CVD ORDER China C-570-046 (CVD)

U.S. Countervailing Duty on HEDP (1-Hydroxyethylidene-1,1-Diphosphonic Acid) from China (C-570-046)

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.

HEDP from China may be subject to a U.S. countervailing duty (CVD) order under case number C-570-046.

Case snapshot

Product	Hydroxyethylidene-1, 1-Diphoshonic Acid (HEDP)
Country	China
Case type	CVD
Case number(s)	C-570-046 (CVD)
Status	Active / continued
Scope control	Commerce written scope language
HTS role	Reference / screening only
Rate note	Varies by exporter/producer and administrative review

Key dates

C-570-046 (CVD)	Federal Register: 2026-05 FR notice 2026-08559 (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

Effective/entry-specific deposit and liquidation treatment depends on Commerce and CBP instructions, not only the publication date.

This explainer covers the U.S. countervailing duty (CVD) order on 1-Hydroxyethylidene-1,1-Diphosphonic Acid (HEDP) from China under case number C-570-046. This is a CVD order only; the material was found by the ITC in 2017 to injure a U.S. industry, and countervailing duties may be assessed on covered entries.

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)

•HEDP in liquid solution form that may include water-treatment grade material
•HEDP in solid, dry, or powder form
•HEDP as a scale and corrosion inhibitor chemical that may be covered
•HEDP used as a chelating or sequestering agent
•HEDP sold as a raw chemical input for water treatment formulations
•HEDP shipped under various concentrations that may fall within scope

Products that may require separate review or may fall outside this order

?Finished consumer products where HEDP is only a minor component (verify against scope)
?Distinct phosphonate chemicals that are not HEDP
?Blended formulations where HEDP is not the covered merchandise (subject to Commerce review)
?Products both produced and exported by a company specifically excluded from the order
?Chemicals of a different CAS identity not described in the scope

Scope control: Any HTS codes are screening references only; Commerce's written scope language controls whether a product is covered, and HEDP in various forms or concentrations may still fall within scope depending on that language.

Who it affects

This typically matters for importers of HEDP or HEDP-containing chemical inputs of Chinese origin, including water-treatment chemical distributors, formulators, and industrial buyers sourcing scale/corrosion inhibitors.

What the duty means

Countervailing duties are collected as a cash deposit at entry; rates vary by producer/exporter and administrative review and can be high. A 0% or de minimis rate is NOT an exemption — the order still applies and entries must be declared. Note this is a CVD order only; no antidumping order is listed here.

Importer checklist — how to assess your risk

☐Gather the commercial invoice description and confirm it identifies HEDP by name and CAS identity.
☐Collect product spec sheets, technical data, and photos showing form and concentration.
☐Verify material composition and confirm whether HEDP is the covered merchandise.
☐Document the intended use and any blending or formulation.
☐Obtain country-of-origin support and manufacturing records.
☐Identify and record both the producer and exporter names and their exact combination.
☐Confirm HTS classification and use it only as a screening reference, not a scope decision.
☐Consult a licensed customs broker or trade counsel to confirm scope; do not rely only on supplier statements.
☐Verify the applicable cash-deposit rate against current Commerce administrative-review results and CBP AD/CVD messages before filing.

Risks to watch

⚠Circumvention or transshipment findings where HEDP is routed through a third country.
⚠Scope inquiries that may clarify whether a specific form or blend is covered.
⚠Applying the wrong producer/exporter combination and claiming a rate that does not apply.
⚠Misdeclaration penalties for failing to declare covered merchandise or using an incorrect rate.

The same or similar chemical may face trade-remedy orders from other origins, so importers should review each country of origin independently and truthfully, without arranging sourcing to evade duties.

FAQ

Is there antidumping duty on HEDP from China?

The order listed here is a countervailing duty (CVD) order under case number C-570-046, not an antidumping order. HEDP from China may be subject to CVD; importers should verify current status with Commerce and CBP.

Does a 0% deposit rate mean no duty?

No. A 0% or de minimis cash-deposit rate is not an exemption. The order still applies, entries must be declared, and rates can change through administrative reviews; verify before filing.

Are HEDP blends or diluted solutions covered?

They may still be covered depending on Commerce's written scope language, which addresses HEDP in various forms and concentrations; confirm with a licensed broker or trade counsel.

Possible risk

Risk signal: Higher concern if the goods are HEDP of Chinese origin used as a water-treatment or scale-inhibitor chemical; separate review is needed for blends, formulations, differing concentrations, and third-country processing. This does not state the goods are covered.

Bottom line: HEDP from China may be covered by CVD order C-570-046; confirm scope, origin, exporter/producer identity, and current cash-deposit rates against Commerce and CBP 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.

· Federal Register notice (2026-05 FR notice 2026-08559 (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.

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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: 2026-07-15