ITC Investigation 701-TA-737 is a U.S. International Trade Commission antidumping (AD) proceeding on Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia; Inv. No. 701-TA-737-738 and 731-TA-1712-1715 (Final) from India, Saudi Arabia, China, and Germany. It's in the final phase and currently in completed status. It links to AD/CVD case A-428-854 — see the linked order for the active deposit rate, scope text, and Federal Register citation.
Phase, parties, documents, and full text from USITC IDS
Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia; Inv. No. 701-TA-737-738 and 731-TA-1712-1715 (Final)
ITC final injury determination completed.
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=== USITC Determination (2) === 61168 Federal Register / Vol. 90, No. 246 / Tuesday, December 30, 2025 / Notices 1 The record is defined in § 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR 207.2(f)). 2 90 FR 45728, 45725, 45723, and 45720 (September 23, 2025). 3 Commissioner David S. Johanson determines that an industry in the United States is threatened with material injury by reason of imports of hexamine from Germany, India, and Saudi Arabia that have been found by Commerce to be sold in the United States at LTFV and subsidized by the government of India. 4 The Commission also finds that imports subject to Commerce’s affirmative critical circumstances determinations with respect to Germany and India are not likely to undermine seriously the remedial effect of the antidumping duty order on hexamine from Germany or the antidumping duty and countervailing duty orders on hexamine from India. 5 Due to the lapse in appropriations and ensuing cessation of Commission operations, the Commission tolled its schedule for this proceeding. The schedule was revised in a subsequent notice published in the Federal Register on November 20, 2025 (90 FR 52436). Issued: December 23, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–24015 Filed 12–29–25; 8:45 am] BILLING CODE 7020–02–P INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–738 and 731– TA–1713–1715 (Final)] Hexamine (Hexamethylenetetramine) From Germany, India, and Saudi Arabia; Determinations On the basis of the record 1 developed in the subject investigations, the United States International Trade Commission (‘‘Commission’’) determines, pursuant to the Tariff Act of 1930 (‘‘the Act’’), that an industry in the United States is materially injured by reason of imports of hexamine from Germany, India, and Saudi Arabia, provided for in subheading 2933.69.50 of the Harmonized Tariff Schedule of the United States, that have been found by the U.S. Department of Commerce (‘‘Commerce’’) to be sold in the United States at less than fair value (‘‘LTFV’’) and subsidized by the government of India. 2 3 4 Background The Commission instituted these investigations effective September 30, 2024, following receipt of petitions filed with the Commission and Commerce by Bakelite Synthetics (Atlanta, Georgia). The Commission scheduled the final phase of the investigations following notification of preliminary determinations by Commerce that imports of hexamine from China were subsidized within the meaning of section 703(b) of the Act (19 U.S.C. 1671b(b)) and sold at LTFV within the meaning of section 733(b) of the Act (19 U.S.C. 1673b(b)). Notice of the scheduling of the final phase of the Commission’s investigations and of a public hearing to be held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on May 22, 2025 (90 FR 21948 and as revised in 90 FR 31241, July 14, 2025). The Commission conducted its hearing on July 18, 2025. All persons who requested the opportunity were permitted to participate. The investigation schedules became staggered when Commerce did not align its antidumping and countervailing duty investigations with respect to China with its antidumping duty investigations with respect to Germany, India, and Saudi Arabia, and its countervailing duty investigation with respect to India, and reached earlier final antidumping and countervailing duty determinations with respect to China. On September 3, 2025, the Commission issued final affirmative determinations in its antidumping and countervailing duty investigations of hexamine from China (90 FR 43234, September 8, 2025). Following notification of final determinations by Commerce that imports of hexamine from Germany, India, and Saudi Arabia were being sold at LTFV within the meaning of section 735(a) of the Act (19 U.S.C. 1673d(a)) and that imports of hexamine from India were being subsidized within the meaning of section 703(b) of the Act (19 U.S.C. 1671b(b)), notice of the supplemental scheduling of the final phase of the Commission’s antidumping duty investigations with respect to Germany, India, and Saudi Arabia and its countervailing duty investigation with respect to India was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on October 1, 2025 (90 FR 47327).5 The Commission made these determinations pursuant to §§ 705(b) and 735(b) of the Act (19 U.S.C. 1671d(b) and 19 U.S.C. 1673d(b)). It completed and filed its determinations in these investigations on December 22, 2025. The views of the Commission are contained in USITC Publication 5693 (December 2025), entitled Hexamine (Hexamethylenetetramine) from Germany, India, and Saudi Arabia: Investigation Nos. 701–TA–738 and 731–TA–1713–1715 (Final). By order of the Commission. Issued: December 22, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–23929 Filed 12–29–25; 8:45 am] BILLING CODE 7020–02–P NATIONAL AERONAUTICS AND SPACE ADMINISTRATION [NASA Document Number: 25–050] Notice of Intent To Grant an Exclusive, Co-Exclusive or Partially Exclusive Patent License AGENCY : National Aeronautics and Space Administration (NASA). ACTION : Notice of intent to grant exclusive, co-exclusive or partially exclusive patent license. SUMMARY : NASA hereby gives notice of its intent to grant an exclusive, co- exclusive or partially exclusive patent license to practice the inventions described and claimed in the patents and/or patent applications listed in SUPPLEMENTARY INFORMATION below. DATES : The prospective exclusive, co- exclusive or partially exclusive license may be granted unless NASA receives written objections including evidence and argument, no later than January 14, 2026 that establish that the grant of the license would not be consistent with the requirements regarding the licensing of federally owned inventions as set forth in the Bayh-Dole Act and implementing regulations. Competing applications completed and received by NASA no later than January 14, 2026 will also be treated as objections to the grant of the contemplated exclusive, co-exclusive or partially exclusive license. Objections submitted in response to this notice will not be made available to the public for inspection and, to the extent permitted by law, will not be released under the Freedom of Information Act. ADDRESSES : Written objections relating to the prospective license or requests for further information may be submitted to Agency Counsel for Intellectual Property, NASA Headquarters at Email: hq-patentoffice@mail.nasa.gov. Questions may be directed to Phone: (202) 358–0646. FOR FURTHER INFORMATION CONTACT : Requests for additional information should be directed to Oliver Sheuer, 202.358.3437, olivia.r.scheuer@ nasa.gov. SUPPLEMENTARY INFORMATION : NASA intends to grant an exclusive, co- VerDate Sep<11>2014 17:02 Dec 29, 2025 Jkt 268001 PO 00000 Frm 00055 Fmt 4703 Sfmt 4703 E:\FR\FM\30DEN1.SGM 30DEN1 khammond on DSK9W7S144PROD with NOTICES ──────────────────────────────────────────────────────────── === Publication 5660 === Hexamine (Hexamethylenetetramine) from China Investigation Nos. 701-TA-737 and 731-TA-1712 (Final) Publication 5660 September 2025 U.S. International Trade Commission Washington, DC 20436 COMMISSIONERS Amy A. Karpel, Chair David S. Johanson Jason E. Kearns Catherine DeFilippo Director of Operations Staff assigned Charles Cummings, Investigator Grace Robinson, Industry Analyst Stephanie Myers Irizarry, Economist Jennifer Catalano, Accountant Mara Alexander, Statistician Ravi Soopramanien, Attorney Elizabeth Haines, Supervisory Investigator U.S. International Trade Commission Address all communications to Secretary to the Commission United States International Trade Commission Washington, DC 20436 Washington, DC 20436 www.usitc.gov Hexamine (Hexamethylenetetramine) from China Investigation Nos. 701-TA-737 and 731-TA-1712 (Final) U.S. International Trade Commission Publication 5660 September 2025 CONTENTS Page i Determinations ..................................................................................................................... 1 Views of the Commission....................................................................................................... 3 Separate Views of Commissioner David S. Johanson ............................................................ 38 Introduction ........................................................................................................ 1.1 Background............................................................................................................................... 1.1 Statutory criteria ...................................................................................................................... 1.2 Organization of report.............................................................................................................. 1.3 Market summary ...................................................................................................................... 1.4 Summary data and data sources .............................................................................................. 1.5 Previous and related investigations ......................................................................................... 1.5 Nature and extent of subsidies and sales at LTFV ................................................................... 1.6 Subsidies ............................................................................................................................... 1.6 Sales at LTFV ......................................................................................................................... 1.8 The subject merchandise ....................................................................................................... 1.10 Commerce’s scope ............................................................................................................. 1.10 Tariff treatment .................................................................................................................. 1.11 The product ............................................................................................................................ 1.13 Description and applications .............................................................................................. 1.13 Manufacturing processes ................................................................................................... 1.14 Domestic like product issues.................................................................................................. 1.17 CONTENTS Page ii Part 2: Conditions of competition in the U.S. market ....................................................... 2.1 U.S. purchasers......................................................................................................................... 2.2 Impact of section 301 tariffs and new or modified tariffs ....................................................... 2.2 Channels of distribution ........................................................................................................... 2.3 Geographic distribution ........................................................................................................... 2.6 Supply and demand considerations ......................................................................................... 2.6 U.S. supply ............................................................................................................................ 2.6 U.S. demand ....................................................................................................................... 2.10 Substitutability issues............................................................................................................. 2.12 Factors affecting purchasing decisions............................................................................... 2.12 Purchase factor comparisons of domestic products, subject imports, and nonsubject imports ............................................................................................................................... 2.16 Comparison of U.S.-produced and imported hexamine .................................................... 2.19 Elasticity estimates ................................................................................................................. 2.23 U.S. supply elasticity ........................................................................................................... 2.23 U.S. demand elasticity ........................................................................................................ 2.23 Substitution elasticity ......................................................................................................... 2.24 CONTENTS Page iii Part 3: U.S. producers’ production, shipments, and employment .................................... 3.1 U.S. producers .......................................................................................................................... 3.1 U.S. production, capacity, and capacity utilization .................................................................. 3.3 Alternative products ............................................................................................................. 3.5 U.S. producers’ U.S. shipments and exports ............................................................................ 3.6 Captive consumption ............................................................................................................... 3.9 Transfers and sales ............................................................................................................... 3.9 First statutory criterion in captive consumption.................................................................. 3.9 Second statutory criterion in captive consumption ........................................................... 3.10 U.S. producers’ inventories .................................................................................................... 3.10 U.S. producers’ imports from subject sources ....................................................................... 3.11 U.S. producers' purchases of imports from subject sources ................................................. 3.11 U.S. employment, wages, and productivity ........................................................................... 3.12 Part 4: U.S. imports, apparent U.S. consumption, and market shares .............................. 4.1 U.S. importers........................................................................................................................... 4.1 U.S. imports .............................................................................................................................. 4.4 Negligibility ............................................................................................................................. 4.13 Cumulation considerations .................................................................................................... 4.14 Fungibility ........................................................................................................................... 4.14 Geographical markets ........................................................................................................ 4.18 Presence in the market ...................................................................................................... 4.20 Apparent U.S. consumption and market shares .................................................................... 4.25 Total market ....................................................................................................................... 4.25 Merchant market................................................................................................................ 4.34 CONTENTS Page iv Part 5: Pricing data ......................................................................................................... 5.1 Factors affecting prices ............................................................................................................ 5.1 Raw material costs ............................................................................................................... 5.1 Transportation costs to the U.S. market .............................................................................. 5.2 U.S. inland transportation costs ........................................................................................... 5.2 Pricing practices ....................................................................................................................... 5.3 Pricing methods .................................................................................................................... 5.3 Sales terms and discounts .................................................................................................... 5.4 Price leadership .................................................................................................................... 5.4 Price data.................................................................................................................................. 5.4 Price trends......................................................................................................................... 5.13 Price comparisons .............................................................................................................. 5.16 Lost sales and lost revenue .................................................................................................... 5.18 Part 6: Financial experience of U.S. producers .................................................................. 6.1 Background............................................................................................................................... 6.1 Operations on hexamine .......................................................................................................... 6.2 Net sales ............................................................................................................................... 6.9 Cost of goods sold and gross profit or loss......................................................................... 6.10 SG&A expenses and operating income or loss................................................................... 6.12 All other expenses and net income or loss ........................................................................ 6.13 Variance analysis ................................................................................................................ 6.14 Capital expenditures, research and development expenses, assets, and return on assets .. 6.17 Capital and investment .......................................................................................................... 6.18 CONTENTS Page v Threat considerations and information on nonsubject countries .......................... 7.1 Subject countries ...................................................................................................................... 7.3 Changes in operations .......................................................................................................... 7.6 Installed and practical overall capacity ................................................................................ 7.7 Constraints on capacity ........................................................................................................ 7.8 Operations on hexamine ...................................................................................................... 7.9 Alternative products ........................................................................................................... 7.22 Exports ................................................................................................................................ 7.22 U.S. inventories of imported merchandise ............................................................................ 7.24 U.S. importers’ outstanding orders........................................................................................ 7.27 Third-country trade actions ................................................................................................... 7.28 Information on nonsubject countries .................................................................................... 7.28 Appendixes A. Federal Register notices .................................................................................................. A.1 B. List of hearing witnesses ................................................................................................. B.1 C. Summary data ................................................................................................................. C.1 D. Nonsubject price data ..................................................................................................... D.1 Note.—Information that would reveal confidential operations of individual firms may not be published. Such information is identified by brackets ([ ]) in confidential reports and is deleted and replaced with asterisks (***) in public reports. Zeroes, null values, and undefined calculations are suppressed and shown as em dashes (—) in tables. If using a screen reader, we recommend increasing the verbosity setting. 1 UNITED STATES INTERNATIONAL TRADE COMMISSION Investigation Nos. 701-TA-737 and 731-TA-1712 (Final) Hexamine (Hexamethylenetetramine) from China DETERMINATIONS On the basis of the record1 developed in the subject investigations, the United States International Trade Commission (“Commission”) determines, pursuant to the Tariff Act of 1930 (“the Act”), that an industry in the United States is materially injured by reason of imports of hexamine from China, provided for in subheading 2933.69.50 of the Harmonized Tariff Schedule of the United States, that have been found by the U.S. Department of Commerce (“Commerce”) to be sold in the United States at less than fair value (“LTFV”) and subsidized by the government of China.2 3 BACKGROUND The Commission instituted these investigations effective September 30, 2024, following receipt of petitions filed with the Commission and Commerce by Bakelite Synthetics (Atlanta, Georgia). The Commission scheduled the final phase of the investigations following notification of preliminary determinations by Commerce that imports of hexamine from China were subsidized within the meaning of section 703(b) of the Act (19 U.S.C. 1671b(b)) and sold at LTFV within the meaning of 733(b) of the Act (19 U.S.C. 1673b(b)). Notice of the scheduling of the final phase of the Commission’s investigations and of a public hearing to be held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on May 22, 2025 (90 FR 21948 and as revised in 90 FR 31241, July 14, 2025). The Commission conducted its hearing on July 18, 2025. All persons who requested the opportunity were permitted to participate. 1 The record is defined in § 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR 207.2(f)). 2 90 FR 33922 and 33923 (July 18, 2025). 3 Commissioner David S. Johanson determines that that an industry in the United States is threatened with material injury by reason of imports of hexamine from China that have been found by Commerce to be sold in the United States at LTFV and subsidized by the government of China. 3 Views of the Commission Based on the record in the final phase of these investigations, we determine that an industry in the United States is materially injured by reason of imports of hexamethylenetetramine (“hexamine”) from China found by the U.S. Department of Commerce (“Commerce”) to be sold in the United States at less than fair value (“LTFV”) and subsidized by the government of China. Background Staggered Investigation Schedules. Although the antidumping duty petitions for hexamine from China, Germany, India, and Saudi Arabia and the countervailing duty petitions for hexamine from China and India were all filed on the same day, September 30, 2024, the investigation schedules became staggered when the U.S. Department of Commerce (“Commerce”) did not postpone the final determinations for its antidumping and countervailing duty investigations regarding China,1 while it did postpone its final determinations for its antidumping duty investigations regarding the other three subject countries,2 and aligned the final determination for its countervailing duty investigation regarding India with that of its corresponding antidumping duty investigation.3 This necessitates earlier Commission determinations in the final phase antidumping and countervailing duty investigations on hexamine from China than in the trailing investigations.4 Pursuant to the statutory cumulation 1 Hexamethylenetetramine From the People's Republic of China: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination, 90 Fed. Reg. 11,508 (Mar. 7, 2025). 2 Hexamethylenetetramine From India: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination and Extension of Provisional Measures, 90 Fed. Reg. 19,178 (May 6, 2025); Hexamethylenetetramine From the Kingdom of Saudi Arabia: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination, and Extension of Provisional Measures, 90 Fed. Reg. 19,180 (May 6, 2025); Hexamethylenetetramine From Germany: Preliminary Affirmative Determination of Sales at Less-Than-Fair-Value, Postponement of Final Determination, and Extension of Provisional Measures, 90 Fed. Reg. 19,186 (May 6, 2025). 3 Hexamethylenetetramine From India: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination, 90 Fed. Reg. 11,512, 11,514 (March 7, 2025). Commerce also aligned its countervailing duty investigation regarding China with that of its corresponding antidumping duty investigation. Hexamethylenetetramine From the People's Republic of China: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination, 90 Fed. Reg. 11,508 (Mar. 7, 2025). 4 Commerce is currently scheduled to issue its final antidumping duty determinations in the trailing investigations regarding Germany, India, and Saudi Arabia, and final countervailing duty (Continued...) 4 provision on staggered investigations, the record for each of these investigations will be the same except that, prior to the Commission’s determinations in the antidumping duty investigations regarding Germany, India, and Saudi Arabia, and the countervailing duty investigation regarding India, the Commission shall include the final Commerce antidumping and countervailing duty determinations, and the parties’ final comments concerning Commerce’s later determinations, in the record.5 Parties to the Investigation. The petitions in these investigations were filed on September 30, 2024, by Bakelite LLC (“Bakelite” or “Petitioner”). Petitioner submitted prehearing and posthearing briefs and final comments, and representatives appeared at the hearing with counsel.6 Two respondent entities participated actively in the final phase of these investigations. Kanoria Chemicals & Industries Limited (“KCIL”), an Indian producer and exporter of subject merchandise, submitted a prehearing brief.7 Counsel for General Authority for Foreign Trade (“GAFT”), an agency of the government of Saudi Arabia, appeared at the hearing and submitted prehearing and posthearing briefs and final comments.8 Data Coverage. The period of investigation in the final phase of these investigations is January 2022 through March 2025 (“POI”). U.S. industry data are based on the questionnaire responses of one domestic producer, accounting for all known U.S. production of in-scope hexamine in 2024.9 U.S. import data are based on the questionnaire responses of eleven U.S. determination in the trailing investigation regarding India, no later than 135 days from May 6, 2025, or by Thursday, September 18, 2025. See, e.g., Hexamethylenetetramine From India: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination and Extension of Provisional Measures, 89 Fed. Reg. 19,178, 19,179-19,180 (May 6, 2025). The Commission’s final determinations in those trailing investigations must be made within 45 days after Commerce’s affirmative final determinations, or no later than Monday, November 3, 2025. See 19 U.S.C. §§ 1671d(b)(2)(B), 1673d(b)(2)(B). 5 See 19 U.S.C. § 1677(7)(G)(iii). 6 Bakelite Prehearing Br., EDIS Doc. No. 856594 (July 11, 2025); Bakelite Posthearing Br., EDIS Doc. No. 857784 (July 25, 2025); Bakelite Final Comments, EDIS Doc. No. 859502 (Aug. 13, 2025). 7 KCIL Prehearing Br., EDIS Doc. No. 856579 (July 11, 2025). KCIL was the sole respondent entity to participate in the preliminary phase of these investigations. Counsel for KCIL filed written testimony ahead of the hearing, EDIS Doc. No. 857035 (July 17, 2025), and was scheduled to appear at the hearing, but was unable to do so due to illness. KCIL did not file a posthearing brief or final comments. 8 GAFT Prehearing Br., EDIS Doc. No. 856607 (July 11, 2025); GAFT Posthearing Br., EDIS Doc. No. 857804 (July 25, 2025); GAFT Final Comments, EDIS Doc. No. 859516 (Aug. 13, 2025). 9 Confidential Staff Report, INV-XX-105 (Aug. 6, 2025) (“CR”); Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia, Inv. Nos. 701-TA-737-738 and 731-TA-1712-1715 (Final), USITC Pub. 5660 (Aug. 2025) (“PR”) at 3.1. In the preliminary and final phases of these investigations, staff sent a U.S. producer questionnaire to ***, identified by Petitioner as a potential U.S. producer of hexamine. This firm reported that its ***. Id. at n.1. 5 importers, estimated to have accounted for a large majority of total subject imports in 2024, including *** percent of subject imports from China, *** percent of subject imports from Germany, *** percent of subject imports from India, and *** percent of subject imports from Saudi Arabia.10 Responding U.S. importers are also believed to account for *** percent of nonsubject imports in 2024.11 The Commission received four responses to its questionnaires from foreign producers of subject merchandise as follows: • one firm in Germany, accounting for *** percent of production of subject merchandise in Germany in 2024; • two firms in India, believed to account for *** percent of production of subject merchandise in India in 2024; and • one firm in Saudi Arabia, accounting for *** percent of production of subject merchandise in Saudi Arabia in 2024.12 The Commission did not receive responses from any foreign producers in China in either phase of these investigations.13 Domestic Like Product A. In General In determining whether an industry in the United States is materially injured or threatened with material injury by reason of imports of subject merchandise, the Commission first defines the “domestic like product” and the “industry.”14 Section 771(4)(A) of the Tariff Act of 1930, as amended (“the Tariff Act”), defines the relevant domestic industry as the “producers as a whole of a domestic like product, or those producers whose collective output of a domestic like product constitutes a major proportion of the total domestic production of the product.”15 In turn, the Tariff Act defines “domestic like product” as “a product which is 10 CR/PR at 4.1-4.2. Staff calculated coverage figures for all subject imports and for individual subject imports from China, India, and Saudi Arabia by comparing subject and total import quantities as reported in questionnaire responses to subject and total import quantities as reported in official U.S. import statistics. Staff believes that the Customs data may overstate import volumes with respect to Germany and nonsubject imports and has calculated import coverage for Germany based on proprietary, Customs-edited records. Id. at notes 5, 7. The use of a different calculation methodology to estimate coverage for Germany explains the apparent mismatch in estimates of total coverage and individual country coverage. 11 CR/PR at 4.1-4.2 & n.6. 12 CR/PR at Table 7.1. 13 CR/PR at Table 7.1. 14 19 U.S.C. § 1677(4)(A). 15 19 U.S.C. § 1677(4)(A). 6 like, or in the absence of like, most similar in characteristics and uses with, the article subject to an investigation.”16 By statute, the Commission’s “domestic like product” analysis begins with the “article subject to an investigation,” i.e., the subject merchandise as determined by Commerce.17 Therefore, Commerce’s determination as to the scope of the imported merchandise that is subsidized and/or sold at less than fair value is “necessarily the starting point of the Commission’s like product analysis.”18 The Commission then defines the domestic like product in light of the imported articles Commerce has identified.19 The decision regarding the appropriate domestic like product(s) in an investigation is a factual determination, and the Commission has applied the statutory standard of “like” or “most similar in characteristics and uses” on a case-by-case basis.20 No single factor is dispositive, and the Commission may consider other factors it deems relevant based on the facts of a particular investigation.21 The 16 19 U.S.C. § 1677(10). 17 19 U.S.C. § 1677(10). The Commission must accept Commerce’s determination as to the scope of the imported merchandise that is subsidized and/or sold at less than fair value. See, e.g., USEC, Inc. v. United States, 34 Fed. App’x 725, 730 (Fed. Cir. 2002) (“The ITC may not modify the class or kind of imported merchandise examined by Commerce.”); Algoma Steel Corp. v. United States, 688 F. Supp. 639, 644 (Ct. Int’l Trade 1988), aff’d, 865 F.3d 240 (Fed. Cir.), cert. denied, 492 U.S. 919 (1989). 18 Cleo Inc. v. United States, 501 F.3d 1291, 1298 (Fed. Cir. 2007); see also Hitachi Metals, Ltd. v. United States, Case No. 19-1289, slip op. at 8-9 (Fed. Circ. Feb. 7, 2020) (the statute requires the Commission to start with Commerce’s subject merchandise in reaching its own like product determination). 19 Cleo, 501 F.3d at 1298 n.1 (“Commerce’s {scope} finding does not control the Commission’s {like product} determination.”); Hosiden Corp. v. Advanced Display Mfrs., 85 F.3d 1561, 1568 (Fed. Cir. 1996) (the Commission may find a single like product corresponding to several different classes or kinds defined by Commerce); Torrington Co. v. United States, 747 F. Supp. 744, 748–52 (Ct. Int’l Trade 1990), aff’d, 938 F.2d 1278 (Fed. Cir. 1991) (affirming the Commission’s determination defining six like products in investigations where Commerce found five classes or kinds). 20 See, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007); NEC Corp. v. Department of Commerce, 36 F. Supp. 2d 380, 383 (Ct. Int’l Trade 1998); Nippon Steel Corp. v. United States, 19 CIT 450, 455 (1995); Torrington Co. v. United States, 747 F. Supp. 744, 749 n.3 (Ct. Int’l Trade 1990), aff’d, 938 F.2d 1278 (Fed. Cir. 1991) (“every like product determination ‘must be made on the particular record at issue’ and the ‘unique facts of each case’”). The Commission generally considers a number of factors, including the following: (1) physical characteristics and uses; (2) interchangeability; (3) channels of distribution; (4) customer and producer perceptions of the products; (5) common manufacturing facilities, production processes, and production employees; and, where appropriate, (6) price. See Nippon, 19 CIT at 455 n.4; Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l Trade 1996). 21 See, e.g., S. Rep. No. 96-249 at 90-91 (1979). 7 Commission looks for clear dividing lines among possible like products and disregards minor variations.22 B. Product Description Commerce has defined the imported merchandise within the scope of these investigations as: {H}examine in granular form, with a particle size of 5 millimeters or less, whether stabilized or unstabilized, whether or not blended, mixed, pulverized, or grounded with other products, containing 50 percent or more hexamine by weight. Hexamine is the common name for hexamethylene tetramine (Chemical Abstract Service #100-97-0), and is also referred to as 1,3,5,7- tetraazaadamantanemethenamine; HMT; HMTA; 1,3,5,7-tetraazatricyclo {3.3.1.13,7} decane; 1,3,5,7-tetraaza adamantane; hexamethylenamine. Hexamine has the chemical formula C6 H12 N4 . Granular hexamine that has been blended with other product(s) is included in this scope when the resulting mix contains 50 percent or more of hexamine by weight, regardless of whether it is blended with inert additives, co-reactants, or any additives that undergo self-condensation. Subject merchandise includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, adding or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the subject country. Merchandise covered by the scope of the investigations can be classified in the Harmonized Tariff Schedule (HTSUS) of the United States under the subheading 2933.69.5000. The HTSUS subheading and Chemical Abstracts Service registry 22 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748-49; see also S. Rep. No. 96-249 at 90-91 (Congress has indicated that the like product standard should not be interpreted in “such a narrow fashion as to permit minor differences in physical characteristics or uses to lead to the conclusion that the product and article are not ‘like’ each other, nor should the definition of ‘like product’ be interpreted in such a fashion as to prevent consideration of an industry adversely affected by the imports under consideration.”). 8 number are provided for convenience and customs purposes only; however, the written description of the scope is dispositive.23 Hexamine is a solid white powder that is highly water soluble and stable at room temperature.24 Hexamine’s properties make it useful as a reactant or catalyst in a variety of applications.25 In explosives and munitions, hexamine is used to form Research Department Explosive (“RDX”), a high-detonation explosive with military and civilian applications.26 In phenolic resins, hexamine is both a curing agent and a catalyst promoting polymerization.27 In rubber and tire manufacturing, hexamine functions as an acceleration and curing agent in vulcanization and as a performance enhancer, and it gives tires additional abrasion resistance and durability.28 Hexamine is also used in fuel tablets, biocides, refractory and friction materials, and as a corrosion inhibitor for metal surfaces.29 C. Arguments of the Parties Petitioner’s Arguments. Petitioner argues that the Commission should define a single domestic like product consisting of granular hexamine coextensive with the scope of these investigations.30 23 Hexamethylenetetramine From the People's Republic of China: Final Affirmative Determination of Sales at Less Than Fair Value, 90 Fed. Reg. 33,922, 33,923 (July 18, 2025); Hexamethylenetetramine From the People's Republic of China: Final Affirmative Countervailing Duty Determination, 90 Fed. Reg. 33,923, 33,924 (July 18, 2025); Hexamethylenetetramine From the Kingdom of Saudi Arabia: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination, and Extension of Provisional Measures, 90 Fed. Reg. 19,180, 19,182 (May 6, 2025); Hexamethylenetetramine From India: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination and Extension of Provisional Measures, 90 Fed. Reg. 19,178, 19,180 (May 6, 2025); Hexamethylenetetramine From Germany: Preliminary Affirmative Determination of Sales at Less-Than-Fair-Value, Postponement of Final Determination, and Extension of Provisional Measures, 90 Fed. Reg. 19,186, 19,187-19,188 (May 6, 2025); Hexamethylenetetramine From India: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination, 90 Fed. Reg. 11,512, 11,514 (March 7, 2025). The scope in both countervailing duty investigations is identical to the scope in the antidumping investigations. 24 CR/PR at 1.13. 25 CR/PR at 1.13. 26 CR/PR at 1.13. 27 CR/PR at 1.13. 28 CR/PR at 1.13. 29 CR/PR at 1.13-1.14. 30 Bakelite Prehearing Br. at 4-5. A representative for KCIL testified at the staff conference that “hexamine is hexamine. It’s a general chemical product having the same chemical composition.” See Transcript of the Preliminary Conference at 54 (Ohja). 9 Respondents’ Arguments. GAFT does not dispute the domestic like product definition proposed by Petitioner.31 KCIL does not address this issue in its brief. D. Analysis In the preliminary phase of these investigations, the Commission defined a single domestic like product consisting of granular hexamine, coextensive with Commerce’s scope.32 Applying its traditional six-factor like product analysis, the Commission found that the evidence on the record indicated that all granular hexamine possesses similar physical characteristics, has the same range of end uses, is produced through the same production processes at the same manufacturing facility using the same employees, is perceived to be a single product category by market participants, and is sold within the same general range of prices.33 Based on the preponderance of similarities among all types of hexamine and in the absence of any contrary argument, the Commission defined a single domestic like product consisting of all granular hexamine, coextensive with Commerce’s scope.34 In the final phase of these investigations, no parties requested that the Commission gather data or other information related to the definition of the like product,35 and the record contains no new information suggesting that the Commission should revisit its definition of the domestic like product from the preliminary phase of the investigations. We therefore define a single domestic like product consisting of granular hexamine, coextensive with the scope of these investigations. Domestic Industry The domestic industry is defined as the domestic “producers as a whole of a domestic like product, or those producers whose collective output of a domestic like product constitutes a major proportion of the total domestic production of the product.”36 In defining the domestic industry, the Commission’s general practice has been to include in the industry producers of all domestic production of the like product, whether toll-produced, captively consumed, or sold in the domestic merchant market. 31 GAFT Prehearing Br. at 3. 32 Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia, Inv. Nos. 701-TA-737-738 and 731-TA-1712-1715 (Preliminary), USITC Pub. 5563 (Nov. 2024) (“Preliminary Determinations”) at 7-9. 33 Preliminary Determinations, USITC Pub. 5563 at 7-9. 34 Preliminary Determinations, USITC Pub. 5563 at 8-9 35 CR/PR at 1.17. 36 19 U.S.C. § 1677(4)(A). 10 There are no related party or other domestic industry issues in these investigations. Therefore, consistent with our definition of the domestic like product, we define the domestic industry to include all domestic producers of granular hexamine. Negligible Imports Pursuant to Section 771(24) of the Tariff Act, imports from a subject country of merchandise corresponding to a domestic like product that account for less than 3 percent of all such merchandise imported into the United States during the most recent 12 months for which data are available preceding the filing of the petition shall be deemed negligible. 19 U.S.C. §§ 1671b(a), 1673b(a), 1677(24)(A)(i), 1677(24)(B); see also 15 C.F.R. § 2013.1 (developing countries for purposes of 19 U.S.C. § 1677(36)). The statute further provides that subject imports from a single country which comprise less than 3 percent of total such imports of the product may not be considered negligible if there are several countries subject to investigation with negligible imports and the sum of such imports from all those countries collectively accounts for more than 7 percent of the volume of all such merchandise imported into the United States. 19 U.S.C. § 1677(24)(A)(ii). In the case of countervailing duty investigations involving developing countries (as designated by the United States Trade Representative), the statute indicates that the negligibility limits are 4 percent and 9 percent, rather than 3 percent and 7 percent. 19 U.S.C. § 1677(24)(B). The Commission’s questionnaire response data indicate that from September 2023 to August 2024, the 12-month period preceding the filing of the petitions, subject imports from China accounted for *** percent of total U.S. imports of hexamine, subject imports from Germany accounted for *** percent of total U.S. imports of hexamine, subject imports from India accounted for *** percent of total U.S. imports of hexamine, and subject imports from Saudi Arabia accounted for *** percent of total U.S. imports of hexamine.37 As subject imports from each subject country are above the statutory threshold, we find that imports from each subject country are not negligible. 37 CR/PR at Table 4.4. The volume of imports from China and India subject to the antidumping and countervailing duty investigations is the same. 11 Cumulation For purposes of evaluating the volume and effects for a determination of material injury by reason of subject imports, section 771(7)(G)(i) of the Tariff Act requires the Commission to cumulate subject imports from all countries as to which petitions were filed and/or investigations self-initiated by Commerce on the same day, if such imports compete with each other and with the domestic like product in the U.S. market. In assessing whether subject imports compete with each other and with the domestic like product, the Commission generally has considered four factors: (1) the degree of fungibility between subject imports from different countries and between subject imports and the domestic like product, including consideration of specific customer requirements and other quality related questions; (2) the presence of sales or offers to sell in the same geographic markets of subject imports from different countries and the domestic like product; (3) the existence of common or similar channels of distribution for subject imports from different countries and the domestic like product; and (4) whether the subject imports are simultaneously present in the market.38 While no single factor is necessarily determinative, and the list of factors is not exhaustive, these factors are intended to provide the Commission with a framework for determining whether the subject imports compete with each other and with the domestic like product.39 Only a “reasonable overlap” of competition is required.40 38 See Certain Cast-Iron Pipe Fittings from Brazil, the Republic of Korea, and Taiwan, Inv. Nos. 731-TA-278-280 (Final), USITC Pub. 1845 (May 1986), aff’d, Fundicao Tupy, S.A. v. United States, 678 F. Supp. 898 (Ct. Int’l Trade), aff’d, 859 F.2d 915 (Fed. Cir. 1988). 39 See, e.g., Wieland Werke, AG v. United States, 718 F. Supp. 50 (Ct. Int’l Trade 1989). 40 The Statement of Administrative Action (SAA) to the Uruguay Round Agreements Act (URAA), expressly states that “the new section will not affect current Commission practice under which the statutory requirement is satisfied if there is a reasonable overlap of competition.” H.R. Rep. No. 103- 316, Vol. I at 848 (1994) (citing Fundicao Tupy, S.A. v. United States, 678 F. Supp. at 902; see Goss Graphic Sys., Inc. v. United States, 33 F. Supp. 2d 1082, 1087 (Ct. Int’l Trade 1998) (“cumulation does not require two products to be highly fungible”); Wieland Werke, AG, 718 F. Supp. at 52 (“Completely overlapping markets are not required.”). 12 A. Arguments of the Parties Petitioner’s Argument. Petitioner argues that the Commission should cumulate subject imports from all four subject countries.41 It contends that subject imports from China, India, Germany, and Saudi Arabia and the domestic like product are fungible.42 Petitioner submits that hexamine from all subject countries and the domestic like product is an intermediate input in the production of chemicals used in the manufacture of plastics, resins, and rubber and, thus, is universally used in the same applications.43 It contends that subject imports from all subject countries and the domestic like product are sold through overlapping channels of distribution.44 It observes that the vast majority of the domestic like product and subject imports were sold to end users, including users in the *** industries.45 Last, Petitioner claims that imports of hexamine from each subject country and domestically produced hexamine products overlapped geographically and were simultaneously present in the U.S. market during the period of investigation.46 Respondents’ Argument. Respondents did not address cumulation for present material injury. B. Analysis We consider subject imports on a cumulated basis because the statutory criteria for cumulation are satisfied. Petitioner filed the antidumping duty petitions with respect to all four countries and the countervailing duty petitions with respect to China and India on the same day, September 30, 2024.47 Furthermore, the record in the final phase of these investigations supports finding a reasonable overlap of competition between subject imports from China, Germany, India, and Saudi Arabia, and between subject imports from each source and the domestic like product, for the reasons discussed below. Fungibility. The record indicates that domestically produced hexamine and imports of hexamine from each subject country are generally fungible.48 Petitioner reported that subject imports from each subject country were *** interchangeable with each other as well as with 41 Bakelite Prehearing Br. at 7. 42 Bakelite Prehearing Br. at 8. 43 Bakelite Prehearing Br. at 8. 44 Bakelite Prehearing Br. at 9. 45 Bakelite Prehearing Br. at 9. 46 Bakelite Prehearing Br. at 9. 47 See Petition, EDIS Doc. No. 833603 (Sep. 30, 2024). None of the statutory exceptions to cumulation apply in these investigations. 48 See, e.g., CR/PR at 2.12. 13 domestically produced hexamine.49 Most U.S. importers reported that subject imports are *** interchangeable with domestically produced hexamine.50 U.S. purchasers reported that subject imports and domestically produced hexamine are *** interchangeable in most comparisons.51 Furthermore, the record shows that subject imports from each subject country overlapped with domestically produced hexamine in terms of hexamine content.52 Majorities of responding U.S. purchasers also reported that domestically produced hexamine and subject imports from each country were comparable on all of the 15 purchasing factors listed in the questionnaire, except for delivery time, which purchasers reported as superior for domestically produced hexamine.53 Moreover, there was overlap between domestically produced hexamine and imports of hexamine from all four subject countries in the pricing products.54 Channels of Distribution. During the POI, Petitioner sold its hexamine products mainly to end users in the “petrochemical and plastic end users” and “all other end users” channels of distribution.55 U.S. importers similarly sold hexamine from all four subject sources mainly in the petrochemical and plastic users channel of distribution, followed by the all other end users channel.56 Geographic Overlap. Petitioner reported selling hexamine to all regions in the contiguous United States.57 Imports from all four subject countries were sold in the Northeast and Midwest regions of the United States.58 Official import statistics also indicate that subject imports from the four subject countries entered the United States through ports located in the East in 2024.59 49 CR/PR at Table 2.13. 50 CR/PR at Table 2.14. 51 CR/PR at Table 2.15. 52 CR/PR at Table 4.5. Hexamine products are sold on the basis of purity. As a percent of U.S. shipments, 45.3 percent or more from each subject source and the domestic producer were greater than 99 percent pure in 2024. Id. 53 CR/PR at Table 2.12. 54 CR/PR at Tables 5.4-5.6. 55 CR/PR at Table 2.2. 56 CR/PR at Table 2.2. 57 CR/PR at Table 2.3. 58 CR/PR at Table 2.3. 59 CR/PR at Table 4.6. Subject imports did not enter the United States through the Western border. Id. 14 Simultaneous Presence in the Market. As reflected by the pricing data, the domestic like product was present in the U.S. market throughout the POI.60 Imports from each subject source were present in all but two of the 39 months of the POI.61 Conclusion. The record indicates that subject imports from each of the subject countries are generally fungible with the domestic like product and each other. The record also indicates that significant volumes of imports from each of the subject countries and the domestic like product overlapped in the “petrochemical and plastic users” channel of distribution, with additional overlap also occurring in the “all other end users” channel, albeit to a lesser degree. Further, imports from each of the subject countries and the domestic like product overlapped in two geographic regions and were simultaneously present in the U.S. market during the POI. Because there is a reasonable overlap of competition between and among subject imports from each subject country and the domestic like product, we cumulate subject imports from China, Germany, India, and Saudi Arabia for purposes of our material injury analysis. Material Injury by Reason of Subject Imports Based on the record in the final phase of these investigations, we find that an industry in the United States is materially injured by reason of imports of hexamine from China that Commerce has found to be sold in the United States at LTFV and subsidized by the government of China. A. Legal Standards In the final phase of antidumping and countervailing duty investigations, the Commission determines whether an industry in the United States is materially injured or threatened with material injury by reason of the imports under investigation.62 In making this determination, the Commission must consider the volume of subject imports, their effect on prices for the domestic like product, and their impact on domestic producers of the domestic like product, but only in the context of U.S. production operations.63 The statute defines “material injury” as “harm which is not inconsequential, immaterial, or unimportant.”64 In 60 CR/PR at Tables 5.4-5.6. 61 CR/PR at Table 4.7. Subject imports from China entered in 9 months of the POI, U.S. imports from Germany entered in 31 months, U.S. imports from India entered in 16 months, and U.S. imports from Saudi Arabia entered in 17 months. Id. 62 19 U.S.C. §§ 1671d(b), 1673d(b). 63 19 U.S.C. § 1677(7)(B). The Commission “may consider such other economic factors as are relevant to the determination” but shall “identify each {such} factor ... and explain in full its relevance to the determination.” 19 U.S.C. § 1677(7)(B). 64 19 U.S.C. § 1677(7)(A). 15 assessing whether the domestic industry is materially injured by reason of subject imports, we consider all relevant economic factors that bear on the state of the industry in the United States.65 No single factor is dispositive, and all relevant factors are considered “within the context of the business cycle and conditions of competition that are distinctive to the affected industry.”66 Although the statute requires the Commission to determine whether the domestic industry is “materially injured or threatened with material injury by reason of” unfairly traded imports,67 it does not define the phrase “by reason of,” indicating that this aspect of the injury analysis is left to the Commission’s reasonable exercise of its discretion.68 In identifying a causal link, if any, between subject imports and material injury to the domestic industry, the Commission examines the facts of record that relate to the significance of the volume and price effects of the subject imports and any impact of those imports on the condition of the domestic industry. This evaluation under the “by reason of” standard must ensure that subject imports are more than a minimal or tangential cause of injury and that there is a sufficient causal, not merely a temporal, nexus between subject imports and material injury.69 In many investigations, there are other economic factors at work, some or all of which may also be having adverse effects on the domestic industry. Such economic factors might include nonsubject imports; changes in technology, demand, or consumer tastes; competition among domestic producers; or management decisions by domestic producers. The legislative history explains that the Commission must examine factors other than subject imports to ensure that it is not attributing injury from other factors to the subject imports, thereby inflating an otherwise tangential cause of injury into one that satisfies the statutory material 65 19 U.S.C. § 1677(7)(C)(iii). 66 19 U.S.C. § 1677(7)(C)(iii). 67 19 U.S.C. §§ 1671d(b), 1673d(b). 68 Angus Chemical Co. v. United States, 140 F.3d 1478, 1484-85 (Fed. Cir. 1998) (“{T}he statute does not ‘compel the commissioners’ to employ {a particular methodology}.”), aff’g, 944 F. Supp. 943, 951 (Ct. Int’l Trade 1996). 69 The Federal Circuit, in addressing the causation standard of the statute, observed that “{a}s long as its effects are not merely incidental, tangential, or trivial, the foreign product sold at less than fair value meets the causation requirement.” Nippon Steel Corp. v. USITC, 345 F.3d 1379, 1384 (Fed. Cir. 2003). This was further ratified in Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873 (Fed. Cir. 2008), where the Federal Circuit, quoting Gerald Metals, Inc. v. United States, 132 F.3d 716, 722 (Fed. Cir. 1997), stated that “this court requires evidence in the record ‘to show that the harm occurred “by reason of” the LTFV imports, not by reason of a minimal or tangential contribution to material harm caused by LTFV goods.’” See also Nippon Steel Corp. v. United States, 458 F.3d 1345, 1357 (Fed. Cir. 2006); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir. 2001). 16 injury threshold.70 In performing its examination, however, the Commission need not isolate the injury caused by other factors from injury caused by unfairly traded imports.71 Nor does the “by reason of” standard require that unfairly traded imports be the “principal” cause of injury or contemplate that injury from unfairly traded imports be weighed against other factors, such as nonsubject imports, which may be contributing to overall injury to an industry.72 It is clear that the existence of injury caused by other factors does not compel a negative determination.73 Assessment of whether material injury to the domestic industry is “by reason of” subject imports “does not require the Commission to address the causation issue in any particular way” as long as “the injury to the domestic industry can reasonably be attributed to the subject 70 SAA at 851-52 (“{T}he Commission must examine other factors to ensure that it is not attributing injury from other sources to the subject imports.”); S. Rep. 96-249 at 75 (1979) (the Commission “will consider information which indicates that harm is caused by factors other than less- than-fair-value imports.”); H.R. Rep. 96-317 at 47 (1979) (“in examining the overall injury being experienced by a domestic industry, the ITC will take into account evidence presented to it which demonstrates that the harm attributed by the petitioner to the subsidized or dumped imports is attributable to such other factors;” those factors include “the volume and prices of nonsubsidized imports or imports sold at fair value, contraction in demand or changes in patterns of consumption, trade restrictive practices of and competition between the foreign and domestic producers, developments in technology and the export performance and productivity of the domestic industry”); accord Mittal Steel, 542 F.3d at 877. 