On June 2, 2017, Petitioners Archer Daniels Midland Company, Cargill Incorporated, and Tate & Lyle Ingredients Americas LLC filed a petition for the imposition of antidumping duties and countervailing duties on imports of Citric Acid and Certain Citrate Salts From Belgium, Colombia, and Thailand.


The merchandise covered by this petition includes all grades and granulation sizes of citric acid, sodium citrate, and potassium citrate in their unblended forms, whether dry or in solution, and regardless of packaging type.

The scope also includes blends of citric acid, sodium citrate, and potassium citrate; as well as blends with other ingredients, such as sugar, where the unblended form(s) of citric acid, sodium citrate, and potassium citrate constitute 40 percent or more, by weight, of the blend. The scope also includes all forms of crude calcium citrate, including dicalcium citrate monohydrate, and tricalcium citrate tetrahydrate, which are intermediate products in the production of citric acid, sodium citrate, and potassium citrate.

The scope does not include calcium citrate that satisfies the standards set forth in the United States Phannacopeia and has been mixed with a functional excipient, such as dextrose or starch, where the excipient constitutes at least 2 percent, by weight, of the product.

The scope includes the hydrous and anhydrous forms of citric acid, the dihydrate and anhydrous forms of sodium citrate, otherwise known as citric acid sodium salt, and the monohydrate and monopotassium forms of potassium citrate. Sodium citrate also includes both trisodium citrate and monosodium citrate which are also known as citric acid trisodium salt and citric acid monosodium salt, respectively.

Citric acid and sodium citrate are classifiable under 2918.14.0000 and 2918.15.1000 of the Harmonized Tariff Schedule of the United States (“HTSUS”), respectively. Potassium citrate and crude calcium citrate are classifiable under 2918.15.5000 and, if included in a mixture or blend, 3824.99.9295 of the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are classifiable under 3824.99.9295 of the HTSUS. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise is dispositive.


Archer Daniels Midland Company 77 West Wacker Drive, Suite 4600 Chicago, Illinois 60601

Cargill Incorporated P.O. Box 9300 Minneapolis, MN 55440

Tate & Lyle Ingredients Americas LLC 5450 Prairie Stone Pkwy Hoffman Estates, IL 60192 USA


Steven A. Jones King & Spalding 1700 Pennsylvania Avenue, N.W. Washington, DC 20006-4706


Belgium 56.02% -118.44%

Colombia 41.18% to 49.46%

Thailand 4.6% -67.1%


Countervailing Duty Petitions issued against Thailand. Amounts of additional duties unspecified.


For a list of foreign products/exporters alleged by Petitioner, please see Attachment I.


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


2014 2015 2016 Jan-Mar 2016 Jan-Mar 2017
Volume (1,000 pounds) 20,705 24,225 18,396 4,363 3,810
Value (1,000 USD) 14,454 15,914 11,323 2,775 2,303
AUV (USD/lb) 0.70 0.66 0.62 0.64 0.60
Volume (1,000 pounds) 40,980 44,597 47,744 10,502 5,692
Value (1,000 USD) 24,985 27,517 28,736 6,323 3,583
AUV (USD/lb) 0.61 0.62 0.60 0.60 0.63
Volume (1,000 pounds) 76,266 89,268 106,728 20,691 36,920
Value (1,000 USD) 48,187 51,567 54,552 11,070 18,905
AUV (USD/lb) 0.63 0.58 0.51 0.53 0.51