Petition Summary: Certain Fatty Acids from Indonesia and Malaysia

On January 28, 2026, Vantage Specialty Chemicals, Inc. (“Petitioner”), filed a petition for the imposition of Antidumping Duties and Countervailing Duties on Imports of Certain Fatty Acids from Indonesia and Malaysia.

SCOPE OF THE INVESTIGATION

The following describes the imported merchandise that is included within the scope of these investigations:

The merchandise subject to these Petitions is certain fatty acids (CFA), which are organic acids made of a hydrocarbon chain with a carboxylic acid group (i.e., an organic acid that contains a carboxyl group (-C(=O)-OH) attached to an R-group, sometimes also written as R-COOH, R-C(O)OH, or R-CO2H) at one end with a carbon chain length (i.e., the number of carbon atoms in the fatty acid chain) of C6, C8, ClO, C12, C14, C16, or C18, with an iodine value below 105 g/100 g and with a ratio of free fatty acids to triglycerides ( also known as the “degree of split” or “DoS”)) of at least 97 percent, including single fatty acid (also referred to as “pure cut”), and blends containing a combination of two or more carbon chain lengths.

CFA is also commonly called pure, pure cut, fractionated, or distilled fatty acid or mixed, mixed cut, or blended fatty acid, with the terms pure, pure cut, fractionated, and distilled typically referring to specific single-chain fatty acids that have been separated from a mixed natural source such as animal fat or vegetable oil using processes like hydrolysis (the breakdown of fat molecules by water, catalyzed by acid, base, or enzymes (lipases) to yield glycerol and free fatty acids), distillation, and crystallization, and the terms mixed or mixed cut referring to combinations, blends or mixtures of different single-chain fatty acids also derived from a natural source such as animal fat or vegetable oil using processes like hydrolysis, distillation, and crystallization. Common names for pure, pure cut, fractionated, or distilled fatty acids forms include stearic acid and oleic acid. Common names for mixed or mixed cut fatty acids include coconut fatty acid, hardened coconut fatty acid, topped coconut fatty acid, topped hardened coconut fatty acid, palm kernel fatty acid, hardened palm kernel fatty acid, topped palm kernel fatty acid, topped hardened palm kernel fatty acid, palm fatty acid, palm stearin fatty acid, palm

fatty acid distillate, and palm olein fatty acid.

CFA is normally associated with Chemical Abstracts Service (CAS) registry numbers 57-11-4, 112-80-1, 61790-38-3, 67701-05-7, 67701-06-8, 67707-01-3, 68938-15-8, 101403-98-9, 91771-90-3, 90990-15-1, 68440-15-3, 84238-17-5, 98106-68-4, 98106-66-2, 84238-17-5, 90990-08-1, and 90990-08-2 but several others may also be used.

CF A ranges in physical form from low viscosity liquids to solids. CF A is covered by the scope of these Petitions irrespective of whether it has gone through a distillation process and regardless of acid content, reactivity, functionality, freeze stability, heat stability, physical form, viscosity, grade, purity, molecular weight, or packaging.

CFA may contain additives, such as catalysts, solvents, antioxidants, fire retardants, colorants, pigments, diluents, thickeners, fillers, softeners, and toughening agents.

Specifically excluded from the scope are CF A containing 90 percent or more, by weight, of fatty acids with carbon chain lengths of C6, C8, or C 10 ( or any combination thereof).

The scope also does not include mixtures of CFA with other materials, when the combined CFA component comprises less than 80 percent of the total weight of the mixture.

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

The scope also includes CFA that is comingled or blended with CFA from sources not subject to these Petitions. Only the subject component of such comingled products is covered by the scope of these Petitions.

The merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 2915.70.01.20, 2915.70.01.50, 2915.90.10.50, 2916.15.10.00, 2916.15.51.00, 3823.11.00.00, 3823.12.00.00, 3823.19.20.00, and 3823.19.40.00, and may also enter under 2915.70.01.10 and 2915.90.10.10.

The HTSUS subheadings set forth above are provided for convenience and customs purposes only. The written description of the scope is dispositive.

PETITIONERS

COUNSEL FOR PETITIONERS

K&L GATES LLP

1601 K. St. NW

Washington, D.C. 20006

(202) 778-9000

NAMED PRODUCERS/EXPORTERS

For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.

NAMED IMPORTERS

For a list of importers alleged by Petitioners, please see Attachment II.

ESTIMATED SCHEDULE

ALLEGED DUMPING MARGINS

Indonesia:

20.08% to 72.03%

Malaysia:

64.67% to 94.41%

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis

ALLEGED SUBSIDIES

For a list of alleged subsidies by the Petitioner, please see Attachment III.

IMPORTS OF SUBJECT MERCHANDISE

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