71 SAA at 851-52 (“{T}he Commission need not isolate the injury caused by other factors from injury caused by unfair imports.”); Taiwan Semiconductor Industry Ass’n, 266 F.3d at 1345 (“{T}he Commission need not isolate the injury caused by other factors from injury caused by unfair imports ... . Rather, the Commission must examine other factors to ensure that it is not attributing injury from other sources to the subject imports.” (emphasis in original)); Asociacion de Productores de Salmon y Trucha de Chile AG v. United States, 180 F. Supp. 2d 1360, 1375 (Ct. Int’l Trade 2002) (“{t}he Commission is not required to isolate the effects of subject imports from other factors contributing to injury” or make “bright-line distinctions” between the effects of subject imports and other causes.); see also Softwood Lumber from Canada, Inv. Nos. 701-TA-414 and 731-TA-928 (Remand), USITC Pub. 3658 at 100-01 (Dec. 2003) (Commission recognized that “{i}f an alleged other factor is found not to have or threaten to have injurious effects to the domestic industry, i.e., it is not an ‘other causal factor,’ then there is nothing to further examine regarding attribution to injury”), citing Gerald Metals, 132 F.3d at 722 (the statute “does not suggest that an importer of LTFV goods can escape countervailing duties by finding some tangential or minor cause unrelated to the LTFV goods that contributed to the harmful effects on domestic market prices.”). 72 S. Rep. 96-249 at 74-75; H.R. Rep. 96-317 at 47. 73 See Nippon Steel Corp., 345 F.3d at 1381 (“an affirmative material-injury determination under the statute requires no more than a substantial-factor showing. That is, the ‘dumping’ need not be the sole or principal cause of injury.”). 17 imports.”74 The Commission ensures that it has “evidence in the record” to “show that the harm occurred ‘by reason of’ the LTFV imports,” and that it is “not attributing injury from other sources to the subject imports.” 75 The Federal Circuit has examined and affirmed various Commission methodologies and has disavowed “rigid adherence to a specific formula.”76 The question of whether the material injury threshold for subject imports is satisfied notwithstanding any injury from other factors is factual, subject to review under the substantial evidence standard.77 Congress has delegated this factual finding to the Commission because of the agency’s institutional expertise in resolving injury issues.78 B. Conditions of Competition and the Business Cycle The following conditions of competition inform our analysis of whether there is material injury by reason of subject imports. 1. Captive Production We next consider the applicability of the statutory captive production provision.79 Petitioner argued in the preliminary phase of these investigations that the captive production 74 Mittal Steel, 542 F.3d at 876 &78; see also id. at 873 (“While the Commission may not enter an affirmative determination unless it finds that a domestic industry is materially injured ‘by reason of’ subject imports, the Commission is not required to follow a single methodology for making that determination ... {and has} broad discretion with respect to its choice of methodology.”) citing United States Steel Group v. United States, 96 F.3d 1352, 1362 (Fed. Cir. 1996) and S. Rep. 96-249 at 75. In its decision in Swiff-Train v. United States, 793 F.3d 1355 (Fed. Cir. 2015), the Federal Circuit affirmed the Commission’s causation analysis as comporting with the Court’s guidance in Mittal. 75 Mittal Steel, 542 F.3d at 873 (quoting from Gerald Metals, 132 F.3d at 722), 877-79. We note that one relevant “other factor” may involve the presence of significant volumes of price-competitive nonsubject imports in the U.S. market, particularly when a commodity product is at issue. In appropriate cases, the Commission collects information regarding nonsubject imports and producers in nonsubject countries in order to conduct its analysis. 76 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal Steel, 542 F.3d at 879 (“Bratsk did not read into the antidumping statute a Procrustean formula for determining whether a domestic injury was ‘by reason’ of subject imports.”). 77 We provide in our discussion below a full analysis of other factors alleged to have caused any material injury experienced by the domestic industry. 78 Mittal Steel, 542 F.3d at 873; Nippon Steel Corp., 458 F.3d at 1350, citing U.S. Steel Group, 96 F.3d at 1357; S. Rep. 96-249 at 75 (“The determination of the ITC with respect to causation is ... complex and difficult, and is a matter for the judgment of the ITC.”). 79 The captive production provision, 19 U.S.C. § 1677(7)(C)(iv), as amended by the Trade Preferences Extension Act of 2015, provides: (iv) CAPTIVE PRODUCTION – If domestic producers internally transfer significant production of the domestic like product for the production of a downstream article and sell significant (Continued...) 18 provision does not apply to these investigations because hexamine is not the predominant input into the relevant downstream product, phenolic resins.80 The Commission adopted this reasoning, and concluded that the captive consumption provision did not apply.81 In the final phase of these investigations, Petitioner does not address this issue and presents arguments based on data for both the merchant market and the total market.82 GAFT argued in its prehearing brief that should the Commission determine not to apply the captive production provision in the final phase of these investigations, it should nevertheless continue to recognize the existence of a significant volume of captive production as a relevant condition of competition.83 The captive production provision can be applied only if, as a threshold matter, significant production of the domestic like product is internally transferred and significant production is sold in the merchant market. We determine that the threshold criterion for application of the captive production provision has been met. During the 2022 to 2024 period, Petitioner internally consumed between *** and *** percent of its annual hexamine production and sold between *** percent and *** percent of its annual production on the merchant market; its internal consumption and merchant market sales accounted for *** percent and *** percent, respectively, of its domestic production in interim 2025.84 We also determine that the first statutory criterion has been met. This criterion focuses on whether any of the domestic like product that is transferred internally for further processing production of the domestic like product in the merchant market, and the Commission finds that- (I) the domestic like product produced that is internally transferred for processing into that downstream article does not enter the merchant market for the domestic like product, and (II) the domestic like product is the predominant material input in the production of that downstream article. The SAA indicates that where a domestic like product is transferred internally for the production of another article coming within the definition of the domestic like product, such transfers do not constitute internal transfers for the production of a “downstream article” for purposes of the captive production provision. SAA at 853. 80 Bakelite Postconf. Br., EDIS Doc. No. (835594) (Oct. 24, 2024), Exh. 1, Answer to Staff Question 1 (at the first three unnumbered pages). 81 Preliminary Determinations, USITC Pub. 5563 at 19-20. 82 See, e.g., Tr. At 21-22 (Boninsegni) (“we saw declines in gross profit, operating income, and net income, whether measured by sales in the total market or merchant market”), 29 (Lutz) (“{t}he merchant market has been cited by the Saudi government as being the relevant metric, and it reflects the most direct competition between the domestic industry and subject imports, although the trends are almost identical in the total market”). 83 GAFT Prehearing Br. at 4, citing Galvanized Steel Wire from China and Mexico, Inv. Nos. 701- TA-479 and 731-TA-1183-1184 (Final), USITC Pub. 4323 (May 2012) at 16. 84 Calculated from CR/PR at Tables 3.3, 3.5, C.1. 19 is in fact sold on the merchant market.85 Petitioner, the sole domestic producer, reported that it did not divert hexamine that was to be internally consumed to the merchant market.86 In applying the second statutory criterion, we generally consider whether the domestic like product is the predominant material input into a downstream product by referring to its share of the raw material cost of the downstream product.87 In these investigations, Petitioner reported that hexamine accounts for *** percent of the value of the downstream powder phenolic resins it produced from hexamine.88 Thus, this criterion is not satisfied. Accordingly, as the second statutory criterion was not satisfied, we find that the captive production provision does not apply and will focus our analysis on the total hexamine market.89 2. Demand Considerations U.S. demand for hexamine is driven by demand for the downstream products for which it is used, namely phenolic polymers, munitions, rubbers and tires, petrochemicals, cleaning products, formaldehyde-based resins, resin-coated frack sands, rubber moldings, and shell sand.90 Demand for some of these products follow general economic conditions.91 85 See, e.g., Hot-Rolled Steel Products from Argentina and South Africa, Inv. Nos. 701-TA-404, 731-TA-898, 905 (Final), USITC Pub. 3446 at 15-16 (Aug. 2001); Certain Cold-Rolled Steel Products from Argentina, Brazil, China, Indonesia, Japan, Russia, Slovakia, South Africa, Taiwan, Turkey and Venezuela, Inv. Nos. 701-TA-393 and 731-TA-829-40 (Final) (Remand), USITC Pub. 3691 at 2 & n.19 (May 2004). 86 Bakelite U.S. producer questionnaire response at II-12; CR/PR at 3.9. 87 See generally, e.g., Polyethylene Terephthalate Film, Sheet and Strip from Brazil, China, Thailand, and the United Arab Emirates, Inv. Nos. 731-TA-1131-1134 (Final), USITC Pub. 4040 at 17 n.103 (October 2008); Polyethylene Terephthalate Film, Sheet, and Strip from India and Taiwan, Inv. Nos. 701-TA-415 and 731-TA-933-934 (Final), USITC Pub. 3518 at 11 & n.51 (June 2002). The Commission has construed “predominant” material input to mean the main or strongest element, and not necessarily a majority, of the inputs by value. See Polyvinyl Alcohol from Germany and Japan, Inv. Nos. 731-TA-1015-16 (Final), USITC Pub. 3604 at 15 n.69 (June 2003). 88 CR/PR at 3.10, Table 3.6. Hexamine, as a share of the total quantity of the downstream product, at *** percent, was even less than its share of the total value of the downstream product. Id. 89 While Petitioner’s internal consumption may still be considered as a condition of competition in the U.S. market, we observe that the merchant market and total market data generally show the same trends, including declining apparent U.S. consumption, a shift in market share from Petitioner and nonsubject imports to subject imports, and declines in Petitioner’s performance indicators over the POI. Compare CR/PR at Tables C.1 with C.2. Accordingly, we find that the industry’s internal consumption, as a condition of competition in the U.S. market, does not warrant separate considerations of merchant market data throughout the injury analysis. 90 CR/PR at 2.10. 91 CR/PR at 2.10. Petitioner reported that the U.S. market was ***, describing demand as ***. Id. at 2.11. Six of eight responding U.S. importers and all responding U.S. purchasers reported that the market was not subject to business cycles. Id. 20 Petitioner reported a *** trend in U.S. demand for hexamine during the POI.92 Most responding U.S. importers and U.S. purchasers reported that demand for hexamine did not change during the period.93 However, a plurality of purchasers reported a downward trend in demand for end use products.94 Apparent U.S. consumption by quantity decreased by *** percent between 2022 and 2024, from *** pounds in 2022 to *** pounds in 2023, and *** pounds in 2024.95 It was *** percent lower in January through March 2025 (“interim 2025”), at *** pounds, than in January through March 2024 (“interim 2024”), at *** pounds.96 3. Supply Considerations Petitioner was the largest supplier of hexamine to the U.S. market throughout the POI, followed by nonsubject imports in 2022 and 2023, and by cumulated subject imports in 2024 and in the interim periods.97 Petitioner produces hexamine at its Riegelwood, North Carolina facility.98 It argues that it reported substantial excess capacity throughout the POI and possessed sufficient practical capacity to supply the entire U.S. market.99 Its ability to respond to changes in demand is enhanced by *** but mitigated by its *** and ***.100 Petitioner was the largest source of supply of hexamine to the U.S. market throughout the POI. Its share of apparent U.S. consumption declined throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.101 It supplied a smaller share of the market in interim 2025, at *** percent, than in interim 2024, at *** percent.102 Petitioner’s practical capacity was constant at *** pounds during the full years of the POI, and *** pounds during the interim periods.103 Its production declined throughout the POI.104 Petitioner’s practical capacity utilization for hexamine was low and, driven by 92 CR/PR at Table 2.6. 93 CR/PR at Table 2.6. 94 CR/PR at Table 2.6. 95 CR/PR at Tables 4.8, C.1. 96 CR/PR at Tables 4.8, C.1. 97 CR/PR at Tables 4.8, C.1. 98 Bakelite U.S. producer questionnaire response at I-2a. 99 Tr. at 27 (Lutz). Information on the record indicates that Petitioner’s practical capacity exceeded apparent U.S. consumption in every segment of the POI. Id. 100 CR/PR at 2.7-2.8. 101 CR/PR at Tables 4.8, C.1. 102 CR/PR at Tables 4.8, C.1. 103 CR/PR at Tables 3.3, C.1. 104 CR/PR at Tables 3.3, C.1. 21 production trends, declined throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.105 Its practical capacity utilization was lower in interim 2025, at *** percent, than in interim 2024, at *** percent.106 Cumulated subject imports were the smallest source of supply to the U.S. market from 2022 and 2023, then the second largest source in 2024 and the interim periods.107 Cumulated subject imports’ share of apparent U.S. consumption increased throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.108 They supplied a larger share of the market in interim 2025, at *** percent, than in interim 2024, at *** percent.109 Nonsubject imports were the second largest source of supply to the U.S. market in 2022 and 2023, then the smallest source of supply in 2024 and the interim periods.110 Nonsubject imports’ share of apparent U.S. consumption declined throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.111 Nonsubject imports supplied less of the market in interim 2025, at *** percent, than in interim 2024, at *** percent.112 Russia accounted for almost all nonsubject imports in 2022 and 2023.113 Imports from Russia exited the U.S. market in 2023, after Russian authorities seized control of Metafrax Chemicals, the largest producer of hexamine in Russia.114 U.S. shipments of imported hexamine from Russia continued in 2024 and interim 2025 as importers sold off existing inventories.115 The remaining U.S. shipments of nonsubject imports in 2024 and interim 2025 were from Spain.116 105 CR/PR at Tables 3.3, C.1. 106 CR/PR at Tables 3.3, C.1. 107 CR/PR at Tables 4.8, C.1. 108 CR/PR at Tables 4.8, C.1. 109 CR/PR at Tables 4.8, C.1. 110 CR/PR at Tables 4.8, C.1. 111 CR/PR at Tables 4.8, C.1. 112 CR/PR at Tables 4.8, C.1. 113 CR/PR at Tables 4.8, C.1. As a share of apparent U.S. consumption by quantity, Russia accounted for *** percent in 2022, *** percent in 2023, and *** percent in 2024. Id. Nonsubject imports from Russia supplied less of the market in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. Nonsubject imports from all other sources supplied *** percent of the market in 2022, *** percent in 2023, and *** percent in 2024. Id. They supplied more of the market in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 114 CR/PR at 2.1. There is no indication that any specific sanctions apply to imports of hexamine from Russia other than the general application of column 2 duties. 115 CR/PR at 4.27 n.31. As a share of apparent U.S. consumption by quantity, U.S. shipments of nonsubject imports from Russia accounted for *** percent in 2024, and *** percent in interim 2025. Id. 116 CR/PR at 4.27 n.31 and 4.31 n.36. In addition to nonsubject imports from Russia, U.S. importers reported importing hexamine from *** during the POI. Id. at 2.9 n.12, Table 4.1 at Note, and 4.7 n.17. Petitioner stated that it was unaware of any hexamine producers in ***, and suggested that (Continued...) 22 Petitioner reported that it did not experience supply constraints during the POI.117 Four of seven responding U.S. importers and four of six responding U.S. purchasers reported that they had not experienced supply constraints during the POI.118 Three importers reported experiencing supply constraints in 2022, one reported constraints occurring in 2023, and two reported constraints occurring in 2024.119 One purchaser reported experiencing supply constraints from Petitioner between 2022 through 2024 due to “supply chain shortages,” and another reported constraints from subject foreign producers/exporters or importers between 2024 and 2025 due to capacity constraints.120 4. Substitutability and Other Conditions We find that there is a moderate-to-high degree of substitutability between domestically produced hexamine and hexamine imported from subject sources. As we noted above in section V.B, most responding market participants reported that subject imports from each subject country were *** interchangeable with domestically produced hexamine.121 In addition, most U.S. purchasers reported that domestically produced hexamine is comparable with imported hexamine on all factors except delivery time.122 With respect to delivery time, there were reported differences in delivery time with the majority of purchasers reporting that domestically produced hexamine is superior to subject imports with respect to delivery time.123 While respondents argue that there are non-price reasons for purchasing subject imports, they do not cite delivery time as a factor lowering the degree of substitutability between subject imports and domestically produced hexamine nor does Petitioner. Given the physical hexamine produced in Saudia Arabia was transshipped through *** to the U.S. market. Bakelite Posthearing Br. at Att. 1, pp.8-9. However, there is no indication that Commerce has made an affirmative transshipment finding, or even initiated such an investigation, with respect to imports of hexamine from ***, and ***. Id. at 4.7. As such, there is not sufficient record support for Petitioner’s assertion that hexamine produced in Saudia Arabia was being transshipped through *** to the U.S. market. Additionally, three U.S. purchasers reported that they had marketing/pricing knowledge of nonsubject imports from the Netherlands. Id. at 2.2 n.6. 117 CR/PR at 2.9. 118 CR/PR at 2.9. 119 CR/PR at Table 2.5. 120 CR/PR at 2.9 and Table 2.5. One of the two purchasers that reported experiencing supply constraints also reported constraints due to the filing of the petitions, indicating that their suppliers had “withheld shipments due to unknown petition penalties.” Id. at 2.9. 121 CR/PR at Tables 2.13-2.15. 122 CR/PR at Table 2.12. 123 CR/PR at Table 2.9. During the POI, Petitioner reported selling *** its commercial U.S. shipments of hexamine from inventory, with lead times of *** days. CR/PR at 2.14. Conversely, responding U.S. importers reported that *** their commercial U.S. shipments of hexamine were produced-to-order, with lead times averaging *** days. Id. 23 similarities observed in these investigations124 between domestically produced hexamine and subject imports and the responses of market participants in these final phase investigations concerning the interchangeability of domestic and subject hexamine, we find that the degree of substitutability is closer to a high degree of substitutability despite reported differences in delivery time. Moreover, as we discuss in more detail in section VI.E below, we are not convinced that Petitioner’s role as a phenolic resins producer is a significant non-price factor that affected its ability to compete for sales of hexamine during the POI. We also find that price is an important factor in purchasing decisions for hexamine. Price/cost, quality, and availability/supply were responding purchasers’ top three most often cited purchasing factors.125 Market participants generally reported that there are sometimes significant non-price factors.126 Petitioner reported selling most of its hexamine through *** and a substantial share through *** in 2024.127 U.S. importers reported selling *** their hexamine in the spot market.128 Petitioner reported that it supplied hexamine pursuant to two long-term contracts during the POI, one of which expired on *** and was not renewed.129 These contracts each contain a price adjustment addendum requiring the seller to adjust prices on a quarterly basis to track movements in methanol and ammonia price indices.130 124 CR/PR at Tables 2.10, 2.12, 2.13. 125 CR/PR at Table 2.8. Responding purchasers identified quality as the most frequently cited first-most important factor (3 firms), followed by price/cost (4 firms), and availability/supply (3 firms). Id. Price was the most frequently reported second-most important factor (four firms) followed by availability/supply as the most frequently reported third-most important factor (4 firms apiece). Id. 126 CR/PR at Tables 2.16-2.18. Petitioner reported that non-price differences were *** significant with respect to the domestic like product and subject imports from China, India, and Saudi Arabia, and *** significant between U.S.-produced hexamine and subject imports from Germany. Id. at Table 2.16. Responding U.S. importers and U.S. purchasers generally reported that non-price differences were *** significant with respect to the domestic like product and subject imports from each subject country. Id. at Tables 2.17-2.18. U.S. importer *** identified tariff and quality concerns as significant nonprice factors with respect to subject imports from China, and supply availability and transportation as significant nonprice factors with respect to subject imports from Germany. Id. at 2.21. 127 CR/PR at Table 5.3. 128 CR/PR at Table 5.3. 129 Bakelite Posthearing Br. at 8-10, Exh. 1, Answers to Commission Questions, at 24. According to Petitioner, the *** remaining contract represented *** percent of its sales in 2024 by volume. Id. 130 Bakelite Posthearing Br., Exh. 6 (containing the supply contract with ***); Bakelite Prehearing Br., Exh. 4, Att. 5 (containing the supply contract with ***). 24 The primary raw materials used to produce hexamine are ammonia and formaldehyde.131 Prices for ammonia peaked in the second quarter of 2022, declined to a period low in the third quarter of 2023, then stabilized in the third quarter of 2024 at a level approximately half of that observed at the start of the POI.132 Additionally, Petitioner’s formaldehyde costs declined from $*** in 2022 to $*** in 2023, and $*** in 2024.133 They were lower in interim 2025, at $***, than in interim 2024, at $***.134 Raw material costs were the largest component of the Petitioner’s cost of goods sold (“COGS”) during the 2022 to 2024 calendar year period.135 As a ratio to total net sales, Petitioner’s raw material costs declined from *** percent in 2022 to *** percent in 2023, *** percent in 2024, and were lower in interim 2025, at *** percent, than in interim 2024, at *** percent.136 Hexamine is imported into the United States under HTSUS statistical reporting number 2933.69.50 at a general duty rate of 6.3 percent ad valorem.137 Effective May 10, 2019, hexamine from China became subject to additional duties of 25 percent ad valorem pursuant to section 301 of the Trade Act of 1974 (19 U.S.C. § 2411 et seq.).138 Effective March 4, 2025, imports of hexamine from China are subject to additional duties of 20 percent ad valorem under the International Emergency Economic Powers Act (50 U.S.C. § 1701 et seq.) (“IEEPA”).139 Moreover, effective May 14, 2025, imports of hexamine from China are subject to an additional 10 percent ad valorem duty under IEEPA.140 Effective April 5, 2025, hexamine from Saudi Arabia is subject to an additional 10.0 percent ad valorem duty under IEEPA.141 Effective August 7, 2025, hexamine from Germany is subject to an additional 8.7 percent ad valorem duty under IEEPA.142 Effective that same day, 131 CR/PR at 5.1. 132 CR/PR at Table 5.1. Petitioner reported that formaldehyde accounted for approximately *** of its raw material costs in 2024, with ammonia accounting for the remaining ***. Id. at 5.1. 133 Bakelite U.S. producer questionnaire response at III-9a. 134 Bakelite U.S. producer questionnaire response at III-9a. 135 CR/PR at Table 6.1. Raw materials as a share of COGS declined from *** percent in 2022 to *** percent in 2024 and were *** percent in interim 2025 compared with *** percent in interim 2024. Id. 136 CR/PR at Table 6.1. 137 CR/PR at 1.11. 138 CR/PR at 1.11. 139 See Further Amended Notice of Implementation of Additional Duties on Products of the People's Republic of China Pursuant to the President's Executive Order 14195, Imposing Duties To Address the Synthetic Opioid Supply Chain in the People's Republic of China, 90 Fed. Reg. 11,426 (Mar. 6, 2025); CR/PR at 1.11. 140 CR/PR at 1.12. 141 CR/PR at 1.11. 142 CR/PR at 1.11. 25 hexamine from India is subject to an additional 25.0 percent ad valorem duty under IEEPA.143 144 C. Volume of Subject Imports Section 771(7)(C)(i) of the Tariff Act provides that the “Commission shall consider whether the volume of imports of the merchandise, or any increase in that volume, either in absolute terms or relative to production or consumption in the United States, is significant.”145 The volume of cumulated subject imports increased by 121.2 percent from 2022 to 2024, from 1.9 million pounds in 2022 to 2.1 million pounds in 2023 and 4.1 million pounds in 2024.146 It was 1.2 percent higher in interim 2025, at 774,000 pounds, than in interim 2024, at 765,000 pounds.147 Cumulated subject imports’ market share increased by *** percentage points by quantity in this period, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.148 It was *** percentage points higher in interim 2025, at *** percent, than in interim 2024, at *** percent.149 We find that the volume of cumulated subject imports and the increase in volume were significant in absolute terms and relative to consumption in the United States during the POI. D. Price Effects of the Subject Imports Section 771(7)(C)(ii) of the Tariff Act provides that, in evaluating the price effects of the subject imports, the Commission shall consider whether: (I) there has been significant price underselling by the imported merchandise as compared with the price of domestic like products of the United States, and (II) the effect of imports of such merchandise otherwise depresses prices to a significant degree or prevents price increases, which otherwise would have occurred, to a significant degree.150 143 CR/PR at 1.11-1.12. 144 The record for the antidumping and countervailing duty investigations with respect to hexamine from China closed on August 11, 2025. Accordingly, the record does not include any additional duties announced after this date. 145 19 U.S.C. § 1677(7)(C)(i). 146 CR/PR at Table 4.2. 147 CR/PR at Table 4.2. 148 CR/PR at Tables 4.8, C.1. 149 CR/PR at Tables 4.8, C.1 150 19 U.S.C. § 1677(7)(C)(ii). 26 As previously discussed in section VI.B.4 above, we find that the domestic like product and cumulated subject imports have a moderate-to-high degree of substitutability, and that price is an important factor in purchasing decisions. The Commission collected quarterly quantity and f.o.b. value pricing data on sales of three types of hexamine shipped to unrelated U.S. customers during the POI.151 One U.S. producer and seven U.S. importers provided usable pricing data for sales of the requested products, although not all firms reported pricing for all products for all quarters.152 The pricing data reported by these firms accounted for 100.0 percent of the U.S. producer’s U.S. commercial shipments of domestically produced hexamine in 2024, virtually all of U.S. shipments of subject imports from China, Germany, and Saudi Arabia, and *** percent of U.S. shipments of subject imports from India.153 Subject imports undersold the domestic like product in 42 of 61 quarterly comparisons, or 68.9 percent of the time, with underselling margins ranging between 1.7 and 58.4 percent, and averaging 23.8 percent.154 Subject imports oversold the domestic like product in the remaining 19 quarterly comparisons, or 31.1 percent of the time, with overselling margins ranging between 0.3 and 393.3, and averaging 58.0 percent.155 The volume of subject import sales in quarters with underselling was *** pounds, representing 77.8 percent of the total volume of subject imports in the pricing products, compared to *** pounds in the quarters with overselling, representing 22.2 percent of the total.156 The frequency of underselling and volume of subject imports associated with underselling increased at the end of the POI. Subject imports undersold the domestic like product in 19 out of 26 instances in 2024 and all six available instances in interim 2025, and the volume of reported cumulated subject import sales in quarterly comparisons in which there was underselling increased from *** pounds in 2022, to *** pounds in 2023, and *** pounds in 2024.157 Further, the volume of subject imports that 151 CR/PR at 5.4. The three pricing products are: Product 1. – “Unstabilized” hexamine, with a hexamine content above 99% by weight; Product 2. – “Stabilized” hexamine, with a hexamine content above 95% but less than or equal to 99% by weight; and Product 3. – “Stabilized” hexamine, with a hexamine content equal to or below 95% by weight. Id. 152 CR/PR at 5.5. 153 CR/PR at 5.5. Commercial shipments do not include the U.S. producer’s captive consumption of a portion of its production of hexamine. Pricing coverage is based on U.S. shipments reported in the questionnaires. 154 CR/PR Table 5.10. 155 CR/PR Table 5.10. 156 Derived from CR/PR Table 5.10. 157 CR/PR at Table 5.12. 27 undersold the domestic like product in the single quarter of interim 2025, at *** pounds, is nearly equivalent to the total amount of underselling in the full years of 2022 and 2023.158 Thus, the quarterly price comparison data show that subject imports predominantly and increasingly undersold the domestic like product in terms of the number of quarterly comparisons and in terms of volume. We have also considered information regarding lost sales. Four of six U.S. purchasers reported purchasing subject imports instead of the domestic product during the POI.159 All four purchasers reported that subject imports were priced lower than the domestic like product, with all four reporting that they purchased subject imports instead of the domestic like product based on price, accounting for *** pounds of hexamine. This total represented *** percent of total reported purchases of subject imports over the full years of the POI (*** pounds) and *** percent of the total volume of purchases of hexamine from all sources reported by purchasers over the full years of the POI (***).160 The other two purchasers reported that price was not a primary reason for purchasing subject imports instead of the domestic product.161 162 Based on the moderate-to-high degree of substitutability between cumulated subject imports and the domestic like product, the importance of price in purchasing decisions, and the prevalence of underselling and lost sales, we find that subject imports significantly undersold the domestic like product. Subject import underselling enabled subject imports to not only gain market share from Petitioner, but also prevented Petitioner from gaining any of the market share ceded by withdrawing nonsubject imports from Russia despite Petitioner having the capacity to supply substantial additional volume of a moderately-to-highly substitutable product. During the 2022 to 2024 period, Petitioner’s market share declined by *** percentage points, from *** percent in 2022 to *** percent in 2024, which went entirely to subject 158 Derived from CR/PR at Table 5.12. 159 CR/PR at Table 5.15. 160 Derived from CR/PR at Tables 5.14, 5.15. 161 CR/PR at Table 5.15. 162 Petitioner appended e-mail correspondence with customers showing that it was engaged in negotiations to conclude long-term supply contracts with U.S. purchasers *** and ***, among others, and renew a supply contract with *** during the POI. Bakelite Prehearing Br., Exh. 4. Although Bakelite characterizes this correspondence as “intelligence regarding subject import prices,” Bakelite Posthearing Br., Exh. 1 at 9, none of these emails explicitly identify subject merchandise as a lower-priced alternative to domestically produced hexamine. Moreover, *** was the only purchaser to report purchasing *** pounds of lower-priced subject imports instead of the domestic like product based primarily on price. CR/PR at Table 5.15. *** did not report purchasing subject imports instead of the domestic like product, whereas *** did not submit a U.S. purchaser questionnaire response. Id. They nevertheless demonstrate that Petitioner faced pressure from purchasers to lower prices that were credible enough to result in the termination of negotiations followed by instances of lost sales to subject imports. 28 imports.163 While interim 2025 data is confined to a single quarter, the data was consistent with the increasing underselling and market share loss trends witnessed during the 2022 to 2024 period, with universal underselling that caused Petitioner to lose *** percentage points of market share to subject imports.164 Further, as discussed above, nonsubject imports from Russia almost completely exited the U.S. market by the end of 2023. In 2022, imports of hexamine from Russia constituted almost all nonsubject imports, and accounted for *** percent of the market, which declined to *** percent in 2023 and *** percent in 2024.165 Subject imports took *** of the market share ceded by imports from Russia, with their share of apparent U.S. consumption nearly *** from *** percent in 2023 to *** percent in 2024 – nonsubject imports from Spain picked up the remaining share of the market ceded by nonsubject imports from Russia.166 By interim 2025, subject imports market share grew to *** percent.167 We have also considered whether cumulated subject imports depressed or suppressed prices to a significant degree. Between the first quarter of 2022 and the first quarter of 2025, reported prices for domestically produced products 1 through 3 were, respectively, ***, ***, and *** percent higher at the end of the POI than at the beginning.168 Prices for products 1 and 2 imported from Germany, the only source for which pricing data were available throughout the POI, increased by *** and *** percent, respectively.169 Indexed data also show that, on a cumulated basis, subject import prices for products 1 and 2 fluctuated over the POI but increased overall by *** and *** percent, respectively.170 We note that one of six responding U.S. purchasers reported that the U.S. producer lowered its prices by *** percent during the POI to compete with lower-priced subject imports.171 163 CR/PR at Tables 4.8, C.1. 164 CR/PR at Tables 5.12, C.1. 165 CR/PR at Tables 4.8, C.1. As previously discussed, U.S. shipments of nonsubject imports from Russia accounted for just *** percent of apparent U.S. consumption in interim 2025. Id. at 4.27 n.31. 166 CR/PR at Tables 4.8, C.1. 167 CR/PR at Tables 4.8, C.1. As discussed in section VI.E below, we disagree with respondents’ contention that subject imports’ gain in market share is accounted for by non-price reasons. 168 CR/PR Tables 5.7-5.8. 169 CR/PR at Table 5.7. 170 CR/PR at Table 5.9. There were limited subject imports reported for pricing product 3. Id. at Table 5.6. 171 CR/PR at Table 5.17. 29 Petitioner’s average ratio of COGS to net sales declined from 2022 to 2024.172 The decline in the COGS-to-net-sales ratio during this period was primarily driven by total raw material costs, which declined from $*** in 2022 to $*** in 2024.173 Petitioner’s unit COGS in the total market decreased irregularly from 2022 to 2024.174 The industry’s net sales average unit values (“AUVs”) also decreased irregularly during this period.175 In sum, we find that cumulated subject imports significantly undersold the domestic like product, which not only prevented Petitioner from gaining any of the *** percentage points of market share ceded by nonsubject imports from Russia from 2022 to 2024 but also resulted in Petitioner losing sales and market share to subject imports during the period. We accordingly find that the cumulated subject imports had significant price effects.176 E. Impact of the Subject Imports177 Section 771(7)(C)(iii) of the Tariff Act provides that examining the impact of subject imports, the Commission “shall evaluate all relevant economic factors which have a bearing on 172 CR/PR at Tables 6.1, C.1. Petitioner’s COGS-to-net-sales ratio declined from *** percent in 2022 to *** percent in 2023, and *** percent in 2024. Id. It was slightly higher in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 173 CR/PR at Table 6.1. Total raw material costs were lower in interim 2025, at $*** than in interim 2024, at $***. Id. 174 CR/PR at Table 6.1. Petitioner’s unit COGS declined from $*** in 2022 to $*** in 2023, then increased to $*** in 2024. Id. It was higher in interim 2025, at $***, than in interim 2024, at $***. Id. 175 CR/PR at Table 6.1. Petitioner’s net sales AUV declined from $*** in 2022 to $*** in 2023, then increased to $*** in 2024. Id. It was higher in interim 2025, at $***, than in interim 2024, at $***. Id. 176 GAFT contends, citing Grain-Oriented Electrical Steel from Germany, Japan, and Poland (“GOES”), that the Commission should reach the same conclusion on the underselling record to find that that “{n}otwithstanding the observed underselling, there were not significant changes in the domestic industry’s market share.” GAFT Prehearing Br. at 18, citing Grain-Oriented Electrical Steel from Germany, Japan, and Poland, Inv. Nos. 731-TA-1233, 1234, and 1236 (Final), USITC Pub. 4491 (Sep. 2014) (“GOES”) at 24. GOES is distinguishable from these investigations. First, the market share shift the Commission found not to be significant in GOES was smaller than the market share shift observed in these investigations. Second, no major nonsubject suppliers of GOES vacated the U.S. market in those investigations, affording domestic and subject suppliers a unique opportunity to substantially increase their sales and market share. Third, the Commission found that the decline in production reported by the domestic industry was entirely attributable to a decline in export shipments. See GOES, USITC Pub. 4491 (Sep. 2014) at 29-30. Exports do not explain Petitioner’s declining production here. 177 The statute instructs the Commission to consider the “magnitude of the dumping margin” in an antidumping proceeding as part of its consideration of the impact of imports. 19 U.S.C. § 1677(7)(C)(iii)(V). In its final determination of sales at LTFV, Commerce found dumping margins of 405.19 percent for imports from the China-wide entity. Hexamethylenetetramine From the People's Republic of China: Final Affirmative Determination of Sales at Less Than Fair Value, 90 Fed. Reg. 33,922 (Continued...) 30 the state of the industry.”178 These factors include output, sales, inventories, capacity utilization, market share, employment, wages, productivity, gross profits, net profits, operating profits, cash flow, return on investment, return on capital, ability to raise capital, ability to service debts, research and development, and factors affecting domestic prices. No single factor is dispositive, and all relevant factors are considered “within the context of the business cycle and conditions of competition that are distinctive to the affected industry.”179 Petitioner’s trade indicators generally declined during the POI. As discussed above in section VI.B.2, Petitioner’s practical capacity was constant throughout the POI.180 Its production declined throughout the POI.181 Resultingly, Petitioner’s practical capacity utilization for hexamine production was relatively low and declined throughout the POI.182 Several of Petitioner’s employment indicators were stable or improved during the POI. Its number of production-related workers (“PRWs”),183 total hours worked,184 hours worked per PRW,185 and unit labor costs186 were virtually unchanged during the period. Wages paid and (July 18, 2025); CR/PR at Table 1.4. We take into account in our analysis the fact that Commerce has made final findings that all subject producers in China are selling subject imports in the United States at LTFV. In addition to this consideration, our impact analysis has considered other factors affecting domestic prices. Our analysis of the significant underselling of subject imports, described in both the price effects discussion and below, is particularly probative to an assessment of the impact of the subject imports. 178 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations, the Commission considers, in addition to imports, other factors that may be contributing to overall injury. While these factors, in some cases, may account for the injury to the domestic industry, they also may demonstrate that an industry is facing difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.”). 179 19 U.S.C. § 1677(7)(C)(iii). This provision was amended by the Trade Preferences Extension Act of 2015, Pub. L. 114-27. 180 CR/PR at Tables 3.3, C.1. Petitioner’s practical capacity was constant at *** pounds during the full years of the POI and *** pounds during the interim periods. Id. 181 CR/PR at Tables 3.3, C.1. Petitioner’s production declined from *** pounds in 2022 to *** in 2023, and *** pounds in 2024. Id. It was lower in interim 2025, at *** pounds, than in interim 2024, at *** pounds. Id. 182 CR/PR at Tables 3.3, C.1. Petitioner’s practical capacity utilization declined from *** percent in 2022 to *** percent in 2023, and *** percent in 2024. Id. It was lower in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 183 CR/PR at Tables 3.8, C.1. The number of PRWs was *** throughout the POI. Id. 184 CR/PR at Tables 3.8, C.1. Petitioner reported *** total hours worked in each full year of the POI, and *** total hours worked during the interim periods. Id. 185 CR/PR at Table 3.8. Petitioner reported *** hours worked per PRW in each full year of the POI, and *** hours worked per PRW during the interim periods. Id. 186 CR/PR at Tables 3.8, C.1. On a dollars per pound basis, unit labor costs were $*** in each segment of the POI, except for interim 2025, where they slightly increased to $***. Id. 31 hourly wages both increased during the POI.187 Petitioner’s productivity, measured on a pounds per hour basis, was the only employment-related indicator to decline over the period.188 Petitioner’s total U.S. shipments by quantity declined throughout the POI.189 Additionally, as discussed in section VI.B.3 above, its market share declined throughout the POI.190 Petitioner’s end-of-period inventories increased irregularly during the POI.191 As a ratio to total shipments, its end-of-period inventories increased during the POI.192 Several of Petitioner’s financial indicators deteriorated during the POI although it remained profitable.193 Petitioner’s net sales revenue declined throughout the POI.194 Its gross 187 CR/PR at Tables 3.8, C.1. Petitioner reported wages paid of $*** in 2022 and 2023, and $*** in 2024. Id. Petitioner’s wages paid were higher in interim 2025, at $***, than in interim 2024, at $***. Id. 188 CR/PR at Tables 3.8, C.1. Petitioner’s productivity declined from *** in 2022 to *** in 2023, and *** in 2024. Id. Its productivity was lower in interim 2025, at ***, than in interim 2024, at ***. Id. 189 CR/PR at Tables 3.4, C.1. Petitioner’s total U.S. shipments declined from *** pounds in 2022 to *** pounds in 2023, and *** pounds in 2024. Id. They were higher in interim 2025, at *** pounds, than in interim 2024, at *** pounds. Id. 190 CR/PR at Tables 4.8, C.1. Petitioner’s share of apparent U.S. consumption declined from *** percent in 2022 to *** percent in 2023, and *** percent in 2024. Id. It was lower in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 191 CR/PR at Tables 3.7, C.1. Petitioner’s end-of-period inventories declined from *** pounds in 2022 to *** pounds in 2023, then increased to *** pounds in 2024. Id. They were higher in interim 2025, at *** pounds, than in interim 2024, at *** pounds. Id. 192 CR/PR at Tables 3.7, C.1. Petitioner’s ratio of end-of-period inventories to total shipments increased from *** percent in 2022 and 2023 to *** percent in 2024. Id. It was higher in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 193 The fact that the domestic industry was profitable during the POI does not preclude an affirmative determination because the record demonstrates that the domestic industry would have performed materially better if subject imports had not significantly increased, gained share from the domestic industry, and prevented it from capturing market share when nonsubject imports from Russia largely exited the market. See 19 U.S.C. § 1677(7)(J) (the existence of a profitable industry, or one whose performance has improved, does not foreclose an affirmative material injury determination). 194 CR/PR at Tables 6.1, C.1. Petitioner’s net sales revenues declined from $*** in 2022 to $*** in 2023, and $*** in 2024. Id. They were lower in interim 2025, at $***, than in interim 2024, at $***. Id. 32 profits declined irregularly during this period.195 Its operating196 and net income197 indicators mostly declined throughout the POI.198 Its ratio of operating income to net sales fluctuated within a narrow band during the POI,199 whereas its ratio of net income to net sales declined.200 Petitioner’s capital expenditures increased irregularly during the POI.201 Its research and development (“R&D”) expenditures also increased irregularly during the period.202 Petitioner’s net assets declined throughout the POI.203 Its return on assets declined irregularly during this period.204 Finally, Petitioner reported negative effects on investment due to subject imports.205 As discussed above, significant volumes of cumulated subject imports undersold the domestic like product to a significant degree, which not only prevented Petitioner from gaining any of the *** percentage points of market share ceded by nonsubject imports from Russia from 2022 to 2024 but also resulted in Petitioner losing sales and market share to increasing subject imports during the period. Consequently, Petitioner’s production, capacity utilization, productivity, and U.S. shipments were all lower than they would otherwise have been, and its end-of-period-inventories higher than they would otherwise have been, during the POI had the 195 CR/PR at Tables 6.1, C.1. Petitioner’s gross profits declined from $*** in 2022 to $*** in 2023, then increased slightly to $*** in 2024. Id. They were lower in interim 2025, at $***, than in interim 2024, at $***. Id. 196 CR/PR at Tables 6.1, C.1. Petitioner’s operating income declined from $*** in 2022 to $*** in 2023 and 2024. Id. Its operating income was lower in interim 2025, at $***, than in interim 2024, at $***. Id. 197 CR/PR at Tables 6.1, C.1. Petitioner’s net income declined from $*** in 2022 to $*** in 2023, and $*** in 2024. Id. Its net income was lower in interim 2025, at $***, than in interim 2024, at $***. Id. 198 CR/PR at Tables 6.1, C.1. 199 CR/PR at Tables 6.1, C.1. Petitioner’s ratio of operating income to net sales increased from *** percent in 2022 to *** percent in 2023, and *** percent in 2024. Id. It was lower in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 200 CR/PR at Tables 6.1, C.1. Petitioner’s ratio of net income to net sales declined from *** percent in 2022 to *** percent in 2023, and *** percent in 2024. Id. It was lower in interim 2025, at *** percent, than in interim 2024, at *** percent. Id. 201 CR/PR at Tables 6.7, C.1. Petitioner’s capital expenditures declined from $*** in 2022 to $*** in 2023, then increased to $*** in 2024. Id. They were higher in interim 2025, at $***, than in interim 2024, at $***. Id. 202 CR/PR at Tables 6.7, C.1. Petitioner’s R&D expenditures declined from $*** to $***, then increased to $*** in 2024. Id. They were unchanged, at $***, during the interim periods. Id. 203 CR/PR at Tables 6.7, C.,1. Petitioner’s net assets declined from $*** in 2022 to $*** in 2023, and $*** in 2024. Id. 204 CR/PR at Table 6.7. Petitioner’s return on assets declined from *** percent in 2022 to *** percent in 2023, then increased to *** percent in 2024. Id. 205 CR/PR at Tables 6.9, 6.10. 33 significant and increasing volume of lower priced subject imports not gained a substantial share of the U.S. market. Petitioner’s declining output and productivity indicators translated directly into reductions in its financial performance indicators, including its net sales revenues, gross profits, operating income, net income, and net income margin. Thus, we find that cumulated subject imports had a significant adverse impact on Petitioner. We are unpersuaded by respondents’ argument that the peculiarities of the U.S. hexamine market attenuated competition between subject imports and Petitioner during the POI. Respondents argue that the share of the market supplied by imports as a whole was largely consistent, as U.S. purchasers hesitated to source more hexamine from Petitioner as it is allegedly a monopolist with a preference for long-term supply contracts that purportedly experienced supply constraints during the POI and, in certain instances, is in direct competition with its customers in downstream markets for phenolic resins.206 Respondents also contend, unconvincingly, that long-term supply contracts insulated Petitioner from competition with imports, and emphasize that the emergence of Spain as a nonsubject source at the end of the POI suggests that nonsubject sources were poised to replace imports from Russia in the market.207 We observe that the total market share represented by U.S. shipments of imports from all sources increased throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.208 It was higher in interim 2025, at *** percent, than in interim 2024, at *** percent.209 The increase in the total market share of imports from all sources was driven by U.S. shipments of cumulated subject imports, which increased their share of supply, gaining the market share ceded by nonsubject imports from Russia as they receded from the U.S. market and also gaining market share from domestic producers such that total imports represented a higher share of the market at the end of the POI than the beginning.210 We also find that the record undermines respondents’ contention that subject imports were pulled into the market for non-price reasons. Subject imports rapidly gained market share during the POI by significantly underselling the domestic like product, and the prevalence of underselling in the pricing data indicate that subject imports did not command a price premium 206 GAFT Posthearing Br. at 2-7. Along similar lines, KCIL contends that subject imports had no adverse impact to Petitioner’s operations, as imports from India were pulled into the U.S. market to meet the supply gap caused by Petitioner’s purported inability to meet demand in the U.S. market. KCIL Prehearing Br. at 1-7. 207 GAFT Final Comments at 3-10. 208 CR/PR at Tables 4.8, C.1. 209 CR/PR at Tables 4.8, C.1. 210 CR/PR at Tables 4.8, C.1. 34 in the market, which would be expected if respondents’ contentions as to nonprice reasons for purchasing subject imports over domestically produced hexamine were correct.211 In addition, the responses of U.S. purchasers concerning the importance of price in purchasing decisions, summarized in section VI.B.4 above, undermines respondents’ contention that the gain in subject imports’ market share is accounted for by non-price reasons.212 Insofar as respondents contend that Petitioner was unable or unwilling to supply hexamine to U.S. purchasers during the POI, we observe that the record does not support a finding that Petitioner was significantly constrained in its ability to supply the market during the period. First, it operated at relatively low and decreasing capacity utilization during the POI. As we discussed in Section VI.B.3 above, most market participants did not report supply constraints during the POI, with only one of six responding U.S. purchasers reporting supply constraints experienced with Petitioner from 2022 to 2024.213 Second, while purchaser *** reported sourcing hexamine from subject sources as “***,” the record does not support that this accounts for subject imports’ growth in market share over the POI. Information provided by Petitioner shows that it was engaged in supply discussions with both *** and ***, another U.S. producer of phenolic resins, during the POI.214 *** even reported that it purchased *** pounds of subject imports instead of the domestic like product primarily due to price.215 The record as a whole thus does not support that subject imports were pulled into the market due to purchasers’ reluctance to purchase from Petitioner on account of competition with Bakelite in the downstream phenolic resins market. And, to the extent that purchasers valued the importance of diversifying supply sources, maintaining a diversity of supply sources did not require purchasers to replace Russian imports entirely with subject imports or to gain market share from the domestic producer and to do so at increasing rates of underselling. Last, we observe that, while Petitioner sold most of its hexamine through long-term supply contracts, it reported a substantial portion of sales (*** percent) in the spot market and had increasing end- of-period inventories that it could have directed towards the spot market.216 Indeed, 211 See generally CR/PR at Tables 5.4-5.6, 5.12. 212 See CR/PR at Table 2.8. 213 CR/PR at Table 2.5. This purchaser, ***, accounted for *** percent of purchases of hexamine during the POI. Derived from id., at Table 5.14. 214 See Bakelite Prehearing Br., Exh. 4. 215 CR/PR at Table 5.15. 216 CR/PR at Tables 3.7, 5.3. Petitioner reported that it sold *** percent of its hexamine products on the spot market in 2024. Id. at Table 5.3. Its inventories in 2024, of *** pounds, were equivalent to *** percent of its total shipments that year. Id. at Table 3.7. Moreover, notwithstanding Petitioner’s stated preference for long-term supply contracts, Tr. at 31 (Lutz), the record lacks any (Continued...) 35 Petitioner’s appended e-mail correspondence with customers shows that it was willing to make spot sales to customers.217 Accordingly, respondents’ argument that the peculiarities of the U.S. hexamine market attenuated competition between subject imports and Petitioner is unpersuasive. We are also not convinced by respondents’ contention that Petitioner’s long-term supply contracts insulated it from competition with subject imports during the POI. Petitioner reported that it maintained *** such contracts during the POI, one of which was not renewed.218 It provided evidence that *** purchased hexamine products at a level *** percent below contractually obligated volume when it terminated its supply contract with Petitioner.219 While the remaining contract accounted for a substantial portion of Petitioner’s sales in 2024 by volume, there are no guarantees that it will be renewed. Customer correspondence provided by Petitioner demonstrates the precarious nature of long-term supply negotiations undertaken by it during the period with seven customers, most of which collapsed.220 Moreover, *** contracts in operation during the POI required Petitioner to adjust prices on a quarterly basis to track movements in raw material prices.221 The relative paucity of these contracts and their ties to raw material prices, which generally declined during the POI, and the substantial volume of confirmed lost sales, undermines respondents’ contention that contracts insulated Petitioner from competition.222 Additionally, the available record information belies respondents’ contention that nonsubject imports could have filled the supply gap vacated by Russia’s exit from the market towards the end of the POI. Nonsubject imports from sources other than Russia were available in small quantities during the POI.223 The record, accordingly, does not show that nonsubject indication that Petitioner refused to sell hexamine to U.S. purchasers on a spot market basis during the POI. 217 Bakelite Prehearing Br., Exh. 4. 218 Bakelite Posthearing Br. at 8-10, Exh. 1, Answers to Commission Questions, at 24. According to Petitioner, the *** remaining contract represented *** percent of its sales in 2024 by volume. Id. 219 Bakelite Posthearing Br. at 9-10; Bakelite Prehearing Br., Exh. 4, Att. 1. 220 See generally Bakelite Prehearing Br., Exh. 4. 221 Bakelite Posthearing Br., Exh. 6; Bakelite Prehearing Br., Exh. 4, Att. 5. These adjustments include downward adjustments pursuant to certain “price events” specified in both agreements. Id. 222 As we discussed in section VI.D above, confirmed lost sales accounted for *** percent of total reported purchases of subject imports over the full years of the POI (*** pounds) and *** percent of the aggregate *** pounds of imports or purchases of hexamine reported by purchasers during the POI. Derived from CR/PR at Tables 5.14, 5.15. 223 CR/PR at Tables 4.8, C.1. Insofar as GAFT contends that nonsubject imports from ***, the Netherlands, and *** could have replaced nonsubject imports from Russia in the U.S. market, the limited available information on nonsubject countries in the final phase of these investigations indicates (Continued...) 