MESSAGE NO: 2233112 DATE: 08 20 1992
CATEGORY: ADA TYPE: ORD
REFERENCE: REFERENCE DATE:
CASES: A - 570 - 815 - -
- - - -
- - - -

PERIOD COVERED: 09 19 1992 TO

LIQ SUSPENSION DATE:

TO: REGIONAL DIRECTORS, COMMERCIAL OPERATIONS
DISTRICT DIRECTORS, AREA AND PORT DIRECTORS

FROM: DIRECTOR, IMPORT SPECIALIST DIVISION

RE: ANTIDUMPING DUTY ORDER ON SULFANILIC ACID FROM THE
PEOPLE'S REPUBLIC OF CHINA.


1. THE DEPARTMENT OF COMMERCE WILL PUBLISH IN THE FEDERAL
REGISTER AUGUST 19, 1992, NOTICE OF ITS ANTIDUMPING DUTY ORDER ON
SULFANILIC ACID FROM THE PEOPLE'S REPUBLIC OF CHINA.

2. THE PRODUCTS COVERED BY THIS ORDER ARE ALL GRADES OF
SULFANILIC ACID, WHICH INCLUDE TECHNICAL (OR CRUDE) SULFANILIC
ACID, REFINED (OR PURIFIED) SULFANILIC ACID AND SODIUM SALT OF
SULFANILIC ACID (SODIUM SULFANILATE).
SULFANILIC ACID IS A SYNTHETIC ORGANIC CHEMICAL PRODUCED FROM
THE DIRECT SULFONATION OF ANILINE WITH SULFURIC ACID. SULFANILIC
ACID IS USED AS A RAW MATERIAL IN THE PRODUCTION OF OPTICAL
BRIGHTENERS, FOOD COLORS, SPECIALTY DYES, AND CONCRETE ADDITIVES.
THE PRINCIPAL DIFFERENCES BETWEEN THE GRADES ARE THE UNDESIRABLE
QUANTITIES OF RESIDUAL ANILINE AND ALKALI INSOLUBLE MATERIALS
PRESENT IN THE SULFANIC ACID. ALL GRADES ARE AVAILABLE AS DRY
FREE FLOWING POWDERS.

TECHNICAL SULFANILIC ACID, CLASSIFIABLE UNDER THE SUBHEADING
2921.42.2420 OF THE HARMONIZED TARIFF SCHEDULE OF THE UNITED
STATES (HTS), CONTAINS 96 PERCENT MINIMUM SULFANILIC ACID, 1.0
PERCENT MAXIMUM ANILINE, AND 1.0 PERCENT MAXIMUM ALKALI INSOLUBLE
MATERIALS. REFINED SULFANILIC ACID, ALSO CLASSIFIABLE UNDER THE
HTS SUBHEADING 2921.42.2420 CONTAINS 98 PERCENT MINIMUM
SULFANILIC ACID, 0.5 PERCENT MAXIMUM ANILINE, AND 0.25 PERCENT
MAXIMUM ALKALI INSOLUBLE MATERIALS. SODIUM SALT OF SULFANILIC
ACID (SODIUM SULFANILATE), CLASSIFIABLE UNDER THE HTS SUBHEADING
2921.42.70, IS A GRANULAR OR CRYSTALLINE MATERIAL CONTAINING
75 PERCENT MINIMUM SULFANILIC ACID, 0.5 PERCENT MAXIMUM ANILINE,
AND 0.25 PERCENT MAXIMUM ALKALI INSOLUBLE MATERIALS BASED ON THE
EQUIVALENT SULFANILIC ACID CONTENT. ALTHOUGH THE HTS SUBHEADINGS
ARE PROVIDED FOR CONVENIENCE AND CUSTOMS PURPOSES, OUR WRITTEN
DESCRIPTION OF THE SCOPE OF THIS PROCEEDING IS DISPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES THIS CASE HAS BEEN ASSIGNED
INVESTIGATION NUMBER A-570-815.

4. BLUE LINE REPORTS ARE REQUIRED FOR WAREHOUSE WITHDRAWALS FOR
CONSUMPTION.

5. THE INTERNATIONAL TRADE COMMISSION (ITC) FOUND THAT A U.S.
INDUSTRY IS THREATENED WITH MATERIAL INJURY BY REASON OF IMPORTS
OF SULFANILIC ACID FROM THE PRC. THE ITC DID NOT DETERMINE
PURSUANT TO SECTION 735 (B)(4)(B) OF THE ACT THAT, BUT FOR THE
SUSPENSION OF LIQUIDATION OF ENTRIES OF SULFANILIC ACID FROM THE
PRC, THE DOMESTIC INDUSTRY WOULD HAVE BEEN MATERIALLY INJURED.
THEREFORE, THE "SPECIAL RULE" PROVISION OF SECTION 736(B)(2)
APPLIES.

6. THEREFORE, FOR SULFANILIC ACID FROM THE PRC, THE CUSTOMS
SERVICE SHALL ASSESS ANTIDUMPING DUTIES ON ALL ENTRIES THAT ARE
ENTERED OR WITHDRAWN FROM WAREHOUSE FOR CONSUMPTION ON OR AFTER
AUGUST 10, 1992, THE DATE ON WHICH THE ITC ISSUED ITS FINAL
AFFIRMATIVE DETEMINATION OF THREAT OF MATERIAL INJURY. THE
CUSTOMS SERVICE SHALL TERMINATE THE SUSPENSION OF LIQUIDATION FOR
ENTRIES ENTERED, OR WITHDRAWN FROM WAREHOUSE, FOR CONSUMPTION
BEFORE AUGUST 10, 1992, AND SHALL RELEASE ANY BOND OR OTHER
SECURITY, AND REFUND ANY CASH DEPOSIT POSTED TO SECURE THE
PAYMENT OF ESTIMATED ANTIDUMPING DUTIES WITH RESPECT TO THERE
ENTRIES. CUSTOMS OFFICERS MUST REQUIRE, AT THE SAME TIME AS
IMPORTERS WOULD NORMALLY DEPOSIT ESTIMATED DUTIES, THE FOLLOWING
CASH DEPOSITS FOR THE SUBJECT MERCHANDISE:


MANUFACTURER/EXPORTER IDENTIFICATION FINAL MARGIN
PRODUCER NUMBER PERCENTAGES

CHINA NATIONAL CHEMICALS IMPORT
& EXPORT CORP. HEBEI BRANCH A-570-815-001 19.14

ALL OTHERS A-570-815-000 85.20

7. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, THEY SHOULD BE REFERRED TO THE IMPORT SPECIALIST
DIVISION, OTHER AGENCY BRANCH VIA E-MAIL ATTRIBUTE "HQ OAB". THE
IMPORTING PUBLIC AND OTHER INTERESTED PARTIES SHOULD CONTACT MARY
JENKINS OR BRIAN SMITH, OFFICE OF ANTIDUMPING INVESTIGATIONS,
IMPORT ADMINISTRATION, INTERNATIONAL TRADE ADMINISTRATION, U.S.
DEPARTMENT OF COMMERCE, TELEPHONE (202) 377-1756 OR (202)
377-1766, RESPECTIVELY.

8. THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS INFORMATION.

NANCY MCTIERNAN