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AD+CVD ORDERS China A-570-168 (AD)C-570-169 (CVD)

U.S. Antidumping and Countervailing Duties on Alkyl Phosphate Esters from China (A-570-168 / C-570-169)

This is an educational summary — NOT a scope determination or filing advice. It does not decide whether your specific goods are covered. Always verify against the latest U.S. Commerce and CBP instructions.

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).

Case snapshot
ProductAlkyl Phosphate Esters
CountryChina
Case typeAD+CVD
Case number(s)A-570-168 (AD) · C-570-169 (CVD)
StatusActive / continued
Scope controlCommerce written scope language
HTS roleReference / screening only
Rate noteVaries by exporter/producer and administrative review
Key dates
A-570-168 (AD)
C-570-169 (CVD)
Status as ofActive — 2026-07-03
ExpirationNo 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 ETDETA2026-07-03
Effective/entry-specific deposit and liquidation treatment depends on Commerce and CBP instructions, not only the publication date.

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.

Products that may be covered (examples)
  • 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
Products that may require separate review or may fall outside this order
  • ?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
Scope control: HTS codes serve only as screening references for customs classification; Commerce's written scope language controls whether a product is covered, and unfinished, blended, or repackaged forms may still be covered depending on that 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.
The same chemical family may be subject to trade-remedy orders from more than one country over time, so importers should independently review the AD/CVD status of each country of origin they source from.

FAQ

Is there antidumping duty on alkyl phosphate esters from China?
There is a U.S. antidumping duty order under case A-570-168 and a separate countervailing duty order under case C-570-169 covering alkyl phosphate esters from China; whether your specific goods are covered depends on Commerce's written scope, so verification is required.
Does a 0% deposit rate mean no duty?
No. A 0% cash-deposit rate is not an exemption — the order still applies, the goods must still be declared as subject merchandise, and rates can change through administrative reviews.
Are parts or unassembled alkyl phosphate esters covered?
Chemical products in bulk, blended, diluted, or repackaged forms may still fall within scope depending on Commerce's written scope language; importers should verify rather than assume any form is excluded.
Needs review
Risk signal: Higher concern if the goods are alkyl phosphate esters of Chinese origin matching the core scope; a separate review is needed for blends, formulations, repackaged goods, and third-country processing before drawing any conclusion.
Bottom line: Alkyl phosphate esters from China may be covered by A-570-168 (AD) and C-570-169 (CVD); confirm scope, origin, exporter/producer identity, and current deposit rates before entry.
Not a scope determination or filing advice — confirm coverage and current deposit rates with a licensed customs broker and the latest Commerce/CBP instructions before entry.

Official sources

These links are for source verification. Confirm the latest applicable rate and instructions with Commerce/CBP before entry.

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Educational summary of a public U.S. Department of Commerce AD/CVD order — not legal advice, a customs broker opinion, or a scope determination. Whether specific goods fall within an order's scope must be confirmed with a licensed customs broker and the latest Commerce/CBP notices.
Last updated: 2026-07-04