SUPPLEMENTARY INFORMATION:

The Petition

On June 24, 2026, the U.S. Department of Commerce (Commerce) received an antidumping duty (AD) petition concerning imports of certain choline salts (choline salts) from the People's Republic of China (China), filed in proper form on behalf of BCP Ingredients Inc. (the petitioner), a domestic producer of choline salts.^[1] The AD Petition was accompanied by a countervailing duty (CVD) petition concerning imports of choline salts from China.^[2]

Between June 29 and July 8, 2026, Commerce requested supplemental information pertaining to certain aspects of the Petition in supplemental questionnaires.^[3] Between July 2 and July 9, 2026, the petitioner filed timely responses to these requests for additional information.^[4]

In accordance with section 732(b) of the Tariff Act of 1930, as amended (the Act), the petitioner alleges that imports of choline salts from China are being, or are likely to be, sold in the United States at less than fair value (LTFV) within the meaning of section 731 of the Act, and that imports of such products are materially injuring, or threatening material injury to, the choline salts industry in the United States. Consistent with section 732(b)(1) of the Act, the Petition was accompanied by information reasonably available to the petitioner supporting its allegations.

Commerce finds that the petitioner filed the Petition on behalf of the domestic industry, because the petitioner is an interested party, as defined in section 771(9)(C) of the Act. Commerce also finds that the petitioner demonstrated sufficient industry support for the initiation of the requested LTFV investigation.^[5]

Period of Investigation (POI)

Because the Petition was filed on June 24, 2026, and because China is a non-market economy (NME) country pursuant to 19 CFR 351.204(b)(1), the POI for the LTFV investigation is October 1, 2025, through March 31, 2026.

Scope of the Investigation

The product covered by this investigation is choline salts from China. For a full description of the scope of this investigation, see the appendix to this notice.

Comments on the Scope of the Investigation

Between June 29 and July 10, 2026, Commerce requested information and clarification from the petitioner regarding the proposed scope to ensure that the scope language in the Petition is an accurate reflection of the products for which the domestic industry is seeking relief.^[6] Between July 2 and 10, 2026, the petitioner provided clarifications and revised the scope.^[7] The description of merchandise covered by this investigation, as described in the appendix to this notice, reflects these clarifications.

As discussed in the Preamble to Commerce's regulations, we are setting aside a period for interested parties to raise issues regarding product coverage ( i.e., scope).^[8] Commerce will consider all scope comments received from interested parties and, if necessary, will consult with interested parties prior to the issuance of the preliminary determination. If scope comments include factual information, all such factual information should be limited to public information.^[9] Commerce requests that interested parties provide at the beginning of their scope comments a public executive summary for each comment or issue raised in their submission. Commerce further requests that interested parties limit their public executive summary of each comment or issue to no more than 450 words, not including citations. Commerce intends to use the public executive summaries as the basis of the comment summaries included in the analysis of scope comments. To facilitate preparation of its questionnaires, Commerce requests that scope comments be submitted by 5:00 p.m. Eastern Time (ET) on August 3, 2026, which is 20 calendar days from the signature date of this notice. Any rebuttal comments, which may include factual information, and should also be limited to public information, must be filed by 5:00 p.m. ET on August 13, 2026, which is 10 calendar days from the initial comment deadline.

Commerce requests that any factual information that parties consider relevant to the scope of this investigation be submitted during that period. However, if a party subsequently finds that additional factual information pertaining to the scope of the investigation may be relevant, the party must contact Commerce and request permission to submit the additional information. All scope comments must be filed simultaneously on the records of the concurrent LTFV and CVD investigations.

Filing Requirements

All submissions to Commerce must be filed electronically via Enforcement and Compliance's Antidumping Duty and Countervailing Duty Centralized Electronic Service System (ACCESS), ( printed page 45242) unless an exception applies.^[10] An electronically filed document must be received successfully in its entirety by the time and date it is due.

Comments on Product Characteristics

Commerce is providing interested parties an opportunity to comment on the appropriate physical characteristics of choline salts to be reported in response to Commerce's AD questionnaires. This information will be used to identify the key physical characteristics of the subject merchandise in order to report the relevant factors of production (FOP) accurately, as well as to develop appropriate product comparison criteria.

