MESSAGE NO: 3322111 DATE: 11 17 1992
CATEGORY: ADA TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: A - 437 - 802 A - 533 - 806
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PERIOD COVERED: 10 22 1992 TO

LIQ SUSPENSION DATE: 10 22 1992

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

FROM: DIRECTOR, IMPORT SPECIALIST DIVISION

RE: PRELIMINARY DETERMINATIONS IN THE ANTIDUMPING DUTY
INVESTIGATIONS OF SULFANILIC ACID FROM THE REPUBLIC OF
HUNGARY AND INDIA

1. THE DEPARTMENT OF COMMERCE WILL PUBLISH IN THE FEDERAL
REGISTER ON OCTOBER 22, 1992, NOTICE OF ITS PRELIMINARY
DETERMINATIONS THAT SULFANILIC ACID, FROM HUNGARY AND INDIA ARE
SOLD IN THE UNITED STATES AT LESS THAN FAIR VALUE.

2. THE MERCHANDISE SUBJECT TO THESE INVESTIGATIONS ARE ALL GRADES
OF SUL FANILIC ACID, WHICH INCLUDE TECHNICAL (OR CRUDE)
SULFANILIC ACID, REFINED (OR PURIFIED) SULFANILIC ACID AND
REFINED SODIUM SALT OF SULFANILIC AC ID (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
BRIGHTNERS, FOOD COLORS, SPECIALTY DYES, AND CONCRETE ADDITIVES.
THE PRINCIPAL DIFFERENCES BETWEEN THE GRADES ARE THE UNDESIRABLE
QUANTITIES OF RESIDUAL ANILINE AND ALKALI INSOLUBLE MATERIAL
PRESENT IN THE SULFANILIC ACID. ALL GRADES ARE AVAILABLE AS DRY,
FREE FOLLOWING POWDERS.


TECHNICAL SULFANILIC ACID, CLASSIFIABLE UNDER THE SUBHEADING
2921.42.24.20 OF THE HARMONIZED TARIFF SCHEDULE (HTS), CONTAINS
96 PERCENT MINIMUM SULFANILIC AID, 1.0 PERCENT MAXIMUM ANILINE
AND 1.0 PERCENT MAXIMUM ALKALI INSOLUBLE MATERIALS. REFINED
SULFANILIC ACID, CLASSIFIABLE UNDER THE HTS SUBHEADING
21.42.24.20 CONTAINS 98 PERCENT MINIMUM SULFANILIC ACID, 0.5
PERCENT MAXIMUM ANILINE AND 0.25 PERCENT MAXIMUM ALKALI INSOLUBLE
MATERIALS. REFINED 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
EQUIVALENT SULFANILIC ACID, 0.5 PERCENT MAXIMUM ANILINE, AND 0.25
PERCENT MAXIMUM ALKALI INSOLUBLE MATERIALS BASED ON THE
EQUIVALENT SULFANILIC ACID CONTENT.
THE HTS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND CUSTOMS
PURPOSES. OUR WRITTEN DESCRIPTION OF THE SCOPE OF THESE
INVESTIGATIONS IS DESPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES, THESE CASES HAVE BEEN
ASSIGNED THE FOLLOWING INVESTIGATION NUMBERS HUNGARY A-437-802
AND INDIA A-533-806.

4. THE DEPARTMENT HAS PRELIMINARILY DETERMINED THAT CRITICAL
CIRCUMSTANCES EXIST WITH RESPECT TO EXPORTS OF SULFANILIC ACID
FROM HUNGARY. THEREFORE, FOR ALL EXPORTS OF SULFANILIC ACID FROM
HUNGARY THE CUSTOMS SERVICE SHALL SUSPEND LIQUIDATION OF SUCH
MERCHANDISE THAT IS ENTERED, OR WITHDRAWN FROM WAREHOUSE. FOR
CONSUMPTION ON OR AFTER JULY 24, 1992, WHICH IS 90 DAYS PRIOR TO
THE DATE OF PUBLICATION OF THE PRELIMINARY DETERMINATION IN THE
FEDERAL REGISTER, AND SHALL REQUIRE A CASH DEPOSIT OR POSTING OF
A BOND EQUAL TO THE APPROPRIATE ESTIMATED PRELIMINARY, MARGIN
PERCENTAGE LISTED BELOW.

5. FOR ALL EXPORTS OF SULFANILIC ACID FROM INDIA THE CUSTOMS
SERVICE SHALL SUSPEND LIQUIDATION OF SUCH MERCHANDISE THAT IS
ENTERED, OR WITHDRAWN FROM WAREHOUSE, FOR CONSUMPTION ON OF AFTER
OCTOBER 22, 1992, AND SHALL REQUIRE A CASH DEPOSIT OR POSTING OF
A BOND EQUAL TO THE APPROPRIATE ESTIMATED PRELIMINARY MARGIN
PERCENTAGE LISTED BELOW:

MANUFACTURER/PRODUCER/ IDENTIFICATION WEIGHTED-AVERAGE
EXPORTER NUMBER MARGIN PERCENTGAGE

HUNGARY

NITROKEMIA A-437-802-001 27.79%
ALL OTHERS A-437-802-000 27.79%

INDIA
ALL MANUFACTURERS/PRODUCERS/
EXPORTERS A-533-806-000 114.8%


6. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, THEY SHOULD BE REFERRED TO THE IMPORT SPECIALIST
DIVISION, OTHER AGENCY BRANCH, CUSTOMS HEADQUARTERS BY E-MAIL
ATTRIBUTE "HQ OAB." THE IMPORTING PUBLIC AND OTHER INTERESTED
PARTIES SHOULD CONTACT MARY JENKINS OF THE OFFICE OF ANTIDUMPING
INVESTIGATIONS, IMPORT ADMINISTRATION, INTERNATIONAL TRADE
ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE,
TELEPHONE (202) 482-1756.

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