Urgent Petition Filed for New Anti-Dumping Duties on MDI Imports from China

On February 12, 2025, at the request of BASF and Dow, the U.S. special MDI Fair Trade Alliance submitted a petition for new anti-dumping (AD) and countervailing duties (CVD) on methylene diphenyl diisocyanate (MDI) imported from China. The estimated dumping margins calculated by the petitioners range from 305.81% to 507.13%.

MDI is a widely used chemical intermediate with applications including the production of rigid foam plastics for various insulation materials, flexible foam plastics for automotive seating, bedding, and furniture, as well as in coatings, adhesives, sealants, and elastomers.

Previously, during President Trump's first term, MDI was already subject to an initial 25% tariff under Section 301. Recently, Trump announced an additional 10% tariff on all goods imported from China, which will also affect MDI. The U.S. domestic industry is now seeking to impose additional anti-dumping and countervailing duties on top of these tariffs to further increase the price of imported MDI.

The anti-dumping and countervailing investigations will be conducted by two federal agencies. The U.S. International Trade Commission (ITC) will investigate whether the imported products have significantly impeded the establishment of the domestic industry. The U.S. Department of Commerce will examine whether the imports are sold at prices below fair value (dumping) or benefit from unfair government subsidies. Both agencies must reach affirmative conclusions of material injury (ITC) or dumping or subsidies (Commerce) for anti-dumping/countervailing duties to be imposed.

The petition encompasses MDI products, including polymer, monomer, and modified MDI. The physical forms of MDI range from low-viscosity liquids to solids. Regardless of whether MDI has undergone a distillation process or its acidity, reactivity, functionality, freeze stability, physical form, viscosity, grade, purity, molecular weight, or packaging, all are included in this petition.

MDI may contain additives such as catalysts, solvents, plasticizers, antioxidants, flame retardants, colorants, pigments, diluents, thickeners, fillers, softeners, and impact modifiers. Mixtures containing MDI, where MDI constitutes less than 40% of the total weight, are excluded from this petition.

MDI can react with itself or with polyols or polyamines, retaining unreacted MDI components, thus transforming into different products that no longer contain isocyanate groups. Products with an NCO content of less than 10% of the total weight are also excluded.

The scope of the petition includes products processed in third countries that match the descriptions provided, including mixing, diluting, adding or removing additives, or any other processing that does not remove the products from the scope of investigation.

Currently, the product can be classified under the HTSUS codes 2929.10.8010 and 3909.31.0000, with related goods also classified under codes 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 estimated dumping margins based on the petitioners' calculations range from 305.81% to 507.13%. However, no specific calculations for subsidy margins were provided by the petitioners.