In order to consider the suggestions of interested parties in developing and issuing the AD questionnaires, all product characteristics comments must be filed by 5:00 p.m. ET on August 3, 2026, which is 20 calendar days from the signature date of this notice. Any rebuttal comments must be filed by 5:00 p.m. ET on August 13, 2026, which is 10 calendar days from the initial comment deadline. All comments and submissions to Commerce must be filed electronically using ACCESS, as explained above, on the record of the LTFV investigation.

Determination of Industry Support for the Petition

Section 732(b)(1) of the Act requires that a petition be filed on behalf of the domestic industry. Section 732(c)(4)(A) of the Act provides that a petition meets this requirement if the domestic producers or workers who support the petition account for: (i) at least 25 percent of the total production of the domestic like product; and (ii) more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the petition. Moreover, section 732(c)(4)(D) of the Act provides that, if the petition does not establish support of domestic producers or workers accounting for more than 50 percent of the total production of the domestic like product, Commerce shall: (i) poll the industry or rely on other information in order to determine if there is support for the petition, as required by subparagraph (A); or (ii) determine industry support using a statistically valid sampling method to poll the “industry.”

Section 771(4)(A) of the Act defines the “industry” as the producers as a whole of a domestic like product. Thus, to determine whether a petition has the requisite industry support, the statute directs Commerce to look to producers and workers who produce the domestic like product. The U.S. International Trade Commission (ITC), which is responsible for determining whether “the domestic industry” has been injured, must also determine what constitutes a domestic like product in order to define the industry. While both Commerce and the ITC apply the same statutory definition regarding the domestic like product,^[11] they do so for different purposes and pursuant to a separate and distinct authority. In addition, Commerce's determination is subject to limitations of time and information. Although this may result in different definitions of the like product, such differences do not render the decision of either agency contrary to law.^[12]

Section 771(10) of the Act defines the domestic like product as “a product which is like, or in the absence of like, most similar in characteristics and uses with, the article subject to an investigation under this title.” Thus, the reference point from which the domestic like product analysis begins is “the article subject to an investigation” ( i.e., the class or kind of merchandise to be investigated, which normally will be the scope as defined in the petition).

With regard to the domestic like product, the petitioner does not offer a definition of the domestic like product distinct from the scope of the investigation.^[13] Based on our analysis of the information submitted on the record, we have determined that choline salts, as defined in the scope, constitute a single domestic like product, and we have analyzed industry support in terms of that domestic like product.^[14]

In determining whether the petitioner has standing under section 732(c)(4)(A) of the Act, we considered the industry support data contained in the Petition with reference to the domestic like product as defined in the “Scope of the Investigation,” in the appendix to this notice. To establish industry support, the petitioner provided its own production of the domestic like product in 2025 and compared this to the total production of the domestic like product for the U.S. choline salts industry.^[15] We relied on data provided by the petitioner for purposes of measuring industry support.^[16]

Our review of the data provided in the Petition, the First and Second General Issues Supplements, and other information readily available to Commerce indicates that the petitioner has established industry support for the Petition.^[17] First, the Petition established support from domestic producers (or workers) accounting for more than 50 percent of the total production of the domestic like product and, as such, Commerce is not required to take further action in order to evaluate industry support ( e.g., polling).^[18] Second, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(i) of the Act because the domestic producers (or workers) who support the Petition account for at least 25 percent of the total production of the domestic like product.^[19] Finally, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(ii) of the Act because the domestic producers (or workers) who support the Petition account for more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the Petition.^[20] Accordingly, Commerce determines that the Petition was filed on behalf of the domestic industry within the meaning of section 732(b)(1) of the Act.^[21]

Allegations and Evidence of Material Injury and Causation

The petitioner alleges that the U.S. industry producing the domestic like ( printed page 45243) product is being materially injured, or is threatened with material injury, by reason of the imports of the subject merchandise sold at LTFV. In addition, the petitioner alleges that subject imports exceed the negligibility threshold provided for under section 771(24)(A) of the Act.^[22]

The petitioner contends that the industry's injured condition is illustrated by a significant increase in the volume of subject imports; reduced market share; lost sales and revenues; underselling and price depression and suppression; decline in production, capacity utilization, and employment variables; and negative impact on financial performance.^[23] We assessed the allegations and supporting evidence regarding material injury, threat of material injury, causation, as well as negligibility, and we have determined that these allegations are properly supported by adequate evidence, and meet the statutory requirements for initiation.^[24]

Allegations of Sales at LTFV

The following is a description of the allegations of sales at LTFV upon which Commerce based its decision to initiate LTFV investigation of imports of choline salts from China. The sources of data for the deductions and adjustments relating to U.S. price and normal value (NV) are discussed in greater detail in the China AD Initiation Checklist.

