
U.S. Commerce Department Finds Countervailable Subsidies for Vanillin from China
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The U.S. Department of Commerce has made a final affirmative determination in its investigation of vanillin from the People’s Republic of China. This means that the Department found producers and exporters in China received unfair financial help, called countervailable subsidies.
Investigation Details
The investigation focused on one company, Jiaxing Guihua Imp. & Exp. Co., Ltd. (Guihua). The period of investigation was from January 1, 2023 through December 31, 2023.
The Department used their normal procedures to check information given by Guihua and used official documents during the process.
Scope of the Investigation
The products in this investigation include all types of vanillin from China. This covers natural vanillin, synthetic vanillin, bio-sourced vanillin (biovanillin), and ethylvanillin. These are chemical compounds used as flavorings.
Vanillin under this investigation has Chemical Abstracts Service (CAS) numbers 121-33-5 or 121-32-4. It must fall under U.S. tariff codes 2912.41.0000 and 2912.42.0000, regardless of its purity, particle size, or physical form.
No changes were made to the scope after the preliminary findings.
Subsidy Programs and Methodology
Commerce examined many programs to see if they gave a financial advantage to Chinese companies. If a program had a financial contribution by the government, gave a benefit, and was specific, it was seen as a subsidy.
Changes were made since the preliminary determination, especially in how Commerce calculated the costs for caustic soda, sulfuric acid, and hydrogen peroxide. The details about these changes and the full list of issues discussed are included in the official Issues and Decision Memorandum.
Final Subsidy Rates
The Department found that Jiaxing Guihua Imp. & Exp. Co., Ltd. benefited from subsidies at a rate of 42.10 percent ad valorem. All other producers and exporters of vanillin in China received the same rate of 42.10 percent.
Suspension of Liquidation
Customs and Border Protection was directed to collect cash deposits and suspend liquidation (final processing) of imported vanillin from China entered into the United States from November 18, 2024, to March 17, 2025. Entries on or after March 18, 2025, were not suspended, but suspension would start again if the U.S. International Trade Commission (ITC) issues a final positive injury decision.
If the ITC finds injury to the U.S. vanillin industry, Commerce will order permanent suspension and collect countervailing duties based on the rates listed. If the ITC says there is no injury, all collected deposits will be refunded or cancelled.
Next Steps
The ITC has up to 45 days to decide if the U.S. vanillin industry is injured by these imports. If injury is found, final duties will be collected. If not, the investigation ends and deposits are refunded.
For more information and full legal details, the Issues and Decision Memorandum is available online via the Department of Commerce’s website.
Summary
The U.S. government has officially found that Chinese vanillin producers, especially Jiaxing Guihua Imp. & Exp. Co., Ltd., benefited from unfair subsidies in 2023. A final duty rate of 42.10 percent has been set for all Chinese exporters of vanillin if the ITC confirms injury to U.S. industry. The process now awaits the ITC’s injury decision.
Legal Disclaimer
This article includes content collected from the Federal Register (federalregister.gov). The content is not an official government publication. This article is for informational purposes only and does not constitute legal advice. For case-specific consultation, please contact us. Read our full Legal Disclaimer, which also includes information on translation accuracy.