36 imports from sources other than Russia were available to absorb most of the *** percentage points of market share ceded by nonsubject imports from Russia during the POI. Moreover, although based on minimal volumes over the POI, U.S. shipment AUVs for nonsubject imports from sources other than Russia were substantially above those of Petitioner’s U.S. shipments of domestic hexamine throughout the POI.224 The record thus does not demonstrate that nonsubject imports could have replaced subject imports without any beneficial effect inuring to Petitioner. Moreover, whether nonsubject imports could have gained market share towards the end of the POI does not change the injurious impact of subject import pricing on Petitioner. We have also considered whether there are other factors that may have had an adverse impact on Petitioner during the period of investigation to ensure that we are not attributing injury from such other factors to the cumulated subject imports. Neither demand trends nor nonsubject imports explain Petitioner’s declining performance. While apparent U.S. consumption declined by *** percentage points during the 2022 to 2024 calendar year period and was *** percentage points lower in interim 2025 than in interim 2024, Petitioner would have performed substantially better if increasing volumes of low-priced subject imports had not gained a substantial share of the U.S. market during the POI.225 Nor do demand trends explain the market share shifts from Petitioner to subject imports observed during the POI.226 Nonsubject imports generally receded from the market during the POI, driven by Russia’s exit in 2023. Their share of apparent U.S. consumption declined throughout the POI, from *** percent in 2022 to *** percent in 2023, and *** percent in 2024.227 They supplied less of the market in interim 2025, at *** percent, than in interim 2024, at *** percent.228 The that the nonsubject industries in *** and the Netherlands that produce heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure, a product category that includes hexamine, are not among the top exporters for that product category. Id. at Table 7.14. Export information for *** is not displayed in Table 7.14, indicating that it is not a significant exporter of heterocyclic compounds. 224 CR/PR at Table C.1. 225 CR/PR at Tables 4.8, C.1. 226 As discussed above in sections VI.C and VI.D, Petitioner lost *** percentage points of market share from 2022 to 2024 to subject imports and supplied *** percentage points less of the market in interim 2025 than in interim 2024 as subject imports continued to increase. CR/PR at Tables 4.8, C.1. GAFT asserts that Petitioner’s declining U.S. shipments tracked consumption trends during the POI. GAFT Prehearing Br. at 24-25. However, Petitioner’s U.S. shipments declined by *** percent from 2022 to 2024, and were *** percent lower in interim 2025 than in interim 2024. CR/PR at Tables 3.4, C.1. Petitioner’s U.S. shipments thus declined at steeper rates than apparent U.S. consumption during the POI.227 CR/PR at Tables 4.8, C.1. 228 CR/PR at Tables 4.8, C.1. 37 record also indicates that the AUVs of U.S. shipments of nonsubject imports were higher than the AUVs of U.S. shipments of cumulated subject imports and the domestic producer in 2024 and interim 2025, after imports from Russia exited the U.S. market.229 In sum, we find that a significant and increasing volume of lower priced cumulated subject imports gained market share at Petitioner’s expense, which significantly impacted Petitioner by causing its performance to be worse than it would otherwise have been. Conclusion For the reasons stated above, we determine that an industry in the United States is materially injured by reason of subject imports of hexamine from China that are sold in the United States at LTFV and subsidized by the government of China. 229 CR/PR at Tables 4.8, C.1. 38 Separate Views Of Commissioner David S. Johanson I join Sections I through VI.B. of the majority’s opinion. I write separately as I find that the domestic producer of hexamine, Bakelite, is not materially injured by reason of subject imports but is threatened with material injury by reason of subject imports. Present Injury The principal reasons that I do not find that the domestic producer is materially injured are as follows. First, the domestic industry was highly profitable throughout the POI. Bakelite’s hexamine operating profit margin was not only high but increasing for the three-year POI, even as subject imports gained *** percentage points of market share.1 Bakelite’s hexamine operations had an operating profit margin of *** percent in 2022, *** percent in 2023, and *** percent in 2024; Bakelite’s operating profit margin was *** percent in the first quarter of 2024 and *** percent in the first quarter of 2025.2 Bakelite’s hexamine net profit margin decreased but only slightly: it was *** percent in 2022, *** percent in 2023, *** percent in 2024; it was *** percent in the first quarter of 2024 and *** percent in the first quarter of 2025.3 In absolute terms Bakelite’s hexamine operating profit decreased *** percent from 2022 to 2024, and its net profit decreased *** percent.4 Yet, these results were strong in an industry that experienced declining apparent consumption and declining demand, ***.5 Bakelite does not describe any of the typical indicators of “material injury” in import injury investigations such as ***.6 Instead, Bakelite describes capital projects related to hexamine production that it contends subject imports forced it to postpone. First, Bakelite 1 CR/PR at Table C.1. 2 CR/PR at Table C.1. 3 CR/PR at Table C.1. 4 CR/PR at Table C.1. 5 CR/PR at 2.11, 6.1 n.3, & Tables 2.6 & C.1. I recognize that the percentage decrease in profits was greater than the percentage decrease in apparent consumption, which decreased *** percent from 2022 to 2024, CR/PR at Table C.1. Yet the domestic industry nevertheless remained highly profitable. 6 CR/PR at Table 6.9; Bakelite Producer QR II-2a. Bakelite notes that ***. CR/PR at 3.2. 39 asserts that replacement of a formaldehyde reactor costing ***.7 This postponement ***.8 Second, Bakelite states that it must replace its ***.9 ***.10 Bakelite apparently instead chose to incur more moderate but slowly increasing capital expenditures on hexamine which Bakelite characterizes as “***.”11 Moreover, I find it questionable whether *** was postponed due to subject imports of hexamine as Bakelite claims. ***, but Bakelite emphasizes that it has more than enough hexamine capacity to satisfy the entire U.S. hexamine market, which in any event is declining, so it is plausible that ***.12 Bakelite’s attribution of responsibility to subject imports for postponement of its *** is equally unclear. ***; in contrast, subject imports have not been alleged or found to be unfairly traded until 2023 and represented a small share of the U.S. hexamine market until imports from Russia ceased in 2024.13 Bakelite gave no indication as to why it would decide to conduct a *** during the POI as opposed to an earlier time. Although a certain level of profitability is needed to ensure an optimum level of new investment depending on the characteristics of an industry, Bakelite’s efforts to show that its high profits fell below that level during the POI are not persuasive. With the hexamine industry experiencing declining demand, Bakelite could already supply the entire market. Bakelite was increasing its capital expenditures *** and was also increasing its research and development expenditures. As such, Bakelite would not need a particularly high level of profits to finance any new investment. In any case, whatever that level of investment might be, the record indicates 7 CR/PR at Table 6.10; Hrg. Tr. 16 (Roderick) (“We’ve been forced to put off capital expenditures including critical upgrades to equipment used in our formaldehyde process.”); Hrg. Tr. 50 (Boninsegni) (“{W}e deferred investment, for example, on our formaldehyde reactors. At the moment, we are running with one less reactor than we usually do because we are not having the demand to sustain this type of equipment.”). 8 CR/PR at Table 6.10. 9 CR/PR at Table 6.10. 10 Calculated from CR/PR at Table C.1. 11 CR/PR at Tables 6.8, C.1. It is also not clear what effect if any the postponement of these investments had on Bakelite’s operations. 12 See Bakelite Prehearing Br. 31; Bakelite Posthearing Br. 2; see also Hrg. Tr. 50 (Boninsegni) (attributing current closure of one formaldehyde reactor to “lack of demand to sustain this type of investment"). I note that formaldehyde has other uses besides hexamine production that may have influenced investment decisions. 13 CR/PR at Table C.1; Hexamethylenetetramine From the People's Republic of China, Germany, India, and Saudi Arabia: Initiation of Less-Than-Fair-Value Investigations, 89 Fed. Reg. 87,545 (Dep’t Commerce Nov. 4, 2024); Hexamethylenetetramine From the People's Republic of China, Germany, India, and Saudi Arabia: Initiation of Countervailing Duty Investigations, 89 Fed. Reg. 87,560 (Dep’t Commerce Nov. 4, 2024). 40 that Bakelite was comfortably exceeding this level at all times during the POI given its high operating and net profit margins.14 In fact, Bakelite’s net profit was *** times as great as its combined capital plus research and development expenses in 2022, *** times as great in 2023, *** times as great in 2024, and *** times as great in the first quarter of 2025, suggesting that Bakelite was consistently using its ample hexamine profits to a large extent for other purposes.15 A second reason that I do not find present material injury is that I place less weight on the one-quarter interim data, and to the extent I do consider it, it suggests that declining consumption caused by *** was a larger cause of any impact on Bakelite’s profitability in this period than were subject imports. Bakelite emphasizes the reduction in Bakelite’s hexamine market share “reached a peak” in the first quarter of 2025.16 Indeed, in the first quarter of 2025 cumulated subject imports’ market share was *** percentage points higher and the domestic producer’s share was *** percentage points lower as compared to interim 2024.17 Furthermore, comparing the interim periods, the domestic industry’s operating profit was *** percent lower and its net profit was *** percent lower.18 The Commission, however, generally does not ascribe much significance to results of a single-quarter interim period.19 Quarterly data are subject to lags due to different contract and sale terms, seasonality, and other fluctuations, and post-petition interim periods especially may reflect temporary post-petition effects that may not persist or may not have arisen but for the petitions themselves. For example, petitions may result in temporary import surges if importers seek to delay the effects of duties. In this case, additionally, International Emergency Economic Powers Act (IEEPA) tariffs were imposed on China starting February 4, 2025, and on Germany, India, and Saudi Arabia starting April 5, 2025, making the relevance of first-quarter 2025 data to current conditions even more uncertain.20 Moreover, this investigation presents an unusual feature. Bakelite filed its petitions on September 30, 2024.21 Starting in the fourth quarter of 2024 and continuing into the first 14 See CR/PR at Table C.1. 15 Calculated from CR/PR at Table C.1. 16 Bakelite Posthearing Br. 5. 17 CR/PR at Table C.1. 18 CR/PR at Table C.1. 19 See, e.g., Electrolytic Manganese Dioxide from China and Australia, Inv. Nos. 731-TA-1124-25 (Preliminary), USITC Pub. 3955 at 17 (Oct. 2007) (“Ordinarily, we are reluctant to place great weight on comparisons of partial-year periods.”). 20 CR/PR at 1.11. 21 CR/PR at 1.1. 41 quarter of 2025, Bakelite ***.22 This was accompanied by sharply reduced apparent consumption, which was *** percent lower in the first quarter of 2025 than in the first quarter of 2024.23 Although apparent consumption was steadily declining throughout the POI as the result of decreasing demand, the drop in apparent consumption in the first quarter of 2025 was particularly abrupt and large. In fact, based on the interim period comparison, the reduction in apparent consumption of *** pounds dwarfed the increase in U.S. shipments of subject imports of *** pounds, suggesting that the drop in consumption had a much larger impact on the market than did the increase in subject imports.24 Again, I place less weight on single-quarter data, but the interim period record suggests that this drop in apparent consumption was a likely result of ***. While price competition from unfairly traded subject imports could explain a shift in market share from domestic production to subject imports, it would not explain an abrupt decrease in apparent consumption as some purchasers stopped buying hexamine altogether; if anything, subject imports would tend to have the opposite effect if they gave purchasers a lower-cost alternative. Third, additional evidence of the lack of material injury to Bakelite’s hexamine operations by reason of subject imports comes from the domestic producer’s employment indicators. Throughout the POI, the domestic industry’s workforce and hours worked did not change, even in interim 2025, while total wages and hourly wages increased slightly.25 Bakelite’s hexamine workforce did not increase when demand and consumption rose in 2022 and did not decrease when demand and consumption fell later in the POI, even in the first quarter of 2025. Subject imports caused no material injury to Bakelite’s hexamine workforce during the POI. Fourth, I find unconvincing Bakelite’s argument that it suffered material injury because its market share was materially lower than it would have been but for unfairly traded subject imports. Bakelite argues that it was materially injured because, when hexamine from Russia exited the U.S. market, Bakelite was unable to gain greater market share than it otherwise would have without unfair competition. According to Bakelite, “{w}hen a major non-subject supplier exits the U.S. market, it is reasonable to expect that the domestic industry will gain 22 CR/PR at Table 5.8 & Figure 5.5. *** The average unit values of Bakelite’s domestic commercial shipments was $*** per pound in interim 2025, up *** percent from $*** per pound in interim 2024 and the ***, and its unit operating profit of $*** per pound in interim 2025 was *** percent higher than its unit operating income in 2024 of $*** per pound and also ***. 23 CR/PR at Table C.1. 24 Calculated from CR/PR at Table C.1. 25 CR/PR at Table C.1; Hrg. Tr. 22 (Boninsegni). 42 greater market share—absent unfairly traded subject imports.”26 Bakelite cites several previous Commission decisions that it asserts “affirmed” this “principle.”27 Yet each of the decisions that Bakelite cites have involved situations in which the Commission previously found the domestic industry to be injured by subject imports of a product and the industry is still struggling to return to its pre-injury condition during a subsequent “follow-on” investigation. For example, in Quartz Surface Products from India and Turkey, imports from China had been previously placed under order, but subsequently a new wave of imports from India and Turkey that were subject to a second investigation was “holding domestic producers at a market share that was less than the market share they held at the beginning of the POI, when they were experiencing the injurious effects of dumped and subsidized nonsubject imports from China.”28 26 Bakelite Posthearing Br. at 1 & Answers at 25. 27 Bakelite Posthearing Br. 1 & n.1 & answers at 25-27. Bakelite cites to Quartz Surface Products from India and Turkey, Inv. Nos. 701-TA-624-625 & 731-TA-1450-1451 (Final), USITC Pub. 5061 (June 2020); Mattresses from Bosnia and Herzegovina, Bulgaria, Burma, Italy, Philippines, Poland, Slovenia, and Taiwan, Inv. Nos. 731-TA-1629-163 (Final), USITC Pub. 5520 (June 2024); Aluminum Foil from Armenia, Brazil, Oman, Russia, and Turkey, Inv. Nos. 701-TA-658-659 and 731-TA-1538-1542 (Final) (Nov. 2021); Common Alloy Aluminum Sheet from Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Turkey, Inv. Nos. 701-TA-639 and 641-42 and 731-TA-1475-1479, 1481-1483, and 1485-1492 (Final) (April 2021); and Certain Ammonium Nitrate from Ukraine, Inv. No. 731-TA-894 (Final), USITC Pub. 3448 (Aug. 2001). 28 Quartz Surface Products from India and Turkey, Inv. Nos. 701-TA-624-625 & 731-TA-1450-1451 (Final), USITC Pub. 5061, at 33 (June 2020). See also Mattresses from Bosnia and Herzegovina, Bulgaria, Burma, Italy, Philippines, Poland, Slovenia, and Taiwan, Inv. Nos. 731-TA-1629-1631, 1633, 1636-1638, and 1640 (Final), USITC Pub. 5520, at 51 (June 2024) (“The increasing volume of subject imports that undersold the domestic like product prevented the domestic industry from gaining more market share as nonsubject imports retreated from the market in 2021 after the Mattresses II orders.”); Aluminum Foil from Armenia, Brazil, Oman, Russia, and Turkey, Inv. Nos. 701-TA-658-659 and 731-TA-1538-1542, at 36-37 (Final) (Nov. 2021) (underselling by subject imports “prevented domestic producers from gaining any of the market share ceded by imports from China after imposition of antidumping and countervailing duty orders”); Common Alloy Aluminum Sheet from Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Turkey, Inv. Nos. 701-TA-639 and 641-42 and 731-TA-1475-1479, 1481-1483, and 1485-1492, at 39 (Final) (April 2021) (“Although imports from China largely exited the U.S. market following institution of antidumping and countervailing duty investigations and imposition of duties, the domestic industry gained only a slight *** percentage points of U.S. market share over the three full years of the POI.”); (Certain Ammonium Nitrate from Ukraine, Inv. No. 731-TA-894 (Final), USITC Pub. 3448, at 11 (Aug. 2001) (“In the {previous} antidumping duty investigation of ammonium nitrate from Russia, the Commission found that imports from Russia had held a significant share of the U.S. market in 1999. The increase of subject imports of ammonium nitrate from Ukraine to the U.S. market between 1999 and 2000 prevented the domestic industry from capturing any additional market share notwithstanding the virtual disappearance of imports of ammonium nitrate from Russia in the U.S. market in 2000.”). 43 It is speculative that Bakelite’s hexamine operations would have gained significantly more market share following Russia’s exit from the U.S. market but for the arrival of imports from the subject countries. As GAFT points out, companies that had previously purchased subject imports from Russia rather than Bakelite are those most likely to prefer alternative sources to Bakelite.29 One possible alternative would have been other nonsubject imports. Record evidence indicates that hexamine was imported during the POI from Spain, the Netherlands, and ***.30 Additionally, the record does not indicate that purchasers would necessarily have turned to Bakelite hexamine but for unfairly traded imports, because underselling by imported hexamine could have persisted even without unfair trade. Imports from Russia undersold the domestic like product in 13 of 18 instances but have not been alleged to have been unfairly traded.31 Furthermore, the preliminary dumping margins and subsidy rates for certain subject sources are considerably lower than the average margins of underselling from those sources, suggesting that not all of the underselling resulted from unfair trade.32 Subject products from all subject sources also sold in the U.S. market sometimes at higher prices than domestic products.33 Finally, purchasers, particularly the most price-sensitive or those with access to other downstream product opportunities, would have had the option not to buy hexamine in the United States at all, as happened in the first quarter of 2025. Even if Bakelite had gained further market share as imports from Russia receded, I do not find that its failure to do so would have constituted a significant adverse impact to an industry producing hexamine in the United States in light of Bakelite’s high profits and the impacts of these high profits on Bakelite’s hexamine operations, in which profits on hexamine were consistently *** greater than capital expenditures and research and development expenses for hexamine production.34 Bakelite did not invest in additional hexamine-related 29 GAFT final comments 4. 30 CR/PR at 2.9 n.12, 4.3 & Table 4.2. Although hexamine imports from those countries had small or very low market shares in the US market and sold at relatively high AUVs during the POI, and these countries are not among the world’s largest exporters of heterocyclic compounds excluding melamine, the same was true of imports of hexamine from Saudi Arabia early in the POI. CR/PR at Tables 7.14, C.1. Yet, Saudi Arabia then became a leading alternative source of hexamine for U.S. importers. 31 CR/PR at Table D.3. 32 CR/PR at Tables 1.3, 1.6, 1.7, 5.10, and 5.11. 33 CR/PR at Table 5.11. 34 Bakelite asserts that material injury can exist even when an industry is profitable or financial indicators show improvement because the Commission “may not determine that there is no material injury or threat of material injury to an industry in the United States merely because that industry is profitable or because the performance of that industry has recently improved.” Bakelite Posthearing Br. (Continued...) 44 capital projects during the POI, though it could have done so given its high operating and net income profits. Nor did Bakelite add more workers when demand increased in 2022 or lay off any when its market share decreased later in the POI; Bakelite did not *** for its production workers. Under these circumstances even higher profits would not have significantly changed its incentives. For these reasons, I conclude that the domestic industry producing hexamine has not suffered present material injury by reason of subject imports. I next address threat of material injury. Threat of Injury For the following reasons, I find that the domestic industry is threatened with material injury by reason of subject imports of hexamine from China. I note that this finding does not apply to subject imports from Germany, India, and Saudi Arabia.35 A. Legal Standards Section 771(7)(F) of the Tariff Act directs the Commission to determine whether the domestic industry is threatened with material injury by reason of the subject imports by analyzing whether “further dumped or subsidized imports are imminent and whether material injury by reason of imports would occur unless an order is issued or a suspension agreement is accepted.”36 The Commission may not make such a determination “on the basis of mere conjecture or supposition” and considers the threat factors “as a whole” in making its determination whether dumped or subsidized imports are imminent and whether material injury by reason of subject imports would occur unless an order issues.37 In considering the existence of threat of material injury, I consider all factors set forth as relevant in the statute.38 1-2 (quoting 19 U.S.C. sec. 1677(7)(J)). Yet, the word “merely” contemplates that profitability, not to mention the level and trends in profitability, are considerations among other factors. 35 On May 6, 2025, Commerce postponed its final AD determinations with respect to Germany, India, and Saudi Arabia for up to 135 days, which will in turn postpone the date of the Commission’s determinations as to those countries. See supra Section I; CR/PR at 1.1 & Appendix A. 36 19 USC 1677(7)(F)(ii). 37 19 USC 1677(7)(F)(ii). 38 See 19 USC 1677(F)(i). These factors are as follows: (I) if a countervailable subsidy is involved, such information as may be presented to it by the administering authority as to the nature of the subsidy (particularly as to whether the countervailable subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement), and whether imports of the subject merchandise are likely to increase, (II) any existing unused production capacity or imminent, substantial increase in production capacity in the exporting country indicating the likelihood of substantially increased imports of (Continued...) 45 B. Cumulation The statute provides that where the conditions for cumulation for present injury are met, “{t}o the extent practicable … the Commission may cumulatively assess the volume and price effects” of subject imports for purposes of a threat analysis.39 In deciding whether to assess subject imports cumulatively for threat purposes, the Commission typically considers whether subject imports from different countries are likely to compete under similar or different conditions of competition in the U.S. market.40 In this case, the statutory factors for cumulation have been met.41 Three additional factors, however, suggest that subject imports from China may compete under different conditions than subject imports from the other three subject sources. the subject merchandise into the United States, taking into account the availability of other export markets to absorb any additional exports, (III) a significant rate of increase of the volume or market penetration of imports of the subject merchandise indicating the likelihood of substantially increased imports, (IV) whether imports of the subject merchandise are entering at prices that are likely to have a significant depressing or suppressing effect on domestic prices and are likely to increase demand for further imports, (V) inventories of the subject merchandise, (VI) the potential for product-shifting if production facilities in the foreign country, which can be used to produce the subject merchandise, are currently being used to produce other products, ... (VIII) the actual and potential negative effects on the existing development and production efforts of the domestic industry, including efforts to develop a derivative or more advanced version of the domestic like product, and (IX) any other demonstrable adverse trends that indicate the probability that there is likely to be material injury by reason of imports (or sale for importation) of the subject merchandise (whether or not it is actually being imported at the time). 19 U.S.C. § 1677(7)(F)(i). To organize my analysis, I discuss the applicable statutory threat factors using the same volume/price/impact framework that applies to our material injury analysis. Thus, I discuss factors (I), (II), (III), (V), and (VI) in the analysis of subject import volume; factor (IV) in the analysis of import price effects; and factors (VIII) and (IX) in the analysis of impact. Factor (VII) concerning agricultural products does not apply in this investigation. 39 19 USC 1677(7)(H); see supra Section V (discussing cumulation for present injury purposes). The statute includes certain exceptions not relevant here. 40 See, e.g., T.B. Wood’s Inc. v. United States, 355 F. Supp. 3d 1265, 1283-84 (Ct. Int’l Trade 2018). Factors considered have included, e.g., differences in volume and capacity trends of subject imports, e.g., Polyethylene Terephthalate Film, Sheet and Strip from Brazil, China, Thailand, and the United Arab Emirates, Inv. Nos. 731-TA-1131-1134 (Final), USITC Pub. 4040, at 33 (Oct. 2008); and whether different countries are subject to Section 201 duties, Certain Cold-Rolled Steel Products from Australia, India, Japan, Sweden, and Thailand, Inv. Nos. 731-TA-965, 971-972, 979, and 981 (Final), USITC Pub. 3536 at 40-41 (Sept. 2002). 41 See supra Section V. 46 First, subject imports from China had a very small and declining share of the U.S. market during the POI, while subject imports from the other subject sources had larger and increasing market shares, particularly in 2024 and interim 2025.42 Second, the tariff treatment of subject imports from China differs from the tariff treatment of subject imports from other subject sources. Subject imports from China have been subject to a section 301 duty of 25 percent throughout the POI.43 Starting on February 4, 2025, subject imports from all four subject countries have also been subject to additional duties under the International Emergency Economic Powers Act (“IEEPA”) at different and varying rates.44 Third, Commerce has found that subject imports from China have several times higher subsidy rates and dumping margins than subject imports from any other source, and nearly a hundred times higher than hexamine from Saudi sources or Indian producer Kanoria. 45 These differences may reflect or cause other differences in conditions of competition, such as differences in capacity or propensity to undersell. For a number of reasons, however, I will use my discretion to consider subject imports from all four sources under investigation cumulatively for purposes of my threat determination as to China. First, IEEPA tariffs are very recent so that their duration and effect are unpredictable. Accordingly, I do not consider them dispositive for my cumulation analysis at this time. Similarly, at this stage Commerce determinations are preliminary except as to China, so I also do not give differences in subsidy rates and dumping margins much weight for cumulation purposes at this time. Second, the Commission has received questionnaire responses from producers/exporters from Germany, India, and Saudi Arabia but none from China.46 This makes it particularly difficult to assess what other differences or similarities may exist in conditions of competition between imports from China and imports from other subject sources, such as the 42 See CR/PR at Table C.1. 43 CR/PR at 1.11. 44 CR/PR at 1.11 to 1.12. As of the close of the record on August 11, 2025, subject imports from China were subject to IEEPA tariffs totaling 30 percent, while the IEEPA rates applicable to Germany, India, and Saudi Arabia were 8.7 percent, 25 percent, and 10 percent, respectively. CR/PR at Table 1.8. 45 Commerce has found all subject imports from China to be subsidized at a rate of 420.73 percent, and to be dumped at a margin of 405.19 percent. CR/PR at Tables 1.2, 1.4. Preliminary subsidy rates applicable to India range from 2.32 percent to 139.55 percent, CR/PR Table 1.3, while dumping margins applicable to other countries range from 1.31 percent to 103.79 percent, CR/PR Tables 1.5 to 1.7. 46 CR/PR at Table 7.1. 47 excess capacity in the various foreign industries. The limited available information regarding hexamine exports from China suggests that China has a very large hexamine capacity and exports more than twice the volume of chemicals in the HTS category that includes hexamine as did the rest of the world combined.47 Accordingly, despite differences in import trends and (apparently) in tariff treatment, and absent any argument to the contrary, I exercise my discretion to consider subject imports from China cumulatively with imports from the other three subject sources for purposes of my determinations regarding China. C. Likely Volume The volume of cumulated subject imports was significant both absolutely and relative to U.S. consumption during the POI – although, as discussed above, the significance of the increase in subject imports during the POI was diminished by the fact that it came at the expense of subject imports from Russia, not Bakelite’s hexamine production. From 2022 to 2024 U.S. shipments of cumulated subject imports increased 186.7 percent by volume and their market share increased from *** percent to *** percent.48 These trends continued over the interim periods: the volume of U.S. shipments of cumulated subject imports was 6.8 percent greater in the first quarter of 2025 than it had been in the first quarter of 2024, and cumulated subject imports’ market share was *** percent compared to *** percent.49 Evidence as to whether subject import volume will continue to increase, however, is mixed. The parties agree that the increase in subject imports was largely a response to a one- time event, the withdrawal of Russian hexamine from the U.S. market leading up to and following Russia’s attack on Ukraine.50 This had essentially run its course by 2024, as imports from Russia *** in 2024 and shipments of hexamine from Russia out of inventory *** in the first quarter of 2025.51 Subject imports also gained market share in 2024 and interim 2025, after imports from Russia had ceased. Yet, elevated shipments of subject imports at the end of the POI were accompanied by unusual conditions, as described above. Foreign producer capacity data also present a mixed picture. The Commission received questionnaire responses from foreign producers accounting for *** hexamine production and 47 CR/PR at Table 7.14; Petitioner Prehearing Br. 45. 48 CR/PR at Table C.1. 49 CR/PR at Table C.1. 50 GAFT Posthearing Br. 8 (citing Hrg. Tr. 42 (Roderick) (“This was a one-time event where Russia had left the market.”). 51 CR/PR at 4.6 n.14 and Table C.1. 48 exports to the United States from Germany and Saudi Arabia, and for the majority of hexamine production and exports to the United States from India.52 Most foreign producers reported and projected high capacity utilization rates. The German producer reported or projected capacity utilization ratios above *** percent from 2024 through 2026, while the Saudi producer reported or projected capacity utilization rates ranging from *** percent through *** percent in this period.53 Indian producers reported lower capacity collective utilization rates, but these rates were increasing from *** percent in 2024 to a projected *** percent in 2025, and to a projected *** percent in 2026.54 Collectively, the cumulated subject industries’ capacity utilization rate increased from *** percent in 2022 to *** percent in 2024; it was *** percent in interim 2024 and *** percent in interim 2025; it is projected to be *** percent in 2025 and *** percent in 2026.55 Although these capacity utilization rates were high and increasing they exclude China because no Chinese producers have responded to questionnaires. Chinese exporters’ high dumping margins, vast exports, and lack of participation suggest they have excess capacity which could fuel increased exports in the future despite their low levels during the POI. The cumulated foreign industries exported approximately *** percent to *** percent of their total shipments, of which a small but increasing percentage has gone to the U.S. market: *** percent in 2022, *** percent in 2023, *** percent in 2024, *** percent in interim 2024 and *** percent in interim 2025.56 Responding foreign producers project that share to decrease to *** percent in 2025 and to *** percent in 2026.57 Foreign producers’ hexamine inventories fluctuated somewhat but ended the POI at nearly the same level at which they began it.58 U.S. importers’ U.S. inventories of subject imports also fluctuated: they were *** pounds in 2022, *** pounds in 2023, *** pounds in 2024, *** pounds in interim 2024 and *** pounds in interim 2025.59 Subsidy rates relating to China were based on facts available with adverse inferences, including export subsidies; Commerce also preliminarily determined that Kanoria received export subsidies, although 52 CR/PR at Table 7.1. 53 CR/PR at Table 7.8. 54 CR/PR at Table 7.8. 55 CR/PR at Table 7.8. 56 CR/PR at Table 7.7. 57 CR/PR at Table 7.7. 58 CR/PR at Table 7.10. Cumulated subject producers’ inventories were (in pounds) *** in 2022, *** 2023, *** in 2024, *** in interim 2024, and *** in interim 2025; they are projected to be *** in 2025 and *** in 2026. CR/PR at Table 7.10. As a share of total shipments these inventories fluctuated between a low of *** percent in 2023 and a high of *** percent in 2022. CR/PR at Table 7.10. 59 CR/PR at Table 7.12. 49 Kanoria’s preliminary total CVD rate of 2.32 percent was quite low.60 Reported arranged imports of subject merchandise totaled *** pounds in the second quarter of 2025, *** pounds in the third quarter, and ***.61 There are no known third-country trade actions relating to hexamine, and no foreign hexamine producer reported any production of alternative products using the same equipment and/or labor as those used to produce hexamine.62 In addition to the factors usually considered in a threat analysis, changes in tariff treatment could affect import levels in the imminent future. ***.63 Nevertheless, as I have noted, current IEEPA tariffs are of uncertain duration and effect and Commerce’s calculated dumping margins and subsidy rates are preliminary, so I will not place significant weight on them at this time. On balance, in light of the large or unreported excess capacity available in China, I find for purposes of this determination that the volume of cumulated subject imports are more likely than not to increase in the imminent future to levels significantly above those observed in the POI. D. Likely Price Effects During the POI cumulated subject imports undersold the domestic like product in 42 of 61 instances involving *** pounds of subject imports with average margins of underselling of 23.8 percent, and oversold the domestic like product in 19 instances involving *** pounds of subject imports with average margins of 58.0 percent.64 Imposition of IEEPA tariffs following the first quarter 2025 interim period could affect these margins, but any impact these tariffs may have is presently quite recent and uncertain. Accordingly, I find that cumulated subject imports will likely continue to undersell domestic like product in the imminent future and that this underselling will contribute to significant increases in nonsubject import volume. E. Likely Impact As discussed above, up until now cumulated subject imports have not had a significant adverse impact on the domestic industry. Prior to the first quarter of 2025 they gained only a very small amount of market share and did nothing to disturb the profitability or employment of Bakelite’s hexamine operations. In the first quarter of 2025 subject imports appeared to have 60 CR/PR at Tables 1.2, 1.3, 1.6 & notes thereto. 61 CR/PR at Table 7.13. 62 CR/PR at 7.21, 7.28. 63 ***. 64 CR/PR at 5.16. 50 a greater impact but that was only for a brief period, was accompanied by unusual conditions, and left the ability of Bakelite to invest in its operations undisturbed. Nevertheless, in light of my findings above that cumulated subject imports will likely continue to increase in volume in the imminent future and that underselling will continue, I find that subject imports threaten to cause material injury to the domestic hexamine industry. 1.1 Introduction Background These investigations result from petitions filed with the U.S. Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“USITC” or “Commission”) by Bakelite Synthetics (Atlanta, Georgia) on September 30, 2024, alleging that an industry in the United States is materially injured and threatened with material injury by reason of subsidized imports of hexamine (hexamethylenetetramine)1 from China and India and less-than-fair-value (“LTFV”) imports from China, Germany, India, and Saudi Arabia. Table 1.1 presents information relating to the background of these investigations.2 3 Table 1.1 Hexamine: Information relating to the background and schedule of this proceeding Effective date Action September 30, 2024 Petitions filed with Commerce and the Commission; institution of the Commission investigations (89 FR 80929, October 4, 2024) October 21, 2024 Commerce’s notices of initiation (89 FR 87545 and 87560, November 4, 2024) November 14, 2024 Commission’s preliminary determinations (89 FR 91786, November 20, 2024) March 7, 2025 Commerce’s preliminary CVD determinations with respect to China and India, and alignment of final CVD determinations with final AD determinations (90 FR 11508 and 11512) May 6, 2025 Commerce’s preliminary AD determinations with respect to China, Germany, India, and Saudi Arabia; postponement of final determinations with respect to Germany, India, and Saudi Arabia (90 FR 19182, 19186, 19178, and 19180); scheduling of final phase of Commission investigations (90 FR 21948, May 22, 2025) July 18, 2025 Commerce’s final China AD and CVD determinations (90 FR 33922 and 33923) July 18, 2025 Commission’s hearing August 15, 2025 Commission’s China AD and CVD votes September 3, 2025 Commission’s China AD and CVD views 1 See the section entitled “The subject merchandise” in Part 1 of this report for a complete description of the merchandise subject in this proceeding. 2 Pertinent Federal Register notices are referenced in appendix A and may be found at the Commission’s website (www.usitc.gov). 3 Appendix B presents witnesses who appeared at the Commission’s hearing. 1.2 Statutory criteria Section 771(7)(B) of the Tariff Act of 1930 (the “Act”) (19 U.S.C. § 1677(7)(B)) provides that in making its determinations of injury to an industry in the United States, the Commission— shall consider (Ⅰ) the volume of imports of the subject merchandise, (Ⅱ) the effect of imports of that merchandise on prices in the United States for domestic like products, and (Ⅲ) the impact of imports of such merchandise on domestic producers of domestic like products, but only in the context of production operations within the United States; and. . . may consider such other economic factors as are relevant to the determination regarding whether there is material injury by reason of imports. Section 771(7)(C) of the Act (19 U.S.C. § 1677(7)(C)) further provides that—4 In evaluating the volume of imports of merchandise, the Commission shall consider whether the volume of imports of the merchandise, or any increase in that volume, either in absolute terms or relative to production or consumption in the United States is significant.. . .In evaluating the effect of imports of such merchandise on prices, the Commission shall consider whether. . .(Ⅰ) there has been significant price underselling by the imported merchandise as compared with the price of domestic like products of the United States, and (Ⅱ) the effect of imports of such merchandise otherwise depresses prices to a significant degree or prevents price increases, which otherwise would have occurred, to a significant degree.. . . In examining the impact required to be considered under subparagraph (B)(ⅰ)(Ⅲ), the Commission shall evaluate (within the context of the business cycle and conditions of competition that are distinctive to the affected industry) all relevant economic factors which have a bearing on the state of the industry in the United States, including, but not limited to. . . (Ⅰ) actual and potential decline in output, sales, market share, gross profits, operating profits, net profits, ability to service debt, productivity, return on investments, return on assets, and utilization of capacity, (Ⅱ) factors affecting domestic prices, (Ⅲ) actual and potential negative effects on cash flow, inventories, employment, wages, growth, ability to raise capital, and investment, (Ⅳ) actual and potential negative effects on the existing development and production efforts of the domestic industry, including efforts to develop a derivative 4 Amended by PL 114—27 (as signed, June 29, 2015), Trade Preferences Extension Act of 2015. 1.3 or more advanced version of the domestic like product, and (Ⅴ) in {an antidumping investigation}, the magnitude of the margin of dumping. In addition, Section 771(7)(J) of the Act (19 U.S.C. § 1677(7)(J)) provides that—5 (J) EFFECT OF PROFITABILITY.—The Commission may not determine that there is no material injury or threat of material injury to an industry in the United States merely because that industry is profitable or because the performance of that industry has recently improved. Organization of report Part 1 of this report presents information on the subject merchandise, subsidy rates/dumping margins, and domestic like product. Part 2 of this report presents information on conditions of competition and other relevant economic factors. Part 3 presents information on the condition of the U.S. industry, including data on capacity, production, shipments, inventories, and employment. Parts 4 and 5 present the volume of subject imports and pricing of domestic and imported products, respectively. Part 6 presents information on the financial experience of the U.S. producer. Part 7 presents the statutory requirements and information obtained for use in the Commission’s consideration of the question of threat of material injury as well as information regarding nonsubject countries. 5 Amended by PL 114—27 (as signed, June 29, 2015), Trade Preferences Extension Act of 2015. 1.4 Market summary Hexamine is generally used to manufacture phenolic resins, tires, explosives, and other industrial products.6 The petitioner, Bakelite, is the sole U.S. producer of hexamine in granular form. The petitioner indicated that there is generally only one major producer in three of the subject foreign industries (Prefere Paraform GmbH & Co. in Germany, Kanoria Chemicals & Industries Limited in India, and Methanol Chemicals Company (Chemanol) in Saudia Arabia) with several major producers of hexamine in China.7 The leading U.S. importer of hexamine from China is ***, the leading importer of hexamine from Germany is ***, the leading importers of hexamine from India are ***, and the leading importers of hexamine from Saudi Arabia are ***. Leading importers of hexamine from nonsubject countries include ***. U.S. purchasers of hexamine are firms that consume hexamine to manufacture downstream products, primarily plastics; leading purchasers include ***. 6 Petition, vol. 1, pp. 7–9. 7 Conference transcript, p. 21 (Roderick). 1.5 Apparent U.S. consumption of hexamine in the total market was approximately *** pounds ($***) in 2024.8 The petitioner, Bakelite, is the only known source of in-scope hexamine production in the United States. Bakelite’s U.S. shipments of hexamine totaled *** pounds ($***) in 2024 and accounted for *** percent of apparent U.S. consumption of the total market by quantity (*** percent by value).9 U.S. shipments of imports from subject sources totaled 4.4 million pounds ($4.3 million) in 2024 and accounted for *** percent of apparent U.S. consumption of the total market by quantity (*** percent by value). U.S. shipments of imports from nonsubject sources totaled approximately *** pounds ($***) in 2024 and accounted for *** percent of apparent U.S. consumption of the total market by quantity (*** percent by value).10 Summary data and data sources A summary of data collected in these investigations is presented in appendix C (table C.1 for the total market and table C.2 for the merchant market). The Commission’s questionnaires collected data for the years 2022 to 2024 and interim periods January through March of 2024 (“interim 2024”) and January through March of 2025 (“interim 2025”). Except as noted, U.S. industry data are based on the questionnaire response of one firm that accounted for all known U.S. production of in-scope hexamine during 2024. U.S. imports are based on the questionnaire responses of 11 responding U.S. importers. Previous and related investigations Hexamine has not been the subject of any prior countervailing duty or antidumping duty investigations in the United States. 8 Apparent U.S. consumption of hexamine in the merchant market was approximately *** pounds ($***) in 2024. 9 Bakelite’s U.S. commercial shipments of hexamine totaled *** pounds ($***) in 2024 and accounted for *** percent of apparent U.S. consumption of the merchant market by quantity (*** percent by value). 10 U.S. shipments of imports from subject sources accounted for *** percent of apparent U.S. consumption of the merchant market by quantity (*** percent by value) in 2024. U.S. shipments of U.S. imports from nonsubject sources accounted for *** percent of apparent U.S. consumption of the merchant market by quantity (*** percent by value) in 2024. 1.6 Nature and extent of subsidies and sales at LTFV Subsidies On July 18, 2025, Commerce published a notice in the Federal Register of its final determinations of countervailable subsidies for producers and exporters of hexamine from China.11 Table 1.2 presents Commerce’s findings of subsidization of hexamine in China. Table 1.2 Hexamine: Commerce’s final subsidy determinations with respect to imports from China Company Subsidy rate (percent ad valorem) Changzhou Highassay Chemical Co 420.73 China Bluestar International Chemical Co., Ltd 420.73 Fengchen Group Co., Ltd 420.73 Hutubi Ruiyuantong Chemicals Co., Ltd 420.73 Jiangsu Guotai Guomian Trading 420.73 Jiaozuo Runhua Chemical Industry Co 420.73 Qingdao Sun Chemical Corp. Ltd 420.73 Runhua Chemical Industry 420.73 Shandong Aojin Chemical Technology Co., Ltd 420.73 All others 420.73 Source: 90 FR 33923, July 18, 2025. Note: All rates are based on facts available with adverse inferences. For further information on programs determined to be countervailable, see Commerce’s associated Issues and Decision Memorandum. On March 7, 2025, Commerce published a notice in the Federal Register of its preliminary determinations of countervailable subsidies for producers and exporters of hexamine from India.12 Table 1.3 presents Commerce’s findings of subsidization of hexamine in India. 11 90 FR 33923, July 18, 2025. 12 90 FR 11512, March 7, 2025. 1.7 Table 1.3 Hexamine: Commerce’s preliminary subsidy determinations with respect to imports from India Entity Preliminary countervailable subsidy rate (percent) Kanoria Chemicals and Industries Limited 2.32 Horizon Chemicals 139.55 Micro Labs Ltd 139.55 Shreenathji Rasayan Private Limited 139.55 Rajsha Chemicals Pvt. Ltd 139.55 All Others 2.32 Source: 90 FR 11512, March 7, 2025. Note: Commerce preliminarily finds Vardhan Limited to be cross-owned with Kanoria Chemicals and Industries Limited. Rates for Horizon Chemicals, Micro Labs Ltd., Shreenathji Rasayan Private Limited, and Rajsha Chemicals Pvt. Ltd are based on facts available with adverse inferences. For further information on programs determined to be countervailable, see Commerce’s associated Issues and Decision Memorandum. 1.8 Sales at LTFV On July 18, 2025, Commerce published notice in the Federal Register of its final determination of sales at LTFV with respect to imports from China.13 Table 1.4 presents Commerce’s dumping margins with respect to imports of hexamine from China. Table 1.4 Hexamine: Commerce’s final weighted-average LTFV margins with respect to imports from China Exporter/producer Weighted-average dumping margin (percent) Cash deposit rate (adjusted for subsidy offset) (percent) China-wide Entity 405.19 394.65 Source: 90 FR 33922, July 18, 2025. Note: The dumping margin rate is based on facts available with adverse inferences. On May 6, 2025, Commerce published notices in the Federal Register of its preliminary determinations of sales at LTFV with respect to imports from Germany, India, and Saudi Arabia.14 Tables 1.5 through 1.7 present Commerce’s dumping margins with respect to imports of hexamine from Germany, India, and Saudi Arabia, respectively. Table 1.5 Hexamine: Commerce’s preliminary weighted-average LTFV margins with respect to imports from Germany Exporter/producer Preliminary estimated weighted-average dumping margin (percent) Prefere Paraform GmbH & Co Kg 52.14 Fiberpipe GFK Vertriebsgesellschaft 80.66 All Others 52.14 Source: 90 FR 19186, May 6, 2025. Note: The rate for Fiberpipe GFK Vertriebsgesellschaft is based on facts available with adverse inferences. 13 90 FR 33922, July 18, 2025. 14 90 FR 19182, 19186, 19178, and 19180, May 6, 2025. 1.9 Table 1.6 Hexamine: Commerce’s preliminary weighted-average LTFV margins with respect to imports from India Exporter/producer Preliminary weighted- average dumping margin (percent) Preliminary cash deposit rate (adjusted for subsidy offset(s)) (percent) Kanoria Chemicals and Industries Limited 3.28 1.31 Horizon Chemicals 105.76 103.79 Micro Labs Limited 105.76 103.79 Shreenathji Rasayan Private Limited 105.76 103.79 Rajsha Chemicals Pvt. Ltd 105.76 103.79 All Others 3.28 1.31 Source: 90 FR 19178, May 6, 2025. Note: Weighted-average dumping margins for Horizon Chemicals, Micro Labs Limited, Shreenathji Rasayan Private Limited, and Rajsha Chemicals Pvt. Ltd. are based on facts available with adverse inferences. The cash deposit rates for Kanoria and all others are adjusted for export subsidies. Table 1.7 Hexamine: Commerce’s preliminary weighted-average LTFV margins with respect to imports from Saudi Arabia Exporter/producer Preliminary dumping margin (percent) Methanol Chemicals Company 4.96 All Others 4.96 Source: 90 FR 19180, May 6, 2025. 1.10 The subject merchandise Commerce’s scope In the current proceeding, Commerce has defined the scope as follows:15 The scope of these investigations covers hexamine in granular form, with a particle size of 5 millimeters or less, whether stabilized or unstabilized, whether or not blended, mixed, pulverized, or grounded with other products, containing 50 percent or more hexamine by weight. Hexamine is the common name for hexamethylene tetramine (Chemical Abstract Service #100-97-0), and is also referred to as 1,3,5,7- tetraazaadamantanemethenamine; HMT; HMTA; 1,3,5,7-tetraazatricyclo {3.3.1.13,7} decane; 1,3,5,7-tetraaza adamantane; hexamethylenamine. Hexamine has the chemical formula C6 H12 N4 . Granular hexamine that has been blended with other product(s) is included in this scope when the resulting mix contains 50 percent or more of hexamine by weight, regardless of whether it is blended with inert additives, co-reactants, or any additives that undergo self- condensation. Subject merchandise includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, adding or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the subject country. 15 90 FR 11508 and 11512, March 7, 2025; and 90 FR 19182, 19186, 19178, and 19180, May 6, 2025. 1.11 Tariff treatment Hexamine is currently provided for in Harmonized Tariff Schedule of the United States (“HTS”) subheading 2933.69.50. The general rate of duty is 6.3 percent for HTS subheading 2933.69.50.16 Decisions on the tariff classification and treatment of imported goods are within the authority of U.S. Customs and Border Protection. Effective September 24, 2018, hexamine originating in China was subject to an additional 10 percent ad valorem duty under section 301 of the Trade Act of 1974. Effective May 10, 2019, the section 301 duty for hexamine was increased to 25 percent.17 Effective February 4, 2025, hexamine originating in China was subject to an additional 10 percent ad valorem duty under the International Emergency Economic Powers Act (“IEEPA”), and on March 4, 2025, that additional duty increased to 20 percent ad valorem.18 Effective April 5, 2025, hexamine originating in Germany or Saudi Arabia was subject to an additional 10 percent ad valorem duty as part of tariffs initiated in April 2025 under IEEPA.19 Effective August 7, 2025, the additional duty for hexamine originating in Germany was adjusted to 8.7 percent.20 Effective April 5, 2025, hexamine originating in India was subject to an additional 10 percent ad valorem duty as part of tariffs initiated in April 2025 under IEEPA. Effective April 9, 2025, India was instead assigned an individualized country reciprocal duty of 26 percent ad valorem. Effective April 10, 2025, individualized country reciprocal duties were suspended and the reciprocal duty rate for hexamine originating in India was returned to 10 percent ad 16 USITC, HTS (2025) Revision 8, Publication 5613, April 2025, p. 29.6.129. 17 83 FR 47974, September 21, 2018; 84 FR 20459, May 9, 2019. See also HTS headings 9903.88.03 and 9903.88.04 and U.S. notes 20(e), 20(f), and 20(g) to subchapter III of chapter 99 and related tariff provisions for this duty treatment. USITC, HTS (2025) Revision 8, Publication 5613, April 2025, pp. 99.3.46, to 99.3.71, 99.3.352. Goods exported from China to the United States prior to May 10, 2019, and entering the United States prior to June 1, 2019, were not subject to the escalated 25 percent duty (84 FR 21892, May 15, 2019). 18 90 FR 9121, February 7, 2025; 90 FR 11426, March 6, 2025; 90 FR 11463, March 7, 2025. See also HTS heading 9903.01.20 and U.S. note 2(s) and HTS heading 9903.01.24 and U.S. note 2(u) to subchapter III of chapter 99 and related tariff provisions for this duty treatment. USITC, HTS (2025) Revision 8, Publication 5613, April 2025, pp. 99.3.3 to 99.3.4, 99.3.297 to 99.3.298. 19 90 FR 15041, April 7, 2025. See also HTS heading 9903.01.25 and U.S. note 2(v) to subchapter III of chapter 99 and related tariff provisions for this duty treatment. USITC, HTS (2025) Revision 8, Publication 5613, April 2025, pp. 99.3.1 to 99.3.10, 99.3.278. 20 Effective August 7, 2025, goods originating from EU nations with a general rate of duty of less than 15 percent were assigned an additional duty such that the sum of the general rate of duty and the additional rate of duty is 15 percent. 90 FR 37963, August 6, 2025. 1.12 valorem.21 Effective August 7, 2025, India was assigned an individualized country duty of 25 percent.22 Effective April 5, 2025, hexamine originating in China was subject to an additional 10 percent ad valorem reciprocal duty under IEEPA. That reciprocal duty rose to 84 percent ad valorem effective April 9, 2025, and rose again to 125 percent effective April 10, 2025. However, effective May 14, 2025, the duty rate for reciprocal tariffs on products originating in China was reduced to 10 percent.23 Table 1.8 Hexamine: Additional tariff treatment for China, Germany, India, Saudi Arabia Tariffs in percent ad valorem Additional tariff China Germany India Saudi Arabia Section 301 25 Not applicable Not applicable Not applicable IEEPA – China specific 20 Not applicable Not applicable Not applicable Tariffs initiated in April 2025 under IEEPA 10 8.7 25 10 Total additional ad valorem rate 55 8.7 25 10 Source: Federal Register notices and other sources cited in this section (Tariff treatment). Note: Duty rates in the table reflect the duty rates as of the writing of this report. See the text above for historical changes to the additional tariffs. Note: IEEPA tariffs are referred to in the table by the date of first implementation, not by the date of subsequent changes to the duty rate. However, the duty rates reported in the text are the duty rates as of the writing of this report. 21 Individualized country reciprocal duties for all countries other than China were suspended until July 9, 2025. 90 FR 15041, April 7, 2025; and 90 FR 15625, April 15, 2025. See also HTS headings 9903.01.25 and 9903.01.XX and U.S. note 2(v) to subchapter III of chapter 99 and related tariff provisions for this duty treatment. USITC, HTS (2025) Revision 8, Publication 5613, April 2025, pp. 99.3.1 to 99.3.10, 99.3.278. 22 90 FR 37963, August 6, 2025. 23 The reciprocal duty is in addition to the 20 percent ad valorem duty under IEEPA that went into effect on March 4, 2025, for China. 90 FR 15041, April 7, 2025; 90 FR 15509, April 14, 2025; 90 FR 15625, April 15, 2025; and 90 FR 21831, May 21, 2025. See also HTS headings 9903.01.25 and 9903.01.63 and U.S. note 2(v) to subchapter III of chapter 99 and related tariff provisions for this duty treatment. USITC, HTS (2025) Revision 8, Publication 5613, April 2025, pp. 99.3.1 to 99.3.10, 99.3.278. 1.13 The product Description and applications Hexamethylenetetramine (C6 H12 N 4 , CAS number 100-97-0), commonly referred to as hexamine, is a crystalline organic compound. It is a highly water soluble, solid white powder that is stable at room temperature.24 Hexamine’s properties make it useful as a reactant or catalyst in a variety of applications across several different industries. Major uses for hexamine include:25 • Explosives and munitions: Hexamine is nitrated with nitric acid to form Research Department Explosive (RDX), a stable, high detonation velocity explosive that has both military and civilian applications. • Phenolic resins: Hexamine is both a curing agent and a catalyst promoting polymerization in producing phenolic resins. The use of hexamine enables resins to solidify and gain strength under heat, adding durability, stability, and heat-resistance to resin products. These properties are important in a variety of industrial applications, including electrical insulation, construction, and automobile manufacturing. • Rubber and Tires:26 Hexamine functions as an accelerator and curing agent in the vulcanization of rubber. Hexamine improves the performance of rubber products by encouraging cross-linking of rubber chains. Hexamine also gives tires additional abrasion resistance and durability. • Energy: Hexamine fuel tablets, which are portable, easily ignitable and clean burning, are used for heating, cooking, or as emergency fuel when other energy supplies are unavailable or impractical to use. • Biocides: Hexamine is used to inhibit the growth of bacteria and fungi in applications such as water treatment, coatings, and personal care products. • Refractory and Friction materials: Hexamine’s heat resistance and stability make it useful in high-temperature refractory materials (used in kilns, incinerators, and furnaces) and as a binder in friction materials such as brake pads and clutch facings. 