunset/injury reviews
- HTS codes are provided for reference/screening only.