Export Compliance Daily is a service of Warren Communications News.

Hexamine: Details of AD/CVD Orders for Germany, India and Saudi Arabia

The Commerce Department issued antidumping duty orders on hexamethylenetetramine (hexamine) from Germany (A-428-854), India (A-533-932) and Saudi Arabia (A-517-807), and a countervailing duty order on hexamine from India (C-533-933).

Sign up for a free preview to unlock the rest of this article

Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.

The orders set permanent antidumping duties and countervailing duties that will remain in place unless revoked by Commerce, which may only take place under certain conditions, such as a sunset or changed circumstances review. Commerce now will begin conducting annual administrative reviews, if requested, to determine final assessments of AD/CVD on importers and make changes to cash deposit rates.

The orders detail a “gap period” of no CVD liability for subject merchandise from India that was entered July 5, 2025, through Dec. 29, 2025, and of no AD liability for subject merchandise from Germany, India and Saudi Arabia entered Nov. 2, 2025, through Dec. 29, 2025. Commerce may only suspend liquidation for a four-month period after its preliminary CVD determination, issued March 7, 2025, and for six months after its preliminary AD determination, issued May 6, 2025. Commerce will order CBP to liquidate, without regard to AD or CVD, any entries during these respective gap periods. Subject merchandise entered during the CVD gap period but outside the AD gap period (i.e., July 5, 2025, through Nov. 1, 2025) will be assessed only AD.

Commerce will order the refund of all AD cash deposits collected on hexamine from Germany and India entered before May 6, 2025, because the ITC reversed Commerce's findings of critical circumstances and retroactive collection of cash deposits.

The ITC also reversed Commerce's critical circumstances finding in the India CVD investigation, according to the commission's final injury report. Though Commerce doesn't reference the ITC's negative critical circumstances finding in its India CVD notice, a negative finding by the ITC would result in the refund of all CVD cash deposits collected on hexamine from India before March 7, 2025.

Commerce also recently issued AD/CVD orders concluding its concurrent AD/CVD investigations on hexamine from China (see 2509100032).

AD/CV Suspension of Liq Instructions

Suspension of liquidation resumes for all entries of subject merchandise entered on or after Dec. 30, 2025, the date that the final ITC affirmative injury determination was published.

CVD Cash Deposit Instructions

Commerce will require importers to pay CVD cash deposits on subject merchandise entered on or after Dec. 30. CVD cash deposits will be required at the following rates:

India

CompanyCVD Rate
Kanoria Chemicals and Industries Limited / Vardhan Limited2.34%
Horizon Chemicals139.57%
Micro Labs Ltd.139.57%
Shreenathji Rasayan Private Limited139.57%
Rajsha Chemicals Pvt. Ltd.139.57%
All Others2.34%

AD Cash Deposit Instructions

An AD cash deposit requirement is also in effect for subject merchandise entered on or after Dec. 30. Commerce will instruct CBP to require, at the same time that importers deposit estimated duties, a cash deposit equal to the rates listed below (as amended from Commerce's final determination on Saudi Arabia):

Saudi Arabia

Exporter/ProducerAD Rate
Methanol Chemicals Company8.1%
All others8.1%

India

Exporter/ProducerAD RateAdjusted*
Kanoria Chemicals and Industries Limited5.11%3.12%
Horizon Chemicals105.76%103.77%
Micro Labs Limited105.76%103.77%
Shreenathji Rasayan Private Limited105.76%103.77%
Rajsha Chemicals Pvt. Ltd105.76%103.77%
All Others5.11%3.12%

*As adjusted for export subsidies found in the concurrent CVD investigation. This rate serves as the AD cash deposit rate for entries on or after Dec. 30.

Germany

Exporter/ProducerAD Rate
Prefere Paraform GmbH & Co Kg59.29%
Fiberpipe GFK Vertriebsgesellschaft102.14%
All others59.29%

(See the notice for additional details, including the full scope description, etc. See 2509220038 for a summary of the final AD determinations, and 2509220027 for summary of the final CVD determinations.)