24 Petition, vol. 1, p. 3. 25 Petition, vol. 1, pp. 7 to 9. 26 Hexamine used in tire production is often of less than 95 percent concentration. Petition, vol. 1, p. 12. 1.14 • Polymers: Similar to some of its uses in rubber and tire production, hexamine serves as a crosslinker in certain polymers. Hexamine enhances the structural integrity of specialty polymers and coatings that require thermal stability and mechanical strength. • Metal Finishing: Hexamine serves as a corrosion inhibitor for metal surfaces, protecting against oxidation and degradation during industrial usage, notably in construction, manufacturing, and automobiles. Manufacturing processes Hexamine is produced from a chemical reaction involving ammonia (NH3 ) and formaldehyde (CH2 O or HCHO).27 Petitioner produces its own formaldehyde via catalytic oxidation of methanol (CH3 OH or MeOH) (figure 1.1), which yields gaseous formaldehyde and water (CH3 OH + O2 CH2 O + H2 O).28 The formaldehyde gas then goes into an absorption column where it is condensed and absorbed into water.29 The resulting solution has a concentration of approximately 50 percent formaldehyde.30 27 Petition, vol. 1, pp. 3 to 4. 28 The chemical reaction to produce formaldehyde occurs inside a reactor at a controlled temperature of approximately 350 o C using a metal oxide catalyst (e.g., iron-molybdenum). The temperature is regulated via a thermal fluid such as oil or steam which absorbs excess heat. Conference transcript p. 12 (Bazinet), Petition, vol. 1, pp. 4–5. An alternative method of industrial production of formaldehyde is referred to as the silver catalyst process. Gerberich, H.R., Seaman, G.C. and (2013). Formaldehyde. In Kirk-Othmer Encyclopedia of Chemical Technology, (Ed.). https://doi.org/10.1002/0471238961.0615181307051802.a01.pub3 29 Conference transcript, p. 13 (Bazinet). 30 Petition, vol. 1, p. 5. 1.15 Figure 1.1 Formaldehyde production process Source: Petition, vol. 1, p. 4. As seen in figure 1.2, formaldehyde (HCHO) is then mixed inside a reactor with anhydrous ammonia (NH3 ) as part of the initial step to produce hexamine: 6CH2 O + 4NH3 C6 H12 N 4 + 6H2 O.31 The heat of the resulting exothermic reaction must be controlled to ensure the quality of the final product.32 The main byproduct of this reaction is water (H2 O),33 which must be recovered and applied to other uses or disposed of in accordance with local laws and regulations.34 As the reaction proceeds, hexamine begins to precipitate out of the solution, creating solid crystals under controlled cooling conditions; the hexamine solution is then processed through a crystallizer unit (see Second Effect and First Effect in figure 1.2) in which evaporation takes place to lower the water content.35 31 Petition, vol. 1, p. 5. 32 Petition, vol. 1, p. 5. 33 Petition, vol. 1, p. 5. 34 Conference transcript, p. 30 (Bazinet). 35 Conference transcript, p. 13 (Bazinet). 1.16 Figure 1.2 Hexamine production process Source: Petition, vol. 1, p. 5. After the crystallization process, the resulting “slurry” mixture is sent to a centrifuge to separate the hexamine crystals from water and any other unreacted materials.36 The extracted crystals are sent to a dryer unit to remove any residual moisture. 37 If the moisture is properly controlled, hexamine in its solid form can have a shelf life of a year or longer.38 In cases where a smaller particle size is required, the hexamine crystals can be ground into a fine powder.39 Hexamine is packaged into containers ranging from 50-pound bags to 2,000-pound supersacks.40 Before packaging, petitioner may also further finish hexamine into several different liquid and solid products, as the petitioner produces liquid products with hexamine diluted to various concentrations.41 The highest possible concentration of hexamine in water is 40 to 45 percent, as precipitation starts to occur above that concentration.42 Petitioner also sells hexamine in the following solid forms: granular hexamine (pure or high concentration), hexamine with a stabilizer to prevent clumping or improve product flow, and hexamine with 36 Conference transcript, p. 13 (Bazinet). 37 Petition, vol. 1, p. 6. 38 Conference transcript, p. 38 (Bazinet). 39 Petition, vol. 1, p. 6. 40 Petition, vol. 1, p. 6. 41 Conference transcript, p. 39 (Roderick). 42 Conference transcript, p. 26 (Bazinet). 1.17 additives to both improve product flow and suppress dust (resulting in a lower concentration of hexamine).43 Both the petitioner and the Indian respondent, Kanoria Chemicals & Industries Limited (“Kanoria”), manufacture their own formaldehyde. Similar to the petitioner, Kanoria also begins hexamine production by producing formaldehyde from methanol44 and produces both pure granular hexamine and granular hexamine with additives for the U.S. market.45 Domestic like product issues No issues with respect to the domestic like product have been raised in these investigations. In the preliminary phase of these investigations, the Commission defined a single domestic like product consisting of hexamine, coextensive with the scope.46 In the final phase of these investigations, no parties requested data or other information necessary for the analysis of the domestic like product. In its prehearing brief, the petitioner argued that the Commission should find a single domestic like product (i.e., granular hexamine coextensive with the scope as defined by Commerce).47 Respondent General Authority for Foreign Trade of Saudi Arabia (“GAFT”) noted in its prehearing brief that it does not dispute the domestic like product proposed by the petitioner.48 Respondent Kanoria made no arguments with respect to the domestic like product in its prehearing brief. 43 Petition, vol. 1, pp. 11 to 12, conference transcript, pp. 32 to 33, 39 (Roderick). Additives include silica, diisodecyl phthalate, or benzoic acid. 44 Conference transcript, pp. 56 to 57 (Ojha). 45 Conference transcript, pp. 57 to 58 (Ojha). 46 Hexamine from China, Germany, India, and Saudi Arabia, Inv. Nos. 701-TA-737-738 and 731-TA- 1712-1715 (Preliminary), USITC Publication 5563, November 2024 (“Preliminary publication”), p. 7. 47 Petitioner prehearing brief, July 11, 2025, p. 4. 48 Respondent GAFT prehearing brief, July 11, 2025, p. 3. 2.1 Part 2: Conditions of competition in the U.S. market Hexamine is a crystalline organic compound derived from ammonia and formaldehyde that is commonly used in products such as explosives and munitions, resins, rubber and tires, and other applications. Bakelite, the sole U.S. producer of granular hexamine, sells hexamine to various end-users and uses hexamine to manufacture and sell phenolic resins.1 In 2021, Russia (a nonsubject country in these investigations) was the largest source of U.S. imports of hexamine, but imports from Russia began to decline ahead of the Russian invasion of Ukraine and continued to decline until Russia exited the U.S. market entirely in 2023.2 According to Bakelite, there are several producers of hexamine in China while Germany, India, and Saudi Arabia each have one major producer.3 The sole U.S. producer, Bakelite, indicated that the market *** subject to distinctive conditions of competition. Specifically, U.S. producer Bakelite reported that “***.” Most responding importers (6 of 8) and purchasers (4 of 5) reported that the market was not subject to distinctive conditions of competition, although purchaser *** reported otherwise, indicating that “***.” Apparent U.S. consumption of hexamine in the total market by quantity declined by *** percent from January 2022 to December 2024 and was *** percent lower during interim 2025 compared with interim 2024. U.S. purchasers The Commission received six usable questionnaire responses from firms that had purchased hexamine between January 2022 and March 2025.4 5 6 One responding purchaser is 1 Preliminary publication, p. 2.1. 2 Russian authorities seized control of Metafrax Chemicals, the largest producer of hexamine in Russia, in 2023. Ibid. 3 Ibid. 4 The following firms provided purchaser questionnaire responses: ***, ***, ***, ***, ***, and ***. 5 Of the six responding purchasers, five purchased the domestic hexamine, two purchased imports of the subject merchandise from China, three purchased imports of hexamine from Germany, three purchased imports of hexamine from India, three purchased imports of hexamine from Saudi Arabia, two purchased imports of hexamine from nonsubject Russia, and one purchased imports of hexamine from “unknown” sources. 6 Six purchasers indicated they had marketing/pricing knowledge of domestic product, three of product imported from China, three of product imported from Germany, four of product imported from India, four of product imported from Saudi Arabia, and three of product imported from nonsubject countries (specifically, Russia and the Netherlands). 2.2 a ***, one is a ***, one is a ***, another is a ***, one is a ***, and one is a ***.7 In general, responding U.S. purchasers were located in the Midwest and Southeast. The largest responding purchaser was ***, followed by ***.8 Impact of section 301 tariffs and new or modified tariffs The U.S. producer, importers, and purchasers were asked to report the impact of section 301 tariffs and new or modified tariffs on overall demand, supply, prices, or raw material costs (table 2.1). The U.S. producer reported *** impact on the U.S. market from 301 tariffs *** from new and modified tariffs. Most responding importers (6 of 8) and purchasers (4 of 6) reported that they did not know if the section 301 tariffs had an impact on the market. Four of eight responding importers and one of six responding purchasers reported that new or modified tariffs had an impact on the hexamine market. 7 Shell sand is a foundry product used in a casting process that utilizes a heated metal pattern to form a hardened shell of sand and resin, which is then used to create metal casting molds or cores. 8 *** reported the firm is owned by ***. 2.3 Table 2.1 Hexamine: Count of firms' responses regarding the impact of the 301 tariffs and new or modified tariffs on China origin products Item Firm type No Yes |Don't know| Impact on U.S. market from section 301 tariffs U.S. producers *** *** *** Impact on U.S. market from section 301 tariffs Importers 1 1 6 Impact on U.S. market from section 301 tariffs Purchasers 2 0 4 Impact of new or modified tariffs U.S. producers *** *** *** Impact of new or modified tariffs Importers 0 4 4 Impact of new or modified tariffs Purchasers 1 1 4 Source: Compiled from data submitted in response to Commission questionnaires. Channels of distribution The U.S. producer sold mainly to ***, while importers sold mainly to ***, as shown in table 2.2. 2.4 Table 2.2 Hexamine: Share of U.S. shipments by source, channel of distribution, and period Shares in percent; interim is January through March Source Channel 2022 2023 2024 Interim 2024 Interim 2025 United States Distributors *** *** *** *** *** United States Tire and rubber end users *** *** *** *** *** United States Petrochemical and plastic end users *** *** *** *** *** United States All other end users *** *** *** *** *** China Distributors *** *** *** *** *** China Tire and rubber end users *** *** *** *** *** China Petrochemical and plastic end users *** *** *** *** *** China All other end users *** *** *** *** *** Germany Distributors *** *** *** *** *** Germany Tire and rubber end users *** *** *** *** *** Germany Petrochemical and plastic end users *** *** *** *** *** Germany All other end users *** *** *** *** *** India Distributors *** *** *** *** *** India Tire and rubber end users *** *** *** *** *** India Petrochemical and plastic end users *** *** *** *** *** India All other end users *** *** *** *** *** Saudi Arabia Distributors *** *** *** *** *** Saudi Arabia Tire and rubber end users *** *** *** *** *** Saudi Arabia Petrochemical and plastic end users *** *** *** *** *** Saudi Arabia All other end users *** *** *** *** *** Table continued. 2.5 Table 2.2 (Continued) Hexamine: Share of U.S. shipments by source, channel of distribution, and period Shares in percent; interim is January through March Source Channel 2022 2023 2024 Interim 2024 Interim 2025 Subject Distributors *** *** *** *** *** Subject Tire and rubber end users *** *** *** *** *** Subject Petrochemical and plastic end users *** *** *** *** *** Subject All other end users *** *** *** *** *** Russia (nonsubject) Distributors *** *** *** *** *** Russia (nonsubject) Tire and rubber end users *** *** *** *** *** Russia (nonsubject) Petrochemical and plastic end users *** *** *** *** *** Russia (nonsubject) All other end users *** *** *** *** *** All other sources Distributors *** *** *** *** *** All other sources Tire and rubber end users *** *** *** *** *** All other sources Petrochemical and plastic end users *** *** *** *** *** All other sources All other end users *** *** *** *** *** Nonsubject Distributors *** *** *** *** *** Nonsubject Tire and rubber end users *** *** *** *** *** Nonsubject Petrochemical and plastic end users *** *** *** *** *** Nonsubject All other end users *** *** *** *** *** All imports Distributors *** *** *** *** *** All imports Tire and rubber end users *** *** *** *** *** All imports Petrochemical and plastic end users *** *** *** *** *** All imports All other end users *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than “0.05” percent. Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 2.6 Geographic distribution The U.S. producer reported selling hexamine to *** regions in the contiguous United States and subject importers reported selling to all regions except the Mountains region (table 2.3). For the U.S. producer, *** percent of sales were within 100 miles of their production facility, *** percent were between 101 and 1,000 miles, and *** percent were over 1,000 miles. Five importers reported that a vast majority, between 90 and 100 percent, of sales were delivered between 101 and 1,000 miles of their firm’s U.S. point of shipment, two reported that all sales were within 100 miles of their firm’s U.S. point of shipment, and one importer reported that all sales were over 1,000 miles of their firm’s U.S. point of shipment. Table 2.3 Hexamine: Count of U.S. producer’s and U.S. importers’ geographic markets Count in number of firms reporting Region U.S. producer China Germany India Saudi Arabia Subject sources Northeast *** *** *** 2 *** 5 Midwest *** *** *** 1 *** 4 Southeast *** *** *** 0 *** 3 Central Southwest *** *** *** 1 *** 1 Mountains *** *** *** 0 *** 0 Pacific Coast *** *** *** 0 *** 2 Other *** *** *** 0 *** 0 All regions (except Other) *** *** *** 0 *** 0 Reporting firms 1 2 2 4 2 8 Source: Compiled from data submitted in response to Commission questionnaires. Note: Other U.S. markets include AK, HI, PR, and VI. Supply and demand considerations U.S. supply Table 2.4 provides a summary of the supply factors regarding hexamine from the U.S. producer and from subject countries.9 Producers in *** have greater capacity than the U.S. producer, and this capacity has increased from 2022 to 2024. The capacity utilization rates for the U.S. producer were lower than those for all subject countries. Between 2022 and 2024, the U.S. producer’s capacity utilization decreased and foreign producers’ capacity utilization rates increased for the responding subject producers. 9 The Commission received two questionnaires from foreign producers in India, one from a foreign producer in Germany, and one from a foreign producer in Saudi Arabia. No foreign producers from China responded. 2.7 Table 2.4 Hexamine: Supply factors that affect the ability to increase shipments to the U.S. market, by country Quantity in pounds; ratio and share in percent Factor Measure United States China Germany India Saudi Arabia Subject Suppliers Capacity 2022 Quantity *** *** *** *** *** *** Capacity 2024 Quantity *** *** *** *** *** *** Capacity utilization 2022 Ratio *** *** *** *** *** *** Capacity utilization 2024 Ratio *** *** *** *** *** *** Inventories to total shipments 2022 Ratio *** *** *** *** *** *** Inventories to total shipments 2024 Ratio *** *** *** *** *** *** Home market shipments 2024 Share *** *** *** *** *** *** Non-US export market shipments 2024 Share *** *** *** *** *** *** Ability to shift production Count *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: The U.S. producer accounted for all of U.S. production of hexamine in 2024. Responding foreign producer/exporter firms in Germany and Saudi Arabia are believed to account for *** production of hexamine in their respective countries in 2024, while the two responding subject producers in India are estimated to account for *** of production of hexamine in 2024. No responses were received from firms in China. For additional data on the number of responding firms and their share of U.S. production and of U.S. imports from each subject country, please refer to Parts 3 and 7. Domestic production Based on available information, U.S. hexamine producer Bakelite has the ability to respond to changes in demand with large changes in the quantity of shipments of U.S.- produced hexamine to the U.S. market. The main contributing factors to this degree of responsiveness of supply is the U.S. producer’s ***.10 Factors mitigating responsiveness of supply include 10 Regarding supply constraints, Bakelite reports that it ***. 2.8 ***. 11 Subject imports from Germany Based on available information, the producer of hexamine from Germany has the ability to respond to changes in demand with moderate to large changes in the quantity of shipments of hexamine to the U.S. market. The main contributing factors to this degree of responsiveness of supply are the ability to shift shipments from alternate markets to the U.S. market. Factors mitigating responsiveness of supply include a very high capacity utilization rate, an inability to shift production to or from other products, and limited availability of inventories. Subject imports from India Based on available information, producers of hexamine from India have the ability to respond to changes in demand with small to moderate changes in the quantity of shipments of hexamine to the U.S. market. The main contributing factors to this degree of responsiveness of supply are the ability to shift shipments from alternate markets or inventories to the U.S. market and the availability of unused capacity. Factors mitigating responsiveness of supply include the high level of home market shipments, an inability to shift production from alternate products, and low inventory levels. Subject imports from Saudi Arabia Based on available information, the producer in Saudi Arabia has the ability to respond to changes in demand with large changes in the quantity of shipments of hexamine to the U.S. market. The main contributing factors to this degree of responsiveness of supply is the ability to shift shipments from alternate markets to the U.S. market. Factors mitigating responsiveness of supply include the high capacity utilization rate, an inability to shift production from alternate products, and low inventory levels. 11 For more information regarding the U.S. producer’s ***, see Part 3. 2.9 Imports from nonsubject sources According to questionnaire data and official import statistics, Russia was the largest source of U.S. imports of hexamine in 2022 and 2023; however, imports from Russia began to decline ahead of the Russian invasion of Ukraine and continued to decline until Russia exited the U.S. market entirely by July 2023. Russia accounted for *** percent of nonsubject source imports in 2023, according to data submitted in response to Commission questionnaires. In 2024, nonsubject imports accounted for *** percent of total reported U.S. imports.12 Supply constraints U.S. producer Bakelite reported that it *** supply constraints since January 1, 2022. Four of seven responding importers reported that they had not experienced supply constraints since January 1, 2022. Of those that reported they had experienced supply constraints, three reported the constraints occurred during 2022, one reported they occurred during 2023, two during 2024, and two during 2025 (table 2.5). Constraints reported by importers included ***. Importer *** reported that the producer in Germany *** has been in tight supply for hexamine *** due to the merchandise from Russia being effectively blocked in the European market, which increased demand in the EU market; this has led to less material available to export to the U.S. market and longer lead times. Two responding purchasers reported that they had experienced supply constraints, with one reporting supply constraints from the domestic producers between 2022 through 2024 and the other purchaser reporting supply constraints from subject foreign producers or importers between 2024 and 2025. Constraints purchasers experienced by domestic producers were for “orders subject to fulfillment based on supply chain shortages” and the constraints they experienced from subject producers or importers were due to capacity constraints. One purchaser reported that supply constraints arose due to the petition filed on September 30, 2024, reporting that their suppliers had “withheld shipments due to unknown petition penalties”. 12 Importers reported *** as nonsubject sources. 2.10 Table 2.5 Hexamine: Count of firms’ responses regarding timing of supply constraints, by firm type and source Count in number of firms reporting Firm type Source 2022 2023 2024 January 1, 2025 - present U.S. producers Domestic *** *** *** *** Importers Imported 3 1 2 2 Purchasers Domestic 1 1 1 0 Purchasers Imported 0 0 1 1 Source: Compiled from data submitted in response to Commission questionnaires. New suppliers No purchasers reported that new suppliers had entered the U.S. market since January 1, 2022. U.S. demand Based on available information, the overall demand for hexamine is likely to experience small changes in response to changes in price. The main contributing factors are the lack of substitute products and the small cost share of hexamine in its reported end-use products. End uses and cost share U.S. demand for hexamine depends on the demand for U.S.-produced downstream products, some of which follow general economic conditions.13 Firms reported end uses including phenolic polymers, munitions, rubbers and tires, petrochemicals, cleaning products, formaldehyde-based resins, resin-coated frack sands, rubber moldings, and shell sand. In these reported end uses, hexamine accounts for a wide range in the cost of the end-use products in which it is used. Firms reported cost shares for these end uses as: cleaning products (*** percent), formaldehyde-based resins (*** percent), munitions (*** percent), phenolic polymers (*** to *** percent), resin-coated frack sands(*** percent), rubber moldings (*** percent), shell sand (*** percent), and tires and rubber (*** to *** percent). 13 Preliminary publication, p. 2.8. 2.11 Business cycles The U.S. producer reported that the market ***. Bakelite described demand as “***”. Six of eight importers, and all responding purchasers indicated that the market was not subject to business cycles. Importer *** reported that demand depends on demand for end use products, stating that “our customers’ demand is subject to increases and decreases in demand based on the sales of their finished products.” Demand trends Most firms reported no change or a decrease in U.S. demand for hexamine since January 1, 2022 (table 2.6). U.S. producer Bakelite reported *** in U.S. demand for hexamine since January 1, 2022, describing the principal factors affecting the change in demand as “***.” Purchaser *** reported that demand for hexamine ***. Table 2.6 Hexamine: Count of firms’ responses regarding overall domestic and foreign demand, by firm type Count in number of firms reporting Market Firm type Steadily Increase Fluctuate upward No change Fluctuate downward Steadily decrease Domestic demand U.S. producer *** *** *** *** *** Domestic demand Importers 1 0 4 2 1 Domestic demand Purchasers 0 0 2 1 0 Foreign demand U.S. producer *** *** *** *** *** Foreign demand Importers 0 0 2 1 0 Foreign demand Purchasers 1 0 1 1 0 Demand for end use products Purchasers 0 0 2 3 1 Source: Compiled from data submitted in response to Commission questionnaires. Substitute products U.S. producer Bakelite reported that there *** substitutes for hexamine, and all responding importers and almost all purchasers (5 of 6) reported that there were no substitutes for hexamine. Purchaser *** reported that ***. 2.12 Substitutability issues This section assesses the degree to which U.S.-produced hexamine and imports of hexamine from subject countries can be substituted for one another by examining the importance of certain purchasing factors and the comparability of hexamine from domestic and imported sources based on those factors. Based on available data, staff believes that there is a moderate degree of substitutability between domestically produced hexamine and hexamine imported from subject sources.14 Factors contributing to this level of substitutability include similarities in reported quality between domestically produced hexamine and hexamine produced in subject countries and little preference for a particular country of origin or producers. Factors reducing substitutability include higher lead times for hexamine produced in subject sources, some quality differences between domestically produced hexamine and hexamine produced in China (as reported by importer ***, for example), and purchaser preferences for hexamine from subject and nonsubject countries over domestic hexamine due to competition with U.S. producer Bakelite in downstream product sales. Factors affecting purchasing decisions Purchaser decisions based on source As shown in table 2.7, most purchasers and their customers only sometimes or never make purchasing decisions based on the producer or country of origin. Table 2.7 Hexamine: Count of purchasers’ responses regarding frequency of purchasing decisions based on producer and country of origin Count in number of firms reporting Firm making decision Decision based on Always Usually Sometimes Never Purchaser Producer 0 1 1 4 Customer Producer 0 0 0 4 Purchaser Country 0 0 2 3 Customer Country 0 0 0 4 Source: Compiled from data submitted in response to Commission questionnaires. 14 The degree of substitution between domestic and imported hexamine depends upon the extent of product differentiation between the domestic and imported products and reflects how easily purchasers can switch from domestically produced hexamine to the hexamine imported from subject countries (or vice versa) when prices change. The degree of substitution may include such factors as quality differences (e.g., grade standards, defect rates, etc.), and differences in sales conditions (e.g., lead times between order and delivery dates, reliability of supply, product services, etc.). 2.13 Importance of purchasing domestic product All responding purchasers reported that their purchases did not require purchasing U.S.- produced product. Most important purchase factors The most often cited top three factors firms consider in their purchasing decisions for hexamine were price/cost (6 firms), quality (5 firms), and availability/supply (5 firms) as shown in table 2.8. Quality was the most frequently cited first-most important factors (cited by 3 firms); price/cost was the most frequently reported second-most important factor (4 firms); and availability/supply was the most frequently reported third-most important factor (4 firms). Other reported factors include lead times and downstream competition with the seller. Table 2.8 Hexamine: Count of ranking of factors used in purchasing decisions as reported by purchasers, by factor Count in number of firms reporting Factor First Second Third Total Price / Cost 1 4 1 6 Quality 3 2 0 5 Availability / Supply 1 0 4 5 All other factors 1 0 1 NA Source: Compiled from data submitted in response to Commission questionnaires. Note: Other factors include downstream competition with the seller. Importance of specified purchase factors Purchasers were asked to rate the importance of 16 factors in their hexamine purchasing decisions (table 2.9). The factors rated as very important by more than half of responding purchasers were availability, product consistency, quality meeting industry standards (6 firms each), price, purity, and reliability of supply (5 firms each), and delivery times (4 firms). Factors reported as somewhat important by a majority of firms include quality exceeding industry standards (5 firms), discounts offered (4 firms), payment terms (4 firms), product range (4 firms), technical support/service (4 firms), and U.S. transportation costs (4 firms). 2.14 Table 2.9 Hexamine: Count of purchasers’ responses regarding importance of purchase factors, by factor Count in number of firms reporting Factor Very important Somewhat important Not important Availability 6 0 0 Delivery terms 2 3 1 Delivery time 4 2 0 Discounts offered 0 4 2 Minimum quantity requirements 0 2 4 Packaging 2 3 1 Payment terms 2 4 0 Price 5 1 0 Product consistency 6 0 0 Product range 0 4 2 Purity 5 1 0 Quality meets industry standards 6 0 0 Quality exceeds industry standards 0 5 1 Reliability of supply 5 1 0 Technical support/service 0 4 2 U.S. transportation costs 1 4 1 Source: Compiled from data submitted in response to Commission questionnaires. Lead times U.S. producer, Bakelite, reported that *** percent of its commercial shipments in 2024 were from inventory, with an average lead time of *** days. ***, responding importers reported that *** percent of their commercial shipments were produced-to-order, with lead times averaging *** days. Supplier certification Three of six responding purchasers (***, ***, and ***) require their suppliers to become certified or qualified to sell hexamine to their firm. One purchaser, ***, reported that a foreign supplier *** had failed in its attempt to qualify hexamine since 2022, stating “***.” Three responding purchasers reported that hexamine purchasers undergo a negotiation process on terms including product availability, quality, delivery times, sources, and price. Minimum quality specifications As can be seen from table 2.10, five responding purchasers reported that domestically produced product always met minimum quality specifications. Half or more of responding purchasers reported that the hexamine imported from India and Saudi Arabia always met 2.15 minimum quality specifications. Two purchasers reported that hexamine from China always meets firms’ customers’ minimum quality specifications (and the remaining three purchasers reported that they did not know about Chinese suppliers’ ability to meet minimum quality specifications). Table 2.10 Hexamine: Count of purchasers’ responses regarding suppliers’ ability to meet minimum quality specifications, by source Count in number of firms reporting Source of purchases Always Usually Sometimes Rarely or never Don't Know United States 5 1 0 0 0 China 2 0 0 0 3 Germany 3 0 0 0 3 India 3 1 0 0 2 Saudi Arabia 3 1 0 0 1 Nonsubject sources 1 0 0 0 1 Source: Compiled from data submitted in response to Commission questionnaires. Note: Purchasers were asked how often domestically produced or imported hexamine meets minimum quality specifications for their own or their customers’ uses. Changes in purchasing patterns Four out of six responding purchasers reported that they had changed suppliers since January 1, 2022. Specifically, firms reported that they added or increased purchases from importer Magnum International, German producer Brenntag, and Sovereign Chemical to increase security of supply. Purchasers were also asked about changes in their purchasing patterns from different countries since January 1, 2022 (table 2.11). Two purchasers reported that their purchase pattern regarding U.S.-produced hexamine remained unchanged, although *** reported that purchase volumes increased in 2022, due to ocean freight issues disrupting supply chains. Two purchasers reported increased purchases of product from subject sources to qualify supply, “build relationships,” and obtain new suppliers. 2.16 Table 2.11 Hexamine: Count of purchasers’ responses regarding changes in purchase patterns from U.S., subject, and nonsubject countries Count in number of firms reporting Source of purchases Steadily Increase Fluctuate upward No change Fluctuate downward Steadily Decrease Did not purchase United States 1 1 2 0 1 0 China 0 0 0 0 2 3 Germany 1 0 1 0 1 0 India 1 2 0 0 0 0 Saudi Arabia 1 0 0 1 1 1 Russia 0 0 0 1 1 2 Other nonsubject sources 0 0 0 0 0 2 Sources unknown 0 0 0 1 0 1 Source: Compiled from data submitted in response to Commission questionnaires. Purchase factor comparisons of domestic products, subject imports, and nonsubject imports Purchasers were asked a number of questions comparing hexamine produced in the United States, subject countries, and nonsubject countries. First, purchasers were asked for a country-by-country comparison on the same 16 factors (table 2.12) for which they were asked to rate the importance. Most purchasers reported that U.S.-produced hexamine and hexamine imported from China, Germany, India, Saudi Arabia, and nonsubject sources were comparable on all factors except on delivery time, which purchasers reported as superior for U.S.-produced hexamine. 2.17 Table 2.12 Hexamine: Count of purchasers’ responses comparing U.S.-produced and imported product, by factor and country pair Count in number of firms reporting Factor Country pair Superior Comparable Inferior Availability U.S. vs China 1 1 0 Delivery terms U.S. vs China 1 1 0 Delivery time U.S. vs China 1 1 0 Discounts offered U.S. vs China 0 2 0 Minimum quantity requirements U.S. vs China 0 2 0 Packaging U.S. vs China 0 2 0 Payment terms U.S. vs China 0 2 0 Price1 U.S. vs China 0 1 1 Product consistency U.S. vs China 0 2 0 Product range U.S. vs China 0 2 0 Purity U.S. vs China 0 2 0 Quality meets industry standards U.S. vs China 0 2 0 Quality exceeds industry standards U.S. vs China 0 2 0 Reliability of supply U.S. vs China 0 2 0 Technical support/service U.S. vs China 0 2 0 U.S. transportation costs U.S. vs China 0 2 0 Table continued. Table 2.12 (Continued) Hexamine: Count of purchasers’ responses comparing U.S.-produced and imported product, by factor and country pair Count in number of firms reporting Factor Country pair Superior Comparable Inferior Availability U.S. vs Germany 1 2 0 Delivery terms U.S. vs Germany 0 3 0 Delivery time U.S. vs Germany 3 0 0 Discounts offered U.S. vs Germany 0 2 0 Minimum quantity requirements U.S. vs Germany 0 3 0 Packaging U.S. vs Germany 0 3 0 Payment terms U.S. vs Germany 0 3 0 Price U.S. vs Germany 1 1 1 Product consistency U.S. vs Germany 1 2 0 Product range U.S. vs Germany 0 3 0 Purity U.S. vs Germany 1 2 0 Quality meets industry standards U.S. vs Germany 0 3 0 Quality exceeds industry standards U.S. vs Germany 0 2 0 Reliability of supply U.S. vs Germany 1 2 0 Technical support/service U.S. vs Germany 0 2 0 U.S. transportation costs U.S. vs Germany 0 2 1 Table continued. 2.18 Table 2.12 (Continued) Hexamine: Count of purchasers’ responses comparing U.S.-produced and imported product, by factor and country pair Count in number of firms reporting Factor Country pair Superior Comparable Inferior Availability U.S. vs India 1 3 0 Delivery terms U.S. vs India 0 4 0 Delivery time U.S. vs India 3 1 0 Discounts offered U.S. vs India 0 3 0 Minimum quantity requirements U.S. vs India 0 4 0 Packaging U.S. vs India 0 4 0 Payment terms U.S. vs India 0 4 0 Price U.S. vs India 0 2 2 Product consistency U.S. vs India 0 4 0 Product range U.S. vs India 0 4 0 Purity U.S. vs India 0 4 0 Quality meets industry standards U.S. vs India 0 4 0 Quality exceeds industry standards U.S. vs India 0 3 0 Reliability of supply U.S. vs India 1 3 0 Technical support/service U.S. vs India 0 3 0 U.S. transportation costs U.S. vs India 0 3 1 Table continued. Table 2.12 (Continued) Hexamine: Count of purchasers’ responses comparing U.S.-produced and imported product, by factor and country pair Count in number of firms reporting Factor Country pair Superior Comparable Inferior Availability U.S. vs Saudi Arabia 1 2 0 Delivery terms U.S. vs Saudi Arabia 0 3 0 Delivery time U.S. vs Saudi Arabia 3 0 0 Discounts offered U.S. vs Saudi Arabia 0 2 0 Minimum quantity requirements U.S. vs Saudi Arabia 0 3 0 Packaging U.S. vs Saudi Arabia 0 3 0 Payment terms U.S. vs Saudi Arabia 0 3 0 Price U.S. vs Saudi Arabia 1 1 1 Product consistency U.S. vs Saudi Arabia 1 2 0 Product range U.S. vs Saudi Arabia 0 3 0 Purity U.S. vs Saudi Arabia 1 2 0 Quality meets industry standards U.S. vs Saudi Arabia 0 3 0 Quality exceeds industry standards U.S. vs Saudi Arabia 0 2 0 Reliability of supply U.S. vs Saudi Arabia 1 2 0 Technical support/service U.S. vs Saudi Arabia 0 2 0 U.S. transportation costs U.S. vs Saudi Arabia 0 2 1 Table continued. 2.19 Table 2.12 (Continued) Hexamine: Count of purchasers’ responses comparing U.S.-produced and imported product, by factor and country pair Count in number of firms reporting Factor Country pair Superior Comparable Inferior Availability U.S. vs. Nonsubject 1 2 0 Delivery terms U.S. vs. Nonsubject 0 3 0 Delivery time U.S. vs. Nonsubject 3 0 0 Discounts offered U.S. vs. Nonsubject 0 2 0 Minimum quantity requirements U.S. vs. Nonsubject 0 3 0 Packaging U.S. vs. Nonsubject 0 3 0 Payment terms U.S. vs. Nonsubject 0 3 0 Price U.S. vs. Nonsubject 1 1 1 Product consistency U.S. vs. Nonsubject 1 2 0 Product range U.S. vs. Nonsubject 0 3 0 Purity U.S. vs. Nonsubject 1 2 0 Quality meets industry standards U.S. vs. Nonsubject 0 3 0 Quality exceeds industry standards U.S. vs. Nonsubject 0 2 0 Reliability of supply U.S. vs. Nonsubject 1 2 0 Technical support/service U.S. vs. Nonsubject 0 2 0 U.S. transportation costs U.S. vs. Nonsubject 0 2 1 Source: Compiled from data submitted in response to Commission questionnaires. Note: With respect to cost/price factors, a rating of superior means that the cost/price for the first source in the country pair is generally lower. For example, if a firm reported “U.S. superior” for price, it meant that the U.S. product was generally priced lower than the imported product. Comparison of U.S.-produced and imported hexamine In order to determine whether U.S.-produced hexamine can generally be used in the same applications as imports from China, Germany, India, and Saudi Arabia, the U.S. producer, importers, and purchasers were asked whether the products can always, frequently, sometimes, or never be used interchangeably. As shown in tables 2.13, Bakelite reported that hexamine is *** interchangeable in most comparisons. As shown in table 2.14, importers’ responses regarding interchangeability varied, with more firms responding that the product is sometimes interchangeable. Importer ***, for example, reported that hexamine from China is “frequently of lower quality,” and interchangeability would depend on the customers’ intended end-use application. Table 2.15 shows that most purchasers report that hexamine is always or frequently interchangeable in most comparisons. 2.20 Table 2.13 Hexamine: Count of U.S. producer reporting the interchangeability between product produced in the United States and in other countries, by country pair Count in number of firms reporting Country pair Always Frequently Sometimes Never United States vs. China *** *** *** *** United States vs. Germany *** *** *** *** United States vs. India *** *** *** *** United States vs. Saudi Arabia *** *** *** *** China vs. Germany *** *** *** *** China vs. India *** *** *** *** China vs. Saudi Arabia *** *** *** *** Germany vs. India *** *** *** *** Germany vs. Saudi Arabia *** *** *** *** India vs. Saudi Arabia *** *** *** *** United States vs. Other *** *** *** *** China vs. Other *** *** *** *** Germany vs. Other *** *** *** *** India vs. Other *** *** *** *** Saudi Arabia vs. Other *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Table 2.14 Hexamine: Count of importers reporting the interchangeability between product produced in the United States and in other countries, by country pair Count in number of firms reporting Country pair Always Frequently Sometimes Never United States vs. China 0 1 1 0 United States vs. Germany 1 1 1 0 United States vs. India 0 1 1 0 United States vs. Saudi Arabia 0 1 1 1 China vs. Germany 0 0 2 0 China vs. India 0 0 1 0 China vs. Saudi Arabia 0 0 1 0 Germany vs. India 1 1 0 0 Germany vs. Saudi Arabia 0 0 1 0 India vs. Saudi Arabia 0 0 1 0 United States vs. Other 0 1 1 0 China vs. Other 0 0 0 0 Germany vs. Other 1 0 0 0 India vs. Other 1 0 0 0 Saudi Arabia vs. Other 0 0 0 0 Source: Compiled from data submitted in response to Commission questionnaires. 2.21 Table 2.15 Hexamine: Count of purchasers reporting the interchangeability between product produced in the United States and in other countries, by country pair Count in number of firms reporting Country pair Always Frequently Sometimes Never United States vs. China 2 0 1 0 United States vs. Germany 1 2 0 0 United States vs. India 1 3 0 0 United States vs. Saudi Arabia 2 2 0 0 China vs. Germany 0 0 1 0 China vs. India 0 0 1 0 China vs. Saudi Arabia 0 0 0 0 Germany vs. India 1 1 1 0 Germany vs. Saudi Arabia 1 0 1 0 India vs. Saudi Arabia 1 1 0 0 United States vs. Other 0 2 0 0 China vs. Other 0 0 0 0 Germany vs. Other 0 0 1 0 India vs. Other 0 2 0 0 Saudi Arabia vs. Other 1 2 0 0 Source: Compiled from data submitted in response to Commission questionnaires. In addition, the U.S. producer, importers, and purchasers were asked to assess how often differences other than price were significant in sales of hexamine from the United States, subject, or nonsubject countries. As seen in tables 2.16 to 2.18, generally importers and purchasers report that there are sometimes significant factors other than price. U.S. producer Bakelite reported that hexamine produced in ***. Importer *** reported that customers are “moving away from material of Chinese origin” due to tariff and quality concerns. It added that supply availability and transportation are important factors when comparing product from the U.S. and Germany. 2.22 Table 2.16 Hexamine: Count of U.S. producers reporting the significance of differences other than price between product produced in the United States and in other countries, by country pair Count in number of firms reporting Country pair Always Frequently Sometimes Never United States vs. China *** *** *** *** United States vs. Germany *** *** *** *** United States vs. India *** *** *** *** United States vs. Saudi Arabia *** *** *** *** China vs. Germany *** *** *** *** China vs. India *** *** *** *** China vs. Saudi Arabia *** *** *** *** Germany vs. India *** *** *** *** Germany vs. Saudi Arabia *** *** *** *** India vs. Saudi Arabia *** *** *** *** United States vs. Other *** *** *** *** China vs. Other *** *** *** *** Germany vs. Other *** *** *** *** India vs. Other *** *** *** *** Saudi Arabia vs. Other *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Table 2.17 Hexamine: Count of importers reporting the significance of differences other than price between product produced in the United States and in other countries, by country pair Count in number of firm reporting Country pair Always Frequently Sometimes Never United States vs. China 1 0 1 0 United States vs. Germany 0 1 2 0 United States vs. India 0 1 1 0 United States vs. Saudi Arabia 1 1 1 0 China vs. Germany 0 0 2 0 China vs. India 0 0 1 0 China vs. Saudi Arabia 0 0 1 0 Germany vs. India 0 0 2 0 Germany vs. Saudi Arabia 0 0 1 0 India vs. Saudi Arabia 0 0 1 0 United States vs. Other 0 0 1 0 China vs. Other 0 0 0 0 Germany vs. Other 0 0 1 0 India vs. Other 0 0 1 0 Saudi Arabia vs. Other 0 0 0 0 Source: Compiled from data submitted in response to Commission questionnaires. 2.23 Table 2.18 Hexamine: Count of purchasers reporting the significance of differences other than price between product produced in the United States and in other countries, by country pair Count in number of firms reporting Country pair Always Frequently Sometimes Never United States vs. China 2 0 1 0 United States vs. Germany 1 1 1 0 United States vs. India 1 1 2 0 United States vs. Saudi Arabia 1 1 2 0 China vs. Germany 2 0 0 0 China vs. India 1 0 0 0 China vs. Saudi Arabia 0 0 0 0 Germany vs. India 1 0 2 0 Germany vs. Saudi Arabia 0 0 2 0 India vs. Saudi Arabia 0 0 2 0 United States vs. Other 1 1 1 0 China vs. Other 0 0 0 0 Germany vs. Other 0 0 1 0 India vs. Other 0 0 2 0 Saudi Arabia vs. Other 0 0 2 0 Source: Compiled from data submitted in response to Commission questionnaires. Elasticity estimates This section discusses elasticity estimates; parties did not comment on these estimates. U.S. supply elasticity The domestic supply elasticity for hexamine measures the sensitivity of the quantity supplied by U.S. producers to changes in the U.S. market price of hexamine. The elasticity of domestic supply depends on several factors including the level of excess capacity, the ease with which producers can alter capacity, producers’ ability to shift to production of other products, the existence of inventories, and the availability of alternate markets for U.S.-produced hexamine. Analysis of these factors above indicates that the U.S. industry has the ability to greatly increase or decrease shipments to the U.S. market; an estimate in the range of 6 to 8 is suggested. U.S. demand elasticity The U.S. demand elasticity for hexamine measures the sensitivity of the overall quantity demanded to a change in the U.S. market price of hexamine. This estimate depends on factors discussed above such as the existence, availability, and commercial viability of substitute products, as well as the component share of the hexamine in the production of any downstream products. Bakelite stated that hexamine is essential in its customers’ operations 2.24 and lacks substitutes.15 Based on the available information, the aggregate demand for hexamine is likely to be moderately inelastic; a range of -0.25 to -0.5 is suggested. Substitution elasticity The elasticity of substitution depends upon the extent of product differentiation between the domestic and imported products.16 Product differentiation, in turn, depends upon such factors as quality (e.g., chemistry, appearance, etc.) and conditions of sale (e.g., availability, sales terms/discounts/promotions, etc.). Based on available information, the elasticity of substitution between U.S.-produced hexamine and imported hexamine is likely to be in the range of in of 3 to 5. Factors contributing to this level of substitutability include: similarities in reported quality between domestically produced hexamine and hexamine produced in subject countries and little preference for particular country of origin or producers. Factors reducing substitutability include: higher lead times for hexamine produced in subject sources, quality differences between domestically produced hexamine and hexamine produced in China, and purchaser preferences for hexamine from subject and nonsubject countries.17 15 Hearing transcript, p. 11 (Brochmann). 16 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of the subject imports and the domestic like products to changes in their relative prices. This reflects how easily purchasers switch from the U.S. product to the subject products (or vice versa) when prices change. 17 On this point, purchasing firm *** added it “***.” 3.1 Part 3: U.S. producers’ production, shipments, and employment The Commission analyzes a number of factors in making injury determinations (see 19 U.S.C. §§ 1677(7)(B) and 1677(7)(C)). Information on the subsidies and dumping margins was presented in Part 1 of this report and information on the volume and pricing of imports of the subject merchandise is presented in Part 4 and Part 5. Information on the other factors specified is presented in this section and/or Part 6 and (except as noted) is based on the questionnaire response of one firm that accounted for all U.S. production of in-scope hexamine during 2024. U.S. producers The Commission issued a U.S. producer questionnaire to the petitioner, the sole U.S. producer of in-scope hexamine, who provided a questionnaire response.1 Table 3.1 lists the petitioner, its production location, position on the petition, and its share of total production. Table 3.1 Hexamine: U.S. producer, their position on the petition, production location, and share of reported production, 2024 Firm Position on petition Production location Share of production Bakelite Petitioner Riegelwood, NC 100.0 Source: Compiled from data submitted in response to Commission questionnaires. 1 The petitioner named one other company as a potential U.S. producer of hexamine in the petition: ***. During the preliminary phase of this proceeding, the company provided a certified response indicating that it had not produced in-scope hexamine during the investigation period. During the final phase, a company representative again responded, “***.” 3.2 Table 3.2 presents information on Bakelite’s ownership as indicated in its questionnaire response. Table 3.2 Hexamine: U.S. producers’ ownership, related and/or affiliated firms Reporting firm Relationship type and related firm Details of relationship Bakelite *** *** Bakelite *** *** Source: Compiled from data submitted in response to Commission questionnaires. Bakelite was asked to report any change in the character of its operations or organization relating to the production of hexamine since 2022, to which it replied that it had experienced *** as follows: “***.” 3.3 U.S. production, capacity, and capacity utilization Table 3.3 presents U.S. producer Bakelite’s installed and practical capacity measures and production using the same equipment/employees.2 Bakelite reported its installed overall capacity was *** at *** pounds for the full year periods (and *** pounds for the interim periods).3 Bakelite ***, thus the company’s ***. The company estimated that its practical capacity (in-scope and overall) was also *** at *** pounds for the full year periods (*** pounds for the interim periods).4 Bakelite’s in-scope hexamine production decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Its hexamine production was *** percent lower across the interim periods (*** pounds compared to *** pounds). Resultingly, Bakelite’s installed overall capacity utilization ratio decreased *** percentage points across the period (from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). It was *** percentage points lower across the interim periods (*** percent compared to *** percent). Bakelite’s practical capacity utilization ratio decreased *** percentage points from 2022 to 2024 (from *** percent in 2022 to *** percent in 2023 and to *** percent in 2 Installed or “theoretical” overall capacity measures the level of production a firm could have attained based solely on existing capital investments and not considering other constraints such as availability of material inputs, labor force, and normal downtime. The two practical capacity measures take into consideration both existing capital investment as well as non-capital investment constraints. Practical overall capacity measures firms’ capacity to produce hexamine as well as any other products produced using the same equipment/machinery, whereas practical hexamine capacity measures only the practical capacity of a firm to produce hexamine based on that firms’ actual product mixes over the period. 3 Bakelite reported that it calculated the installed capacity figure as follows: “***.” 4 Bakelite reported that it calculated its practical capacity figures as follows: “***.” The company reported that it would need to do the following to achieve its reported installed capacity: “***.” 3.4 2024). Practical capacity utilization was *** percentage points lower across the interim periods (*** percent compared to *** percent). Table 3.3 Hexamine: U.S. producer Bakelite's installed and practical capacity and production on the same equipment as in-scope production, by period Capacity and production in 1,000 pounds; utilization in percent; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Installed overall Capacity *** *** *** *** *** Installed overall Production *** *** *** *** *** Installed overall Utilization *** *** *** *** *** Practical overall Capacity *** *** *** *** *** Practical overall Production *** *** *** *** *** Practical overall Utilization *** *** *** *** *** Practical hexamine Capacity *** *** *** *** *** Practical hexamine Production *** *** *** *** *** Practical hexamine Utilization *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Figure 3.1 Hexamine: U.S. producer Bakelite's practical capacity, production, and capacity utilization, by period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 3.5 Alternative products During the preliminary phase, Bakelite reported the production of out-of-scope aqueous hexamine (“OOS aqueous hexamine”) using the same machinery and/or employees as used to produce in-scope hexamine. OOS aqueous hexamine is less than 50 percent hexamine by weight, and thus out-of-scope. However, during the final phase, the company did not report the production of any alternative products using the same machinery and/or equipment in its capacity table. The company indicated: “***.” Bakelite provided the following estimates of its shipments of liquid hexamine in pounds during the investigation period and noted: “***.”5 5 Email correspondence with ***. 3.6 U.S. producers’ U.S. shipments and exports Bakelite’s total shipments Table 3.4 presents Bakelite’s U.S. shipments, export shipments, and total shipments. U.S. shipments accounted for the vast majority of Bakelite’s total shipments, accounting for *** percent or more of the company’s total shipments by quantity and *** percent or more of its total shipments by value across the reporting periods (with export shipments representing the remaining *** percent or less by quantity and *** percent or less by value of shipments). Bakelite’s U.S. shipments, by quantity, decreased by *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Bakelite’s U.S. shipments were *** percent lower in interim 2025 than interim 2024 (*** pounds compared to *** pounds). The company’s U.S. shipments decreased *** percent by value from 2022 to 2024 (decreasing from *** in 2022 to $*** in 2023 and to $*** in 2024). The value of Bakelite’s U.S. shipments was *** percent lower across the interim periods ($*** compared to $***). Bakelite’s U.S. shipment unit values decreased irregularly from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). U.S. shipment unit values were $*** per pound higher in interim 2025 than interim 2024 ($*** per pound compared to $*** per pound). Bakelite’s total shipments, by quantity, decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Total shipments were *** percent lower in interim 2025 compared to interim 2024 (*** pounds compared to *** pounds). The value of Bakelite’s total shipments decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024). The value of the company’s total shipments was *** percent lower across the interim periods ($*** compared to $***). Bakelite’s total shipment unit values also decreased irregularly from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). Bakelite’s total shipment unit values were $*** per pound higher in interim 2025 than interim 2024 ($*** per pound compared to $*** per pound). 3.7 Table 3.4 Hexamine: U.S. producer Bakelite’s total shipments, by destination and period Quantity in 1,000 pounds; value in 1,000 dollars; unit value in dollars per pound; shares in percent; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 U.S. shipments Quantity *** *** *** *** *** Export shipments Quantity *** *** *** *** *** Total shipments Quantity *** *** *** *** *** U.S. shipments Value *** *** *** *** *** Export shipments Value *** *** *** *** *** Total shipments Value *** *** *** *** *** U.S. shipments Unit value *** *** *** *** *** Export shipments Unit value *** *** *** *** *** Total shipments Unit value *** *** *** *** *** U.S. shipments Share of quantity *** *** *** *** *** Export shipments Share of quantity *** *** *** *** *** Total shipments Share of quantity 100.0 100.0 100.0 100.0 100.0 U.S. shipments Share of value *** *** *** *** *** Export shipments Share of value *** *** *** *** *** Total shipments Share of value 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Bakelite’s U.S. shipments Table 3.5 presents Bakelite’s U.S. shipments by type and period. Commercial U.S. shipments accounted for the majority of Bakelite’s U.S. shipments representing between *** and *** percent of the company’s U.S. shipments by quantity (and between *** and *** percent by value) across reporting periods. Internal consumption accounted for the remainder of the company’s U.S. shipments in each reporting period accounting for between *** and *** percent of U.S. shipments of hexamine by quantity (and between *** and *** percent by value).6 Bakelite’s commercial U.S. shipments by quantity decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024) and were *** percent lower in interim 2025 than in interim 2024 (*** pounds compared to *** pounds). The value of Bakelite’s commercial U.S. shipments decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to slightly greater than $*** in 2023 and to slightly less than $*** in 2024). The value of Bakelite’s U.S. commercial shipments was *** percent lower across the interim periods ($*** compared to $***). Bakelite’s U.S. commercial shipment unit values decreased irregularly from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). The company’s U.S. 6 Bakelite reported that it internally consumed its hexamine to produce ***. 