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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
Commerce's Enforcement and Compliance unit investigated lysine imports from China after a petition (initiated around June 2025) alleging sales at less-than-fair-value. The March 2026 preliminary determination set provisional measures and cash-deposit requirements effective from that publication date; the July 2026 final determination confirmed and refined those findings after verification visits (April 2026) and comment briefing.
The 139.83%/139.65% China-wide rate is an adverse-facts-available (AFA) rate — Commerce applied it after finding Zhengzhou Longgu (the only respondent with an individually calculated margin) and the Eppen Group of producers uncooperative, and after denying the Eppen Group separate-rate status in the final determination (a reversal from the preliminary stage). This AFA rate is calculated as a simple average of the top-10 transaction margins found for the Eppen Group. Most named exporters not individually examined but qualifying for a "separate rate" — trading through intermediaries like Agromate Sg, Ainore (Tianjin), Aollen Biotech, Pegasus, and Qiqihar Longjiang Fufeng — instead get the 73.55%/73.37% rate, derived from the same Eppen Group calculation since it was the only non-AFA, non-zero rate on the record.
A parallel countervailing-duty (subsidy) investigation ran on the same timeline and was finalized the same day (23 July 2026); its provisional CVD liquidation-suspension period lapsed in September 2025 under the statutory 120-day cap, so CVD cash deposits are not currently being collected pending the ITC's parallel injury finding.
establish a qualifying separate rate — a severity-defining margin for an amino-acid feed additive with limited non-China substitute supply at scale (Indonesia, South Korea, Japan being the main alternative producers).
July 2026 final LTFV finding (i.e., by ~early September 2026); a negative ITC finding would terminate the proceeding and refund all cash deposits.
of landed cost at the China-wide rate, likely accelerating sourcing shifts to Southeast Asian and South Korean producers (CJ CheilJedang, Ajinomoto affiliates).
bite (a formal AD order vs. termination/refund) hinges on that finding.
International Trade, which could reopen the China-wide-rate assignment for its exports.