New Trade Case on Imports of Hexamine From Four Countries

The Petition

Bakelite LLC (“Bakelite” or “Petitioner”), the sole U.S. producer of granular hexamine in the United States filed a petition asking the U.S. government to impose antidumping (“AD”) duties on imports of hexamine from four countries: the People’s Republic of China (“China”), the Federal Republic of Germany (“Germany”), the Republic of India (“India”), and the Kingdom of Saudi Arabia (“Saudi Arabia”). The petition also requests the imposition of countervailing (“CVD”) duties on imports of hexamine from China and India.

Hexamine covered by these petitions includes hexamethylenetetramine, commonly known as hexamine, in granular form, derived from ammonia and formaldehyde. Hexamine is a crystalline, organic compound formed by the reaction of formaldehyde and ammonia. It has a cage-like molecular structure that imparts unique properties, making it highly versatile for various industrial applications. It is a white powder, highly soluble in water, and known for its stability at room temperature. Hexamine is commonly utilized in sectors such as explosives and munitions, resins catalysts, rubber and tires, energy, and other end-use applications. Due to its reactive nature, hexamine can act as a key ingredient in chemical processes or as an intermediate to create other compounds. Please see below for the full text of the proposed scope for the investigations.

Key Facts

Petitioner: Bakelite LLC.

Foreign Producers/Exporters and U.S. Importers: Please contact Clark Hill’s international trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins:  Petitioner alleged the following AD and CVD margins:

• China: AD margin of 723.50% ad valorem, and a CVD margin above de minimis;
• Germany: AD margins ranging from 106.33% to 99.96% ad valorem;
• India: AD margins ranging from 33.66 to 43.27% ad valorem, and a CVD margin above de minimis; and
• Saudi Arabia: AD margin of 482.29% ad valorem.

The Investigation

The Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) will conduct the investigations. The ITC will determine if there is a reasonable indication that the imports are injuring or threatening to injure the U.S. industry. The DOC will determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD duty margins that importers will need to pay on their entries.

Importers will be required to deposit the calculated AD/CVD duties on their imports as of the date that the DOC publishes its affirmative preliminary determination in the Federal Register. In this case, the DOC’s preliminary determinations are currently expected by Nov. 29, 2024 (CVD) and Feb. 12, 2025 (AD). Importers should be aware that entries may be subject to cash deposits before these dates if the DOC finds that there is a surge of imports after the petition was filed.

Next Steps

All U.S. importers and foreign producers are advised to prepare as soon as possible due to the strict statutory deadlines in these cases. If this product is of interest to you, please contact Clark Hill’s international trade team so that we can provide you with additional information.

A schedule of approximate key dates is attached below.

The Scope

The proposed scope of these investigations describes the subject merchandise as:

The scope of the Order covers hexamine in granular form or powder, regardless of particle size, or as a slurry, stabilized or unstabilized, whether or not blended, mixed, pulverized, or grounded with other products, containing more than 50 percent hexamine by weight.

Hexamine is the common name for hexamethylene tetramine (Chemical Abstract Service # 100-97-0), and is also referred to as 1,3,5,7-tetraazaadamantanemethenamine; HMT; HMTA; 1,3,5,7-tetraazatricyclo {3.3.1.13,7} decane; 1,3,5,7-tetraaza adamantane; hexamethylenamine. Hexamine has the chemical formula C6H12N4.

Granular hexamine that has been blended with other product(s) is included in this scope when the resulting mix contains 50 percent or more of hexamine by weight, which includes but is not limited to, (1) inert additives that do not react with hexamine; (2) co-reactants that react with hexamine when heated; and (3) additives that undergo self-condensation or reaction with other components when utilized in a mixture. Examples of such inert additives include but are not limited to precipitated silica, benzoic acid, aluminum silicate, diisodecyl phthalate (DIDP), calcium carbonate, magnesium stearate, citric acid, and metal oxides. Examples of such co-reactants include but are not limited to phenolic resins, alkylphenol novolacs, boron-modified novolac, phosphorous-modified novolac, rubber modified novolac, CNSL-novolac, tannin, lignin, tung oil, limonene-phenol condensate, resorcinol novolac, aniline-PF condensate, dicy-UF condensate, and and 1,3-dihydroxybenzene. Examples of such additives that undergo self-condensation or reaction with other components when utilized in a mixture include, but are not limited to polyvinyl alcohol, urea, ammonium nitrate, and zinc dinitramide.

Subject merchandise includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, adding, or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the subject country.

Hexamine that has been blended with other products is included within this scope when such blends include constituent parts that have been intermingled, but that have not been chemically reacted with each other to produce a different product.

Excluded from this scope is pharmaceutical hexamine in tablet or capsule form.

Merchandise covered by the scope of this petition can be classified in the Harmonized Tariff Schedule (“HTS”) of the United States under the subheadings 2933.69.5000. This tariff classification is provided for convenience and customs purposes; however, the written description of the scope is dispositive.

Contact Clark Hill

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680), Kevin Williams (kwilliams@clarkhill.com; 312-985-5907), Aristeo Lopez (alopez@clarkhill.com; 202-552-2366), Kelsey Christensen (kchristensen@clarkhill.com; 202-640-6670), Sally Alghazali (salghazali@clarkhill.com; 202-572-8676), or other members of Clark Hill’s International Trade Business Unit.

Approximate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/30/2024
DOC Initiation Date	20	**10/20/2024
DOC Q&V Questionnaires	44	11/13/2024
ITC Preliminary Determination	45	11/14/2024
DOC Separate Rate Applications	50	11/19/2024
DOC Preliminary AD Determination	160	**3/9/2025
DOC Final AD Determination	235	5/23/2025
ITC Final AD Determination	280	7/7/2025
DOC AD Publication of Order	287	7/14/2025
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/30/2024
DOC Initiation Date	20	**10/20/2024
DOC Q&V Questionnaires	44	11/13/2024
ITC Preliminary Determination	45	11/14/2024
DOC Preliminary CVD Determination	85	12/24/2024
Request for a DOC Hearing	122	1/30/2025
DOC Final CVD Determination	160	**3/9/2025
ITC Final CVD Determination	205	4/23/2025
DOC CVD Publication of Order	212	4/30/2025

* All deadlines are approximate and may change throughout the course of an investigation. Contact Clark Hill for current updates and details.

** Indicates a deadline that currently falls on a weekend or Federal holiday, which will be extended to the next business day.

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