U.S. Price

The petitioner based export price (EP) on pricing information for choline salts produced in China and sold or offered for sale in the U.S. market.^[25] The petitioner made certain adjustments to U.S. price to calculate a net ex-factory U.S. price, where applicable.^[26]

Normal Value

Commerce considers China to be an NME country.^[27] In accordance with section 771(18)(C)(i) of the Act, any determination that a foreign country is an NME country shall remain in effect until revoked by Commerce. Therefore, we continue to treat China as an NME country for purposes of the initiation of the LTFV investigation. Accordingly, we base NV on FOPs valued in surrogate market economy countries in accordance with section 773(C) of the Act.

The petitioner claims that Mexico, Malaysia, and the Republic of Türkiye (Türkiye) are appropriate surrogate countries for China because they are market economy countries that are at a level of economic development comparable to that of China and are a significant producers of comparable merchandise.^[28] The petitioner provided publicly available information from Mexico, Malaysia, and Türkiye to value all FOPs.^[29] Based on the information provided by the petitioner, we believe it is appropriate to use Mexico, Malaysia, and Türkiye as surrogate countries for China to value all FOPs for initiation purposes.

Interested parties will have the opportunity to submit comments regarding surrogate country selection and, pursuant to 19 CFR 351.301(c)(3)(i), will be provided an opportunity to submit publicly available information to value FOPs within 30 days before the scheduled date of the preliminary determination.

Factors of Production

Because information regarding the volume of inputs consumed by Mexican, Malaysian, and Turkish producers/exporters were not reasonably available, the petitioner used its own production experience and product-specific consumptions rates as a surrogate to value the Chinese manufacturers' FOPs.^[30] Additionally, the petitioner calculated factory overhead, SG&A, and profit based on the experiences of Mexican, Malaysian, and Turkish producers of comparable merchandise.^[31]

Fair Value Comparisons

Based on the data provided by the petitioner, there is reason to believe that imports of choline salts from China are being, or are likely to be, sold in the United States at LTFV. Based on comparisons of EP or NV in accordance with sections 772 and 773 of the Act, the estimated dumping margins for choline salts from China covered by this initiation range from (1) China (Mexico surrogate)—129.43 to 229.44 percent; (2) China (Malaysia surrogate)—73.39 to 147.26 percent; (3) China (Türkiye surrogate)—189.49 to 313.82 percent.^[32]

Initiation of LTFV Investigation

Based upon the examination of the Petition and supplemental responses, we find that they meet the requirements of section 732 of the Act. Therefore, we are initiating a LTFV investigation to determine whether imports of choline salts from China are being, or are likely to be, sold in the United States at LTFV. In accordance with section 733(b)(1)(A) of the Act and 19 CFR 351.205(b)(1), unless postponed, we will make our preliminary determination no later than 140 days after the date of this initiation.

Respondent Selection

In the Petition, the petitioner identified 92 companies in China as producers and/or exporters of choline salts.^[33] Our standard practice for respondent selection in an AD investigation involving an NME country is to select respondents based on quantity and value (Q&V) questionnaires in cases where Commerce has determined that the number is large, and it cannot individually examine each company based upon its resources. Therefore, considering the number of producers and/or exporters identified in the Petition, Commerce will solicit Q&V information that can serve as a basis for selecting exporters for individual examination in the event that Commerce determines that the number is large and decides to limit the number of respondents individually examined pursuant to section 777A(c)(2) of the Act. Given the number of producers and/or exporters identified in the Petition, Commerce has determined that it will issue Q&V questionnaires to the largest producers and/or exporters in China that are identified in the U.S. Customs and Border Protection POI entry data for which there is complete address information on the record.^[34]

Commerce will post the Q&V questionnaires along with filing instruction on Commerce's website at https://www.trade.gov/​ec-adcvd-qv-questionnaire. Producers/exporters of choline salts from China that do not receive Q&V questionnaires may still ( printed page 45244) submit a response to the Q&V questionnaire and can obtain a copy of the Q&V questionnaire from Commerce's website. Responses to the Q&V questionnaire may be submitted by the relevant Chinese producers/exporters no later than 5:00 p.m. ET on July 28, 2026, which is two weeks from the signature date of this notice. All Q&V questionnaire responses must be filed electronically via ACCESS. An electronically filed document must be received successfully in its entirety by ACCESS no later than 5:00 p.m. ET on the deadline noted above.

