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Commerce Announces New Dumping Investigation On Certain Sanitizing, Disinfecting, And Bleaching Agents From China

July 30, 2004

Lowering Dumping Duties By Submission of a Voluntary
"Section A" Response

The U.S. Department of Commerce has announced a dumping investigation on chlorinated isocyanurates ("chlorinated isos") from the People's Republic of China and Spain.  

Chlorinated isos are classified under subheading 2933.69.6050 of the HTSUS, and are used as sanitizing, disinfecting, and bleaching agents in swimming pool sanitizers, machine dishwashing detergents, toilet bowl cleaners, bleaches and scouring powders, and in water treatment applications. They are imported in powder, granular, and tablet forms.

Potential Dumping Margins To Be Applied

The alleged margins, in the case of trichlor and dichlor imported from the PRC, range from 109.14% to 157.82%. Commerce recently selected two Chinese suppliers of chlorinated isocyanurates to be "mandatory respondents", and will require them to respond to antidumping questionnaires within strict time limits.  

Lower Dumping Margins By Submission Of Voluntary Section A Questionnaire Responses

Commerce will accept voluntary "Section A" questionnaire responses from other suppliers of this product. Many Chinese suppliers of wooden bedroom furniture successfully obtained a dumping rate that was significantly lower than the "country-wide rate" set by Commerce, based on responses from the mandatory respondents.

Responses to the Section A portion of the questionnaire are due August 27, 2004. If the responses to the Section A questionnaire are not sufficient, or a company does not respond to a Section A questionnaire, Chinese suppliers will be assessed the "China-wide" rate, which may range from 109.14% to 157.82%.

Importers of "chlorinated isos" can protect their interests by facilitating the submission of a voluntary "Section A" questionnaire response from their suppliers. The area of antidumping duties is a difficult and a complicated one, and planning your strategy carefully and well in advance is essential. Professional advice should be obtained with regard to responding to an antidumping questionnaire. Our law firm specializes in antidumping and Customs law. If you wish assistance in preparing the Section A responses, please contact us as soon as possible.

If you have any questions on any of the issues raised in this newsletter, please contact Stephen Spraitzar at (415) 288-0427 or via email at

Stephen Spraitzar is an attorney with the Law Offices of George R. Tuttle in San Francisco. The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright 2005 by Tuttle Law Offices.

All rights reserved. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.


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