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PETITION FOR THE IMPOSITION OF ANTIDUMPING DUTIES ON ACRYLONITRILE-BUTADIENE RUBBER FROM FRANCE, MEXICO, AND SOUTH KOREA

I.  Type of Action: Antidumping Duty (“AD”): France, Mexico, And South Korea

II.  Product:

The product covered by this investigation is commonly referred to as acrylonitrile butadiene rubber or nitrile rubber (“NBR”). NBR is a synthetic rubber produced by the emulsion polymerization of butadiene and acrylonitrile with or without the incorporation of a third component selected from methacrylic acid or isoprene. NBR is sold in bale, slab, crumb, powder, pellet, particulate, and liquid form. NBR in the latex form (HTSUS at subheading 4002.51.00) is excluded from the scope of this investigation. Also excluded from the scope of this investigation is: a) NBR containing additives (e.g. nitrile rubber further compounded with fillers, reinforcement agents, vulcanization agents, etc.; by example, products classified under HTSUS subheading 4005); b) NBR containing rubber processing chemicals, NBR containing other materials used for further processing beyond the polymerization process: and, (c) hydrogenated NBR (commonly referred to as HNBR) produced by subsequent dissolution and hydrogenation of NBR. The merchandise subject to this investigation is classified in the HTSUS at subheading 4002.59.00. Although the HTSUS subheading is provided for convenience and customs purposes, the written description of the merchandise under investigation is dispositive.

III.  HTS classifications:

NBR is currently classified under subheading 4002.59.00 of the HTSUS, as “Synthetic rubber and factice derived from oils, in primary forms or in plates, sheets or strip; mixtures of any product of heading 4001 with any product of this heading, in primary forms or in plates sheets or strip; Acrylonitrile-butadiene rubber (NBR); Other.”

The general tariff (Column 1) assessed on imported goods entering the U.S. under HTSUS subheading 4002.59 is Free. The HTSUS subheadings are provided for convenience and Customs purposes, whereas the written scope description of the merchandise under investigation is dispositive. To ensure complete accuracy to identify subject imports, the written description of the subject merchandise is dispositive for defining the scope of subject imports.

IV.  Date of Filing: June 30, 2021

V.  Petitioners: Zeon Chemicals L.P. and Zeon GP, LLC

VI.  Foreign Producers/Exporters:

Please contact our office for a list filed with the petition.

VII.  US Importers named:

Please contact our office for a list filed with the petition.

VIII.  Alleged Dumping Margins:

France:                       72.27%

Mexico:                       97.00%

South Korea              110.31%

IX. Comments:

A.  Projected date of ITC Preliminary Conference: August 14, 2021.

B.  The earliest theoretical date for retroactive suspension of liquidation is September 8, 2021.

Please contact our office for a complete projected schedule for the AD investigation.

C.  Volume and Value of Imports:

If you have questions regarding how this investigation may impact future imports of scope merchandise or whether a particular product is within the scope of the investigation, please contact one of our attorneys.

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