3.8 commercial shipment unit values were higher in interim 2025 than interim 2024 ($*** per pound compared to $*** per pound). Bakelite’s internal consumption by quantity decreased by *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Internal consumption was *** percent across the interim periods (*** pounds compared to *** pounds). The value of Bakelite’s internal consumption decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024) and was *** percent lower in interim 2025 compared to interim 2024 ($*** compared to $***). The unit values of Bakelite’s internal consumption decreased irregularly by $*** per pound from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). Bakelite’s internal consumption unit value was $*** per pound higher across the interim periods ($*** per pound compared to $*** per pound). Table 3.5 Hexamine: U.S. producer Bakelite’s U.S. shipments, by type and period Quantity in 1,000 pounds; value in 1,000 dollars; unit values in dollars per pound; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Commercial U.S. shipments Quantity *** *** *** *** *** Internal consumption Quantity *** *** *** *** *** Transfers to related firms Quantity *** *** *** *** *** U.S. shipments Quantity *** *** *** *** *** Commercial U.S. shipments Value *** *** *** *** *** Internal consumption Value *** *** *** *** *** Transfers to related firms Value *** *** *** *** *** U.S. shipments Value *** *** *** *** *** Commercial U.S. shipments Unit value *** *** *** *** *** Internal consumption Unit value *** *** *** *** *** Transfers to related firms Unit value *** *** *** *** *** U.S. shipments Unit value *** *** *** *** *** Commercial U.S. shipments Share of quantity *** *** *** *** *** Internal consumption Share of quantity *** *** *** *** *** Transfers to related firms Share of quantity *** *** *** *** *** U.S. shipments Share of quantity *** *** *** *** *** Commercial U.S. shipments Share of value *** *** *** *** *** Internal consumption Share of value *** *** *** *** *** Transfers to related firms Share of value *** *** *** *** *** U.S. shipments Share of value 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 3.9 Captive consumption Section 771(7)(C)(ⅳ) of the Act states that–7 If domestic producers internally transfer significant production of the domestic like product for the production of a downstream article and sell significant production of the domestic like product in the merchant market, and the Commission finds that– (I) the domestic like product produced that is internally transferred for processing into that downstream article does not enter the merchant market for the domestic like product, and (II) the domestic like product is the predominant material input in the production of that downstream article, then the Commission, in determining market share and the factors affecting financial performance . . ., shall focus primarily on the merchant market for the domestic like product. Transfers and sales As reported in table 3.5, internal consumption accounted for between *** and *** percent of Bakelite’s U.S. shipments of hexamine by quantity (***). First statutory criterion in captive consumption The first requirement for application of the captive consumption provision is that the domestic like product that is internally transferred for processing into that downstream article not enter the merchant market for the domestic like product. Bakelite reported internal consumption of hexamine for the production of ***. Bakelite did not report diverting hexamine intended for internal consumption to the merchant market. 7 Amended by PL 114–27 (as signed, June 29, 2015), Trade Preferences Extension Act of 2015. 3.10 Second statutory criterion in captive consumption The second criterion of the captive consumption provision concerns whether the domestic like product is the predominant material input in the production of the downstream article that is captively produced. With respect to the downstream articles resulting from captive production, Bakelite estimated that hexamine comprises *** percent of the finished cost and *** percent of the weight of the downstream product (***) as shown in table 3.6. Table 3.6 Hexamine: U.S. producer Bakelite's contribution to downstream product Share in percent Material input Share of value Share of quantity Hexamine *** *** All other material inputs *** *** All material inputs 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. U.S. producers’ inventories Table 3.7 presents Bakelite’s end-of-period inventories and the ratio of these inventories to its production, U.S. shipments, and total shipments. Bakelite’s end-of-period inventories increased irregularly by *** percent from 2022 to 2024 and were *** percent higher across the interim periods. Resultingly, end-of-period inventories as a ratio to Bakelite’s U.S. production, U.S. shipments, and total shipments increased irregularly from 2022 to 2024 by ***, ***, and *** percentage points, respectively. These ratios were ***, ***, and *** percentage points higher across the interim periods, respectively. Table 3.7 Hexamine: U.S. producers’ inventories and their ratio to select items, by period Quantity in 1,000 pounds; ratios in percent; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 End-of-period inventory quantity *** *** *** *** *** Inventory ratio to U.S. production *** *** *** *** *** Inventory ratio to U.S. shipments *** *** *** *** *** Inventory ratio to total shipments *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 3.11 U.S. producers’ imports from subject sources Bakelite reported that ***. U.S. producers' purchases of imports from subject sources Bakelite reported that ***. 3.12 U.S. employment, wages, and productivity Table 3.8 shows Bakelite’s employment-related data. With respect to employment trends, Bakelite reported that its employment indicators were “***.” Bakelite reported its average production and related workers (PRWs) employed to be constant at *** PRWs across each of the full year and interim periods of the investigation period. The company reported those PRWs worked *** hours in each of the full year periods and *** hours in both interim periods. Resultingly, Bakelite’s reported hours worked per PRW was also constant. As noted on page 3.2, Bakelite reported, “***.” The company’s reported total wages paid increased *** percent from 2022 to 2024 (approximately $*** in both 2022 and 2023 to $*** in 2024). Hourly wages increased *** percent from 2022 to 2024 (increasing from $*** per hour in 2022 and 2023 to $*** per hour in 2024). Bakelite’s hourly wages were also *** percent higher across the interim periods ($*** per hour compared to $*** per hour). Bakelite’s productivity per worker as measured in pounds per hour decreased *** percent from 2022 to 2024 (decreasing from *** pounds per hour in 2022 to *** pounds per hour in 2023 and to *** pounds per hour in 2024). Reported productivity was *** percent lower in interim 2025 than interim 2024 (*** pounds per hour compared to *** pounds per hour). Bakelite’s unit labor costs increased *** percent from 2022 to 2024 (increasing from $*** per thousand pounds in 2022 to $*** per thousand pounds in 2023 and $*** per thousand pounds in 2024). Unit labor costs were *** percent higher in interim 2025 than interim 2024 ($*** per thousand pounds compared to $*** per thousand pounds).8 Table 3.8 Hexamine: U.S. producers’ employment related information, by period Interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Production and related workers (PRWs) (number) *** *** *** *** *** Total hours worked (1,000 hours) *** *** *** *** *** Hours worked per PRW (hours) *** *** *** *** *** Wages paid ($1,000) *** *** *** *** *** Hourly wages (dollars per hour) *** *** *** *** *** Productivity (pounds per hour) *** *** *** *** *** Unit labor costs (dollars per pound) *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 8 These figures are presented in dollars per pound as opposed to dollars per thousand pounds in table 3.8 and are thus rounded to approximately *** per pound in the full year and interim 2024 periods and to $*** in the interim 2025 period. 4.1 Part 4: U.S. imports, apparent U.S. consumption, and market shares U.S. importers The Commission issued importer questionnaires to 22 firms believed to be importers of subject hexamine, as well as to U.S. producer, Bakelite.1 Usable questionnaire responses were received from ten firms: Bradex; Continental Tire the Americas, LLC (“Continental”); Cross World; InterAtlas; Lanxess Corporation (“Lanxess”); Magnum International, Inc. (“Magnum”); Maxam North America, Inc. (“Maxam”); Neuchem; Riverside Specialty Chemicals Inc. (“Riverside”); and Seatex LLC (“Seatex”).2 3 1 The Commission issued questionnaires to those firms identified in the petitions; staff research; and proprietary, Census-edited Customs’ import records. 2 Additionally, five firms submitted a response certifying that their firm had not imported hexamine since January 1, 2022: ***. 3 ***. 4.2 Questionnaire responses are estimated to represent the following shares of U.S. imports of hexamine during 2024:4 • China: *** percent • Germany: *** percent5 • India: *** percent • Saudi Arabia: *** percent • Subject sources: *** percent6 • Nonsubject sources: *** percent7 4 Questionnaire coverage estimates have been calculated by comparing quantities of U.S. imports as reported in questionnaire responses to quantities of U.S. imports as reported in official U.S. import statistics of the U.S. Department of Commerce Census Bureau using HTS statistical reporting number 2933.69.5000, accessed on June 23, 2025, with corrections from Census dated May 12, 2025, except for the Germany and nonsubject coverage estimate calculations as described in footnotes 5 and 7. 5 ***. 6 ***. 7 ***. 4.3 Table 4.1 presents the U.S. importers that have provided questionnaire responses, their headquarters, and the shares of imports within each source for 2024. Table 4.1 Hexamine: U.S. importers, their headquarters, and share of imports within each source, 2024 Share in percent Firm Headquarters China Germany India Saudi Arabia Subject sources BIMEX Brodheadsville, PA *** *** *** *** *** Bradex Bradford, ON *** *** *** *** *** Continental Fort Mill, SC *** *** *** *** *** Cross World Cape May, NJ *** *** *** *** *** InterAtlas St. Catharines, ON *** *** *** *** *** Lanxess Pittsburgh, PA *** *** *** *** *** Magnum Crown Point, IN *** *** *** *** *** MAXAM Mooresville, NC *** *** *** *** *** Neuchem Sparks, NV *** *** *** *** *** Riverside Haskell, NJ *** *** *** *** *** Seatex Rosenberg, TX *** *** *** *** *** All firms Various 100.0 100.0 100.0 100.0 100.0 Table continued. Table 4.1 (Continued) Hexamine: U.S. importers, their headquarters, and share of imports within each source, 2024 Share in percent Firm Headquarters Russia All other sources Nonsubject sources All import sources BIMEX Brodheadsville, PA *** *** *** *** Bradex Bradford, ON *** *** *** *** Continental Fort Mill, SC *** *** *** *** Cross World Cape May, NJ *** *** *** *** InterAtlas St. Catharines, ON *** *** *** *** Lanxess Pittsburgh, PA *** *** *** *** Magnum Crown Point, IN *** *** *** *** MAXAM Mooresville, NC *** *** *** *** Neuchem Sparks, NV *** *** *** *** Riverside Haskell, NJ *** *** *** *** Seatex Rosenberg, TX *** *** *** *** All firms Various — 100.0 100.0 100.0 Source: Compiled from data in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. Note: ***. 4.4 U.S. imports Table 4.2 presents data for U.S. imports of hexamine by source and period as reported in questionnaire responses.8 Total U.S. imports of hexamine, by quantity, decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Total U.S. imports were *** percent higher in interim 2025 than in interim 2024 (*** pounds compared to *** pounds).9 By value, total U.S. imports of hexamine irregularly decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to approximately $*** in 2023 and 2024). The value of U.S. imports was *** percent higher across the interim periods ($*** compared to $***). 8 ***. 9 U.S. import quantities and values reported in hundreds of thousands are rounded numbers. 4.5 Subject imports, by quantity, increased 121.2 percent from 2022 to 2024 (increasing from 1.9 million pounds in 2022 to 2.1 million pounds in 2023 and to 4.1 million pounds in 2024)10 and were 1.2 percent higher across the interim periods (774,000 pounds compared to 765,000 pounds).11 By value, subject imports increased 95.6 percent from 2022 to 2024 (increasing from $1.6 million in 2022 to $3.2 million in 2024).12 Subject imports were 13.3 percent higher across the interim periods by value ($640,000 compared to $565,000).13 10 U.S. imports from Saudi Arabia increased by *** percent from 2022 to 2024 and were thus responsible for the bulk of the increase in subject imports (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). U.S. imports from India also increased (albeit irregularly) *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). Comparatively, U.S. imports of hexamine from China and Germany both decreased irregularly. U.S. imports from China decreased irregularly *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 before decreasing to *** pounds in 2024). U.S. imports from Germany decreased irregularly *** percent (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). 11 U.S. imports from India and Saudi Arabia were higher across the interim periods, while U.S. imports from China and Germany were lower. U.S. imports from India were *** percent higher across interim periods (*** pounds compared to *** pounds), and U.S. imports from Saudi Arabia were *** percent higher across interim periods (*** pounds compared to *** pounds). U.S. imports from Germany were *** percent lower across interim periods (*** pounds compared to *** pounds), while there were *** reported U.S. imports of hexamine from China in interim 2025 compared to *** pounds in interim 2024. 12 By value, U.S. imports of hexamine from Saudi Arabia increased *** percent from 2022 to 2024 (increasing from $*** in 2022 to $*** in 2023 and to $*** in 2024). The value of U.S. imports of hexamine from India increased *** percent irregularly from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 before increasing to $*** in 2024). The value of U.S. imports of hexamine from Germany decreased irregularly by *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 before increasing to $*** in 2024). The value of U.S. imports of hexamine from China decreased irregularly by *** percent from 2022 to 2024 (increasing from $*** in 2022 to $*** in 2023 before decreasing to $*** in 2024). 13 There were *** reported U.S. imports of hexamine from China in interim 2025 compared to $*** worth of imports from China in interim 2024. The value of U.S. imports of hexamine from Germany, India, and Saudi Arabia were all higher across the interim periods. U.S. imports from Germany were *** percent higher across interim periods by value ($*** compared to $***). U.S. imports from India were *** percent higher across the interim periods ($*** compared to $***). U.S. imports from Saudi Arabia were *** percent higher across the interim periods ($*** compared to $***). 4.6 U.S. imports of hexamine from nonsubject sources decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). U.S. imports of hexamine from nonsubject sources were *** percent higher across the interim periods (*** pounds compared to *** pounds). By value, U.S. nonsubject imports decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024).14 The value of nonsubject imports was *** percent higher across the interim periods ($*** compared to $***). Resultingly, nonsubject imports (nearly all from Russia) were the leading source of U.S. imports of hexamine, by quantity, in 2022 and 2023. U.S. imports from Russia accounted for *** percent of total U.S. imports in 2022, and this share decreased to *** percent in 2023 by quantity (*** percent of the share of the total value in 2022 decreasing to *** percent in 2023). Following Russia’s exit from the market, subject imports increased to *** percent of total U.S. imports, by quantity, in 2024 (*** percent by value). Saudi Arabia was the largest subject source in 2024 (*** percent of all 2024 imports by quantity and *** percent by value), followed by India (*** percent of all 2024 imports by quantity and *** percent by value), Germany (*** percent of all 2024 imports by quantity and *** percent by value), and China (*** percent of all 2024 imports by quantity and *** percent by value). 14 Russia was previously the largest source of U.S. imports of hexamine; however, imports from Russia began to decline ahead of Russia’s invasion of Ukraine and continued to decline until Russia exited the U.S. market entirely in 2023 after Russian authorities seized control of Metafrax Chemicals, the largest producer of hexamine in Russia. U.S. imports of hexamine from Russia decreased from *** pounds ($***) in 2022 to *** pounds ($***) in 2023 and decreased to zero in 2024 and interim 2025. 4.7 Average unit values (“AUVs”) of imports from subject sources decreased from 2022 to 2024 (decreasing from $0.87 per pound in 2022 to $0.80 per pound in 2023 and to $0.77 per pound in 2024).15 AUVs of imports from subject sources were higher across the interim periods ($0.83 per pound compared to $0.74 per pound).16 AUVs of imports from nonsubject sources increased irregularly from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024).17 AUVs of imports from nonsubject sources were higher in interim 2025 than interim 2024 ($*** per pound compared to $*** per pound). AUVs of imports from all sources increased irregularly from 2022 to 2024 (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound). AUVs of imports from all import sources were higher across the interim periods ($*** per pound compared to $*** per pound). 15 AUVs of imports from all individual subject sources were lower in 2024 than in 2022. AUVs of imports from China decreased irregularly (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). AUV’s of imports from Germany decreased from $*** per pound in 2022 to $*** per pound in 2023 and to $*** per pound in 2024. AUV’s of imports from India decreased irregularly (increasing from $*** per pound in 2022 to $*** per pound in 2023 before decreasing to $*** per pound in 2024). AUV’s of imports from Saudi Arabia decreased irregularly over the full year periods (decreasing from $*** per pound in 2022 to $*** per pound in 2023 before increasing to $*** per pound in 2024). 16 There were zero reported U.S. imports of hexamine from China in interim 2025. AUVs of imports from Germany, India, and Saudi Arabia were all higher in interim 2025 than interim 2024 ($*** per pound compared to $*** per pound for Germany, $*** per pound compared to $*** per pound for India, and $*** per pound compared to $*** per pound for Saudi Arabia). 17 As previously noted, virtually all nonsubject imports in 2022 and 2023 were from Russia, whereas all nonsubject imports in 2024 reported in questionnaire responses were from Spain. Petitioner stated that it was unaware of hexamine production in Spain. Hearing transcript, pp. 66, 80 (Kanna). ***. 4.8 Table 4.2 Hexamine: U.S. imports by source and period Quantity in 1,000 pounds; value in 1,000 dollars; unit values in dollars per pound; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 China Quantity *** *** *** *** *** Germany Quantity *** *** *** *** *** India Quantity *** *** *** *** *** Saudi Arabia Quantity *** *** *** *** *** Subject sources Quantity 1,862 2,069 4,119 765 774 Russia Quantity *** *** *** *** *** All other sources Quantity *** *** *** *** *** Nonsubject sources Quantity *** *** *** *** *** All import sources Quantity *** *** *** *** *** China Value *** *** *** *** *** Germany Value *** *** *** *** *** India Value *** *** *** *** *** Saudi Arabia Value *** *** *** *** *** Subject sources Value 1,617 1,649 3,164 565 640 Russia Value *** *** *** *** *** All other sources Value *** *** *** *** *** Nonsubject sources Value *** *** *** *** *** All import sources Value *** *** *** *** *** China Unit value *** *** *** *** *** Germany Unit value *** *** *** *** *** India Unit value *** *** *** *** *** Saudi Arabia Unit value *** *** *** *** *** Subject sources Unit value 0.87 0.80 0.77 0.74 0.83 Russia Unit value *** *** *** *** *** All other sources Unit value *** *** *** *** *** Nonsubject sources Unit value *** *** *** *** *** All import sources Unit value *** *** *** *** *** Table continued. 4.9 Table 4.2 (Continued) Hexamine: U.S. imports by source and period Share and ratio in percent; ratio represents the ratio to U.S. production; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 China Share of quantity *** *** *** *** *** Germany Share of quantity *** *** *** *** *** India Share of quantity *** *** *** *** *** Saudi Arabia Share of quantity *** *** *** *** *** Subject sources Share of quantity *** *** *** *** *** Russia Share of quantity *** *** *** *** *** All other sources Share of quantity *** *** *** *** *** Nonsubject sources Share of quantity *** *** *** *** *** All import sources Share of quantity 100.0 100.0 100.0 100.0 100.0 China Share of value *** *** *** *** *** Germany Share of value *** *** *** *** *** India Share of value *** *** *** *** *** Saudi Arabia Share of value *** *** *** *** *** Subject sources Share of value *** *** *** *** *** Russia Share of value *** *** *** *** *** All other sources Share of value *** *** *** *** *** Nonsubject sources Share of value *** *** *** *** *** All import sources Share of value 100.0 100.0 100.0 100.0 100.0 China Ratio *** *** *** *** *** Germany Ratio *** *** *** *** *** India Ratio *** *** *** *** *** Saudi Arabia Ratio *** *** *** *** *** Subject sources Ratio *** *** *** *** *** Russia Ratio *** *** *** *** *** All other sources Ratio *** *** *** *** *** Nonsubject sources Ratio *** *** *** *** *** All import sources Ratio *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.10 Figure 4.1 Hexamine: U.S. import quantities and average unit values, by source and period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 4.11 Table 4.3 Hexamine: Changes in U.S. imports by source and period Changes (Δ) in percent (%); interim period is January through March Source Measure 2022 to 2024 2022 to 2023 2023 to 2024 Interim 2024 to 2025 China %Δ Quantity ▼*** ▲*** ▼*** ▼*** Germany %Δ Quantity ▼*** ▼*** ▲*** ▼*** India %Δ Quantity ▲*** ▼*** ▲*** ▲*** Saudi Arabia %Δ Quantity ▲*** ▲*** ▲*** ▲*** Subject sources %Δ Quantity ▲121.2 ▲11.1 ▲99.1 ▲1.2 Russia %Δ Quantity ▼*** ▼*** ▼*** *** All other %Δ Quantity ▲*** ▼*** ▲*** ▲*** Nonsubject sources %Δ Quantity ▼*** ▼*** ▼*** ▲*** All import sources %Δ Quantity ▼*** ▼*** ▼*** ▲*** China %Δ Value ▼*** ▲*** ▼*** ▼*** Germany %Δ Value ▼*** ▼*** ▲*** ▲*** India %Δ Value ▲*** ▼*** ▲*** ▲*** Saudi Arabia %Δ Value ▲*** ▲*** ▲*** ▲*** Subject sources %Δ Value ▲95.6 ▲2.0 ▲91.8 ▲13.3 Russia %Δ Value ▼*** ▼*** ▼*** *** All other %Δ Value ▲*** ▼*** ▲*** ▲*** Nonsubject sources %Δ Value ▼*** ▼*** ▼*** ▲*** All import sources %Δ Value ▼*** ▼*** ▲*** ▲*** China %Δ Unit value ▼*** ▼*** ▲*** ▼*** Germany %Δ Unit value ▼*** ▼*** ▼*** ▲*** India %Δ Unit value ▼*** ▲*** ▼*** ▲*** Saudi Arabia %Δ Unit value ▼*** ▼*** ▲*** ▲*** Subject sources %Δ Unit value ▼(11.5) ▼(8.2) ▼(3.6) ▲12.0 Russia %Δ Unit value ▼*** ▼*** ▼*** *** All other %Δ Unit value ▲*** ▼*** ▲*** ▲*** Nonsubject sources %Δ Unit value ▲*** ▼*** ▲*** ▲*** All import sources %Δ Unit value ▲*** ▼*** ▲*** ▲*** Table continued. 4.12 Table 4.3 (Continued) Hexamine: Changes in U.S. imports by source and period Changes (Δ) in percentage point (ppt); interim period is January through March Source Measure 2022 to 2024 2022 to 2023 2023 to 2024 Interim 2024 to 2025 China ppt Δ Quantity ▲*** ▲*** ▼*** ▼*** Germany ppt Δ Quantity ▲*** ▼*** ▲*** ▼*** India ppt Δ Quantity ▲*** ▼*** ▲*** ▲*** Saudi Arabia ppt Δ Quantity ▲*** ▲*** ▲*** ▲*** Subject sources ppt Δ Quantity ▲*** ▲*** ▲*** ▼*** Russia ppt Δ Quantity ▼*** ▼*** ▼*** *** All other ppt Δ Quantity ▲*** ▼*** ▲*** ▲*** Nonsubject sources ppt Δ Quantity ▼*** ▼*** ▼*** ▲*** All import sources ppt Δ Quantity *** *** *** *** China ppt Δ Value ▼*** ▲*** ▼*** ▼*** Germany ppt Δ Value ▲*** ▼*** ▲*** ▼*** India ppt Δ Value ▲*** ▼*** ▲*** ▲*** Saudi Arabia ppt Δ Value ▲*** ▲*** ▲*** ▲*** Subject sources ppt Δ Value ▲*** ▲*** ▲*** ▼*** Russia ppt Δ Value ▼*** ▼*** ▼*** *** All other ppt Δ Value ▲*** ▼*** ▲*** ▲*** Nonsubject sources ppt Δ Value ▼*** ▼*** ▼*** ▲*** All import sources ppt Δ Value *** *** *** *** China ppt Δ Ratio ▲*** ▲*** ▼*** ▼*** Germany ppt Δ Ratio ▲*** ▼*** ▲*** ▲*** India ppt Δ Ratio ▲*** ▼*** ▲*** ▲*** Saudi Arabia ppt Δ Ratio ▲*** ▲*** ▲*** ▲*** Subject sources ppt Δ Ratio ▲*** ▲*** ▲*** ▲*** Russia ppt Δ Ratio ▼*** ▼*** ▼*** *** All other ppt Δ Ratio ▲*** ▼*** ▲*** ▲*** Nonsubject sources ppt Δ Ratio ▼*** ▼*** ▼*** ▲*** All import sources ppt Δ Ratio ▼*** ▼*** ▼*** ▲*** Source: Compiled from data submitted in response to Commission questionnaires. Note: Shares and ratios shown as “0.0” percent represent non-zero values less than “0.05” percent (if positive) and greater than “(0.05)” percent (if negative). Zeroes, null values, and undefined calculations are suppressed and shown as “—“. Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease. 4.13 Negligibility The statute requires that an investigation be terminated without an injury determination if imports of the subject merchandise are found to be negligible.18 Negligible imports are generally defined in the Act, as amended, as imports from a country of merchandise corresponding to a domestic like product where such imports account for less than 3 percent of the volume of all such merchandise imported into the United States in the most recent 12-month period for which data are available that precedes the filing of the petition or the initiation of the investigation. However, if there are imports of such merchandise from a number of countries subject to investigations initiated on the same day that individually account for less than 3 percent of the total volume of the subject merchandise, and if the imports from those countries collectively account for more than 7 percent of the volume of all such merchandise imported into the United States during the applicable 12-month period, then imports from such countries are deemed not to be negligible.19 As shown in table 4.4, U.S. imports from China accounted for *** percent, U.S. imports from Germany accounted for *** percent, U.S. imports from India accounted for *** percent, and U.S. imports from Saudi Arabia accounted for *** percent of total U.S. imports of hexamine, by quantity, from September 2023 through August 2024. U.S. imports from subject sources accounted for *** percent of total U.S. imports of hexamine by quantity during the negligibility period. Table 4.4 Hexamine: U.S. imports in the twelve-month period preceding the filing of the petitions, September 2023 through August 2024 Quantity in 1,000 pounds; share in percent Source of imports Quantity Share of quantity China *** *** Germany *** *** India *** *** Saudi Arabia *** *** Russia *** *** All other sources *** *** All sources *** 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 18 Sections 703(a)(1), 705(b)(1), 733(a)(1), and 735(b)(1) of the Act (19 U.S.C. §§ 1671b(a)(1), 1671d(b)(1), 1673b(a)(1), and 1673d(b)(1)). 19 Section 771 (24) of the Act (19 U.S.C § 1677(24)). 4.14 Cumulation considerations In assessing whether imports should be cumulated, the Commission determines whether U.S. imports from the subject countries compete with each other and with the domestic like product and has generally considered four factors: (1) fungibility, (2) presence of sales or offers to sell in the same geographical markets, (3) common or similar channels of distribution, and (4) simultaneous presence in the market. Information regarding channels of distribution, market areas, and interchangeability appear in Part 2. Additional information concerning fungibility, geographical markets, and simultaneous presence in the market is presented below. Fungibility The Commission collected data on U.S. shipments by hexamine content level with the following breakout options: greater than 50 percent to 91 percent purity hexamine, between 91 percent and 95 percent purity hexamine, greater than 95 percent to 99 percent purity hexamine, and greater than 99 percent to 100 percent purity hexamine. Shipments vary by hexamine content as additives can be included in shipments depending on the customers’ end- use needs for reasons such as improving particle flow, preventing agglomeration, and for dust suppression purposes. 4.15 Table 4.5 and figure 4.2 present U.S. shipments by level of hexamine content/presence of additives as reported by U.S. producer Bakelite and by U.S. importers. As shown in the table and figure, the vast majority of Bakelite’s 2024 U.S. shipments were of greater than 99 percent purity hexamine (*** percent of U.S. shipments) followed by 95 to 99 percent purity hexamine (*** percent of U.S. shipments). Bakelite also reported the remaining *** percent of its 2024 U.S. shipments were of 91 to 95 percent purity hexamine. Comparatively, *** percent of U.S. shipments of hexamine from subject sources were of greater than 99 percent purity hexamine followed by 95 to 99 percent purity hexamine (*** percent of U.S. shipments), and U.S. shipments of 50 to 91 percent purity hexamine (*** percent of U.S. shipments).20 Approximately *** percent of U.S. shipments from nonsubject sources were of 95 to 99 percent purity hexamine with the remaining *** percent of U.S. shipments from nonsubject sources being greater than 99 percent purity hexamine. 20 *** the reported 2024 U.S. shipments of U.S. imports from China were of greater than 99 percent purity hexamine. Approximately *** percent of 2024 U.S. shipments of U.S. imports from Germany were of greater than 99 percent purity hexamine with the remaining *** percent being between 95 and 99 percent purity hexamine. Approximately *** percent of U.S. shipments of U.S. imports from India in 2024 were of greater than 99 percent purity hexamine followed by 95 to 99 percent purity hexamine (*** percent) and 50 to 91 percent purity hexamine (*** percent). Approximately *** percent of 2024 U.S. shipments of imports from Saudi Arabia were of greater than 99 percent purity hexamine with the remaining *** percent being between 95 and 99 percent purity. 4.16 Table 4.5 Hexamine: U.S. producers' and U.S. importers' U.S. shipments, by source and hexamine molecule content, 2024 Quantity in 1,000 pounds Source Greater than 50 and less than or equal to 91 percent Greater than 91 and less than or equal to 95 percent Greater than 95 and less than or equal to 99 percent Greater than 99 and less than or equal to 100 percent All concentrations U.S. producers *** *** *** *** *** China *** *** *** *** *** Germany *** *** *** *** *** India *** *** *** *** *** Saudi Arabia *** *** *** *** *** Subject sources *** *** *** *** *** Russia *** *** *** *** *** All other sources *** *** *** *** *** Nonsubject sources *** *** *** *** *** All import sources *** *** *** *** *** All sources *** *** *** *** *** Table continued. Table 4.5 (Continued) Hexamine: U.S. producers' and U.S. importers' U.S. shipments, by source and hexamine molecule content, 2024 Share across in percent Source Greater than 50 and less than or equal to 91 percent Greater than 91 and less than or equal to 95 percent Greater than 95 and less than or equal to 99 percent Greater than 99 and less than or equal to 100 percent All concentrations U.S. producers *** *** *** *** 100.0 China *** *** *** *** 100.0 Germany *** *** *** *** 100.0 India *** *** *** *** 100.0 Saudi Arabia *** *** *** *** 100.0 Subject sources *** *** *** *** 100.0 Russia *** *** *** *** 100.0 All other sources *** *** *** *** 100.0 Nonsubject sources *** *** *** *** 100.0 All import sources *** *** *** *** 100.0 All sources *** *** *** *** 100.0 Table continued. 4.17 Table 4.5 (Continued) Hexamine: U.S. producers' and U.S. importers' U.S. shipments, by source and hexamine content level, 2024 Share down in percent Source Greater than 50 and less than or equal to 91 percent Greater than 91 and less than or equal to 95 percent Greater than 95 and less than or equal to 99 percent Greater than 99 and less than or equal to 100 percent All concentrations U.S. producers *** *** *** *** *** China *** *** *** *** *** Germany *** *** *** *** *** India *** *** *** *** *** Saudi Arabia *** *** *** *** *** Subject sources *** *** *** *** *** Russia *** *** *** *** *** All other sources *** *** *** *** *** Nonsubject sources *** *** *** *** *** All import sources *** *** *** *** *** All sources 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent. Zeroes, null values, and undefined calculations are suppressed and shown as “—“. Figure 4.2 Hexamine: U.S. producers' and U.S. importers' U.S. shipments, by source and hexamine content level, 2024 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires 4.18 Geographical markets Table 4.6 presents U.S. import quantities of hexamine as reported under HTS statistical reporting number 2933.69.5000 by source and border of entry region during 2024. In 2024, official import statistics show that approximately 62.9 percent of U.S. imports of hexamine from subject sources entered through customs entry districts in the East region21 of the United States followed by the North region (35.7 percent)22 and the South region (1.4 percent)23 with no U.S. imports of hexamine reported as having entered through the West region.24 All U.S. imports of hexamine from China and Saudi Arabia and the majority of imports from India (69.9 percent) entered through the East border in 2024. Comparatively, the vast majority of imports from Germany entered through the North border (91.3 percent) with the remainder entering through the South and East borders in 2024. Approximately 30.1 percent of U.S. imports of hexamine from India entered through the North border in 2024. 21 The eastern border of entry encompasses the following customs entry districts: Washington, DC; Savannah, Georgia; Portland, Maine; Baltimore, Maryland; Boston, Massachusetts; Charlotte, North Carolina; Buffalo and Ogdensburg, New York; Philadelphia, Pennsylvania; San Juan, Puerto Rico; Charleston, South Carolina; Norfolk, Virginia; and St. Albans, Vermont. 22 The northern border encompasses the following customs entry districts: Chicago, Illinois; Detroit, Michigan; St. Louis, Missouri; Duluth and Minneapolis, Minnesota; Great Falls, Montana; Pembina, North Dakota; and Cleveland, Ohio. 23 The southern border encompasses the following customs entry districts: Mobile, Alabama; New Orleans, Louisiana; Miami and Tampa, Florida; and Dallas-Fort Worth, El Paso, Houston-Galveston, and Laredo, Texas. 24 The western border encompasses the following customs entry districts: Anchorage, Alaska; Los Angeles, San Diego, and San Francisco, California; Honolulu, Hawaii; Columbia-Snake, Oregon; and Seattle, Washington. 4.19 Table 4.6 Hexamine: U.S. imports by source and by border of entry, 2024 Quantity in 1,000 pounds Source East North South West All borders China 79 — — — 79 Germany 51 1,244 68 — 1,362 India 1,032 445 — — 1,476 Saudi Arabia 1,812 — — — 1,812 Subject sources 2,974 1,688 68 — 4,730 Russia — — — — — All other sources 1,602 — 2 — 1,604 Nonsubject sources 1,602 — 2 — 1,604 All import sources 4,576 1,688 70 — 6,334 Table continued. Table 4.6 (Continued) Hexamine: U.S. imports by source and by border of entry, 2024 Share in percent Source East North South West All borders China 100.0 — — — 100.0 Germany 3.7 91.3 5.0 — 100.0 India 69.9 30.1 — — 100.0 Saudi Arabia 100.0 — — — 100.0 Subject sources 62.9 35.7 1.4 — 100.0 Russia — — — — — All other sources 99.9 — 0.1 — 100.0 Nonsubject sources 99.9 — 0.1 — 100.0 All import sources 72.2 26.7 1.1 — 100.0 Table continued. Table 4.6 (Continued) Hexamine: U.S. imports by source and by border of entry, 2024 Share in percent Source East North South West All borders China 1.7 — — — 1.3 Germany 1.1 73.7 96.8 — 21.5 India 22.5 26.3 — — 23.3 Saudi Arabia 39.6 — — — 28.6 Subject sources 65.0 100.0 96.8 — 74.7 Russia — — — — — All other sources 35.0 — 3.2 — 25.3 Nonsubject sources 35.0 — 3.2 — 25.3 All import sources 100.0 100.0 100.0 — 100.0 Source: Compiled from official U.S. import statistics of the U.S. Department of Commerce Census Bureau using statistical reporting number 2933.69.5000, accessed June 23, 2025. Imports are based on the imports for consumption data series. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. There were no U.S. imports from Russia after June 2023. 4.20 Presence in the market Table 4.7 and figures 4.3 and 4.4 present monthly U.S. imports for subject countries and nonsubject sources as reported in questionnaire responses. U.S. imports of hexamine from subject sources entered the country in 34 of the 39 months between January 2022 and March 2025.25 U.S. imports from nonsubject sources entered in 19 of the 39 months between January 2022 and March 2025.26 In total, imports of hexamine from all sources were present in all but two of the months between January 2022 and March 2025. 25 U.S. imports from China entered in 9 of the 39 months, U.S. imports from Germany entered in 31 of the 39 months, U.S. imports from India entered in 16 of the 39 months, and U.S. imports from Saudi Arabia entered in 17 of the 39 months between January 2022 and March 2025. 26 U.S. imports from nonsubject source Russia entered in 13 of the 18 months between January 2022 and June 2023 but were not present at all in the U.S. market in the months after June 2023. U.S. imports from sources other than subject sources or Russia were present in 9 of the 39 months between January 2022 and March 2025. 4.21 Table 4.7 Hexamine: U.S. imports, by month and source Quantity in 1,000 pounds Year Month China Germany India Saudi Arabia Subject sources 2022 January *** *** *** *** *** 2022 February *** *** *** *** *** 2022 March *** *** *** *** *** 2022 April *** *** *** *** *** 2022 May *** *** *** *** *** 2022 June *** *** *** *** *** 2022 July *** *** *** *** *** 2022 August *** *** *** *** *** 2022 September *** *** *** *** *** 2022 October *** *** *** *** *** 2022 November *** *** *** *** *** 2022 December *** *** *** *** *** 2023 January *** *** *** *** *** 2023 February *** *** *** *** *** 2023 March *** *** *** *** *** 2023 April *** *** *** *** *** 2023 May *** *** *** *** *** 2023 June *** *** *** *** *** 2023 July *** *** *** *** *** 2023 August *** *** *** *** *** 2023 September *** *** *** *** *** 2023 October *** *** *** *** *** 2023 November *** *** *** *** *** 2023 December *** *** *** *** *** Table continued 4.22 Table 4.7 (Continued) Hexamine: U.S. imports, by month and source Quantity in 1,000 pounds Year Month Russia All other sources Nonsubject sources All import sources 2022 January *** *** *** *** 2022 February *** *** *** *** 2022 March *** *** *** *** 2022 April *** *** *** *** 2022 May *** *** *** *** 2022 June *** *** *** *** 2022 July *** *** *** *** 2022 August *** *** *** *** 2022 September *** *** *** *** 2022 October *** *** *** *** 2022 November *** *** *** *** 2022 December *** *** *** *** 2023 January *** *** *** *** 2023 February *** *** *** *** 2023 March *** *** *** *** 2023 April *** *** *** *** 2023 May *** *** *** *** 2023 June *** *** *** *** 2023 July *** *** *** *** 2023 August *** *** *** *** 2023 September *** *** *** *** 2023 October *** *** *** *** 2023 November *** *** *** *** 2023 December *** *** *** *** Table continued. 4.23 Table 4.7 (Continued) Hexamine: U.S. imports, by month and source Quantity in 1,000 pounds Year Month China Germany India Saudi Arabia Subject sources 2024 January *** *** *** *** *** 2024 February *** *** *** *** *** 2024 March *** *** *** *** *** 2024 April *** *** *** *** *** 2024 May *** *** *** *** *** 2024 June *** *** *** *** *** 2024 July *** *** *** *** *** 2024 August *** *** *** *** *** 2024 September *** *** *** *** *** 2024 October *** *** *** *** *** 2024 November *** *** *** *** *** 2024 December *** *** *** *** *** 2025 January *** *** *** *** *** 2025 February *** *** *** *** *** 2025 March *** *** *** *** *** Table continued. Table 4.7 (Continued) Hexamine: U.S. imports, by month and source Quantity in 1,000 pounds Year Month Russia All other sources Nonsubject sources All import sources 2024 January *** *** *** *** 2024 February *** *** *** *** 2024 March *** *** *** *** 2024 April *** *** *** *** 2024 May *** *** *** *** 2024 June *** *** *** *** 2024 July *** *** *** *** 2024 August *** *** *** *** 2024 September *** *** *** *** 2024 October *** *** *** *** 2024 November *** *** *** *** 2024 December *** *** *** *** 2025 January *** *** *** *** 2025 February *** *** *** *** 2025 March *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.24 Figure 4.3 Hexamine: U.S. imports from individual subject sources, by source and month * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. Figure 4.4 Hexamine: U.S. imports from aggregated subject and nonsubject sources, by month * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 4.25 Apparent U.S. consumption and market shares Total market Total market by quantity Table 4.8 and figure 4.5 present data on apparent U.S. consumption and U.S. market shares by quantity for the total market for hexamine. Total apparent U.S. consumption of hexamine decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Total apparent U.S. consumption was *** percent lower across the interim periods (*** pounds compared to *** pounds). U.S. producer Bakelite’s total U.S. shipments decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Bakelite’s total market share decreased *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). Bakelite’s U.S. shipments were *** percent lower across the interim periods (*** pounds compared to *** pounds), and the company’s share of apparent U.S. consumption was *** percentage points lower across the interim periods (*** percent compared to *** percent). 4.26 U.S. shipments of subject imports increased 186.7 percent from 2022 to 2024 (increasing from 1.5 million pounds in 2022 to 1.7 million pounds in 2023 and to 4.4 million pounds in 2024).27 Subject imports’ share of total apparent U.S. consumption increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024).28 U.S. shipments of subject imports were 6.8 percent higher across the interim periods (880,000 pounds compared to 825,000 pounds),29 and subject imports’ share of apparent U.S. consumption was *** percentage points higher across the interim periods (*** percent compared to *** percent).30 27 U.S. shipments of imports from China decreased irregularly by *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 before decreasing to *** pounds in 2024). U.S. shipments of imports from Germany decreased irregularly by *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). U.S. shipments of imports from India increased irregularly by *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). U.S. shipments of imports from Saudi Arabia increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). 28 The total market share represented by U.S. shipments of imports from China increased from *** percent in 2022 to *** percent in 2023 before decreasing back to *** percent in 2024. The total market share represented by U.S. shipments of imports from Germany increased irregularly by *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The total market share represented by U.S. shipments of imports from India increased irregularly by *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The total market share represented by U.S. shipments of imports from Saudi Arabia increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). 29 U.S. shipments of imports from Germany were *** percent lower across the interim periods (*** pounds compared to *** pounds). U.S. shipments of imports from India were *** percent higher across the interim periods (*** pounds compared to *** pounds). U.S. shipments of imports from Saudi Arabia were *** percent lower across the interim periods (*** pounds compared to *** pounds). There were *** U.S. shipments of imports from China in interim 2025 compared to *** pounds of U.S. shipments of imports from China in interim 2024. 30 The total market share represented by U.S. shipments of imports from China was *** percentage points lower across the interim periods (*** percent compared to *** percent). The total market share represented by U.S. imports from Germany was *** percentage points higher across the interim periods (*** percent compared to *** percent). The total market share represented by U.S. imports from India was *** percentage points higher across the interim periods (*** percent compared to *** percent). The total market share represented by U.S. imports from Saudi Arabia was *** percentage points higher across the interim periods (*** percent compared to *** percent). 4.27 U.S. shipments of nonsubject imports decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024).31 Nonsubject imports’ total market share decreased *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). Nonsubject import shipments were *** percent lower across the interim periods (*** pounds compared to *** pounds), and nonsubject imports’ total market share was *** percentage points lower across the interim periods (*** percent compared to *** percent). 31 Virtually all the U.S. shipments of nonsubject imports were from Russia in 2022 and 2023, but U.S. imports of hexamine from Russia dropped to *** in 2024 and interim 2025. U.S. shipments from inventories of imports from Russia accounted for *** percent of apparent consumption in 2024 and *** percent of apparent consumption in interim 2025. The remaining U.S. shipments of nonsubject imports in 2024 and interim 2025 were reported by *** who reported importing the hexamine from ***. U.S. shipments of imports from *** (all of which was reported as ***) accounted for *** and *** percent of apparent consumption in 2024 and interim 2025, respectively. 4.28 Table 4.8 Hexamine: Apparent U.S. total market consumption and market shares based on quantity data, by source and period Quantity in 1,000 pounds; shares in percent; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 U.S. producers Quantity *** *** *** *** *** China Quantity *** *** *** *** *** Germany Quantity *** *** *** *** *** India Quantity *** *** *** *** *** Saudi Arabia Quantity *** *** *** *** *** Subject sources Quantity 1,518 1,683 4,353 825 880 Russia Quantity *** *** *** *** *** All other sources Quantity *** *** *** *** *** Nonsubject sources Quantity *** *** *** *** *** All import sources Quantity *** *** *** *** *** All sources Quantity *** *** *** *** *** U.S. producers Share *** *** *** *** *** China Share *** *** *** *** *** Germany Share *** *** *** *** *** India Share *** *** *** *** *** Saudi Arabia Share *** *** *** *** *** Subject sources Share *** *** *** *** *** Russia Share *** *** *** *** *** All other sources Share *** *** *** *** *** Nonsubject sources Share *** *** *** *** *** All import sources Share *** *** *** *** *** All sources Share 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.29 Figure 4.5 Hexamine: Apparent U.S. total market consumption and market shares based on quantity data, by source and period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 4.30 Total market by value Table 4.9 and figure 4.6 present data on apparent U.S. consumption and U.S. market shares by value for the total market for hexamine. Total apparent U.S. consumption of hexamine decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024). Total apparent U.S. consumption was *** percent lower across the interim periods ($*** compared to $***). The value of U.S. producer Bakelite’s total U.S. shipments decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024). Bakelite’s total market share decreased irregularly by *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The value of Bakelite’s U.S. shipments was *** percent lower across the interim periods ($*** compared to $***), and the company’s total market share was *** percentage points lower across the interim periods (*** percent compared to *** percent). The value of U.S. shipments of subject imports increased 174.5 percent from 2022 to 2024 (increasing from $1.6 million in 2022 to $1.8 million in 2023 and to $4.3 million in 2024).32 Subject imports’ total market share increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024).33 U.S. shipments of subject imports were 10.4 percent higher across the interim periods 32 The value of U.S. shipments of imports from China decreased irregularly by *** percent from 2022 to 2024 (increasing from $*** in 2022 to $*** in 2023 before decreasing to $*** in 2024). The value of U.S. shipments of imports from Germany decreased irregularly by *** percent over the period (decreasing from $*** in 2022 to $*** in 2023 before increasing to $*** in 2024). The value of U.S. shipments of imports from India increased irregularly by *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 before increasing to $*** in 2024). The value of U.S. shipments of imports from Saudi Arabia increased *** percent from 2022 to 2024 (increasing from $*** in 2022 to $*** in 2023 and to $*** in 2024). 33 The share of the value of apparent U.S. consumption represented by U.S. shipments of imports from China increased from *** percent in 2022 to *** percent in 2023 before decreasing back to *** percent in 2024). Germany’s share of total apparent U.S. consumption by value was *** from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing back to *** percent in 2024). U.S. imports from India’s share of total apparent U.S. consumption by value increased *** percentage points irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). U.S. imports from Saudi Arabia’s share of total apparent U.S. consumption by value increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). 4.31 by value ($866,000 compared to $784,000),34 and subject imports’ total market share was *** percentage points higher across the interim periods (*** percent compared to *** percent).35 The value of U.S. shipments of nonsubject imports decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 and to $*** in 2024).36 Nonsubject imports’ total market share decreased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024). The value of U.S. shipments of nonsubject imports was *** percent lower across the interim periods ($*** compared to $***), and nonsubject imports’ total market share was *** percentage points lower across the interim periods (*** percent compared to *** percent). 34 The value of U.S. shipments of imports from China was *** in interim 2025 compared to $*** in interim 2024. The value of U.S. shipments of imports from Germany was *** percent higher across the interim periods ($*** compared to $***). The value of U.S. shipments of imports from India was *** percent higher across the interim periods ($*** compared to $***). The value of U.S. shipments of imports from Saudi Arabia was *** percent lower across the interim periods ($*** compared to $***). 35 The total market share represented by U.S. shipments of imports from China was *** percentage points lower across the interim periods (*** percent compared to *** percent). The total market share represented by U.S. shipments of imports from Saudi Arabia was *** percentage points lower across the interim periods (*** percent compared to *** percent). Comparatively, the total market shares held by U.S. shipments of imports from Germany and India were both higher across the interim periods. The total market share represented by U.S. shipments of imports from Germany was *** percentage points higher across the interim periods (*** percent compared to *** percent), while the total market share represented by U.S. shipments of imports from India was *** percentage points higher across the interim periods (*** percent compared to *** percent). 36 As previously noted, virtually all the U.S. shipments of nonsubject imports were from Russia in 2022 and 2023, but U.S. imports of hexamine from Russia dropped to *** in the 2024 and interim 2025 periods. The value of U.S. shipments from inventories of imports from Russia accounted for *** percent of apparent consumption in 2024 and *** percent of apparent consumption in interim 2025 by value. The remaining U.S. shipments of nonsubject imports in 2024 and interim 2025 were reported by *** who reported importing the hexamine from ***. U.S. shipments of imports from *** (all of which was reported as ***) accounted for *** and *** percent of apparent consumption by value in 2024 and interim 2025, respectively. 4.32 Table 4.9 Hexamine: Apparent U.S. total market consumption and total shares based on value data, by source and period Value in 1,000 dollars; shares in percent; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 U.S. producers Value *** *** *** *** *** China Value *** *** *** *** *** Germany Value *** *** *** *** *** India Value *** *** *** *** *** Saudi Arabia Value *** *** *** *** *** Subject sources Value 1,550 1,831 4,255 784 866 Russia Value *** *** *** *** *** All other sources Value *** *** *** *** *** Nonsubject sources Value *** *** *** *** *** All import sources Value *** *** *** *** *** All sources Value *** *** *** *** *** U.S. producers Share *** *** *** *** *** China Share *** *** *** *** *** Germany Share *** *** *** *** *** India Share *** *** *** *** *** Saudi Arabia Share *** *** *** *** *** Subject sources Share *** *** *** *** *** Russia Share *** *** *** *** *** All other sources Share *** *** *** *** *** Nonsubject sources Share *** *** *** *** *** All import sources Share *** *** *** *** *** All sources Share 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.33 Figure 4.6 Hexamine: Apparent U.S. total market consumption and market shares based on value data, by source and period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 4.34 Merchant market Merchant market by quantity Table 4.10 and figure 4.7 present data on apparent U.S. consumption and U.S. market shares by quantity for hexamine for the merchant market. Apparent U.S. merchant market consumption decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Apparent U.S. merchant market consumption was *** percent lower across the interim periods (*** pounds compared to *** pounds). U.S. producer Bakelite’s commercial U.S. shipments decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). Bakelite’s share of the merchant market decreased *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). Bakelite’s commercial U.S. shipments were *** percent lower across the interim periods (*** pounds compared to *** pounds), and the company’s share of the merchant market was *** percentage points lower across the interim periods (*** percent compared to *** percent). 4.35 Subject imports’ share of the merchant market increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024).37 Subject imports’ share of the merchant market was *** percentage points higher across the interim periods (*** percent compared to *** percent).38 Nonsubject imports’ share of the merchant market decreased *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). Nonsubject imports’ share of the merchant market was *** percentage points lower in interim 2025 than interim 2024 (*** percent compared to *** percent). 37 The share of the merchant market represented by U.S. shipments of imports from China increased from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024. The share of the merchant market represented by U.S. shipments of imports from Germany increased *** percentage points irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The share of the merchant market represented by U.S. shipments of imports from India increased *** percentage points irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The share of the merchant market represented by U.S. shipments of imports from Saudi Arabia increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). 38 Shares for U.S. shipments of imports from Germany, India, and Saudi Arabia were higher across the interim periods, while the share for U.S. shipments of imports from China was lower. Germany’s share was *** percentage points higher across the interim periods (*** percent compared to *** percent). India’s share of apparent U.S. consumption was *** percentage points higher across the interim periods (*** percent compared to *** percent). Saudi Arabia’s share of apparent U.S. consumption was *** percentage points higher across the interim periods (*** percent compared to *** percent). China’s merchant market share was *** percentage points lower across the interim periods (*** percent compared to *** percent). 4.36 Table 4.10 Hexamine: Apparent U.S. merchant market consumption and market shares based on quantity data, by source and period Quantity in 1,000 pounds; shares in percent; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 U.S. producers Quantity *** *** *** *** *** China Quantity *** *** *** *** *** Germany Quantity *** *** *** *** *** India Quantity *** *** *** *** *** Saudi Arabia Quantity *** *** *** *** *** Subject sources Quantity 1,518 1,683 4,353 825 880 Russia Quantity *** *** *** *** *** All other sources Quantity *** *** *** *** *** Nonsubject sources Quantity *** *** *** *** *** All import sources Quantity *** *** *** *** *** All sources Quantity *** *** *** *** *** U.S. producers Share *** *** *** *** *** China Share *** *** *** *** *** Germany Share *** *** *** *** *** India Share *** *** *** *** *** Saudi Arabia Share *** *** *** *** *** Subject sources Share *** *** *** *** *** Russia Share *** *** *** *** *** All other sources Share *** *** *** *** *** Nonsubject sources Share *** *** *** *** *** All import sources Share *** *** *** *** *** All sources Share 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.37 Figure 4.7 Hexamine: Apparent U.S. merchant market consumption and market shares based on quantity data, by source and period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 4.38 Merchant market by value Table 4.11 and figure 4.8 present data on apparent U.S. consumption and U.S. market shares by value for hexamine for the merchant market. Apparent U.S. merchant market consumption decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to $*** in 2023 before increasing to $*** in 2024). Apparent U.S. merchant market consumption was *** percent lower across the interim periods ($*** compared to $***). The value of U.S. producer Bakelite’s commercial U.S. shipments decreased *** percent from 2022 to 2024 (decreasing from $*** in 2022 to slightly greater than $*** in 2023 and to slightly less than $*** in 2024). Bakelite’s share of the merchant market decreased irregularly by *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). Bakelite’s commercial U.S. shipments were *** percent lower across the interim periods ($*** compared to $***), and the company’s share of the merchant market was *** percentage points lower across the interim periods (*** percent compared to *** percent). 4.39 Subject imports’ share of the merchant market increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024).39 Subject imports’ share of the merchant market was *** percentage points higher across the interim periods (*** percent compared to *** percent).40 Nonsubject imports’ share of the merchant market decreased *** percentage points irregularly from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024). Nonsubject imports’ share of the merchant market was *** percentage points lower across the interim periods (*** percent compared to *** percent). 39 The share of the merchant market represented by U.S. shipments of imports from China increased from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024). The share of the merchant market represented by U.S. shipments of imports from Germany decreased *** percentage points irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The share of the merchant market represented by U.S. shipments of imports from India increased *** percentage points irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The share of the merchant market apparent represented by U.S. shipments of imports from Saudi Arabia increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). 