MESSAGE NO: 3346111 DATE: 12 11 1992
CATEGORY: ADA TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: A - 533 - 806 - -
- - - -
- - - -

PERIOD COVERED: 12 07 1992 TO

LIQ SUSPENSION DATE: 12 07 1992

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

FROM: DIRECTOR, IMPORT SPECIALIST DIVISION

RE: PRELIMINARY DETERMINATION OF CRITICAL CIRCUMSTANCES IN THE
ANTIDUMPING INVESTIGATION OF SULFANILIC ACID FROM INDIA


1. THE DEPARTMENT OF COMMERCE PUBLISHED IN THE FEDERAL REGISTER
ON DECEMBER 7, 1992, NOTICE OF ITS PRELIMINARY AFFIRMATION
CRITICAL CIRCUMSTANCES DETERMINATION OF SULFANILIC ACID, FROM
INDIA.

2. THE MERCHANDISE SUBJECT TO THESE INVESTIGATIONS ARE ALL GRADES
OF SULFANILIC ACID, WHICH INCLUDE TECHNICAL (OR CRUDE) SULFANILIC
ACID, REFINED (OR PURIFIED) SULFANILIC ACID AND REFINED 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
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
2921.42.24.20 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 THIS
INVESTIGATION IS DESPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES, THIS CASE HAS BEEN ASSIGNED
THE FOLLOWING INVESTIGATION NUMBER INDIA A-533-806.

4. THE DEPARTMENT HAS PRELIMINARILY DETERMINED THAT CRITICAL
CIRCUMSTANCES EXIST WITH RESPECT TO EXPORTS OF SULFANILIC ACID
FROM INDIA FOR THE FOLLOWING COMPANIES: BETA NAPTHOL (P) LTD,
KANORIA CHEMICALS AND INDUSTRIES LTD., AND CHEMCO INTERNATIONAL.
THEREFORE, FOR ALL EXPORTS OF SULFANILIC ACID FROM INDIA MADE BY
THE ABOVE REFERENCED COMPANIES, 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.


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

INDIA

ALL MANUFACTURERS/PRODUCERS/

EXPORTERS A-533-806-000 114.8%


5. 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.

THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS INFORMATION.

NANCY MCTIERNAN