U.S. Finds Chinese MDI Sold Below Fair Value in Preliminary Decision

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The U.S. Department of Commerce announced a preliminary finding on methylene diphenyl diisocyanate (MDI) from China. Commerce determined that MDI from the People’s Republic of China is being, or is likely to be, sold in the United States at less-than-fair-value (LTFV).

What is MDI?

MDI is a chemical used in making foams and plastics. It has two or more isocyanate groups connected to benzene rings with methylene bridges. MDI can be liquid or solid. Some of the common names for MDI include Polymeric MDI, Monomeric MDI, and Modified MDI. The investigation covers all types and grades of MDI from China, regardless of their physical form, additives, or packaging.

Investigation Scope

The investigation covers MDI and products containing more than 40% MDI by weight. Some products with less MDI or that are highly modified are not included. If MDI is processed in a third country or mixed with MDI from other sources, only the Chinese component is covered.

Preliminary Dumping Margins

Commerce found these estimated dumping margins for Chinese exporters and producers:

  • Covestro Polymers (China) Co., Ltd.: 376.12%
  • Shandong Mingko Co., Ltd.: 376.12%
  • China-wide entity: 511.75% (based on facts available with adverse inferences)

These margins show that MDI from China is being sold in the U.S. at much lower prices than normal value.

Suspension of Liquidation

U.S. Customs and Border Protection will suspend liquidation of MDI from China that is entered or withdrawn for consumption on or after the date of publication of the notice. Importers will need to provide a cash deposit equal to the dumping margin above for their specific supplier.

How Did Commerce Make Its Decision?

Commerce used information from the original petition and relied on facts available for the China-wide entity. For companies not individually examined, Commerce used the average margin alleged in the petition (376.12%).

No Changes to Scope

No parties commented on the scope of the products covered. Therefore, the scope remains unchanged from the initial notice.

Public Comments and Hearing Requests

Interested parties can submit written comments (case briefs) within 30 days of the notice’s publication. Parties may also request a hearing on the issues raised. If requested, the hearing date will be announced by Commerce.

Postponement of Final Decision

Wanhua Singapore and Wanhua Ningbo requested to postpone the final determination. Commerce agreed, extending the final decision deadline to 135 days after this notice. Provisional measures (such as cash deposits) may now last up to six months.

Next Steps

Commerce will send its findings to the U.S. International Trade Commission (ITC). If the final determination confirms the preliminary findings, the ITC will then decide if imports of MDI from China harm U.S. industry.

Details and Contacts

The full decision can be found online at https://access.trade.gov. For further information, contact Kayden Jenson or Christopher Maciuba at the International Trade Administration in Washington, DC.

This finding was published in the Federal Register on September 16, 2025 (Volume 90, Number 177, Pages 44629-44632).


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