40 Shares of apparent U.S. merchant market consumption for Germany and India were higher across the interim periods, while the shares for Saudi Arabia and China were lower. The share of the merchant market represented by U.S. shipments of imports from Germany was *** percentage points higher across the interim periods (*** percent compared to *** percent). The share of the merchant market represented by U.S. shipments of imports from India was *** percentage points higher across the interim periods (*** percent compared to *** percent). The share of the merchant market represented by U.S. shipments of imports from China was *** percentage points lower in across the interim periods (*** percent compared to *** percent). The share of the merchant represented by U.S. shipments of imports from Saudi Arabia was *** percentage points lower across the interim periods (*** percent compared to *** percent). 4.40 Table 4.11 Hexamine: Apparent U.S. merchant market consumption and total shares based on value data, by source and period Value in 1,000 dollars; shares in percent; interim period is January through March Source Measure 2022 2023 2024 Interim 2024 Interim 2025 U.S. producers Value *** *** *** *** *** China Value *** *** *** *** *** Germany Value *** *** *** *** *** India Value *** *** *** *** *** Saudi Arabia Value *** *** *** *** *** Subject sources Value 1,550 1,831 4,255 784 866 Russia Value *** *** *** *** *** All other sources Value *** *** *** *** *** Nonsubject sources Value *** *** *** *** *** All import sources Value *** *** *** *** *** All sources Value *** *** *** *** *** U.S. producers Share *** *** *** *** *** China Share *** *** *** *** *** Germany Share *** *** *** *** *** India Share *** *** *** *** *** Saudi Arabia Share *** *** *** *** *** Subject sources Share *** *** *** *** *** Russia Share *** *** *** *** *** All other sources Share *** *** *** *** *** Nonsubject sources Share *** *** *** *** *** All import sources Share *** *** *** *** *** All sources Share 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 4.41 Figure 4.8 Hexamine: Apparent U.S. merchant market consumption and market shares based on value data, by source and period * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 5.1 Part 5: Pricing data Factors affecting prices Raw material costs Hexamine is produced from a mixture of ammonia and formaldehyde.1 As shown in figure 5.1 and table 5.1, prices for ammonia peaked in the early part of 2022 before decreasing to a low in the latter half of 2023, and then stabilizing at a somewhat higher level since the latter half of 2024. Bakelite reported that the cost of hexamine closely follows the cost of raw materials.2 U.S. producer Bakelite reported that raw materials, as a share of its cost of goods sold (“COGS”), declined from *** percent in 2022 to *** percent in 2024, and were *** percent in interim 2025 compared with *** percent in interim 2024. Bakelite reported that formaldehyde accounted for approximately *** of its raw material costs in 2024, and ammonia accounted for the remaining ***. Figure 5.1 Raw materials: *** average prices by month, January 2022 to February 2025 * * * * * * * Source: ***, accessed June 20, 2025. 1 Preliminary publication, p V-1. 2 Ibid. 5.2 Table 5.1 Raw materials: *** average prices, by month, January 2022 to February 2025 Dollars per pound, NA denotes data is not available Month 2022 2023 2024 2025 January *** *** *** *** February *** *** *** *** March *** *** *** NA April *** *** *** NA May *** *** *** NA June *** *** *** NA July *** *** *** NA August *** *** *** NA September *** *** *** NA October *** *** *** NA November *** *** *** NA December *** *** *** NA Source: ***, accessed June 20, 2025. Transportation costs to the U.S. market Transportation costs for hexamine shipped from subject countries to the United States as a share of landed duty paid values averaged 19.9 percent for China, 14.1 percent for Germany, 15.2 percent for India, and 10.8 percent for Saudi Arabia during 2024. These estimates were derived from official import data and represent the transportation and other charges on imports.3 U.S. inland transportation costs U.S. producer Bakelite reported that it typically *** transportation ***, and most importers (6 of 8) reported that they typically arrange transportation to their customers. U.S. producer Bakelite reported that its U.S. inland transportation costs averaged *** percent while most importers reported costs of 5 to 10 percent.4 3 The estimated transportation costs were obtained by subtracting the customs value from the c.i.f. value of the imports for 2024 and then dividing by the customs value based on the HTS statistical reporting number 2933.69.5000. 4 In addition, importer *** reported inland transportation costs of 22 percent. 5.3 Pricing practices Pricing methods U.S. producer Bakelite reported setting prices using ***, and importers reported setting prices using transaction-by-transaction negotiations (table 5.2). Importer *** reported that it generally adds a “reasonable” margin to its costs when determining price. Table 5.2 Hexamine: Count of U.S. producer’s and importers’ reported price setting methods Method U.S. producer U.S. importers Transaction-by-transaction *** 5 Contract *** 0 Set price list *** 0 Other *** 3 Responding firms 1 7 Source: Compiled from data submitted in response to Commission questionnaires. Note: The sum of responses down may not add up to the total number of responding firms as each firm was instructed to check all applicable price setting methods employed. U.S. producer Bakelite reported selling most of its hexamine through *** and a substantial share through ***. Importers reported selling *** their sales in the spot market (table 5.3). Table 5.3 Hexamine: U.S. producer’s and importers’ shares of commercial U.S. shipments by type of sale, 2024 Share in percent Sale type U.S. producer Subject U.S. importers Long-term contracts *** *** Annual contract *** *** Short-term contracts *** *** Spot sales *** *** All sales types 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Because of rounding, figures may not add to the totals shown. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.4 U.S. producer Bakelite reported that ***. Bakelite reported having ***. ***. *** of six purchasers reported changes in their frequency of purchases since 2022, citing a decline in demand. *** purchasers reported contacting between one and two suppliers before making a purchase, while ***, ***, and *** reported contacting between one to three, one to four, and two to three suppliers, respectively. Sales terms and discounts Bakelite typically quotes prices on *** basis and most importers typically quote prices on a delivered basis. Bakelite reported that it ***. Most importers (6 of 7) reported that they do not have a discount policy, and importer *** reported that it may give case-by-case price reductions during negotiations. Price leadership One purchaser reported that Bakelite is the price leader and that it implemented inconsistent price increases prior to the filing of the petitions. Price data The Commission requested U.S. producers and importers to provide quarterly data for the total quantity and f.o.b. value of the following hexamine products shipped to unrelated U.S. customers during January 2022 to March 2025. Product 1.— “Unstabilized” Hexamine, with a hexamine content above 99% by weight. Product 2.— “Stabilized” Hexamine, with a hexamine content above 95% but less than or equal to 99% by weight. Product 3.— “Stabilized” Hexamine, with a hexamine content equal to or below 95% by weight. 5.5 U.S. producer Bakelite and seven importers provided usable pricing data for sales of the requested products, although not all firms reported pricing for all products for all quarters.5 Pricing data reported by these firms accounted for *** of the U.S. producer’s U.S. shipments of hexamine, virtually all of U.S. shipments of subject imports from China, Germany, and Saudi Arabia, and *** percent of U.S. shipments of subject imports from India. Pricing data reported for nonsubject Russia accounted for virtually all U.S. shipments of hexamine from Russia.6 Price data for products 1 to 3 are presented in tables 5.4 to 5.6 and figures 5.2 to 5.4. Nonsubject Russia prices are presented in Appendix D. Table 5.4 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 1 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity China price China quantity China margin Germany price Germany quantity Germany margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Table continued. 5 Per-unit pricing data are calculated from total quantity and total value data provided by U.S. producers and importers. The precision and variation of these figures may be affected by rounding, limited quantities, and producer or importer estimates. 6 Pricing coverage is based on U.S. shipments reported in questionnaires. 5.6 Table 5.4 (Continued) Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 1 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity India price India quantity India margin Saudi Arabia price Saudi Arabia quantity Saudi Arabia margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Table continued. Table 5.4 (Continued) Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 1 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity Subject price Subject quantity Subject margin 2022 Q1 *** *** *** *** *** 2022 Q2 *** *** *** *** *** 2022 Q3 *** *** *** *** *** 2022 Q4 *** *** *** *** *** 2023 Q1 *** *** *** *** *** 2023 Q2 *** *** *** *** *** 2023 Q3 *** *** *** *** *** 2023 Q4 *** *** *** *** *** 2024 Q1 *** *** *** *** *** 2024 Q2 *** *** *** *** *** 2024 Q3 *** *** *** *** *** 2024 Q4 *** *** *** *** *** 2025 Q1 *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 1: “Unstabilized” Hexamine, with a hexamine content above 99% by weight. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.7 Figure 5.2 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 1, by source and quarter Price of product 1 * * * * * * * Volume of product 1 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 1: “Unstabilized” Hexamine, with a hexamine content above 99% by weight. 5.8 Table 5.5 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 2 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity China price China quantity China margin Germany price Germany quantity Germany margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Table continued. Table 5.5 (Continued) Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 2 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity India price India quantity India margin Saudi Arabia price Saudi Arabia quantity Saudi Arabia margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Table continued. 5.9 Table 5.5 (Continued) Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 2 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity Subject price Subject quantity Subject margin 2022 Q1 *** *** *** *** *** 2022 Q2 *** *** *** *** *** 2022 Q3 *** *** *** *** *** 2022 Q4 *** *** *** *** *** 2023 Q1 *** *** *** *** *** 2023 Q2 *** *** *** *** *** 2023 Q3 *** *** *** *** *** 2023 Q4 *** *** *** *** *** 2024 Q1 *** *** *** *** *** 2024 Q2 *** *** *** *** *** 2024 Q3 *** *** *** *** *** 2024 Q4 *** *** *** *** *** 2025 Q1 *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 2: “Stabilized” Hexamine, with a hexamine content above 95% but less than or equal to 99% by weight. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.10 Figure 5.3 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 2, by source and quarter Price of product 2 * * * * * * * Volume of product 2 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 2: “Stabilized” Hexamine, with a hexamine content above 95% but less than or equal to 99% by weight. 5.11 Table 5.6 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 3 and margins of underselling/(overselling), by source and quarter Price in dollars per pound, quantity in pounds, margin in percent Period U.S. price U.S. quantity Germany price Germany quantity Germany margin 2022 Q1 *** *** *** *** *** 2022 Q2 *** *** *** *** *** 2022 Q3 *** *** *** *** *** 2022 Q4 *** *** *** *** *** 2023 Q1 *** *** *** *** *** 2023 Q2 *** *** *** *** *** 2023 Q3 *** *** *** *** *** 2023 Q4 *** *** *** *** *** 2024 Q1 *** *** *** *** *** 2024 Q2 *** *** *** *** *** 2024 Q3 *** *** *** *** *** 2024 Q4 *** *** *** *** *** 2025 Q1 *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 3: “Stabilized” Hexamine, with a hexamine content equal to or below 95% by weight. Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent. Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.12 Figure 5.4 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 3, by source and quarter Price of product 3 * * * * * * * Volume of product 3 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 3: “Stabilized” Hexamine, with a hexamine content equal to or below 95% by weight. 5.13 Price trends In general, prices for domestic and most imported hexamine increased between January 2022 to March 2025. Table 5.7 summarizes the price trends by country and by product. Domestic price increases ranged from *** to *** percent during January 2022 to March 2025 while import price increases ranged from *** to *** percent over the period. Tables 5.8 and 5.9 (and figures 5.5 and 5.6) present price indexes for U.S.-produced hexamine and imported hexamine from subject sources, respectively. Table 5.7 Hexamine: Summary of price data, by product and source, January 2022 to March 2025 Quantity in pounds, price in dollars per pound Product Source Number of quarters Quantity of shipments Low price High price First quarter price Last quarter price Percent change in price over period Product 1 United States 13 *** *** *** *** *** *** Product 1 China 5 *** *** *** *** *** *** Product 1 Germany 12 *** *** *** *** *** *** Product 1 India 6 *** *** *** *** *** *** Product 1 Saudi Arabia 6 *** *** *** *** *** *** Product 2 United States 13 *** *** *** *** *** *** Product 2 China 4 *** *** *** *** *** *** Product 2 Germany 12 *** *** *** *** *** *** Product 2 India 4 *** *** *** *** *** *** Product 2 Saudi Arabia 9 *** *** *** *** *** *** Product 3 United States 13 *** *** *** *** *** *** Product 3 China — *** *** *** *** *** *** Product 3 Germany 3 *** *** *** *** *** *** Product 3 India — *** *** *** *** *** *** Product 3 Saudi Arabia — *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Percent change column is percentage change from the first quarter 2022 to the first quarter in 2025. Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent. Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.14 Table 5.8 Hexamine: Indexed U.S. producer prices, by quarter Index in percent, 2022 Q1= 100.0 percent Period Product 1 Product 2 Product 3 2022 Q1 100.0 100.0 100.0 2022 Q2 *** *** *** 2022 Q3 *** *** *** 2022 Q4 *** *** *** 2023 Q1 *** *** *** 2023 Q2 *** *** *** 2023 Q3 *** *** *** 2023 Q4 *** *** *** 2024 Q1 *** *** *** 2024 Q2 *** *** *** 2024 Q3 *** *** *** 2024 Q4 *** *** *** 2025 Q1 *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Figure 5.5 Hexamine: Indexed U.S. producer prices, by quarter * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 5.15 Table 5.9 Hexamine: Indexed subject U.S. importer prices, by quarter Index in percent, 2022 Q1=100.0 percent Period Product 1 Product 2 Product 3 2022 Q1 100.0 100.0 *** 2022 Q2 *** *** 100.0 2022 Q3 *** *** *** 2022 Q4 *** *** *** 2023 Q1 *** *** *** 2023 Q2 *** *** *** 2023 Q3 *** *** *** 2023 Q4 *** *** *** 2024 Q1 *** *** *** 2024 Q2 *** *** *** 2024 Q3 *** *** *** 2024 Q4 *** *** *** 2025 Q1 *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 3 is indexed to 2022 Q2. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. Figure 5.6 Hexamine: Indexed U.S. importer prices, by quarter * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. 5.16 Price comparisons As shown in tables 5.10 to 5.12, prices for product imported from subject countries were below those for U.S.-produced product in 42 of 61 instances (*** pounds); margins of underselling ranged from 1.7 to 58.4 percent and averaged 23.8 percent. In the remaining 19 instances (*** pounds), prices for product from subject countries were between 0.3 and 393.3 percent above prices for the domestic product, and averaged 58.0 percent. The majority of the quarters of underselling (22 of 42) were attributable to imports of hexamine from Germany. Hexamine imports from India and Saudi Arabia also undersold domestic product in a majority of quarters, while product imported from China oversold domestic product in two-thirds (6 of 9) of relevant quarters As shown in table 5.11, prices for product imported from China were below those for U.S.-produced product in three of nine underselling instances (*** pounds); margins of underselling ranged from *** to *** percent. In six instances (*** pounds), prices for product from China were between *** and *** percent above prices for the domestic product. Prices for product imported from Germany were below those for U.S.-produced product in 22 of 27 underselling instances (*** pounds); margins of underselling ranged from *** to *** percent. In 5 of 19 overselling instances (*** pounds), prices for product from Germany were between *** and *** percent above prices for the domestic product. Prices for product imported from India were below those for U.S.-produced product in 9 of 10 instances (*** pounds); margins of underselling ranged from *** to *** percent. Prices for product imported from Saudi Arabia were below those for U.S.-produced product in 8 out of 15 instances (*** pounds); margins of underselling ranged from *** to *** percent. In the seven overselling instances (*** pounds), prices for product from Saudi Arabia were between *** and *** percent above prices for the domestic product. 5.17 Table 5.10 Hexamine: Instances of underselling and overselling and the range and average of margins, by product Quantity in pounds; margin in percent Product Type Number of quarters Quantity Average margin Min margin Max margin Product 1 Underselling 27 *** *** *** *** Product 2 Underselling 15 *** *** *** *** Product 3 Underselling — — — — — Total, all products Underselling 42 6,015,273 23.8 1.7 58.4 Product 1 Overselling 2 *** *** *** *** Product 2 Overselling 14 *** *** *** *** Product 3 Overselling 3 *** *** *** *** Total, all products Overselling 19 1,717,548 (58.0) (0.3) (393.3) Source: Compiled from data submitted in response to Commission questionnaires. Note: These data include only quarters in which there is a comparison between the U.S. and subject product. Table 5.11 Hexamine: Instances of underselling and overselling and the range and average of margins, by source Quantity in pounds; margin in percent Source Type Number of quarters Quantity Average margin Min margin Max margin China Underselling 3 *** *** *** *** Germany Underselling 22 *** *** *** *** India Underselling 9 *** *** *** *** Saudi Arabia Underselling 8 *** *** *** *** Total, all subject sources Underselling 42 *** *** *** *** China Overselling 6 *** *** *** *** Germany Overselling 5 *** *** *** *** India Overselling 1 *** *** *** *** Saudi Arabia Overselling 7 *** *** *** *** Total, all subject sources Overselling 19 *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: These data include only quarters in which there is a comparison between the U.S. and subject product. 5.18 Table 5.12 Hexamine: Instances of underselling and overselling and the range and average of margins, by year Quantity in pounds; margin in percent Year Type Number of quarters Quantity Average margin Min margin Max margin 2022 Underselling 7 *** *** *** *** 2023 Underselling 10 *** *** *** *** 2024 Underselling 19 *** *** *** *** 2025 Q1 Underselling 6 *** *** *** *** Total, all periods Underselling 42 *** *** *** *** 2022 Overselling 3 *** *** *** *** 2023 Overselling 9 *** *** *** *** 2024 Overselling 7 *** *** *** *** 2025 Q1 Overselling — *** *** *** *** Total, all periods Overselling 19 *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: These data include only quarters in which there is a comparison between the U.S. and subject product. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. Lost sales and lost revenue In the preliminary phase of the investigations, the Commission requested that the U.S. producer of hexamine report purchasers with which they experienced instances of lost sales or revenue due to competition from imports of hexamine from China, Germany, India, and Saudi Arabia during January 2021 through June 2024. Bakelite, the sole U.S. producer, reported instances of lost sales and also instances of needing to reduce prices or roll back announced price increases. In its lost sales and lost revenue allegations, Bakelite identified *** firms with which it lost sales or revenue (*** consisting of lost sales allegations, *** consisting of lost revenue allegations, and *** consisting of both types of allegations). One of the allegations was with respect to imports from ***,7 one with respect to imports from ***, one with respect to imports from ***, and one with respect to imports from ***.8 In the final phase of the investigations, Bakelite reported that it ***. 7 The allegation with respect to purchaser *** noted both *** and *** as the country of origin for the imported product. 8 In addition, Bakelite provided *** instances where hexamine imports from *** allegedly caused it to lose sales or reduce prices. 5.19 Staff contacted 27 purchasers and received responses from 6 purchasers. Aggregated U.S. purchasers’ reported purchases and imports from domestic, subject countries, nonsubject country Russia, and all other sources are shown in table 5.13. Responding purchasers reported purchasing *** pounds of hexamine during January 2022 to March 2025 (table 5.14). Of the responding purchasers, two firms reported that, since 2022, they had purchased imported hexamine from China, two from Germany, two from India, and two from Saudi Arabia instead of U.S.-produced product (table 5.16).9 As shown in table 5.15, purchasers reported that decisions to purchase subject hexamine were due to *** percent were from U.S. producers, *** percent were from China, *** percent were from Germany, *** percent were from India, *** percent were from Saudi Arabia, *** percent were from nonsubject Russia, and *** percent were from unknown sources. One of these purchasers reported that import prices from India were lower than U.S.-produced product, and the purchaser reported that price was a primary reason for the decision to purchase imported product rather than U.S.-produced product. *** reported that China is no longer a supplier and that sanctions impacted its purchases of hexamine from Russia. Purchasers identified higher product quality and the U.S. producer being a direct competitor as non-price reasons for purchasing imported rather than U.S.-produced product. As shown in table 5.17, one purchaser, reported that the U.S. producer had reduced prices in order to compete with lower-priced imports from China, Germany, India, and Saudi Arabia.10 9 Purchaser *** reported purchases from “sources unknown,” with merchandise purchased from firms ***. 10 *** reported that the U.S. producer’s price increased but began fluctuating downward in Q2 and Q3 2025. 5.20 Table 5.13 Hexamine: Aggregated U.S. purchasers’ reported purchases and imports, by source and period Quantity in 1,000 pounds; share in percent; ratio in percent; ratio represents the ratio to overall apparent consumption Source Measure 2022 2023 2024 Domestic Quantity *** *** *** Subject Quantity *** *** *** Russia Quantity *** *** *** All other nonsubject/unknown Quantity *** *** *** Nonsubject/unknown Quantity *** *** *** All sources Quantity *** *** *** Domestic Share of quantity *** *** *** Subject Share of quantity *** *** *** Russia Share of quantity *** *** *** All other nonsubject/unknown Share of quantity *** *** *** Nonsubject/unknown Share of quantity *** *** *** All sources Share of quantity 100.0 100.0 100.0 Domestic Ratio *** *** *** Subject Ratio *** *** *** Russia Ratio *** *** *** All other nonsubject/unknown Ratio *** *** *** Nonsubject/unknown Ratio *** *** *** All sources Ratio *** *** *** Table continued. 5.21 Table 5.13 Hexamine (Continued): Aggregated U.S. purchasers’ reported purchases and imports, by source and period Change in quantity (%Δ) percent; Change in share of quantity (ppt Δ) in percentage points; Change in ratio (ppt Δ) in percentage points; Ratio represents the ratio to overall apparent consumption Source Measure 2022 to 2024 2022 to 2023 2023 to 2024 Domestic %Δ Quantity ▼*** ▼*** ▼*** Subject %Δ Quantity ▲*** ▲*** ▲*** Russia %Δ Quantity ▼*** ▼*** ▼*** All other nonsubject/unknown %Δ Quantity ▲*** ▲*** ▲*** Nonsubject/unknown %Δ Quantity ▼*** ▼*** ▼*** All sources %Δ Quantity ▼*** ▲*** ▼*** Domestic ppt Δ Quantity ▼*** ▼*** ▲*** Subject ppt Δ Quantity ▲*** ▲*** ▲*** Russia ppt Δ Quantity ▼*** ▼*** ▼*** All other nonsubject/unknown ppt Δ Quantity ▲*** ▲*** ▲*** Nonsubject/unknown ppt Δ Quantity ▼*** ▼*** ▼*** All sources ppt Δ Quantity *** *** *** Domestic ppt Δ Ratio ▼*** ▼*** ▼*** Subject ppt Δ Ratio ▲*** ▲*** ▲*** Russia ppt Δ Ratio ▼*** ▼*** ▼*** All other nonsubject/unknown ppt Δ Ratio ▲*** ▲*** ▲*** Nonsubject/unknown ppt Δ Ratio ▼*** ▼*** ▼*** All sources ppt Δ Ratio ▼*** ▲*** ▼*** Source: Compiled from data submitted in response to Commission questionnaires. Table 5.14 Hexamine: Purchasers’ reported purchases and imports, by firm and source Quantity in 1,000 pounds, share in percent Purchaser Domestic quantity Subject quantity All other quantity Change in domestic share 2022- 2024 Change in subject country share 2022- 2024 Change in all other share 2022- 2024 *** *** *** *** *** *** *** *** *** *** *** ▼*** ▲*** *** *** *** *** *** ▼*** ▲*** ▼*** *** *** *** *** ▲*** ▼*** *** *** *** *** *** ▼*** ▲*** ▼*** *** *** *** *** ▼*** ▲*** *** All firms *** *** *** ▼*** ▲*** ▼*** Source: Compiled from data submitted in response to Commission questionnaires. Note: All other includes all other sources and unknown sources. Change is the percentage point change in the share of the firm’s total purchases of domestic and/or subject country imports between first and last years. Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 5.22 Table 5.15 Hexamine: Purchasers’ responses to purchasing subject imports instead of domestic product, by firm Quantity in 1,000 pounds Purchaser Purchased subject imports instead of domestic Imports priced lower Choice based on price Quantity Explanation *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** All firms Yes: 4; No: 1 Yes: 4; No: 0 Yes: 4; No: 1 *** Source: Compiled from data submitted in response to Commission questionnaires. 5.23 Table 5.16 Hexamine: Purchasers’ responses to purchasing subject imports instead of domestic product, by source Count in number of firms reporting; Quantity in 1,000 pounds Source Count of purchasers reporting subject instead of domestic Count of purchasers reported that imports were priced lower Count of purchasers reporting that price was a primary reason for shift Quantity China *** *** *** *** Germany *** *** *** *** India *** *** *** *** Saudi Arabia *** *** *** *** Any subject source *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. Table 5.17 Hexamine: Purchasers’ responses to U.S. producer price reductions, by firm Count in number of firms reporting; Price reduction in percent Purchaser Reported producers lowered prices Estimated percent of U.S. price reduction Explanation *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** All firms Yes: 1; No: 3 3.0 NA Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 6.1 Part 6: Financial experience of U.S. producers Background1 The petitioner, Bakelite, is the sole U.S. producer of in-scope hexamine. Bakelite reported financial data for a fiscal year ending December 31 st and on the basis of GAAP.2 The industry’s net sales are composed of commercial sales and internal consumption. During the period examined, January 1, 2022, through March 31, 2025, commercial sales represented *** percent of total net sales quantity and internal consumption represented the remaining *** percent.3 Figure 6.1 presents Bakelite’s share of sales quantity in 2024. 1 The following abbreviations are used in the tables and/or text of this section: generally accepted accounting principles (“GAAP”), fiscal year (“FY”), net sales (“NS”), cost of goods sold (“COGS”), selling, general, and administrative expenses (“SG&A expenses”), average unit values (“AUVs”), research and development expenses (“R&D expenses”), and return on assets (“ROA”). 2 The trade and financial sections reconciled. ***. Email from ***, July 6, 2025; Bakelite, “Bakelite Synthetics Announces Agreement to Acquire LRBG Chemicals, Inc.” August 28, 2023, https://bakelite.com/bakelite-synthetics-announces-agreement-to-acquire-lrbg-chemicals-inc/; LRBG Chemicals, “About Us: Our History,” accessed August 5, 2025, https://lrbgchemicals.com/our-history/; Bakelite, “Bakelite Synthetics Completes Acquisition of Georgia-Pacific Chemicals,” May 27, 2022, https://bakelite.com/acquisition-of-georgia-pacific-chemicals/. Staff verified the results of Bakelite with its corporate records. ***. Staff verification report, Bakelite, August 7, 2025. 3 ***. Email from ***, July 6, 2025. 6.2 Figure 6.1 Hexamine: U.S. producer Bakelite’s share of sales quantity in 2024, by type * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. Operations on hexamine Table 6.1 presents data on the U.S. producer’s total operations in relation to hexamine, while table 6.2 presents corresponding changes in AUVs. Financial results for the merchant market are presented in table 6.3, while table 6.4 presents the corresponding changes in AUVs for the merchant market. 6.3 Table 6.1 Hexamine: U.S. producer Bakelite’s results of total market operations, by item and period Quantity in 1,000 pounds; value in 1,000 dollars; ratios in percent Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Commercial sales Quantity *** *** *** *** *** Internal consumption Quantity *** *** *** *** *** Total net sales Quantity *** *** *** *** *** Commercial sales Value *** *** *** *** *** Internal consumption Value *** *** *** *** *** Total net sales Value *** *** *** *** *** Raw materials: Formaldehyde Value *** *** *** *** *** Raw materials: Ammonia Value *** *** *** *** *** COGS: Raw materials Value *** *** *** *** *** COGS: Direct labor Value *** *** *** *** *** COGS: Other factory Value *** *** *** *** *** COGS: Total Value *** *** *** *** *** Gross profit or (loss) Value *** *** *** *** *** SG&A expenses Value *** *** *** *** *** Operating income or (loss) Value *** *** *** *** *** Interest expense Value *** *** *** *** *** All other expenses Value *** *** *** *** *** Net income or (loss) Value *** *** *** *** *** Depreciation/amortization Value *** *** *** *** *** Cash flow Value *** *** *** *** *** Raw materials: Formaldehyde Ratio to NS *** *** *** *** *** Raw materials: Ammonia Ratio to NS *** *** *** *** *** COGS: Raw materials Ratio to NS *** *** *** *** *** COGS: Direct labor Ratio to NS *** *** *** *** *** COGS: Other factory Ratio to NS *** *** *** *** *** COGS: Total Ratio to NS *** *** *** *** *** Gross profit Ratio to NS *** *** *** *** *** SG&A expense Ratio to NS *** *** *** *** *** Operating income or (loss) Ratio to NS *** *** *** *** *** Net income or (loss) Ratio to NS *** *** *** *** *** Table continued. 6.4 Table 6.1 (Continued) Hexamine: U.S. producer Bakelite’s results of total market operations, by item and period Shares in percent; unit values in dollars per pound; count in number of firms reporting Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Raw materials: Formaldehyde Share *** *** *** *** *** Raw materials: Ammonia Share *** *** *** *** *** COGS: Raw materials Share *** *** *** *** *** COGS: Direct labor Share *** *** *** *** *** COGS: Other factory Share *** *** *** *** *** COGS: Total Share 100.0 100.0 100.0 100.0 100.0 Commercial sales Unit value *** *** *** *** *** Internal consumption Unit value *** *** *** *** *** Total net sales Unit value *** *** *** *** *** Raw materials: Formaldehyde Unit value *** *** *** *** *** Raw materials: Ammonia Unit value *** *** *** *** *** COGS: Raw materials Unit value *** *** *** *** *** COGS: Direct labor Unit value *** *** *** *** *** COGS: Other factory Unit value *** *** *** *** *** COGS: Total Unit value *** *** *** *** *** Gross profit or (loss) Unit value *** *** *** *** *** SG&A expenses Unit value *** *** *** *** *** Operating income or (loss) Unit value *** *** *** *** *** Net income or (loss) Unit value *** *** *** *** *** Operating losses Count *** *** *** *** *** Net losses Count *** *** *** *** *** Data Count 1 1 1 1 1 Source: Compiled from data submitted in response to Commission questionnaires. Note: Share represents share of COGS. Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 6.5 Table 6.2 Hexamine: Changes in AUVs between comparison periods for the total market Changes in percent; interim period is January through March Item 2022–24 2022–23 2023–24 Interim 2024–25 Commercial sales ▼*** ▼*** ▲*** ▲*** Internal consumption ▼*** ▼*** ▲*** ▲*** Total net sales ▼*** ▼*** ▲*** ▲*** Raw materials: Formaldehyde ▼*** ▼*** ▼*** ▼*** Raw materials: Ammonia ▼*** ▼*** ▼*** ▼*** COGS: Raw materials ▼*** ▼*** ▼*** ▼*** COGS: Direct labor ▼*** ▼*** ▲*** ▲*** COGS: Other factory ▲*** ▲*** ▲*** ▲*** COGS: Total ▼*** ▼*** ▲*** ▲*** Table continued. Table 6.2 (Continued) Hexamine: Changes in AUVs between comparison periods for the total market Changes in dollars per pound; interim period is January through March Item 2022–24 2022–23 2023–24 Interim 2024–25 Commercial sales ▼*** ▼*** ▲*** ▲*** Internal consumption ▼*** ▼*** ▲*** ▲*** Total net sales ▼*** ▼*** ▲*** ▲*** Raw materials: Formaldehyde ▼*** ▼*** ▼*** ▼*** Raw materials: Ammonia ▼*** ▼*** ▼*** ▼*** COGS: Raw materials ▼*** ▼*** ▼*** ▼*** COGS: Direct labor ▼*** ▼*** ▲*** ▲*** COGS: Other factory ▲*** ▲*** ▲*** ▲*** COGS: Total ▼*** ▼*** ▲*** ▲*** Gross profit or (loss) ▼*** ▼*** ▲*** ▲*** SG&A expense ▲*** ▼*** ▲*** ▲*** Operating income or (loss) ▼*** ▼*** ▲*** ▲*** Net income or (loss) ▼*** ▼*** ▼*** ▼*** Source: Compiled from data submitted in response to Commission questionnaires. Note: Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease. 6.6 Table 6.3 Hexamine: U.S. producer Bakelite’s results of merchant market operations, by item and period Quantity in 1,000 pounds; value in 1,000 dollars; ratios in percent; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Merchant market sales Quantity *** *** *** *** *** Merchant market sales Value *** *** *** *** *** Raw materials: Formaldehyde Value *** *** *** *** *** Raw materials: Ammonia Value *** *** *** *** *** COGS: Raw materials Value *** *** *** *** *** COGS: Direct labor Value *** *** *** *** *** COGS: Other factory Value *** *** *** *** *** COGS: Total Value *** *** *** *** *** Gross profit or (loss) Value *** *** *** *** *** SG&A expenses Value *** *** *** *** *** Operating income or (loss) Value *** *** *** *** *** Interest expense Value *** *** *** *** *** All other expenses Value *** *** *** *** *** Net income or (loss) Value *** *** *** *** *** Raw materials: Formaldehyde Ratio to NS *** *** *** *** *** Raw materials: Ammonia Ratio to NS *** *** *** *** *** COGS: Raw materials Ratio to NS *** *** *** *** *** COGS: Direct labor Ratio to NS *** *** *** *** *** COGS: Other factory Ratio to NS *** *** *** *** *** COGS: Total Ratio to NS *** *** *** *** *** Gross profit Ratio to NS *** *** *** *** *** SG&A expense Ratio to NS *** *** *** *** *** Operating income or (loss) Ratio to NS *** *** *** *** *** Net income or (loss) Ratio to NS *** *** *** *** *** Table continued. 6.7 Table 6.3 (Continued) Hexamine: U.S. producer Bakelite’s results of merchant market operations, by item and period Shares in percent; unit values in dollars per pound; count in number of firms reporting; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Raw materials: Formaldehyde Share *** *** *** *** *** Raw materials: Ammonia Share *** *** *** *** *** COGS: Raw materials Share *** *** *** *** *** COGS: Direct labor Share *** *** *** *** *** COGS: Other factory Share *** *** *** *** *** COGS: Total Share 100.0 100.0 100.0 100.0 100.0 Merchant market sales Unit value *** *** *** *** *** Raw materials: Formaldehyde Unit value *** *** *** *** *** Raw materials: Ammonia Unit value *** *** *** *** *** COGS: Raw materials Unit value *** *** *** *** *** COGS: Direct labor Unit value *** *** *** *** *** COGS: Other factory Unit value *** *** *** *** *** COGS: Total Unit value *** *** *** *** *** Gross profit or (loss) Unit value *** *** *** *** *** SG&A expenses Unit value *** *** *** *** *** Operating income or (loss) Unit value *** *** *** *** *** Net income or (loss) Unit value *** *** *** *** *** Operating losses Count *** *** *** *** *** Net losses Count *** *** *** *** *** Data Count 1 1 1 1 1 Source: Compiled from data submitted in response to Commission questionnaires. Note: Share represents share of COGS. 6.8 Table 6.4 Hexamine: Changes in merchant market AUVs between comparison periods Changes in percent; interim period is January through March Item 2022–24 2022–23 2023–24 Interim 2024–25 Merchant market sales ▼*** ▼*** ▲*** ▲*** Raw materials: Formaldehyde ▼*** ▼*** ▼*** ▲*** Raw materials: Ammonia ▼*** ▼*** ▼*** ▲*** COGS: Raw materials ▼*** ▼*** ▼*** ▲*** COGS: Direct labor ▼*** ▼*** ▲*** ▲*** COGS: Other factory ▲*** ▲*** ▲*** ▲*** COGS: Total ▼*** ▼*** ▲*** ▲*** Table continued. Table 6.4 (Continued) Hexamine: Changes in merchant market AUVs between comparison periods Changes in dollars per pound; interim period is January through March Item 2022–24 2022–23 2023–24 Interim 2024–25 Merchant sales ▼*** ▼*** ▲*** ▲*** Raw materials: Formaldehyde ▼*** ▼*** ▼*** ▲*** Raw materials: Ammonia ▼*** ▼*** ▼*** ▲*** COGS: Raw materials ▼*** ▼*** ▼*** ▲*** COGS: Direct labor ▼*** ▼*** ▲*** ▲*** COGS: Other factory ▲*** ▲*** ▲*** ▲*** COGS: Total ▼*** ▼*** ▲*** ▲*** Gross profit or (loss) ▼*** ▼*** ▲*** ▲*** SG&A expense ▲*** ▼*** ▲*** ▲*** Operating income or (loss) ▼*** ▼*** ▲*** ▲*** Net income or (loss) ▼*** ▼*** ▼*** ▼*** Source: Compiled from data submitted in response to Commission questionnaires. Note: Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease. 6.9 Net sales Total market As shown in table 6.1, both the quantity and value of the industry’s total market net sales decreased between 2022 and 2024, and the quantity and value were lower in interim 2025 when compared with the same period in 2024.4 The industry’s total net sales AUV decreased from $*** per pound in 2022 to $*** per pound in 2024. The industry’s net sales AUV was higher in interim 2025, at $*** per pound, than in interim 2024, at $*** per pound. Merchant market The merchant market sales trends were similar to the trends for total market net sales for 2022 to 2024. As shown in table 6.3, the industry’s merchant market sales, by both quantity and value, decreased between 2022 and 2024. Additionally, the merchant market net sales quantity and value were lower in interim 2025 than in interim 2024.5 The industry’s merchant market net sales AUV decreased from $*** per pound in 2022 to $*** and was higher in interim 2025, at $*** per pound, than in interim 2024, at $*** per pound. 4 Net sales quantity for the total market decreased by *** percent and net sales value decreased by *** percent between 2022 and 2024. Net sales quantity was *** percent lower in interim 2025 compared with interim 2024. In the same interim periods, the net sales value was *** percent lower. 5 Merchant market sales quantity decreased by *** percent and merchant sales value decreased by *** percent between 2022 and 2024. Merchant market sales quantity was *** percent lower in interim 2025 compared with interim 2024. In the same interim periods, the merchant market sales value was *** percent lower. 6.10 Cost of goods sold and gross profit or loss Total market Raw material costs, direct labor, and other factory costs accounted for ***, ***, and *** percent of total market COGS, respectively, in 2024. Total raw material costs decreased from $*** in 2022 to $*** in 2024, and were lower in interim 2025, at $*** than in interim 2024, at $***. On a per-pound basis, raw material costs decreased from $*** in 2022 to $*** in 2024 and were lower in interim 2025, at $***, than in interim 2024, at $***.6 The industry’s cost of direct labor decreased from $*** in 2022 to $*** in 2024 but was higher in interim 2025 ($***) than in interim 2024 ($***). The average unit cost of direct labor decreased from $*** per pound in 2022 to $*** per pound in 2024 and was higher in interim 2025 than in interim 2024 ($*** per pound compared to $*** per pound). Other factory costs increased from $*** in 2022 to $*** in 2024 and were higher in interim 2025, at $***, than in interim 2024, at $***. On a per-pound basis, other factory costs increased from $*** per pound in 2022 to $*** per pound in 2024. Other factory costs were higher on a per-pound basis in interim 2025, at $***, than in interim 2024, at $***.7 Total COGS decreased by *** percent, from $*** in 2022 to $*** in 2024 and was lower in interim 2025, at $***, than in interim 2024 at $***. Gross profit irregularly decreased from $*** in 2022 to $*** in 2024 and was lower in interim 2025, at $***, than in interim 2024, at $***. Total market COGS as a ratio to net sales value decreased from *** percent in 2022 to *** percent in 2024 and was higher in interim 2025, at *** percent, than in interim 2024, at *** percent. Gross profit as a ratio to net sales increased from *** percent to *** percent from 2022 to 2024 and was lower in interim 2025 (***) percent) than in interim 2024 (***) percent). 6 Bakelite stated that it had worked a great deal towards reducing its raw material costs by methods such as acquisition and achieving supplier economies of scale. Hearing transcript, pp. 48 to 49 (Boninsegni). 7 ***. Email from ***, July 6, 2025. 6.11 Merchant market Raw material costs, direct labor, and other factory costs accounted for ***, ***, and *** percent of merchant market COGS, respectively, in 2024. Total raw material costs decreased from $*** in 2022 to $*** in 2024 and were lower in interim 2025, at $***, than in interim 2024, at $***. On a per-pound basis, merchant market raw material costs decreased from $*** in 2022 to $*** in 2024 but were higher in interim 2025, at $***, than in interim 2024, at $***. The industry’s cost of direct labor for the merchant market decreased from $*** in 2022 to $*** in 2024 but was higher in interim 2025 ($***) than in interim 2024 ($***). The average unit cost of direct labor decreased from $*** per pound in 2022 to $*** per pound in 2024 and was higher in interim 2025 ($*** per pound) than in interim 2024 ($*** per pound). Other factory costs for the merchant market increased from $*** in 2022 to $*** in 2024 and were higher in interim 2025, at $***, than in interim 2024, at $***. On a per-pound basis, other factory costs increased from $*** in 2022 to $*** in 2024. They were higher on a per-pound basis in interim 2025, at $***, than in interim 2024, at $***. Merchant market COGS decreased by *** percent, from $*** in 2022 to $*** in 2024. COGS was *** percent lower in interim 2025, at $***, than in interim 2024, at $***. There was an overall decrease in gross profit from $*** in 2022 to $*** in 2024, and it was lower in interim 2025, at $***, than in interim 2024, at $***. Merchant market COGS as a ratio to net sales value decreased from *** percent in 2022 to *** percent in 2024 but was higher in interim 2025, at *** percent, than in interim 2024, at *** percent. Gross profit as a ratio to net sales increased from *** percent to *** percent from 2022 to 2024 but was lower in interim 2025 (***) percent) than in interim 2024 (***) percent). 6.12 SG&A expenses and operating income or loss Total market Total market SG&A expenses increased overall from $*** in 2022 to $*** in 2024 and were higher in interim 2025, at $***, than in interim 2024, at $***. The SG&A expense ratio (SG&A expenses as a share of sales) increased from *** percent in 2022 to *** percent in 2024 and were higher in interim 2025, at *** percent, than in interim 2024, at *** percent.8 Total market operating income decreased from $*** in 2022 to $*** in 2024. Operating income was lower in interim 2025 ($***) than interim 2024 ($***). The operating margin (operating income as a ratio to net sales) increased from *** percent in 2022 to *** percent in 2024 and was lower in interim 2025 (*** percent) than in in interim 2024 (*** percent). Merchant market Merchant market SG&A expenses increased overall from $*** in 2022 to $*** in 2024 and were higher in interim 2025, at $***, than in interim 2024, at $***. The SG&A expense ratio for the merchant market (SG&A expenses as a share of sales) increased from *** percent in 2022 to *** percent in 2024 and was higher in interim 2025, at *** percent, than in interim 2024, at *** percent. Merchant market operating income decreased irregularly from $*** in 2022 to $*** in 2024. Merchant market operating income was lower in interim 2025, at $***, than in interim 2024, at $***. The operating margin (operating income as a ratio to net sales) increased from *** percent in 2022 to *** percent in 2024 and was lower in interim 2025, at *** percent, than in interim 2024, at *** percent. 8 ***. Email from ***, July 6, 2025. 6.13 All other expenses and net income or loss Total market Classified below the total market operating income level are interest expense, other expense, and other income, which are listed in table 6.1.9 Interest expense for the total market increased from $*** in 2022 to $*** in 2024 and was higher in interim 2025, at $***, than in interim 2024, at $***. All other expenses for the total market increased irregularly from $*** in 2022 to $*** in 2023 and to $*** in 2024; they were higher in interim 2025, at $***, than in interim 2024, at $***.10 Total market net income decreased from $*** in 2022 to $*** in 2024 and was lower in interim 2025 $*** than in interim 2024 $***. Merchant market Classified below the total market operating income level are interest expense, other expense, and other income, which are listed in table 6.3.11 Interest expense for the merchant market increased from $*** in 2022 to $*** in 2024 and was higher in interim 2025, at $***, than in interim 2024, at $***. All other expenses for the merchant market increased irregularly from $*** in 2022 to $*** in 2024 and were higher in interim 2025, at $***, than in interim 2024, at $***.12 Merchant market net income decreased overall from $*** in 2022 to $*** in 2024. Merchant market net income was lower in interim 2025 ($***) than in interim 2024 ($***). 9 ***. 10 ***. Email from ***, July 6, 2025. 11 ***. 12 See footnote above referring to interest and all other expenses for the total market. 6.14 Variance analysis A variance analysis for the total hexamine operations of the U.S. producer is presented in table 6.5.13 The information for this variance analysis is derived from table 6.1. A variance analysis for the merchant market hexamine operations of the U.S. producer is presented in table 6.6, the information for which is derived from table 6.3. The total market variance analysis in table 6.6 shows that the decrease in total market operating income between 2022 and 2024 was primarily attributable to unfavorable price and volume variances despite a smaller favorable cost/expense variance. Lower operating income in interim 2025 compared with interim 2024 is primarily attributable to unfavorable cost/expense and volume variances that outweighed a smaller favorable price variance. 13 The Commission’s variance analysis is calculated in three parts: Sales variance, cost of sales variance (COGS variance), and SG&A expense variance. Each part consists of a price variance (in the case of the sales variance) or a cost or expense variance (in the case of the COGS and SG&A expense variance), and a volume variance. The sales or cost/expense variance is calculated as the change in unit price or per-unit cost/expense times the new volume, while the volume variance is calculated as the change in volume times the old unit price or per-unit cost/expense. Summarized at the bottom of the table, the price variance is from sales; the cost/expense variance is the sum of those items from COGS and SG&A variances, respectively, and the volume variance is the sum of the volume components of the net sales, COGS, and SG&A expense variances. The overall volume component of the variance analysis is generally small. 6.15 Table 6.5 Hexamine: Variance analysis on the total market operations of U.S. producer Bakelite between comparison periods Value in 1,000 dollars; interim period is January through March Item 2022-24 2022-23 2023-24 Interim 2024-25 Net sales price variance *** *** *** *** Net sales volume variance *** *** *** *** Total net sales variance *** *** *** *** COGS cost variance *** *** *** *** COGS volume variance *** *** *** *** COGS total variance *** *** *** *** Gross profit variance *** *** *** *** SG&A cost variance *** *** *** *** SG&A volume variance *** *** *** *** SG&A total variance *** *** *** *** Operating income price variance *** *** *** *** Operating income cost/expense variance *** *** *** *** Operating income volume variance *** *** *** *** Operating income total variance *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Unfavorable variances (which are negative) are shown in parentheses, all others are favorable (positive). The merchant market variance analysis in table 6.6 shows that the increase in merchant market operating income between 2022 and 2024 was primarily attributable to unfavorable cost/expense and price variances that offset a favorable volume variance. Lower merchant market operating income in interim 2025 compared with interim 2024 is primarily attributable to unfavorable price and volume variances that outweighed a favorable cost/expense variance. 6.16 Table 6.6 Hexamine: Variance analysis on the merchant market operations of U.S. producer Bakelite between comparison periods Value in 1,000 dollars; interim period is January through March Item 2022-24 2022-23 2023-24 Interim 2024-25 Commercial sales price variance *** *** *** *** Commercial sales volume variance *** *** *** *** Total commercial sales variance *** *** *** *** COGS cost variance *** *** *** *** COGS volume variance *** *** *** *** COGS total variance *** *** *** *** Gross profit variance *** *** *** *** SG&A cost variance *** *** *** *** SG&A volume variance *** *** *** *** SG&A total variance *** *** *** *** Operating income price variance *** *** *** *** Operating income cost/expense variance *** *** *** *** Operating income volume variance *** *** *** *** Operating income total variance *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Unfavorable variances (which are negative) are shown in parentheses, all others are favorable (positive). 6.17 Capital expenditures, research and development expenses, assets, and return on assets Table 6.7 presents Bakelite’s total market capital expenditures, R&D expenses, assets, and return on assets, and the firm’s narrative explanations of the nature, focus, and significance of the items are presented in table 6.8.14 The industry’s capital expenditures increased overall between 2022 and 2024 and were higher in interim 2025 than interim 2024. R&D expenses increased overall from 2022 to 2024 and were the same in the interim periods. As for assets in the industry, they decreased from 2022 to 2024 and the corresponding ROA *** in *** three yearly periods. Table 6.7 Hexamine: U.S. producer Bakelite’s capital expenditures, R&D expenses, total net assets, and ROA, by item and period Value in 1,000 dollars; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Capital expenditures *** *** *** *** *** R&D expenses *** *** *** *** *** Total net assets *** *** *** *** *** Return on assets *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: NA indicates not applicable. Zeroes, null values, and undefined calculations are suppressed and shown as “— “. 14 The operating ROA is calculated as operating income divided by total assets. With respect to a firm’s overall operations, the total asset value reflects an aggregation of a number of assets which are generally not product specific. Thus, high-level allocations are generally required in order to report a total asset value on a product-specific basis. 6.18 Table 6.8 Hexamine: U.S. producer Bakelite's narrative descriptions of its capital expenditures, R&D expenses, and total net assets Item Narrative on capital expenditures Capital expenditures *** R&D expenses *** Total net assets *** Source: Compiled from data submitted in response to Commission questionnaires. Capital and investment The Commission requested the U.S. producer of hexamine to describe any actual or potential negative effects of imports of hexamine from China, Germany, India, and Saudi Arabia on the firm’s growth, investment, ability to raise capital, development and production efforts, or the scale of capital investments. Table 6.9 presents the impact in each category and table 6.10 provides the U.S. producer’s narrative responses. 6.19 Table 6.9 Hexamine: U.S. producer Bakelite’s count indicating actual and anticipated negative effects of imports from subject sources on investment, growth, and development since January 1, 2022, by effect Number of firms reporting Effect Category Count Cancellation, postponement, or rejection of expansion projects Investment *** Denial or rejection of investment proposal Investment *** Reduction in the size of capital investments Investment *** Return on specific investments negatively impacted Investment *** Other investment effects Investment *** Any negative effects on investment Investment *** Rejection of bank loans Growth *** Lowering of credit rating Growth *** Problem related to the issue of stocks or bonds Growth *** Ability to service debt Growth *** Other growth and development effects Growth *** Any negative effects on growth and development Growth *** Anticipated negative effects of imports Future *** Source: Compiled from data submitted in response to Commission questionnaires. Table 6.10 Hexamine: U.S. producer Bakelite’s narratives relating to actual and anticipated negative effects of imports on investment, growth, and development, since January 1, 2022, by effect Item Narrative on impact of imports *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 7.1 Threat considerations and information on nonsubject countries Section 771(7)(F)(ⅰ) of the Act (19 U.S.C. § 1677(7)(F)(ⅰ)) provides that— In determining whether an industry in the United States is threatened with material injury by reason of imports (or sales for importation) of the subject merchandise, the Commission shall consider, among other relevant economic factors1-- (I) if a countervailable subsidy is involved, such information as may be presented to it by the administering authority as to the nature of the subsidy (particularly as to whether the countervailable subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement), and whether imports of the subject merchandise are likely to increase, (II) any existing unused production capacity or imminent, substantial increase in production capacity in the exporting country indicating the likelihood of substantially increased imports of the subject merchandise into the United States, taking into account the availability of other export markets to absorb any additional exports, (III) a significant rate of increase of the volume or market penetration of imports of the subject merchandise indicating the likelihood of substantially increased imports, (IV) whether imports of the subject merchandise are entering at prices that are likely to have a significant depressing or suppressing effect on domestic prices, and are likely to increase demand for further imports, (V) inventories of the subject merchandise, 1 Section 771(7)(F)(ⅱ) of the Act (19 U.S.C. § 1677(7)(F)(ⅱ)) provides that “The Commission shall consider {these factors} . . . as a whole in making a determination of whether further dumped or subsidized imports are imminent and whether material injury by reason of imports would occur unless an order is issued or a suspension agreement is accepted under this title. The presence or absence of any factor which the Commission is required to consider . . . shall not necessarily give decisive guidance with respect to the determination. Such a determination may not be made on the basis of mere conjecture or supposition.” 7.2 (VI) the potential for product-shifting if production facilities in the foreign country, which can be used to produce the subject merchandise, are currently being used to produce other products, (VII) in any investigation under this title which involves imports of both a raw agricultural product (within the meaning of paragraph (4)(E)(ⅳ)) and any product processed from such raw agricultural product, the likelihood that there will be increased imports, by reason of product shifting, if there is an affirmative determination by the Commission under section 705(b)(1) or 735(b)(1) with respect to either the raw agricultural product or the processed agricultural product (but not both), (VIII) the actual and potential negative effects on the existing development and production efforts of the domestic industry, including efforts to develop a derivative or more advanced version of the domestic like product, and (IX) any other demonstrable adverse trends that indicate the probability that there is likely to be material injury by reason of imports (or sale for importation) of the subject merchandise (whether or not it is actually being imported at the time).2 Information on the nature of the subsidies was presented earlier in this report; information on the volume and pricing of imports of the subject merchandise is presented in Parts 4 and 5; and information on the effects of imports of the subject merchandise on U.S. producers’ existing development and production efforts is presented in Part 6. Information on inventories of the subject merchandise; foreign producers’ operations, including the potential for “product-shifting;” any other threat indicators, if applicable; and any dumping in third- country markets, follows. Also presented in this section of the report is information obtained for consideration by the Commission on nonsubject countries. 2 Section 771(7)(F)(ⅲ) of the Act (19 U.S.C. § 1677(7)(F)(ⅲ)) further provides that, in antidumping investigations, “. . . the Commission shall consider whether dumping in the markets of foreign countries (as evidenced by dumping findings or antidumping remedies in other WTO member markets against the same class or kind of merchandise manufactured or exported by the same party as under investigation) suggests a threat of material injury to the domestic industry.” 7.3 Subject countries The Commission issued foreign producers’ or exporters’ questionnaires to the following number of firms believed to possibly produce and/or export hexamine in their respective foreign industries: 14 in China, 3 in Germany, 7 in India, and 2 in Saudi Arabia.3 Usable responses to the Commission’s questionnaire were received from one firm in Germany (Prefere Paraform GmbH & Co. or “Prefere”), two firms in India (Kanoria Chemicals & Industries Limited or “Kanoria” and Shreenathji Rasayan Pvt. Ltd. or “M/S Shreenathji”), and one firm in Saudi Arabia (Methanol Chemicals Company (Chemanol) or “Chemanol”).4 Table 7.1 presents the number of producers/exporters in each subject foreign industry that responded to the Commission’s questionnaire, their estimated shares of total production of hexamine within their respective subject foreign industry during 2024, and the estimated shares that their exports to the United States comprised as a share of the total exports of hexamine to the United States from their respective foreign industries in 2024. 