Opportunity

Federal Register #2026-17795

Trade Circumvention Inquiry: Alkyl Phosphate Esters and PFA in Spray-Foam Systems from Thailand (Chinese-Origin Components)

Buyer

International Trade Administration, Department of Commerce

Posted

September 01, 2026

Identifier

2026-17795

NAICS

325211, 325998, 325991

This opportunity involves a trade enforcement action by the U.S. Department of Commerce, International Trade Administration: - Initiation of a country-wide circumvention inquiry on spray-foam systems assembled in Thailand using alkyl phosphate esters produced in China - Focus is on whether these imports are evading existing antidumping and countervailing duty orders - The inquiry is prompted by a request from ICLIP America, Inc. - Scope covers alkyl phosphate esters (including perfluoroalkoxy alkane, or PFA) in primary form - Includes PFA resin in pellets, granules, cubes, powder, flakes, fluff, or aqueous dispersions - Compounded forms must contain at least 80% PFA by dry weight - Exclusions based on melting temperature, melt flow rate, and composition - No specific OEMs, vendors, part numbers, or purchase quantities are listed - The Department will issue questionnaires to Thai producers/exporters if products are found within scope - The goal is to prevent circumvention of trade orders and ensure proper enforcement of duties

Description

The U.S. Department of Commerce is initiating a country-wide circumvention inquiry to determine whether spray-foam systems from Thailand, which are completed or assembled with components produced in China, are circumventing the antidumping and countervailing duty orders on certain alkyl phosphate esters from China. The inquiry follows a request from ICLIP America, Inc. and involves evaluating whether the assembly or completion in Thailand is minor or insignificant and whether the value of Chinese-origin esters is a significant portion of the total value. Commerce will issue questionnaires to producers and exporters in Thailand if the ongoing scope inquiry determines the products are within the scope of the orders. The inquiry aims to prevent evasion of the existing trade orders.

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