3 These firms were identified through a review of information submitted in the petition and presented in third-party sources. During the staff conference, the petitioner indicated that there is generally only one major producer/exporter in three of the subject foreign industries (Prefere Paraform GmbH & Co. in Germany, Kanoria in India, and Chemanol in Saudia Arabia) with several major producers of hexamine in China. Conference transcript, p. 21 (Roderick). 4 Four firms also submitted responses certifying that they had not produced or exported hexamine since January 1, 2022: ***. 7.4 Table 7.1 Hexamine: Number of responding producers/exporters, approximate share of production, and exports to the United States as a share of U.S. imports, by subject foreign industry, 2024 Subject foreign industry Number of responding firms Approximate share of production (percent) Exports as a share of U.S. imports from subject country (percent) China — *** *** Germany 1 *** *** India 2 *** *** Saudi Arabia 1 *** *** Source: Compiled from data submitted in response to Commission questionnaires and official U.S. import statistics of the U.S. Department of Commerce Census Bureau using HTS statistical reporting number 2933.69.5000, accessed on June 23, 2025. Note: “Approximate share of production” reflects the responding firms’ estimates of their production as a share of total foreign industry production of hexamine in 2024. ***. Since not all firms have perfect knowledge of the industry in their home market, different firms might use different denominators in estimating their firm's share of the total requested. Exports as a share of U.S. imports” reflects a comparison of export data reported by subject producers in response to the Commission’s foreign producer/exporter questionnaire with official Commerce import statistics using primary HTS statistical reporting number 2933.69.5000, accessed on June 23, 2025. ***. Zeroes, null values, and undefined calculations are suppressed and shown as “—”. 7.5 Table 7.2 presents information on the hexamine operations of the responding subject producers by firm, while table 7.3 presents the information grouped by subject foreign industry. Table 7.2 Hexamine: Summary data on responding subject foreign producers in 2024, by firm Quantity in 1,000 pounds; Shares in percent Producer and subject foreign industry Production (pounds) Share of reported production (percent) Exports to the United States (pounds) Share of reported exports to the United States (percent) Total shipments (pounds) Share of firm's total shipments exported to the United States (percent) Germany: Prefere *** *** *** *** *** *** India: Kanoria *** *** *** *** *** *** India: M/S Shreenathji *** *** *** *** *** *** Saudi Arabia: Chemanol *** *** *** *** *** *** All individual producers *** 100.0 *** 100.0 *** *** Source: Compiled from data submitted in response to Commission questionnaires. Table 7.3 Hexamine: Summary data for subject foreign producers in 2024, by firm Quantity in 1,000 pounds; Shares in percent Subject foreign industry Production (1,000 pounds) Share of reported production (percent) Exports to the United States (1,000 pounds) Share of reported exports to the United States (percent) Total shipments (1,000 pounds) Share of firm's total shipments exported to the United States (percent) China *** *** *** *** *** *** Germany *** *** *** *** *** *** India *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** All subject foreign industries *** 100.0 *** 100.0 *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 7.6 Changes in operations Subject producers were asked to report any change in the character of their operations or organization relating to the production of hexamine since January 1, 2022, and to describe any anticipated changes to the character or nature of their operations relating to the production of hexamine in the near future. Two of the four responding subject producers indicated that they had experienced and/or anticipated changes as shown in table 7.4. Table 7.4 Hexamine: Reported changes in operations and anticipated changes in operations in the subject countries since January 1, 2022, by type, subject foreign industry, and firm Item Subject foreign industry, firm name, and accompanying narrative response regarding changes in operations and anticipated changes Other *** Expansions *** Anticipated changes in operations *** Source: Compiled from data submitted in response to Commission questionnaires. Table 7.5 presents events in the subject countries’ industries since January 1, 2022, as reported in public sources. Table 7.5 Hexamine: Important industry events in the subject foreign industry since 2022 Item Subject foreign industry Firm: Event Supply and marketing agreement Germany Prefere Paraform and Evos: Rotterdam B.V. (“Evos”), September 2023: The firms reached an agreement under which Prefere Resins assumed the exclusive supply and marketing of hexamine and other chemicals to Evos’ existing customers. Expansion/ plant opening India Kanoria Chemicals & Industries, September 2024: The firm added additional production capacity of 18 metric tons per day to its existing plant in Ankleshwar, Gujarat, India. Kanoria also opened an additional plant to produce the input formaldehyde. Source: “Prefrere Resins to Acquire the Supply and Marketing of Paraformaldehyde and Hexamethyelenetramine from Evos,” Prefere Resins website. Accessed October 28, 2024. https://prefere.com/en/company/news/Evos-2023. “Kanoria Chemicals doubles hexamine production with new manufacturing plants in Guarat,” The Hindu Businessline, September 6, 2024. https://www.thehindubusinessline.com/markets/stock-markets/kanoria-chemicals-doubles-hexamine- production-with-new-manufacturing-plants-in-gujarat/article68612998.ece. 7.7 Installed and practical overall capacity Table 7.6 presents data on subject producers’ installed capacity, practical overall capacity, and practical hexamine capacity and production on the same equipment.5 None of the responding subject producers reported any production of alternate products using the same equipment and/or machinery as used to produce in-scope hexamine. As such, the reported overall production and hexamine production figures as well as the practical hexamine and practical overall figures for capacity and capacity utilization were identical in all periods. From 2022 to 2024, subject producers’ practical capacity increased by *** percent (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024).6 Subject practical capacity was also *** percent higher in interim 2025 than in interim 2024 (*** pounds compared to *** pounds).7 Subject producers’ hexamine production increased by *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Hexamine production, however, was *** percent lower across the interim periods (*** pounds compared to *** pounds). As a result of hexamine production increasing more than practical capacity, subject practical capacity utilization increased by *** percentage points from 2022 to 2024 (from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024).8 Practical capacity utilization was *** percentage points lower across the interim periods (*** percent compared to *** percent).9 5 Installed or “theoretical” overall capacity measures the level of production firms could have attained based solely on existing capital investments and not considering other constraints such as availability of material inputs, labor force, and normal downtime. The two practical capacity measures take into consideration both existing capital investment as well as non-capital investment constraints. Practical overall capacity measures firms’ capacity to produce hexamine as well as any other products produced using the same equipment/machinery, whereas practical hexamine capacity measures only the practical capacity of firms to produce hexamine based on firms’ actual product mixes over the period. 6 Responding subject producers’ reported that their collective installed capacity increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). 7 Installed capacity was collectively *** percent higher in interim 2025 than interim 2024 (*** pounds compared to *** pounds). 8 Installed capacity utilization collectively increased *** percentage points from 2022 to 2024 (from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). 9 Installed capacity utilization was collectively *** percentage points lower in interim 2025 than in interim 2024 (*** percent compared to *** percent). 7.8 Table 7.6 Hexamine: Producers' in subject foreign industries installed and practical capacity and production on the same equipment as subject production, by period Capacity and production in 1,000 pounds; utilization in percent; interim period is January through March Item Measure 2022 2023 2024 Interim 2024 Interim 2025 Installed overall Capacity *** *** *** *** *** Installed overall Production *** *** *** *** *** Installed overall Utilization *** *** *** *** *** Practical overall Capacity *** *** *** *** *** Practical overall Production *** *** *** *** *** Practical overall Utilization *** *** *** *** *** Practical hexamine Capacity *** *** *** *** *** Practical hexamine Production *** *** *** *** *** Practical hexamine Utilization *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Constraints on capacity Subject producers were asked to describe any constraints that set limits on their firms’ overall capacity over the period. Prefere reported *** constraints as follows, “***.”10 Kanoria reported, “***.”11 10 Prefere foreign producer questionnaire response at II-3d. 11 Kanoria foreign producer questionnaire response at II-3c. 7.9 Operations on hexamine Aggregate hexamine operations in the subject countries Table 7.7 presents information on the hexamine operations of the responding subject producers/exporters (aggregate data for all subject foreign industries). The four responding foreign producers reported the majority of their collective shipments were export shipments in all periods (between *** percent and *** percent of total shipments across the periods) with home market shipments representing the remainder (between *** and *** percent of total shipments across the periods).12 Subject producers’ exports to the United States as a share of their total shipments increased from *** percent of the subject producers’ total shipments in 2022 to *** percent of the subject producers’ total shipments in interim 2025. Subject producers’ exports to the United States increased by *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Exports to the United States were *** percent higher across the interim periods (*** pounds compared to *** pounds). Subject producers projected their exports to the United States would be *** pounds in 2025 and *** pounds in 2026. Subject producers’ exports to all other markets also increased by *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). All other market exports were *** percent higher across the interim periods (*** pounds compared to *** pounds). Subject producers collectively projected their exports to all other markets would increase by *** percent in 2025 compared to 2024 at *** pounds and would increase further to *** pounds in 2026. 12 The vast majority of subject producers’ reported home market shipments were commercial shipments, which accounted for between *** and *** percent of total shipments during 2022 to 2024 and the interim periods. 7.10 Table 7.7 Hexamine: Data on subject foreign industries, by item and period Quantity in 1,000 pounds; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 Capacity *** *** *** *** *** *** *** Production *** *** *** *** *** *** *** End-of-period inventories *** *** *** *** *** *** *** Internal consumption *** *** *** *** *** *** *** Commercial home market shipments *** *** *** *** *** *** *** Home market shipments *** *** *** *** *** *** *** Exports to the United States *** *** *** *** *** *** *** Exports to all other markets *** *** *** *** *** *** *** Export shipments *** *** *** *** *** *** *** Total shipments *** *** *** *** *** *** *** Table continued. Table 7.7 (Continued) Hexamine: Data on subject foreign industries, by period Shares and ratios in percent; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 Capacity utilization ratio *** *** *** *** *** *** *** Inventory ratio to production *** *** *** *** *** *** *** Inventory ratio to total shipments *** *** *** *** *** *** *** Internal consumption share *** *** *** *** *** *** *** Commercial home market shipments share *** *** *** *** *** *** *** Home market shipments share *** *** *** *** *** *** *** Exports to the United States share *** *** *** *** *** *** *** Exports to all other markets share *** *** *** *** *** *** *** Export shipments share *** *** *** *** *** *** *** Total shipments share 100.0 100.0 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. 7.11 Practical hexamine capacity and production by subject foreign industry Table 7.8 presents information on subject producers’ production, capacity, and capacity utilization by subject country. German producer Prefere’s practical hexamine capacity increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 and 2023 to *** pounds in 2024). Prefere’s practical capacity was flat across the interim periods at *** pounds. Prefere projected that its practical capacity would be the same in 2025 and 2026 as compared to 2024. Prefere’s production increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). The company’s production was *** percent higher across the interim periods (*** pounds compared to *** pounds). The company projected its hexamine production would be virtually the same in 2025 and 2026 as compared to 2024. Resultingly, Prefere’s practical capacity utilization increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). The company’s practical capacity utilization was *** percentage points higher across the interim periods (*** percent compared to *** percent). Prefere projected its practical capacity utilization would be the same in 2025 and 2026 as its reported 2024 practical capacity utilization. From 2022 to 2024, the practical hexamine capacity of the subject producers in India increased *** percent (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Subject practical capacity in India was *** percent higher across the interim periods (*** pounds compared to *** pounds).13 The Indian firms projected their collective capacity would increase *** percent in 2025 and 2026 as compared to 2024 to *** pounds.14 The Indian producers’ collective production increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Production in India was *** percent lower in interim 2025 compared to interim 2024 (*** pounds 13 Indian firm Kanoria reported its practical capacity increased from *** pounds in 2022 to *** pounds in 2024 and also increased across the interim periods (*** pounds compared to *** pounds). As noted in the operational changes section, Kanoria reported that it ***. Indian producer M/S Shreenathji reported its practical capacity was flat from 2022 to 2024 and across the interim periods at *** pounds for the full year periods and *** pounds for the interim periods. 14 Indian firm Kanoria projected its practical capacity would increase to *** pounds in 2025 and 2026, while M/S Shreenathji projected its practical capacity would be the same in 2025 and 2026 as in 2024. 7.12 compared to *** pounds).15 The Indian firms’ capacity utilization increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). Practical capacity utilization was *** percentage points lower across the interim periods (*** percent compared to *** percent).16 The Indian producers’ projected their collective hexamine production would increase to *** pounds in 2025 and to *** pounds in 2026.17 The Indian firms projected that their practical capacity utilization would be *** percent in 2025 and *** percent in 2026. Their share of total production increased from *** percent in 2022 to *** percent in 2024. Saudi producer Chemanol’s practical hexamine capacity increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in both 2023 and 2024). Chemanol’s practical capacity was flat across the interim periods at *** pounds. Chemanol projected that its practical capacity would be the same in 2025 and 2026 as compared to 2024. Chemanol’s production increased irregularly by *** percent from 2022 to 2024 (increasing from approximately *** pounds in 2022 and 2023 to *** pounds in 2024). Chemanol’s production was *** percent lower across the interim periods (*** pounds compared to *** pounds). The company projected its hexamine production would be lower in 2025 and 2026 as compared to 2024 (*** pounds in 2025 and then increasing to *** pounds in 2026). Resultingly, Chemanol’s practical capacity utilization increased irregularly *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The company’s practical capacity utilization was *** percentage points lower across the interim periods (*** percent compared to *** percent). Chemanol projected its practical capacity utilization would be lower at *** percent in 2025 before increasing to *** percent in 2026. 15 Kanoria reported its production increased from *** pounds in 2022 to *** pounds in 2024 and was higher across the interim periods (*** pounds compared to *** pounds. M/S Shreenathji reported its production increased from *** in 2022 to *** pounds in 2024. It reported its production was lower across the interim periods (*** pounds compared to *** pounds). 16 Kanoria’s capacity utilization increased from *** percent in 2022 to *** percent in 2024 and was lower across the interim periods (*** percent compared to *** percent). M/S Shreenathji’s capacity utilization increased from *** percent in 2022 to *** percent in 2024 and was lower across the interim periods (*** percent compared to *** percent). 17 Kanoria projected production would increase to *** pounds in both 2025 and 2026. M/S Shreenathji projected its production would increase to *** pounds in 2025 and to *** pounds in 2026. 7.13 Table 7.8 Hexamine: Subject foreign industries' output: Practical capacity, by subject foreign industry and period Practical capacity Quantity in 1,000 pounds; interim period is January through March Subject foreign industry 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. Table 7.8 (Continued) Hexamine: Subject foreign industries' output: Production, by subject foreign industry and period Production Quantity in 1,000 pounds; interim period is January through March Subject foreign industry 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. 7.14 Table 7.8 (Continued) Hexamine: Subject foreign industries' output: Capacity utilization ratio, by subject foreign industry and period Capacity utilization ratio Capacity utilization in percent Subject foreign industry 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. Table 7.8 (Continued) Hexamine: Subject foreign industries' output: Share of production, by subject foreign industry and period Share of production Share in percent Subject foreign industry 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries 100.0 100.0 100.0 100.0 100.0 100.0 100.0 Source: Compiled from data submitted in response to Commission questionnaires. Note: Capacity utilization ratio represents the ratio of the subject producer’s production to its production capacity. 7.15 Hexamine exports, by subject country Table 7.9 presents information on subject producers’ exports of hexamine by subject country. German producer Prefere’s exports to the United States increased *** percent irregularly from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 before decreasing to *** pounds in 2024). Its exports to the United States were *** percent higher across the interim periods (*** pounds compared to *** pounds). The company projected that its exports to the United States would increase *** percent in 2025 compared to 2024 to *** pounds but decrease to *** pounds in 2026. Prefere’s total exports increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Its total exports were *** percent higher across the interim periods (*** pounds compared to *** pounds). The company projected that its total exports would be *** percent higher in 2025 than its 2024 exports (at *** pounds) but would decrease to *** pounds in 2026. The German company reported that its exports to the United States as a share of its total shipments increased irregularly from 2022 to 2024 (from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024). Its exports to the United States as a share of its total shipments was *** percentage points higher across the interim periods (*** percent compared to *** percent). Prefere reported the majority of its total shipments as being exports during the period (*** percent or higher in all periods). The Indian producers’ exports to the United States collectively increased *** percent irregularly from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). The Indian producers’ exports to the United States were *** percent lower across the interim periods (*** pounds compared to *** pounds). The subject firms in India collectively projected their exports to the United States would be *** pounds in 2025 and 2026. The Indian producers’ total exports increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Total exports of the Indian producers were *** percent higher across the interim periods (*** pounds compared to *** pounds). The companies projected that their total exports would be *** percent higher in 2025 than 2024 at *** pounds and would increase to *** pounds in 2026. 7.16 The Indian producers’ exports to the United States as a share of their total shipments increased irregularly *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). Their exports to the United States as a share of their total exports was lower across the interim periods (*** percent compared to *** percent). The Indian firms projected their exports to the United States as a share of total shipments would be *** percent in 2025 and *** percent in 2026. The Indian firms’ share of total shipments exported increased from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). They projected their share of total shipments exported would be *** percent in 2025 and *** percent in 2026. Saudi producer Chemanol’s exports to the United States increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Its exports to the United States, however, were *** percent lower across the interim periods (*** pounds compared to *** pounds). The company projected that its exports to the United States would increase *** percent in 2025 compared to 2024 to *** pounds and increase further to *** pounds in 2026. Chemanol’s total exports increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). Its total exports were *** percent lower across the interim periods (*** pounds compared to *** pounds). The company projected that its total exports would be *** percent lower in 2025 than its 2024 exports (at *** pounds) but would increase to *** pounds in 2026. Chemanol reported that its exports to the United States as a share of its total shipments increased from 2022 to 2024 (from *** percent in 2022 to *** in 2023 and to *** percent in 2024). Its exports to the United States as a share of its total shipments was lower across the interim periods (*** percent compared to *** percent). Chemanol reported virtually all its shipments as being exports (*** percent or higher in all periods). 7.17 Table 7.9 Hexamine: Subject foreign industries' exports: Exports to the United States, by subject foreign industry and period Exports to the United States Quantity in 1,000 pounds; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. Table 7.9 (Continued) Hexamine: Subject foreign industries' exports: Share of total shipments exported to the United States, by subject foreign industry and period Share of total shipments exported to the United States Share in percent; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. 7.18 Table 7.9 (Continued) Hexamine: Subject foreign industries' exports: Total exports, by subject foreign industry and period Total exports Quantity in 1,000 pounds; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. Table 7.9 (Continued) Hexamine: Subject foreign industries' exports: Share of total shipments exported, by subject foreign industry and period Share of total shipments exported Share in percent; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 7.19 Hexamine inventories, by subject foreign industry Table 7.10 presents information on the ending inventories of the responding producers by subject foreign country. German producer Prefere reported that its end-of-period inventories increased *** percent from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024). The company’s end-of-period inventories were *** percent lower across the interim periods (*** pounds). Prefere projected its end-of-period inventories would be *** percent lower in 2025 than 2024, at *** pounds but would increase to *** pounds in 2026. Prefere’s ratio of end-of-period inventories to total shipments increased *** percentage points from 2022 to 2024 (increasing from *** percent in 2022 and 2023 to *** percent in 2024). The company’s ratio of end-of-period inventories was lower across the interim periods (*** percent compared to *** percent). Based on Prefere’s projections, its ratios of end-of-period inventories would be *** percent in 2025 and *** percent in 2026. The Indian producers’ end-of-period inventories increased *** percent irregularly from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). The companies’ end-of-period inventories were *** percent higher across the interim periods (*** pounds compared to *** pounds).18 The Indian producers collectively projected their end of period inventories would be *** percent higher in 2025 than in 2024, at *** pounds but would then decrease slightly to *** pounds in 2026.19 The Indian firms’ ratio of end-of-period inventories to total shipments by period increased irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024).20 The companies’ collective ratio of end-of-period inventories was higher across the interim periods (*** percent compared to *** percent). Based on the Indian firms’ projections, the companies’ collective ratio of end-of-period inventories would be *** and *** percent in 2025 and 2026, respectively. 18 The end-of-period inventories for both producers increased irregularly (decreasing from 2022 to 2023 before increasing in 2024). Both firms also reported higher end-of-period inventories across the interim periods. 19 Kanoria projected its end-of-period inventories would be higher in 2025 and 2026 than its 2024 end-of-period inventories, while M/S Shreenathji projected that its end-of-period inventories would be lower in 2025 and 2026 than its 2024 end-of-period inventories. 20 Kanoria’s ratio of end-of-period inventories to total shipments ratios were generally lower than the ratios calculated for M/S Shreenathji (ranging from *** percent to *** percent for Kanoria compared to *** percent to *** percent for M/S Shreenathji). 7.20 Saudi producer Chemanol reported that its end-of-period inventories decreased *** percent irregularly from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). The company’s end-of-period inventories were *** percent higher across the interim periods (*** pounds compared to *** pounds). Chemanol projected its end of period inventories would be *** percent lower in 2025 than 2024, at *** pounds but would increase to *** pounds in 2026. Chemanol’s ratio of end-of- period inventories to total shipments decreased irregularly *** percentage points from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The company’s ratio of end-of-period inventories was higher across the interim periods (*** percent compared to *** percent). Based on Chemanol’s projections, the ratio of end-of-period inventories would be *** percent in 2025 and *** percent in 2026. Resultingly, the responding subject companies’ end-of-period inventories collectively decreased *** percent irregularly from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 before increasing to *** pounds in 2024). The subject companies’ end-of- period inventories for interim 2024 period were *** percent higher across the interim periods (*** pounds compared to *** pounds). The companies collectively projected their end-of- period inventories would be *** percent higher in 2026 than 2025, at *** pounds and would increase further in 2026 to *** pounds. The ratio of end-of-period inventories to total shipments by period decreased irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The subject companies’ collective ratio of end-of-period inventories was higher across the interim periods (*** percent compared to *** percent). Based on the projections, the ratio of end-of-period inventories to total shipments would be *** percent in 2025 and *** percent in 2026. 7.21 Table 7.10 Hexamine: Subject foreign industries’ ending inventories: Ending inventories, by source and period Quantity in 1,000 pounds; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Table continued. Table 7.10 (Continued) Hexamine: Subject foreign industries’ ending inventories: Ratio of ending inventories to total shipments, by source and period Ratio in percent; interim period is January through March Item 2022 2023 2024 Interim 2024 Interim 2025 Projection 2025 Projection 2026 China *** *** *** *** *** *** *** Germany *** *** *** *** *** *** *** India *** *** *** *** *** *** *** Saudi Arabia *** *** *** *** *** *** *** All subject foreign industries *** *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 7.22 Alternative products The responding producers in Germany, India, and Saudi Arabia did not report any production of alternative products using the same equipment and/or labor as those used to produce hexamine during the period of investigation. Exports Table 7.11 presents Global Trade Atlas (“GTA”) data for exports under HS subheading 2933.69 (“Heterocyclic Compounds (Excluding Melamine) Containing an Unfused Triazine Ring (Whether or not Hydrogenated) in the Structure”), a category which contains hexamine and out-of-scope products, from subject countries to the United States and to all destination markets. Exports to the United States collectively reported for the subject foreign industries under this category decreased 14.6 percent irregularly from 2022 to 2024 (decreasing from 211.4 million pounds in 2022 to 107.6 million pounds in 2023 before increasing to 180.6 million pounds in 2024).21 Exports to all destination markets collectively reported for the subject foreign industries under this category increased 6.7 percent from 2022 to 2024 (decreasing from 1.4 billion pounds in 2022 to 1.2 billion pounds in 2023 before increasing to 1.5 billion pounds in 2024).22 Resultingly, the share of exports exported to the United States from all subject exporting industries decreased from 15.4 percent of all exports in 2022 to 8.9 percent of exports in 2023 before increasing to 12.4 percent of total exports in 2024. 21 Exports to the United States from China, Germany, and India decreased irregularly, while exports to the United States from Saudi Arabia increased across this period. 22 Global exports under this category decreased irregularly for Germany and India, increased irregularly for China, and increased across the period for Saudi Arabia. 7.23 Table 7.11 Heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure: Global exports from subject exporters: Exports to the United States, by exporter and period Quantity in 1,000 pounds Exporter Measure 2022 2023 2024 China Quantity 199,345 95,464 160,451 Germany Quantity 8,794 6,042 7,978 India Quantity 3,235 1,629 2,902 Saudi Arabia Quantity 36 4,508 9,279 Subject exporters Quantity 211,411 107,643 180,610 Table continued. Table 7.11 (Continued) Heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure: Global exports from subject exporters: Exports to all destination markets, by exporter and period Quantity in 1,000 pounds Exporter Measure 2022 2023 2024 China Quantity 1,238,361 1,070,601 1,316,265 Germany Quantity 93,830 91,218 91,918 India Quantity 23,976 24,432 22,567 Saudi Arabia Quantity 14,038 18,725 31,479 Subject exporters Quantity 1,370,206 1,204,976 1,462,230 Table continued. Table 7.11 (Continued) Heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure: Global exports from subject exporters: Share of exports exported to the United States, by exporter and period Share in percent Exporter Measure 2022 2023 2024 China Share 16.1 8.9 12.2 Germany Share 9.4 6.6 8.7 India Share 13.5 6.7 12.9 Saudi Arabia Share 0.3 24.1 29.5 Subject exporters Share 15.4 8.9 12.4 Source: Official exports statistics and official global imports statistics from Saudi Arabia and Russia (constructed exports) under HS subheading 2933.69.50, as reported by various national statistical authorities in the Global Trade Atlas Suite database, accessed June 20, 2025. Note: Shares represent the shares exported to the United States out of all destination markets. 7.24 U.S. inventories of imported merchandise Table 7.12 presents data on U.S. importers’ reported inventories of hexamine. Overall, U.S. importers reported inventories of imports from subject sources increased *** percent irregularly from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 before decreasing to *** pounds in 2024).23 U.S. importers’ inventories of imports from subject sources were *** percent higher across the interim periods (*** pounds compared to *** pounds).24 The ratio of inventories of imports from subject sources to imports from subject sources decreased *** percentage points irregularly from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024).25 The ratio of subject inventories to subject imports was higher across the interim periods (*** percent compared to *** percent).26 The ratio of end-of-period inventories of imports from subject sources to U.S. shipments of imports from subject sources decreased irregularly from 2022 to 2024 (increasing from *** percent in 2022 to *** percent in 2023 before decreasing to 23 U.S. importers’ inventories of imports from India decreased from 2022 to 2024 (decreasing from *** pounds in 2022 and 2023 to *** pounds in 2024). U.S. importers’ inventories of imports from Saudi Arabia increased irregularly from 2022 to 2024 (increasing from *** pounds in 2022 to *** pounds in 2023 before decreasing to *** pounds in 2024). U.S. importers did not report holding any inventories of imported hexamine from China in any of the periods and *** pounds in inventories from Germany in 2023 and *** pounds in inventories from Germany in 2024. 24 U.S. importers’ inventories of imports from Saudia Arabia were lower across the interim periods (*** pounds compared to *** pounds), higher for India (*** pounds compared to *** pounds), and the same for Germany (*** in both periods. No inventories of imported hexamine from China were reported in either interim period. 25 The ratio of inventories of U.S. imports from Germany to U.S. imports from Germany was *** percent in 2023 and *** percent in 2024. The ratio of inventories of U.S. imports from India to U.S. imports from India increased from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024. The ratio of inventories of U.S. imports from Saudi Arabia to U.S. imports from Saudi Arabia was *** percent in 2023 and *** percent in 2024. U.S. importers did not report holding any inventories of imported hexamine from China in any of the periods. 26 The inventory to import ratios were higher for Germany and India across the interim periods (*** percent compared to *** percent for Germany and *** percent compared to *** for India) and lower for Saudi Arabia (*** percent compared to *** percent). 7.25 *** percent in 2024).27 The ratio of subject inventories to U.S. shipment of subject imports was higher across the interim periods (*** percent compared to *** percent).28 U.S. importers’ inventories of nonsubject U.S. imports decreased *** percent from 2022 to 2024 (decreasing from *** pounds in 2022 to *** pounds in 2023 and to *** pounds in 2024).29 The ratio of inventories of nonsubject U.S. imports to nonsubject U.S. imports decreased irregularly from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 before increasing to *** percent in 2024). The ratio of inventories of nonsubject U.S. imports to U.S. shipments of imports from nonsubject sources decreased from 2022 to 2024 (decreasing from *** percent in 2022 to *** percent in 2023 and to *** percent in 2024). U.S. importers’ inventories of imports from nonsubject sources were *** in interim 2025 as compared to *** pounds in interim 2024. In interim 2024, the ratios of nonsubject import inventories to nonsubject imports, U.S. shipments of nonsubject imports, and total shipments of nonsubject imports were ***, ***, and *** percent, respectively. 27 The ratio of inventories of U.S. imports from Germany to U.S. shipments of imports from Germany was *** percent in 2023 and *** percent in 2024. The ratio of inventories of U.S. imports from India to U.S. shipments of imports from India increased from *** percent in 2022 to *** percent in 2023 before decreasing to *** percent in 2024. The ratio of inventories of U.S. imports from Saudi Arabia to U.S. shipments of imports from Saudi Arabia was *** percent in 2023 and *** percent in 2024. U.S. importers did not report holding any inventories of imported hexamine from China in any of the periods. 28 The inventory to U.S. shipments of import ratios were higher for Germany, India, and Saudi Arabia across the interim periods (*** percent compared to *** percent, *** percent compared to ***, and *** percent compared to *** percent, respectively) and lower for Saudi Arabia (*** percent compared to *** percent). 29 The vast majority of the reported nonsubject inventories were from Russia. Inventories of imports from Russia had completely left the market as of the interim 2025 period. 7.26 Table 7.12 Hexamine: U.S. importers’ inventories and their ratio to select items, by source and period Quantity in pounds; ratio in percent Measure Source 2022 2023 2024 Interim 2024 Interim 2025 Inventories quantity China *** *** *** *** *** Ratio to imports China *** *** *** *** *** Ratio to U.S. shipments of imports China *** *** *** *** *** Ratio to total shipments of imports China *** *** *** *** *** Inventories quantity Germany *** *** *** *** *** Ratio to imports Germany *** *** *** *** *** Ratio to U.S. shipments of imports Germany *** *** *** *** *** Ratio to total shipments of imports Germany *** *** *** *** *** Inventories quantity India *** *** *** *** *** Ratio to imports India *** *** *** *** *** Ratio to U.S. shipments of imports India *** *** *** *** *** Ratio to total shipments of imports India *** *** *** *** *** Inventories quantity Saudi Arabia *** *** *** *** *** Ratio to imports Saudi Arabia *** *** *** *** *** Ratio to U.S. shipments of imports Saudi Arabia *** *** *** *** *** Ratio to total shipments of imports Saudi Arabia *** *** *** *** *** Inventories quantity Subject *** *** *** *** *** Ratio to imports Subject *** *** *** *** *** Ratio to U.S. shipments of imports Subject *** *** *** *** *** Ratio to total shipments of imports Subject *** *** *** *** *** Inventories quantity Russia *** *** *** *** *** Ratio to imports Russia *** *** *** *** *** Ratio to U.S. shipments of imports Russia *** *** *** *** *** Ratio to total shipments of imports Russia *** *** *** *** *** Inventories quantity All other sources *** *** *** *** *** Ratio to imports All other sources *** *** *** *** *** Ratio to U.S. shipments of imports All other sources *** *** *** *** *** Ratio to total shipments of imports All other sources *** *** *** *** *** Inventories quantity Nonsubject *** *** *** *** *** Ratio to imports Nonsubject *** *** *** *** *** Ratio to U.S. shipments of imports Nonsubject *** *** *** *** *** Ratio to total shipments of imports Nonsubject *** *** *** *** *** Inventories quantity All *** *** *** *** *** Ratio to imports All *** *** *** *** *** Ratio to U.S. shipments of imports All *** *** *** *** *** Ratio to total Shipments of imports All *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Quantities shown as “0” represent quantities greater than zero but less than 500 pounds. Zeroes, null values, and undefined calculations are suppressed and shown as “—“. 7.27 U.S. importers’ outstanding orders The Commission requested importers to indicate whether they imported or arranged for the importation of hexamine from China, Germany, India, or Saudi Arabia after March 30, 2025. Of the ten responding U.S. importers, four U.S. importers reported such arranged imports. Their reported data are presented in table 7.13. As shown, responding importers collectively reported *** pounds in arranged imports for the period covering April 2025 through March 2026, *** percent of which are from subject sources. Of the *** pounds in reported arranged imports from subject sources, *** percent were reported as being arranged from Saudi Arabia, *** percent were reported as being arranged from Germany, and *** percent were reported as being arranged from India, while there were *** arranged imports reported from China. Table 7.13 Hexamine: Arranged imports, by source and by period Quantity in 1,000 pounds Source Q2 2025 Q3 2025 Q4 2025 Q1 2026 Total China *** *** *** *** *** Germany *** *** *** *** *** India *** *** *** *** *** Saudi Arabia *** *** *** *** *** Subject sources *** *** *** *** *** Nonsubject sources *** *** *** *** *** All import sources *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. 7.28 Third-country trade actions Based on available information, hexamine from the subject countries has not been subject to other antidumping or countervailing duty investigations outside the United States during the period of investigation.30 Information on nonsubject countries Table 7.14 presents data for global exports of heterocyclic compounds containing an unfused triazine ring under HS 2933.69, a subheading that includes out-of-scope products. Total volume of global exports decreased by 5.9 percent during the period of investigation, with a sharper (19.6 percent) decline from 2022 to 2023. However, the volume of exports increased from China (6.3 percent), the United States (11.8 percent), Saudi Arabia (124.2 percent) and Belgium (65.3 percent) over the entire period. In 2024, subject countries and the United States combined accounted for an 82.4 percent share of global exports, an increase from 72.7 percent in 2022. China was the largest global exporter during the period of investigation, expanding its share from 65.7 percent in 2022 to 74.2 percent in 2024. Russia’s exports under 2933.69 decreased from 41.5 million pounds in 2022 to 14.5 million pounds in 2024 (65.0 percent).31 Petitioner notes that this decline coincided with the build up to the invasion of Ukraine, emphasizing hexamine’s use in producing the explosive RDX.32 Spain’s exports under 2933.69 decreased from 78.5 million pounds in 2022 to 65.2 million pounds in 2024 (16.0 percent).33 30 On October 20, 2020 India terminated antidumping duties on hexamine produced in or originating from China and the United Arab Emirates. These duties of $84.25 per metric ton were initiated in March 2014. WTO Trade Remedies Portal, accessed October 30, 2024. 14/16/2013-1/2 - Investigation details - Trade Remedies Data Portal. 31 Official global imports statistics from Russia (constructed exports) under HS subheadings 2933.69 as reported by various national statistical authorities in the Global Trade Atlas Suite database, accessed June 20, 2025. 32 Petition, vol. 1, pp. 18 to 19. Petitioner stated that Russia’s exit from the U.S. market was not sudden and that “Bakelite and other suppliers and customers of hexamine” had information about Russia’s departure from the market in 2021. Hearing transcript, pp. 28 (Lutz), 44 (Groden), and 75 (Roderick); Petitioner’s posthearing brief, attachment 1, p. 27. 33 Petitioner stated that it unaware of hexamine production in Spain. Hearing transcript, pp. 66, 80 (Kanna). 7.29 Table 7.14 Heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure: Global exports, by reporting country and by period Quantity in 1,000 pounds; value in 1,000 dollars Exporting country Measure 2022 2023 2024 United States Quantity 34,404 22,519 38,455 China Quantity 1,238,361 1,070,601 1,316,265 Germany Quantity 93,830 91,218 91,918 India Quantity 23,976 24,432 22,567 Saudi Arabia Quantity 14,038 18,725 31,479 Subject exporters Quantity 1,370,206 1,204,976 1,462,230 Spain Quantity 78,530 60,272 65,199 Japan Quantity 54,068 39,921 43,701 United Kingdom Quantity 40,709 36,339 32,061 Belgium Quantity 13,003 19,476 21,490 France Quantity 22,172 14,016 14,836 Russia Quantity 41,478 16,801 14,527 Netherlands Quantity 40,700 14,898 13,489 All other exporters Quantity 189,632 86,217 68,148 All reporting exporters Quantity 1,884,902 1,515,434 1,774,135 United States Value 134,298 97,021 112,683 China Value 1,908,910 1,224,621 1,320,516 Germany Value 289,087 326,420 293,891 India Value 116,697 117,585 109,831 Saudi Arabia Value 13,483 11,200 20,733 Subject exporters Value 2,328,178 1,679,826 1,744,971 Spain Value 127,725 93,866 88,801 Japan Value 110,588 77,211 84,803 United Kingdom Value 34,840 24,706 18,735 Belgium Value 29,672 56,284 56,771 France Value 53,820 37,915 37,006 Russia Value 22,009 6,644 6,089 Netherlands Value 107,189 61,369 103,735 All other exporters Value 456,429 359,472 317,085 All reporting exporters Value 3,404,747 2,494,314 2,570,679 Table continued. 7.30 Table 7.14 (Continued) Heterocyclic compounds (excluding melamine) containing an unfused triazine ring (whether or not hydrogenated) in the structure: Global exports, by reporting country and by period Unit values in dollars per pound; Shares in percent Exporting country Measure 2022 2023 2024 United States Unit value 3.90 4.31 2.93 China Unit value 1.54 1.14 1.00 Germany Unit value 3.08 3.58 3.20 India Unit value 4.87 4.81 4.87 Saudi Arabia Unit value 0.96 0.60 0.66 Subject exporters Unit value 1.70 1.39 1.19 Spain Unit value 1.63 1.56 1.36 Japan Unit value 2.05 1.93 1.94 United Kingdom Unit value 0.86 0.68 0.58 Belgium Unit value 2.28 2.89 2.64 France Unit value 2.43 2.71 2.49 Russia Unit value 0.53 0.40 0.42 Netherlands Unit value 2.63 4.12 7.69 All other exporters Unit value 2.41 4.17 4.65 All reporting exporters Unit value 1.81 1.65 1.45 United States Share of quantity 1.8 1.5 2.2 China Share of quantity 65.7 70.6 74.2 Germany Share of quantity 5.0 6.0 5.2 India Share of quantity 1.3 1.6 1.3 Saudi Arabia Share of quantity 0.7 1.2 1.8 Subject exporters Share of quantity 72.7 79.5 82.4 Spain Share of quantity 4.2 4.0 3.7 Japan Share of quantity 2.9 2.6 2.5 United Kingdom Share of quantity 2.2 2.4 1.8 Belgium Share of quantity 0.7 1.3 1.2 France Share of quantity 1.2 0.9 0.8 Russia Share of quantity 2.2 1.1 0.8 Netherlands Share of quantity 2.2 1.0 0.8 All other exporters Share of quantity 10.1 5.7 3.8 All reporting exporters Share of quantity 100.0 100.0 100.0 Source: Official exports statistics under HS subheading 2933.69 as reported by various national statistical authorities in the Global Trade Atlas Suite database, accessed June 5, 2025, and official global imports statistics from Saudi Arabia and Russia under HS subheading 3920.62 as reported by UN comtrade in the Global Trade Atlas Suite database, accessed June 20, 2025. Note: Shares and ratios shown as "0.0" represent values greater than zero, but less than "0.05" percent. Zeroes, null values, and undefined calculations are suppressed and shown as “—“. United States is shown at the top followed by the countries under investigation, all remaining top exporting countries in descending order of 2024 data. A.1 APPENDIX A FEDERAL REGISTER NOTICES A.3 The Commission makes available notices relevant to its investigations and reviews on its website, www.usitc.gov. In addition, the following tabulation presents, in chronological order, Federal Register notices issued by the Commission and Commerce during the current proceeding. Citation Title Link 89 FR 80929, October 4, 2024 Hexamine (Hexamethylenetetramine) From China, Germany, India, and Saudi Arabia; Notice of Institution of Antidumping and Countervailing Duty Investigations and Scheduling of Preliminary Phase Investigations https://www.govinfo.gov/cont ent/pkg/FR-2024-10- 04/pdf/2024-22956.pdf 89 FR 87545, November 4, 2024 Hexamethylenetetramine From the People's Republic of China, Germany, India, and Saudi Arabia: Initiation of Less-Than-Fair-Value Investigations https://www.govinfo.gov/cont ent/pkg/FR-2024-11- 04/pdf/2024-25525.pdf 89 FR 87560, November 4, 2024 Hexamethylenetetramine From the People's Republic of China and India: Initiation of Countervailing Duty Investigations https://www.govinfo.gov/cont ent/pkg/FR-2024-11- 04/pdf/2024-25524.pdf 89 FR 91786, November 20, 2024 Hexamine (Hexamethylenetetramine) From China, Germany, India, and Saudi Arabia; Determinations https://www.govinfo.gov/cont ent/pkg/FR-2024-11- 20/pdf/2024-26998.pdf 90 FR 11508, March 7, 2025 Hexamethylenetetramine From the People's Republic of China: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination https://www.govinfo.gov/cont ent/pkg/FR-2025-03- 07/pdf/2025-03639.pdf 90 FR 11512, March 7, 2025 Hexamethylenetetramine From India: Preliminary Affirmative Countervailing Duty Determination and Alignment of Final Determination With Final Antidumping Duty Determination https://www.govinfo.gov/cont ent/pkg/FR-2025-03- 07/pdf/2025-03644.pdf 90 FR 19182, May 6, 2025 Hexamethylenetetramine From the People's Republic of China: Preliminary Affirmative Determination of Sales at Less Than Fair Value https://www.govinfo.gov/cont ent/pkg/FR-2025-05- 06/pdf/2025-07802.pdf 90 FR 19186, May 6, 2025 Hexamethylenetetramine From Germany: Preliminary Affirmative Determination of Sales at Less-Than-Fair-Value, Postponement of Final Determination, and Extension of Provisional Measures https://www.govinfo.gov/cont ent/pkg/FR-2025-05- 06/pdf/2025-07803.pdf 90 FR 19178, May 6, 2025 Hexamethylenetetramine From India: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination and Extension of Provisional Measures https://www.govinfo.gov/cont ent/pkg/FR-2025-05- 06/pdf/2025-07804.pdf 90 FR 19180, May 6, 2025 Hexamethylenetetramine From the Kingdom of Saudi Arabia: Preliminary Affirmative Determination of Sales at Less Than Fair Value, Postponement of Final Determination, and Extension of Provisional Measures https://www.govinfo.gov/cont ent/pkg/FR-2025-05- 06/pdf/2025-07805.pdf A.4 Citation Title Link 90 FR 21948, May 22, 2025 Hexamine From China, Germany, India, and Saudi Arabia; Scheduling of the Final Phase of Countervailing Duty and Antidumping Duty Investigations https://www.govinfo.gov/cont ent/pkg/FR-2025-05- 22/pdf/2025-09157.pdf 90 FR 33922, July 18, 2025 Hexamethylenetetramine From the People's Republic of China: Final Affirmative Determination of Sales at Less Than Fair Value https://www.govinfo.gov/cont ent/pkg/FR-2025-07- 18/pdf/2025-13563.pdf 90 FR 33923, July 18, 2025 Hexamethylenetetramine From the People's Republic of China: Final Affirmative Countervailing Duty Determination https://www.govinfo.gov/cont ent/pkg/FR-2025-07- 18/pdf/2025-13564.pdf B.1 APPENDIX B LIST OF HEARING WITNESSES B.3 CALENDAR OF PUBLIC HEARING Those listed below appeared in the United States International Trade Commission’s hearing: Subject: Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia Inv. Nos.: 701-TA-737-738 and 731-TA-1712-1715 (Final) Date and Time: July 18, 2025 - 9:30 a.m. Sessions were held in connection with these investigations in the Main Hearing Room (Room 101), 500 E Street, SW., Washington, DC. OPENING REMARKS: In Support of Imposition (Matthew L. Kanna, Greenberg Traurig, LLP) In Opposition to Imposition (Matthew W. Solomon, White & Case LLP) In Support of the Imposition of the Antidumping and Countervailing Duty Orders: Greenberg Traurig, LLP Washington, DC on behalf of Bakelite LLC (“Bakelite”) Jesse L. Neese, Director, Strategy and Regulatory Affairs, Bakelite Jaret Brochmann, Vice President, Sales and Technical Services, Bakelite Laura Boninsegni, Vice President, FP&A and Regional Finance Leader, Bakelite Brad Roderick, Director, Bakelite Ronald Bazinet, Plant Manager, Bakelite Stephanie Velez, Assistant Director, Greenberg Traurig, LLP B.4 In Support of the Imposition of the Antidumping and Countervailing Duty Orders (continued): Ana Leme, Paralegal, Greenberg Traurig, LLP Jennifer Lutz, Partner, Ion Economics, LLC Cara Groden, Senior Economic Consultant, Ion Economics, LLC Matthew L. Kanna ) ) – OF COUNSEL Claudia D. Hartleben ) In Opposition to the Imposition of the Antidumping and Countervailing Duty Orders: White & Case LLP Washington, DC on behalf of General Authority for Foreign Trade (“GAFT”) Jay C. Campbell ) ) – OF COUNSEL Matthew W. Solomon ) REBUTTAL/CLOSING REMARKS: In Support of Imposition (Claudia D. Hartleben, Greenberg Traurig, LLP) In Opposition to Imposition (Jay C. Campbell, White & Case LLP) C.1 APPENDIX C SUMMARY DATA C.2 Table C.1: Hexamine: Summary data concerning the total U.S. market ..................................... C.3 Table C.2: Hexamine: Summary data concerning the merchant U.S. market ............................. C.5 Table C.1 Hexamine: Summary data concerning the U.S. total market, by item and period Interim Item 2022 2023 2024 2024 2025 2022–24 2022–23 2023–24 2024–25 U.S. total market consumption quantity: Amount...................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Producers' share (fn1).............................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Importers' share (fn1): China.................................................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** Germany.............................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** India..................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Saudi Arabia........................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Subject sources.............................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Russia.................................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All other sources.................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Nonsubject sources........................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All import sources...................... *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** U.S. total market consumption value: Amount...................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Producers' share (fn1).............................. *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Importers' share (fn1): China.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Germany.............................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** India..................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Saudi Arabia........................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Subject sources.............................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Russia.................................................. *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** All other sources.................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Nonsubject sources........................ *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** All import sources...................... *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** U.S. importers' U.S. shipments of imports from: China: Quantity................................................ *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Ending inventory quantity.................... *** *** *** *** *** *** *** *** *** Germany: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** India: Quantity................................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Value.................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** *** ▼*** ▲*** Saudi Arabia: Quantity................................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Value.................................................... *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** Subject sources: Quantity................................................ 1,518 1,683 4,353 825 880 ▲186.7 ▲10.9 ▲158.6 ▲6.8 Value.................................................... 1,550 1,831 4,255 784 866 ▲174.5 ▲18.1 ▲132.4 ▲10.4 Unit value............................................. $1.02 $1.09 $0.98 $0.95 $0.98 ▼(4.2) ▲6.6 ▼(10.1) ▲3.5 Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Russia: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All other sources: Quantity................................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Value.................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** *** ▼*** Nonsubject sources:................................. Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All import sources: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Table continued. C.3 Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted; Interim period is January through Reported data Period change comparisons Calendar year Interim Calendar year Total market Table C.1 Continued Hexamine: Summary data concerning the U.S. total market, by item and period Interim Item 2022 2023 2024 2024 2025 2022–24 2022–23 2023–24 2024–25 U.S. producers': Practical capacity quantity........................ *** *** *** *** *** *** *** *** *** Production quantity................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Capacity utilization (fn1)............................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** U.S. shipments: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Export shipments: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Ending inventory quantity......................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Inventories/total shipments (fn1).............. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Production workers................................... *** *** *** *** *** *** *** *** *** Hours worked (1,000s)............................. *** *** *** *** *** *** *** *** *** Wages paid ($1,000)................................ *** *** *** *** *** ▲*** *** ▲*** ▲*** Hourly wages (dollars per hour)............... *** *** *** *** *** ▲*** *** ▲*** ▲*** Productivity (pounds per hour)................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit labor costs......................................... *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Net sales: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Cost of goods sold (COGS)...................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Gross profit or (loss) (fn2)......................... *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** SG&A expenses........................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Operating income or (loss) (fn2)............... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Net income or (loss) (fn2)......................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit COGS................................................ *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit SG&A expenses................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit operating income or (loss) (fn2)........ *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit net income or (loss) (fn2).................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** COGS/sales (fn1)...................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Operating income or (loss)/sales (fn1)..... *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Net income or (loss)/sales (fn1)............... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Capital expenditures................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Research and development expenses.... *** *** *** *** *** ▲*** ▼*** ▲*** *** Total assets............................................... *** *** *** *** *** ▼*** ▼*** ▼*** *** fn1.--Reported data are in percent and period changes are in percentage points. Source: Compiled from data submitted in response to Commission questionnaires. 508-compliant tables for these data are contained in parts 3, 4, 6, and 7 of this report. fn2.--Percent changes only calculated when both comparison values represent profits; The directional change in profitability provided when one or both comparison values represent a loss. Note.--Shares and ratios shown as “0.0” percent represent non-zero values less than “0.05” percent (if positive) and greater than “(0.05)” percent (if negative). Zeroes, null values, and undefined calculations are suppressed and shown as “—“. Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease. C.4 Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted; Interim period is January through Reported data Period change comparisons Calendar year Interim Calendar year Table C.2 Hexamine: Summary data concerning the U.S. merchant market, by item and period Interim Item 2022 2023 2024 2024 2025 2022–24 2022–23 2023–24 2024–25 U.S. merchant market consumption quantity: Amount...................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Producers' share (fn1).............................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Importers' share (fn1): China.................................................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** Germany.............................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** India..................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Saudi Arabia........................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Subject sources.............................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Russia.................................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All other sources.................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Nonsubject sources........................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All import sources...................... *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** U.S. merchant market consumption value: Amount...................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Producers' share (fn1).............................. *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Importers' share (fn1): China.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Germany.............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** India..................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Saudi Arabia........................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Subject sources.............................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Russia.................................................. *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** All other sources.................................. *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Nonsubject sources........................ *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** All import sources...................... *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** U.S. importers' U.S. shipments of imports from: China: Quantity................................................ *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Ending inventory quantity.................... *** *** *** *** *** *** *** *** *** Germany: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** India: Quantity................................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Value.................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** *** ▼*** ▲*** Saudi Arabia: Quantity................................................ *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Value.................................................... *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▼*** Subject sources: Quantity................................................ 1,518 1,683 4,353 825 880 ▲186.7 ▲10.9 ▲158.6 ▲6.8 Value.................................................... 1,550 1,831 4,255 784 866 ▲174.5 ▲18.1 ▲132.4 ▲10.4 Unit value............................................. $1.02 $1.09 $0.98 $0.95 $0.98 ▼(4.2) ▲6.6 ▼(10.1) ▲3.5 Ending inventory quantity.................... *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Russia: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All other sources: Quantity................................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Value.................................................... *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** *** ▼*** Nonsubject sources:................................. Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▲*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** All import sources: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▲*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▲*** ▲*** ▼*** ▲*** Ending inventory quantity.................... *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Table continued. Reported data Period change comparisons Calendar year Interim Calendar year C.5 Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted; Interim period is January through Merchant market Table C.2 Continued Hexamine: Summary data concerning the U.S. merchant market, by item and period Interim Item 2022 2023 2024 2024 2025 2022–24 2022–23 2023–24 2024–25 U.S. producers': Commercial U.S. shipments: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Commercial sales: Quantity................................................ *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Value.................................................... *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Unit value............................................. *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Cost of goods sold (COGS)...................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Gross profit or (loss) (fn2)......................... *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** SG&A expenses........................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Operating income or (loss) (fn2)............... *** *** *** *** *** ▼*** ▼*** ▲*** ▼*** Net income or (loss) (fn2)......................... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** Unit COGS................................................ *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit SG&A expenses................................ *** *** *** *** *** ▲*** ▼*** ▲*** ▲*** Unit operating income or (loss) (fn2)........ *** *** *** *** *** ▼*** ▼*** ▲*** ▲*** Unit net income or (loss) (fn2).................. *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** COGS/sales (fn1)...................................... *** *** *** *** *** ▼*** ▼*** ▼*** ▲*** Operating income or (loss)/sales (fn1)..... *** *** *** *** *** ▲*** ▲*** ▲*** ▼*** Net income or (loss)/sales (fn1)............... *** *** *** *** *** ▼*** ▼*** ▼*** ▼*** fn1.--Reported data are in percent and period changes are in percentage points. Source: Compiled from data submitted in response to Commission questionnaires. 508-compliant tables for these data are contained in parts 3, 4, 6, and 7 of this report. fn2.--Percent changes only calculated when both comparison values represent profits; The directional change in profitability provided when one or both comparison values represent a loss. Note.--Shares and ratios shown as “0.0” percent represent non-zero values less than “0.05” percent (if positive) and greater than “(0.05)” percent (if negative). Zeroes, null values, and undefined calculations are suppressed and shown as “—“. Period changes preceded by a “▲” represent an increase, while period changes preceded by a “▼” represent a decrease. C.6 Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted; Interim period is January through Reported data Period change comparisons Calendar year Interim Calendar year D.1 APPENDIX D NONSUBJECT PRICING D.3 Two importers reported price data for Russia for products 1 and 2. No price data were reported for product 3. Price data reported by these firms accounted for *** of U.S. shipments from Russia. These price items and accompanying data are comparable to those presented in tables 5.4 to 5.5. Price and quantity data for Russia are shown in tables D.1 to D.2 and in figure D.1 to D.2 (with domestic and subject sources). In comparing nonsubject country pricing data with U.S. producer pricing data, prices for product imported from Russia were lower than prices for U.S.-produced product in 13 instances and higher in 5 instances. In comparing nonsubject country pricing data with subject country pricing data, prices for product imported from Russia were lower than prices for product imported from subject countries in 14 instances and higher in 19 instances. A summary of price differentials is presented in table D.3. D.4 Table D.1 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported nonsubject product 1 and margins of underselling/(overselling), by source and quarter Period U.S. price U.S. quantity Russia price Russia quantity Russia margin Subject price Subject quantity Subject margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 1: “Unstabilized” Hexamine, with a hexamine content above 99% by weight. D.5 Figure D.1 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 1, by source and quarter Price of product 1 * * * * * * * Volume of product 1 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. D.6 Table D.2 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported nonsubject product 2 and margins of underselling/(overselling), by source and quarter Period U.S. price U.S. quantity Russia price Russia quantity Russia margin Subject price Subject quantity Subject margin 2022 Q1 *** *** *** *** *** *** *** *** 2022 Q2 *** *** *** *** *** *** *** *** 2022 Q3 *** *** *** *** *** *** *** *** 2022 Q4 *** *** *** *** *** *** *** *** 2023 Q1 *** *** *** *** *** *** *** *** 2023 Q2 *** *** *** *** *** *** *** *** 2023 Q3 *** *** *** *** *** *** *** *** 2023 Q4 *** *** *** *** *** *** *** *** 2024 Q1 *** *** *** *** *** *** *** *** 2024 Q2 *** *** *** *** *** *** *** *** 2024 Q3 *** *** *** *** *** *** *** *** 2024 Q4 *** *** *** *** *** *** *** *** 2025 Q1 *** *** *** *** *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. Note: Product 2: “Stabilized” Hexamine, with a hexamine content above 95% but less than or equal to 99% by weight. D.7 Figure D.2 Hexamine: Weighted-average f.o.b. prices and quantities of domestic and imported product 2, by source and quarter Price of product 2 * * * * * * * Volume of product 2 * * * * * * * Source: Compiled from data submitted in response to Commission questionnaires. D.8 Table D.3 Hexamine: Summary of higher/(lower) unit values for nonsubject price data, by source, January 2022 through March 2025 Comparison source Benchmark source Number of quarters lower Quantity lower Number of quarters higher Quantity higher Russia United States *** *** *** *** Russia China *** *** *** *** Russia Germany *** *** *** *** Russia India *** *** *** *** Russia Saudi Arabia *** *** *** *** Source: Compiled from data submitted in response to Commission questionnaires. ──────────────────────────────────────────────────────────── === A–428–854 - Germany AD === Federal Register :: Request Access { "imports": { "application": "/assets/application-cc464116.js", "@hotwired/turbo-rails": "/assets/turbo.min-86bf8853.js", "@hotwired/stimulus": "/assets/stimulus.min-7ea3d58b.js", "@hotwired/stimulus-loading": "/assets/stimulus-loading-25917588.js", "controllers/application": "/assets/controllers/application-e5a449db.js", "controllers/site_feedback_controller": "/assets/controllers/site_feedback_controller-a99fc93f.js", "controllers/unblock_controller": "/assets/controllers/unblock_controller-9520f896.js" } } import "application" Request Access Due to aggressive automated scraping of FederalRegister.gov and eCFR.gov, programmatic access to these sites is limited to access to our extensive developer APIs. 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Upload Attachment * I am requesting technical help. site-feedback#openModal" aria-label="Open site help form"> Site Help ──────────────────────────────────────────────────────────── === A–517– 807 - Saudi Arabia AD === Federal Register :: Request Access { "imports": { "application": "/assets/application-cc464116.js", "@hotwired/turbo-rails": "/assets/turbo.min-86bf8853.js", "@hotwired/stimulus": "/assets/stimulus.min-7ea3d58b.js", "@hotwired/stimulus-loading": "/assets/stimulus-loading-25917588.js", "controllers/application": "/assets/controllers/application-e5a449db.js", "controllers/site_feedback_controller": "/assets/controllers/site_feedback_controller-a99fc93f.js", "controllers/unblock_controller": "/assets/controllers/unblock_controller-9520f896.js" } } import "application" Request Access Due to aggressive automated scraping of FederalRegister.gov and eCFR.gov, programmatic access to these sites is limited to access to our extensive developer APIs. 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Upload Attachment * I am requesting technical help. site-feedback#openModal" aria-label="Open site help form"> Site Help ──────────────────────────────────────────────────────────── === USITC Determination (1) === 43234 Federal Register / Vol. 90, No. 171 / Monday, September 8, 2025 / Notices 1 The record is defined in § 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR 207.2(f)). 2 90 FR 33922 and 33923 (July 18, 2025). 3 Commissioner David S. Johanson determines that that an industry in the United States is threatened with material injury by reason of imports of hexamine from China that have been found by Commerce to be sold in the United States at LTFV and subsidized by the government of China. INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–737 and 731– TA–1712 (Final)] Hexamine (Hexamethylenetetramine) From China Determinations On the basis of the record 1 developed in the subject investigations, the United States International Trade Commission (‘‘Commission’’) determines, pursuant to the Tariff Act of 1930 (‘‘the Act’’), that an industry in the United States is materially injured by reason of imports of hexamine from China, provided for in subheading 2933.69.50 of the Harmonized Tariff Schedule of the United States, that have been found by the U.S. Department of Commerce (‘‘Commerce’’) to be sold in the United States at less than fair value (‘‘LTFV’’) and subsidized by the government of China. 2 3 Background The Commission instituted these investigations effective September 30, 2024, following receipt of petitions filed with the Commission and Commerce by Bakelite Synthetics (Atlanta, Georgia). The Commission scheduled the final phase of the investigations following notification of preliminary determinations by Commerce that imports of hexamine from China were subsidized within the meaning of section 703(b) of the Act (19 U.S.C. 1671b(b)) and sold at LTFV within the meaning of 733(b) of the Act (19 U.S.C. 1673b(b)). Notice of the scheduling of the final phase of the Commission’s investigations and of a public hearing to be held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on May 22, 2025 (90 FR 21948 and as revised in 90 FR 31241, July 14, 2025). The Commission conducted its hearing on July 18, 2025. All persons who requested the opportunity were permitted to participate. The Commission made these determinations pursuant to §§ 705(b) and 735(b) of the Act (19 U.S.C. 1671d(b) and 19 U.S.C. 1673d(b)). It completed and filed its determinations in these investigations on September 3, 2025. The views of the Commission are contained in USITC Publication 5660 (September 2025), entitled Hexamine (Hexamethylenetetramine) from China: Investigation Nos. 701–TA–737 and 731–TA–1712 (Final). By order of the Commission. Issued: September 3, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–17114 Filed 9–5–25; 8:45 am] BILLING CODE 7020–02–P DEPARTMENT OF JUSTICE Drug Enforcement Administration [Docket No. DEA–1561] Importer of Controlled Substances Application: VA Cooperative Studies Program AGENCY : Drug Enforcement Administration, Justice. ACTION : Notice of application. SUMMARY : VA Cooperative Studies Program has applied to be registered as an importer of basic class(es) of controlled substance(s). Refer to Supplementary Information listed below for further drug information. DATES : Registered bulk manufacturers of the affected basic class(es), and applicants, therefore, may submit electronic comments on or objections to the issuance of the proposed registration on or before October 8, 2025. Such persons may also file a written request for a hearing on the application on or before October 8, 2025. ADDRESSES : The Drug Enforcement Administration requires that all comments be submitted electronically through the Federal eRulemaking Portal, which provides the ability to type short comments directly into the comment field on the web page or attach a file for lengthier comments. Please go to https://www.regulations.gov and follow the online instructions at that site for submitting comments. Upon submission of your comment, you will receive a Comment Tracking Number. Please be aware that submitted comments are not instantaneously available for public view on https://www.regulations.gov. If you have received a Comment Tracking Number, your comment has been successfully submitted and there is no need to resubmit the same comment. All requests for a hearing must be sent to: (1) Drug Enforcement Administration, Attn: Hearing Clerk/OALJ, 8701 Morrissette Drive, Springfield, Virginia 22152; and (2) Drug Enforcement Administration, Attn: DEA Federal Register Representative/DPW, 8701 Morrissette Drive, Springfield, Virginia 22152. All requests for a hearing should also be sent to: Drug Enforcement Administration, Attn: Administrator, 8701 Morrissette Drive, Springfield, Virginia 22152. SUPPLEMENTARY INFORMATION : In accordance with 21 CFR 1301.34(a), this is notice that on May 9, 2025, VA Cooperative Studies Program, 2401 Centre Avenue South East, Albuquerque, New Mexico 87106, applied to be registered as an importer of the following basic class(es) of controlled substance(s): Controlled substance Drug code Schedule Marihuana Extract ......... 7350 I Tetrahydrocannabinols .. 7370 I The company plans to import finished dosage unit products containing the above listed controlled substances for research and clinical trial studies only. No other activities for these drug codes are authorized for this registration. Approval of permit applications will occur only when the registrant’s business activity is consistent with what is authorized under 21 U.S.C. 952(a)(2). Authorization will not extend to the import of Food and Drug Administration-approved or non- approved finished dosage forms for commercial sale. Justin Wood, Acting Deputy Assistant Administrator. [FR Doc. 2025–17210 Filed 9–5–25; 8:45 am] BILLING CODE P NATIONAL FOUNDATION ON THE ARTS AND THE HUMANITIES National Endowment for the Arts Subject 30-Day Notice for the ‘‘2025 Final Descriptive Report Update’’ Proposed Collection; Comment Request AGENCY : National Endowment for the Arts. ACTION : Notice. SUMMARY : The National Endowment for the Arts (NEA) has submitted the following public information collection request (ICR) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995: VerDate Sep<11>2014 16:41 Sep 05, 2025 Jkt 265001 PO 00000 Frm 00069 Fmt 4703 Sfmt 4703 E:\FR\FM\08SEN1.SGM 08SEN1 khammond on DSK9W7S144PROD with NOTICES ──────────────────────────────────────────────────────────── === C–570–181 - China CVD === Federal Register :: Request Access { "imports": { "application": "/assets/application-cc464116.js", "@hotwired/turbo-rails": "/assets/turbo.min-86bf8853.js", "@hotwired/stimulus": "/assets/stimulus.min-7ea3d58b.js", "@hotwired/stimulus-loading": "/assets/stimulus-loading-25917588.js", "controllers/application": "/assets/controllers/application-e5a449db.js", "controllers/site_feedback_controller": "/assets/controllers/site_feedback_controller-a99fc93f.js", "controllers/unblock_controller": "/assets/controllers/unblock_controller-9520f896.js" } } import "application" Request Access Due to aggressive automated scraping of FederalRegister.gov and eCFR.gov, programmatic access to these sites is limited to access to our extensive developer APIs. Please visit FederalRegister.gov API documentation or eCFR.gov API documentation to learn more about how to access the API. Your request has been flagged as potentially automated. If you are human user receiving this message, please complete the CAPTCHA (bot test) below and click "Request Access". You may occassionally be asked to complete the CAPTCHA again, this is normal and part of our security measures. unblock#handleSubmit"> Request Access An official website of the United States government. If you experiencing issues with the CAPTCHA or want to request a wider IP range, you can use the "Site Help" button found in the lower, right of this page to make a request. × IP Access Help This contact form is only for IP Access help. Please do not provide confidential information or personal data. * Your Name * Email * How can we help you? Upload Attachment * I am requesting technical help. site-feedback#openModal" aria-label="Open site help form"> Site Help ──────────────────────────────────────────────────────────── === USITC Scheduling (1) === 21948 Federal Register / Vol. 90, No. 98 / Thursday, May 22, 2025 / Notices 1 The record is defined in § 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR 207.2(f)). 2 90 FR 14605, 14611, 14618, 14621, and 14623 (April 3, 2025). 3 90 FR 14613, 14616, 14628, and 14636 (April 3, 2025). INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–716–719 and 731–TA–1683–1687 (Final)] Epoxy Resins From China, India, South Korea, Taiwan, and Thailand Determinations On the basis of the record 1 developed in the subject investigations, the United States International Trade Commission (‘‘Commission’’) determines, pursuant to the Tariff Act of 1930 (‘‘the Act’’), that an industry in the United States is materially injured by reason of imports of epoxy resins from South Korea, Taiwan, and Thailand, provided for in subheading 3907.30.00 of the Harmonized Tariff Schedule of the United States, that have been found by the U.S. Department of Commerce (‘‘Commerce’’) to be sold in the United States at less than fair value (‘‘LTFV’’) and to be subsidized by the governments of South Korea and Taiwan. 2 The Commission further determines that imports of epoxy resins from China and India found by Commerce to be sold in the United States at LTFV and to be subsidized by the governments of China and India 3 are negligible and terminates the antidumping and countervailing duty investigations concerning China and India. Background The Commission instituted these investigations effective April 3, 2024, following receipt of petitions filed with the Commission and Commerce by the U.S. Epoxy Resin Producers Ad Hoc Coalition which is comprised of Olin Corporation, Clayton, Missouri and Westlake Corporation, Houston, Texas. The final phase of the investigations was scheduled by the Commission following notification of preliminary determinations by Commerce that imports of epoxy resins from China, India, and Taiwan were subsidized within the meaning of section 703(b) of the Act (19 U.S.C. 1671b(b)) and that such products from China, India, South Korea, Taiwan, and Thailand were sold at LTFV within the meaning of 733(b) of the Act (19 U.S.C. 1673b(b)). Notice of the scheduling of the final phase of the Commission’s investigations and of a public hearing to be held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on November 22, 2024 (89 FR 92719), as revised on December 11, 2024 (89 FR 99904). The Commission conducted its hearing on April 3, 2025. All persons who requested the opportunity were permitted to participate. The Commission made these determinations pursuant to §§ 705(b) and 735(b) of the Act (19 U.S.C. 1671d(b) and 19 U.S.C. 1673d(b)). It completed and filed its determinations in these investigations on May 19, 2025. The views of the Commission are contained in USITC Publication 5619 (May 2025), entitled Epoxy Resins from China, India, South Korea, Taiwan, and Thailand: Investigation Nos. 701–TA– 716–719 and 731–TA–1683–1687 (Final). By order of the Commission. Issued: May 19, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–09232 Filed 5–21–25; 8:45 am] BILLING CODE 7020–02–P INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–737–738 and 731–TA–1712–1715 (Final)] Hexamine From China, Germany, India, and Saudi Arabia; Scheduling of the Final Phase of Countervailing Duty and Antidumping Duty Investigations AGENCY : United States International Trade Commission. ACTION : Notice. SUMMARY : The Commission hereby gives notice of the scheduling of the final phase of antidumping and countervailing duty investigation Nos. 701–TA–737–738 and 731–TA–1712– 1715 (Final) pursuant to the Tariff Act of 1930 (‘‘the Act’’) to determine whether an industry in the United States is materially injured or threatened with material injury, or the establishment of an industry in the United States is materially retarded, by reason of imports of hexamine from China, Germany, India, and Saudi Arabia, provided for in subheading 2933.69.50 of the Harmonized Tariff Schedule of the United States, preliminarily determined by the Department of Commerce (‘‘Commerce’’) to be sold at less-than-fair-value and to be subsidized by the governments of China and India. DATES : May 6, 2025. FOR FURTHER INFORMATION CONTACT : Charles Cummings ((202) 708–1666), Office of Investigations, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. Hearing-impaired persons can obtain information on this matter by contacting the Commission’s TDD terminal on 202– 205–1810. Persons with mobility impairments who will need special assistance in gaining access to the Commission should contact the Office of the Secretary at 202–205–2000. General information concerning the Commission may also be obtained by accessing its internet server (https:// www.usitc.gov). The public record for these investigations may be viewed on the Commission’s electronic docket (EDIS) at https://edis.usitc.gov. SUPPLEMENTARY INFORMATION : Scope.—For purposes of these investigations, Commerce has defined the subject merchandise as ‘‘hexamine in granular form, with a particle size of 5 millimeters or less, whether stabilized or unstabilized, whether or not blended, mixed, pulverized, or grounded with other products, containing 50 percent or more hexamine by weight. Hexamine is the common name for hexamethylene tetramine (Chemical Abstract Service # 100–97–0), and is also referred to as 1,3,5,7- tetraazaadamantanemethenamine; HMT; HMTA; 1,3,5,7-tetraazatricyclo {3.3.1.13,7} decane; 1,3,5,7-tetraaza adamantane; hexamethylenamine. Hexamine has the chemical formula C6H12N4. Granular hexamine that has been blended with other product(s) is included in this scope when the resulting mix contains 50 percent or more of hexamine by weight, regardless of whether it is blended with inert additives, co-reactants, or any additives that undergo self-condensation. Subject merchandise includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, adding or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the subject country.’’ Background.—The final phase of these investigations is being scheduled pursuant to sections 705(b) and 731(b) of the Tariff Act of 1930 (19 U.S.C. 1671d(b) and 1673d(b)), as a result of affirmative preliminary determinations by Commerce that certain benefits VerDate Sep<11>2014 16:33 May 21, 2025 Jkt 265001 PO 00000 Frm 00063 Fmt 4703 Sfmt 4703 E:\FR\FM\22MYN1.SGM 22MYN1 khammond on DSK9W7S144PROD with NOTICES 21949Federal Register / Vol. 90, No. 98 / Thursday, May 22, 2025 / Notices which constitute subsidies within the meaning of § 703 of the Act (19 U.S.C. 1671b) are being provided to manufacturers, producers, or exporters in China and India of hexamine, and that such products from China, Germany, India, and Saudi Arabia are being sold in the United States at less than fair value within the meaning of § 733 of the Act (19 U.S.C. 1673b). The investigations were requested in petitions filed on September 30, 2024, by Bakelite Synthetics (Atlanta, Georgia). For further information concerning the conduct of this phase of the investigations, hearing procedures, and rules of general application, consult the Commission’s Rules of Practice and Procedure, part 201, subparts A and B (19 CFR part 201), and part 207, subparts A and C (19 CFR part 207). Participation in the investigations and public service list.—Persons, including industrial users of the subject merchandise and, if the merchandise is sold at the retail level, representative consumer organizations, wishing to participate in the final phase of these investigations as parties must file an entry of appearance with the Secretary to the Commission, as provided in § 201.11 of the Commission’s rules, no later than 21 days prior to the hearing date specified in this notice. A party that filed a notice of appearance during the preliminary phase of the investigations need not file an additional notice of appearance during this final phase. The Secretary will maintain a public service list containing the names and addresses of all persons, or their representatives, who are parties to the investigations. Please note the Secretary’s Office will accept only electronic filings during this time. Filings must be made through the Commission’s Electronic Document Information System (EDIS, https:// edis.usitc.gov). No in-person paper- based filings or paper copies of any electronic filings will be accepted until further notice. Limited disclosure of business proprietary information (BPI) under an administrative protective order (APO) and BPI service list.—Pursuant to § 207.7(a) of the Commission’s rules, the Secretary will make BPI gathered in the final phase of these investigations available to authorized applicants under the APO issued in the investigations, provided that the application is made no later than 21 days prior to the hearing date specified in this notice. Authorized applicants must represent interested parties, as defined by 19 U.S.C. 1677(9), who are parties to the investigations. A party granted access to BPI in the preliminary phase of the investigations need not reapply for such access. A separate service list will be maintained by the Secretary for those parties authorized to receive BPI under the APO. Staff report.—The prehearing staff report in the final phase of these investigations will be placed in the nonpublic record on July 3, 2025, and a public version will be issued thereafter, pursuant to § 207.22 of the Commission’s rules. Hearing.—The Commission will hold a hearing in connection with the final phase of these investigations beginning at 9:30 a.m. on Friday, July 18, 2025. Requests to appear at the hearing should be filed in writing with the Secretary to the Commission on or before Monday, July 14, 2025. Any requests to appear as a witness via videoconference must be included with your request to appear. Requests to appear via videoconference must include a statement explaining why the witness cannot appear in person; the Chairman, or other person designated to conduct the investigations, may in their discretion for good cause shown, grant such a request. Requests to appear as remote witness due to illness or a positive COVID–19 test result may be submitted by 3 p.m. the business day prior to the hearing. Further information about participation in the hearing will be posted on the Commission’s website at https://www.usitc.gov/calendarpad/ calendar.html. A nonparty who has testimony that may aid the Commission’s deliberations may request permission to present a short statement at the hearing. All parties and nonparties desiring to appear at the hearing and make oral presentations should attend a prehearing conference, if deemed necessary, to be held at 9:30 a.m. on Tuesday, July 15, 2025. Parties shall file and serve written testimony and presentation slides in connection with their presentation at the hearing by no later than noon on July 17, 2025. Oral testimony and written materials to be submitted at the public hearing are governed by sections 201.6(b)(2), 201.13(f), and 207.24 of the Commission’s rules. Parties must submit any request to present a portion of their hearing testimony in camera no later than 7 business days prior to the date of the hearing. Written submissions.—Each party who is an interested party shall submit a prehearing brief to the Commission. Prehearing briefs must conform with the provisions of § 207.23 of the Commission’s rules; the deadline for filing is July 11, 2025. Parties shall also file written testimony in connection with their presentation at the hearing, and posthearing briefs, which must conform with the provisions of § 207.25 of the Commission’s rules. The deadline for filing posthearing briefs is July 25, 2025. In addition, any person who has not entered an appearance as a party to the investigations may submit a written statement of information pertinent to the subject of the investigations, including statements of support or opposition to the petition, on or before July 25, 2025. On August 13, 2025, the Commission will make available to parties all information on which they have not had an opportunity to comment. Parties may submit final comments on this information on or before August 15, 2025, but such final comments must not contain new factual information and must otherwise comply with § 207.30 of the Commission’s rules. All written submissions must conform with the provisions of § 201.8 of the Commission’s rules; any submissions that contain BPI must also conform with the requirements of §§ 201.6, 207.3, and 207.7 of the Commission’s rules. The Commission’s Handbook on Filing Procedures, available on the Commission’s website at https:// www.usitc.gov/documents/handbook_ on_filing_procedures.pdf, elaborates upon the Commission’s procedures with respect to filings. Additional written submissions to the Commission, including requests pursuant to § 201.12 of the Commission’s rules, shall not be accepted unless good cause is shown for accepting such submissions, or unless the submission is pursuant to a specific request by a Commissioner or Commission staff. In accordance with §§ 201.16(c) and 207.3 of the Commission’s rules, each document filed by a party to the investigations must be served on all other parties to the investigations (as identified by either the public or BPI service list), and a certificate of service must be timely filed. The Secretary will not accept a document for filing without a certificate of service. Authority: These investigations are being conducted under authority of title VII of the Tariff Act of 1930; this notice is published pursuant to § 207.21 of the Commission’s rules. By order of the Commission. Issued: May 16, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–09157 Filed 5–21–25; 8:45 am] BILLING CODE 7020–02–P VerDate Sep<11>2014 16:33 May 21, 2025 Jkt 265001 PO 00000 Frm 00064 Fmt 4703 Sfmt 4703 E:\FR\FM\22MYN1.SGM 22MYN1 khammond on DSK9W7S144PROD with NOTICES ──────────────────────────────────────────────────────────── === USITC Scheduling (2) === 47327Federal Register / Vol. 90, No. 188 / Wednesday, October 1, 2025 / Notices confirm their origin but suggested they may have come from New Mexico, a state the family frequently visited. There is no known provenance or provenience information available. No hazardous substances are known to have been applied to the items. Determinations CSUMB has determined that: • The two sacred objects/objects of cultural patrimony described in this notice are, according to the Native American traditional knowledge of an Indian Tribe or Native Hawaiian organization, specific ceremonial objects needed by a traditional Native American religious leader for present-day adherents to practice traditional Native American religion, and have ongoing historical, traditional, or cultural importance central to the Native American group, including any constituent sub-group (such as a band, clan, lineage, ceremonial society, or other subdivision). • There is a connection between the cultural items described in this notice with the Pueblo of San Felipe, New Mexico. Requests for Repatriation Additional, written requests for repatriation of the cultural items in this notice must be sent to the authorized representative identified in this notice under ADDRESSES. Requests for repatriation may be submitted by any lineal descendant, Indian Tribe, or Native Hawaiian organization not identified in this notice who shows, by a preponderance of the evidence, that the requestor is a lineal descendant or a culturally affiliated Indian Tribe or Native Hawaiian organization. Repatriation of the cultural items in this notice to a requestor may occur on or after October 31, 2025. If competing requests for repatriation are received, CSUMB must determine the most appropriate requestor prior to repatriation. Requests for joint repatriation of the cultural items are considered a single request and not competing requests. CSUMB is responsible for sending a copy of this notice to the Indian Tribes and Native Hawaiian organizations identified in this notice and to any other consulting parties. Authority: Native American Graves Protection and Repatriation Act, 25 U.S.C. 3004 and the implementing regulations, 43 CFR 10.9. Dated: September 18, 2025. Melanie O’Brien, Manager, National NAGPRA Program. [FR Doc. 2025–19122 Filed 9–30–25; 8:45 am] BILLING CODE 4312–52–P INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–738 and 731– TA–1713–1715 (Final)] Hexamine From Germany, India, and Saudi Arabia; Supplemental Schedule for the Final Phase of Countervailing Duty and Antidumping Duty Investigations AGENCY : United States International Trade Commission. ACTION : Notice. DATES : September 23, 2025. FOR FURTHER INFORMATION CONTACT : Charles Cummings (202–708–1666), Office of Investigations, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. Hearing-impaired persons can obtain information on this matter by contacting the Commission’s TDD terminal at 202– 205–1810. Persons with mobility impairments who will need special assistance in gaining access to the Commission should contact the Office of the Secretary at 202–205–2000. General information concerning the Commission may also be obtained by accessing its internet server (https:// www.usitc.gov). The public record for these investigations may be viewed on the Commission’s electronic docket (EDIS) at https://edis.usitc.gov. SUPPLEMENTARY INFORMATION : Effective May 6, 2025, the Commission established a general schedule for the conduct of the final phase of its countervailing duty and antidumping duty investigations on hexamethylenetetramine (‘‘hexamine’’) from China, Germany, India, and Saudi Arabia (90 FR 21948, May 22, 2025, and as revised in 90 FR 31241, July 14, 2025), following preliminary determinations by the U.S. Department of Commerce (‘‘Commerce’’) that imports of hexamine from China were being subsidized by the government of China (90 FR 19182, May 6, 2025) and that imports of hexamine from China were being sold in the United States at less than fair value (90 FR 11508, March 7, 2025). Notice of the scheduling of the final phase of the Commission’s investigations and of a public hearing held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on May 22, 2025 (90 FR 21948). The Commission conducted its hearing on July 18, 2025. All persons who requested the opportunity were permitted to participate. Commerce has issued final affirmative countervailing duty and antidumping duty determinations with respect to hexamine from China (90 FR 33923 and 33922, July 18, 2025). The Commission subsequently issued its final determinations that an industry in the United States was materially injured by reason of imports of hexamine from China provided for in subheading 2933.69.50 of the Harmonized Tariff Schedule of the United States (‘‘HTSUS’’) that have been found by Commerce to be subsidized by the government of China and sold in the United States at less than fair value (90 FR 43234, September 8, 2025). Commerce has issued final affirmative countervailing duty determinations with respect to imports of hexamine from India (90 FR 45720, September 23, 2025) and antidumping duty determinations with respect to imports of hexamine from Germany, India, and Saudi Arabia (90 FR 45728, 45725, and 45723, September 23, 2025). Accordingly, the Commission is currently issuing a supplemental schedule for its countervailing duty investigation on imports of hexamine from India and its antidumping duty investigations on imports of hexamine from Germany, India, and Saudi Arabia. This supplemental schedule is as follows: the deadline for filing supplemental party comments on Commerce’s final countervailing duty and antidumping duty determinations is 5:15 p.m. on October 3, 2025. Supplemental party comments may address only Commerce’s final countervailing duty determinations regarding imports of hexamine from India and Commerce’s final antidumping duty determinations regarding imports of hexamine from Germany, India, and Saudi Arabia. These supplemental final comments may not contain new factual information and may not exceed five (5) pages in length. The supplemental staff report in the final phase of the current investigations will be placed in the nonpublic record on October 17, 2025, and a public version will be issued thereafter. For further information concerning this proceeding see the Commission’s notice cited above and the Commission’s Rules of Practice and Procedure, part 201, subparts A and B VerDate Sep<11>2014 17:43 Sep 30, 2025 Jkt 265001 PO 00000 Frm 00037 Fmt 4703 Sfmt 4703 E:\FR\FM\01OCN1.SGM 01OCN1 lotter on DSK11XQN23PROD with NOTICES1 47328 Federal Register / Vol. 90, No. 188 / Wednesday, October 1, 2025 / Notices (19 CFR part 201), and part 207, subparts A and C (19 CFR part 207). Additional written submissions to the Commission, including requests pursuant to section 201.12 of the Commission’s rules, shall not be accepted unless good cause is shown for accepting such submissions, or unless the submission is pursuant to a specific request by a Commissioner or Commission staff. In accordance with sections 201.16(c) and 207.3 of the Commission’s rules, each document filed by a party to the investigations must be served on all other parties to the investigations (as identified by either the public or BPI service list), and a certificate of service must be timely filed. The Secretary will not accept a document for filing without a certificate of service. Please note the Secretary’s Office will accept only electronic filings during this time. Filings must be made through the Commission’s Electronic Document Information System (EDIS, https:// edis.usitc.gov.) No in-person paper- based filings or paper copies of any electronic filings will be accepted until further notice. Authority: This proceeding is being conducted under authority of title VII of the Tariff Act of 1930; this notice is published pursuant to section 207.21 of the Commission’s rules. By order of the Commission. Issued: September 29, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–19165 Filed 9–30–25; 8:45 am] BILLING CODE 7020–02–P INTERNATIONAL TRADE COMMISSION [Investigation No. 731–TA–1046 (Fourth Review)] Tetrahydrofurfuryl Alcohol From China; Institution of a Five-Year Review AGENCY : United States International Trade Commission. ACTION : Notice. SUMMARY : The Commission hereby gives notice that it has instituted a review pursuant to the Tariff Act of 1930, as amended, to determine whether revocation of the antidumping duty order on tetrahydrofurfuryl alcohol from China would be likely to lead to continuation or recurrence of material injury. Pursuant to the Act, interested parties are requested to respond to this notice by submitting the information specified below to the Commission. DATES : Instituted October 1, 2025. To be assured of consideration, the deadline for responses is October 31, 2025. Comments on the adequacy of responses may be filed with the Commission by December 11, 2025. FOR FURTHER INFORMATION CONTACT : Alec Resch (202–708–1448), Office of Investigations, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. Hearing- impaired persons can obtain information on this matter by contacting the Commission’s TDD terminal on 202– 205–1810. Persons with mobility impairments who will need special assistance in gaining access to the Commission should contact the Office of the Secretary at 202–205–2000. General information concerning the Commission may also be obtained by accessing its internet server (https:// www.usitc.gov). The public record for this proceeding may be viewed on the Commission’s electronic docket (EDIS) at https://edis.usitc.gov. SUPPLEMENTARY INFORMATION : Background.—On August 6, 2004, the Department of Commerce (‘‘Commerce’’) issued an antidumping duty order on imports of tetrahydrofurfuryl alcohol from China (69 FR 47911). Commerce issued a continuation of the antidumping duty order on imports of tetrahydrofurfuryl alcohol from China following Commerce’s and the Commission’s first five-year reviews, effective December 16, 2009 (74 FR 66616), second five-year reviews, effective April 16, 2015 (80 FR 20470), and third five-year reviews, effective November 9, 2020 (85 FR 71321). The Commission is now conducting a fourth review pursuant to section 751(c) of the Act, as amended (19 U.S.C. 1675(c)), to determine whether revocation of the order would be likely to lead to continuation or recurrence of material injury to the domestic industry within a reasonably foreseeable time. Provisions concerning the conduct of this proceeding may be found in the Commission’s Rules of Practice and Procedure at 19 CFR part 201, subparts A and B, and 19 CFR part 207, subparts A and F. The Commission will assess the adequacy of interested party responses to this notice of institution to determine whether to conduct a full or expedited review. The Commission’s determination in any expedited review will be based on the facts available, which may include information provided in response to this notice. Definitions.—The following definitions apply to this review: (1) Subject Merchandise is the class or kind of merchandise that is within the scope of the five-year review, as defined by Commerce. (2) The Subject Country in this review is China. (3) The Domestic Like Product is the domestically produced product or products which are like, or in the absence of like, most similar in characteristics and uses with, the Subject Merchandise. In its original determination and its expedited first, second, and third five-year review determinations, the Commission defined a single Domestic Like Product consisting of all domestically produced tetrahydrofurfuryl alcohol coextensive with Commerce’s scope. (4) The Domestic Industry is the U.S. producers as a whole of the Domestic Like Product, or those producers whose collective output of the Domestic Like Product constitutes a major proportion of the total domestic production of the product. In its original determination and its expedited first, second, and third five-year review determinations, the Commission defined the Domestic Industry as all U.S. producers of tetrahydrofurfuryl alcohol. (5) An Importer is any person or firm engaged, either directly or through a parent company or subsidiary, in importing the Subject Merchandise into the United States from a foreign manufacturer or through its selling agent. Participation in the proceeding and public service list.—Persons, including industrial users of the Subject Merchandise and, if the merchandise is sold at the retail level, representative consumer organizations, wishing to participate in the proceeding as parties must file an entry of appearance with the Secretary to the Commission, as provided in § 201.11(b)(4) of the Commission’s rules, no later than 21 days after publication of this notice in the Federal Register. The Secretary will maintain a public service list containing the names and addresses of all persons, or their representatives, who are parties to the proceeding. Former Commission employees who are seeking to appear in Commission five-year reviews are advised that they may appear in a review even if they participated personally and substantially in the corresponding underlying original investigation or an earlier review of the same underlying investigation. The Commission’s designated agency ethics official has advised that a five-year review is not the same particular matter as the underlying original investigation, and a five-year review is not the same particular matter as an earlier review of the same underlying investigation for purposes of VerDate Sep<11>2014 17:43 Sep 30, 2025 Jkt 265001 PO 00000 Frm 00038 Fmt 4703 Sfmt 4703 E:\FR\FM\01OCN1.SGM 01OCN1 lotter on DSK11XQN23PROD with NOTICES1 ──────────────────────────────────────────────────────────── === USITC Scheduling (Revised) === 52436 Federal Register / Vol. 90, No. 222 / Thursday, November 20, 2025 / Notices submissions will be available for public inspection on EDIS. This action is taken under the authority of section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and in Part 210 of the Commission’s Rules of Practice and Procedure (19 CFR part 210). By order of the Commission. Issued: November 17, 2025 Lisa Barton, Secretary to the Commission. [FR Doc. 2025–20371 Filed 11–19–25; 8:45 am] BILLING CODE 7020–02–P INTERNATIONAL TRADE COMMISSION [Investigation Nos. 701–TA–738 and 731– TA–1713–1715 (Final)] Hexamine from Germany, India, and Saudi Arabia; Revised Schedule for the Subject Proceeding AGENCY : United States International Trade Commission. ACTION : Notice. DATES : November 17, 2025. FOR FURTHER INFORMATION CONTACT : Charles Cummings (202–708–1666), Office of Investigations, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. Hearing-impaired persons can obtain information on this matter by contacting the Commission’s TDD terminal on 202– 205–1810. Persons with mobility impairments who will need special assistance in gaining access to the Commission should contact the Office of the Secretary at 202–205–2000. General information concerning the Commission may also be obtained by accessing its internet server (https:// www.usitc.gov). The public record for this proceeding may be viewed on the Commission’s electronic docket (EDIS) at https://edis.usitc.gov. SUPPLEMENTARY INFORMATION : Effective September 23, 2025, the Commission established a schedule for the conduct of the subject proceeding (90 FR 47327, October 1, 2025). Due to the lapse in appropriations and ensuing cessation of Commission operations, the Commission is revising its schedule as follows: the deadline for filing supplemental party comments on Commerce’s final countervailing duty and antidumping duty determinations is 5:15 p.m. on November 19, 2025. Supplemental party comments may address only Commerce’s final countervailing duty determinations regarding imports of hexamine from India (90 FR 45720, September 23, 2025) and Commerce’s final antidumping duty determinations regarding imports of hexamine from Germany, India, and Saudi Arabia (90 FR 45728, 45725, and 45723, September 23, 2025). These supplemental final comments may not contain new factual information and may not exceed five (5) pages in length. The supplemental staff report in the final phase of the current investigations will be placed in the nonpublic record on December 2, 2025, and a public version will be issued thereafter. For further information concerning this proceeding, see the Commission’s notice cited above and the Commission’s Rules of Practice and Procedure, part 201, subparts A and B (19 CFR part 201), and part 207, subparts A and C (19 CFR part 207). Authority: This proceeding is being conducted under authority of title VII of the Tariff Act of 1930; this notice is published pursuant to section 207.21 of the Commission’s rules. By order of the Commission. Issued: November 17, 2025. Lisa Barton, Secretary to the Commission. [FR Doc. 2025–20341 Filed 11–19–25; 8:45 am] BILLING CODE 7020–02–P INTERNATIONAL TRADE COMMISSION [Investigation No. 337–TA–1393] Certain Vehicle Telematics, Fleet Management, and Video-Based Safety Systems, Devices, and Components Thereof; Second Notice of Request for Submissions on the Public Interest AGENCY : U.S. International Trade Commission. ACTION : Notice. SUMMARY : Notice is hereby given that on September 8, 2025, the presiding administrative law judge (‘‘ALJ’’) issued a Final Initial Determination on Violation (‘‘FID’’) of Section 337. The FID includes a Recommended Determination on remedy and bonding should a violation be found in the above-captioned investigation. The Commission is soliciting submissions on public interest issues raised by the recommended relief should the Commission find a violation. This notice is soliciting comments from the public and interested government agencies only. FOR FURTHER INFORMATION CONTACT : Paul Lall, Office of the General Counsel, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436, telephone (202) 205–2043. Copies of non-confidential documents filed in connection with this investigation may be viewed on the Commission’s electronic docket (EDIS) at https:// edis.usitc.gov. For help accessing EDIS, please email EDIS3Help@usitc.gov. General information concerning the Commission may also be obtained by accessing its internet server at https:// www.usitc.gov. Hearing-impaired persons are advised that information on this matter can be obtained by contacting the Commission’s TDD terminal on (202) 205–1810. SUPPLEMENTARY INFORMATION : Section 337 of the Tariff Act of 1930 provides that, if the Commission finds a violation, it shall exclude the articles concerned from the United States unless, after considering the effect of such exclusion upon the public health and welfare, competitive conditions in the United States economy, the production of like or directly competitive articles in the United States, and United States consumers, it finds that such articles should not be excluded from entry. (19 U.S.C. 1337(d)(1)). A similar provision applies to cease and desist orders. (19 U.S.C. 1337(f)(1)). The Commission is soliciting submissions on public interest issues raised by the recommended relief should the Commission find a violation, specifically: a limited exclusion order and cease and desist order directed to certain vehicle telematics, fleet management, and video-based safety systems, devices, and components thereof imported, sold for importation, and/or sold after importation by respondent Motive Technologies Inc. Parties are to file public interest submissions pursuant to 19 CFR 210.50(a)(4). The Commission is interested in further development of the record on the public interest in this investigation. Accordingly, members of the public and interested government agencies are invited to file submissions of no more than five (5) pages, inclusive of attachments, concerning the public interest in light of the ALJ’s Recommended Determination on Remedy and Bonding issued in this investigation on September 8, 2025. Comments should address whether issuance of the recommended remedial orders in this investigation, should the Commission find a violation, would affect the public health and welfare in the United States, competitive conditions in the United States economy, the production of like or directly competitive articles in the VerDate Sep<11>2014 19:07 Nov 19, 2025 Jkt 268001 PO 00000 Frm 00084 Fmt 4703 Sfmt 4703 E:\FR\FM\20NON1.SGM 20NON1 lotter on DSK11XQN23PROD with NOTICES1
Active order issued from this investigation
Investigation 701-TA-737 is a U.S. International Trade Commission antidumping (AD) proceeding on Hexamine (Hexamethylenetetramine) from China, Germany, India, and Saudi Arabia; Inv. No. 701-TA-737-738 and 731-TA-1712-1715 (Final) from India, Saudi Arabia, China, Germany. The ITC determines whether U.S. industry is materially injured (or threatened) by imports under investigation; Commerce determines whether dumping or subsidization is occurring. Both findings are required for an AD/CVD order to be issued.
701-TA-737 is in the final phase, with status completed. Final phase — the ITC's final determination on injury, after Commerce issues its final dumping/subsidy determination. An affirmative final determination from both agencies triggers issuance of an AD/CVD order.
Yes — investigation 701-TA-737 resulted in AD/CVD case A-428-854. The linked order page on this catalog has the active deposit rate, scope text, and Federal Register citation.
The USITC publishes investigation determinations and milestones on its Investigations Data Service (IDS) at ids.usitc.gov. Tandom's catalog re-syncs from IDS daily; new phases, votes, and determinations appear here within 24 hours of USITC publication.
Tandom guides relevant to AD/CVD investigations
Where trade compliance APIs fit in a broker's filing pipeline: HTS classification, duty calculation, AD/CVD scope match, and post-summary corrections.
Open resource
Cash deposit cascade, separate rates, all-others, and PRC-wide rates. Worked example on case A-570-910 (galvanized welded steel pipe from China) with three exporter-specific rates.
Open resource
Scope text is authoritative; the HTS list is illustrative. Read scope, find past rulings, and file a 19 CFR 351.225 inquiry. Worked example on case A-570-106 (wooden cabinets from China).
Open resource
A practical workflow for checking antidumping and countervailing duty exposure on a US entry. For brokers and ops teams who need the answer before filing.
Open resource
Drop the Tandom Duty Calculator API into a TMS, broker software, or in-house ERP. Code samples, the response shape, and ACE reporting order, in 2026.
Open resource
Run thousands of product descriptions through HTS classification, score the confidence, and triage borderline rows. Public search endpoint plus the closed-beta three-layer Classifier.
Open resource