Interested parties must submit applications for disclosure under administrative protective order (APO) in accordance with 19 CFR 351.305(b). Instructions for filing such applications may be found on Commerce's website at https://www.trade.gov/​administrative-protective-orders.

Separate Rates

In order to obtain separate rate status in an NME investigation, exporters and producers must submit a separate rate application. The specific requirements for submitting a separate rate application in an NME investigation are outlined in detail in the application itself, which is available on Commerce's website at https://www.trade.gov/​non-market-economy-separate-rate-applications-and-certifications. Note that Commerce recently promulgated new regulations pertaining to separate rates, including the separate rate application deadline and eligibility for separate rate status, in 19 CFR 351.108.^[35] Pursuant to 19 CFR 351.108(d)(1), the separate rate application will be due 21 days after publication of this initiation notice.^[36] Exporters and producers must file a timely separate rate application if they want to be considered for individual examination. In addition, pursuant to 19 CFR 351.108(e), exporters and producers who submit a separate rate application and have been selected as mandatory respondents will be eligible for consideration for separate rate status only if they fully respond to all parts of Commerce's AD questionnaire and participate in the LTFV proceeding as mandatory respondents.^[37] Commerce requires that companies from China submit a response to the Q&V questionnaire and a separate rate application by the respective deadlines to receive consideration for separate rate status. Companies not filing a timely Q&V questionnaire response will not receive separate rate consideration.

Use of Combination Rates

Commerce will calculate combination rates for certain respondents that are eligible for a separate rate in an NME investigation. The Separate Rates and Combination Rates Bulletin states:

{w}hile continuing the practice of assigning separate rates only to exporters, all separate rates that {Commerce} will now assign in its NME investigation will be specific to those producers that supplied the exporter during the period of investigation. Note, however, that one rate is calculated for the exporter and all of the producers which supplied subject merchandise to it during the period of investigation. This practice applies both to mandatory respondents receiving an individually calculated separate rate as well as the pool of non-investigated firms receiving the {weighted average} of the individually calculated rates. This practice is referred to as the application of “combination rates” because such rates apply to specific combinations of exporters and one or more producers. The cash-deposit rate assigned to an exporter will apply only to merchandise both exported by the firm in question and produced by a firm that supplied the exporter during the period of investigation.^[38]

Distribution of Copies of the Petition

In accordance with section 732(b)(3)(A) of the Act and 19 CFR 351.202(f), a copy of the public version of the Petition has been provided to the Government of China via ACCESS. To the extent practicable, we will attempt to provide a copy of the public version of the Petition to each exporter named in the Petition, as provided under 19 CFR 351.203(c)(2).

ITC Notification

Commerce will notify the ITC of our initiation, as required by section 732(d) of the Act.

Preliminary Determination by the ITC

The ITC will preliminarily determine, within 45 days after the date on which the Petition was filed, whether there is a reasonable indication that imports of choline salts from China are materially injuring, or threatening material injury to, a U.S. industry.^[39] A negative ITC determination will result in the investigation being terminated.^[40] Otherwise, this LTFV investigation will proceed according to statutory and regulatory time limits.

Submission of Factual Information

Factual information is defined in 19 CFR 351.102(b)(21) as: (i) evidence submitted in response to questionnaires; (ii) evidence submitted in support of allegations; (iii) publicly available information to value factors under 19 CFR 351.408(c) or to measure the adequacy of remuneration under 19 CFR 351.511(a)(2); (iv) evidence placed on the record by Commerce; and (v) evidence other than factual information described in (i)-(iv). Section 351.301(b) of Commerce's regulations requires any party, when submitting factual information, to specify under which subsection of 19 CFR 351.102(b)(21) the information is being submitted ^[41] and, if the information is submitted to rebut, clarify, or correct factual information already on the record, to provide an explanation identifying the information already on the record that the factual information seeks to rebut, clarify, or correct.^[42] Time limits for the submission of factual information are addressed in 19 CFR 351.301, which provides specific time limits based on the type of factual information being submitted. Interested parties should review the regulations prior to submitting factual information in this investigation.

Extensions of Time Limits

Parties may request an extension of time limits before the expiration of a time limit established under 19 CFR 351.301, or as otherwise specified by Commerce. In general, an extension request will be considered untimely if it is filed after the expiration of the time limit established under 19 CFR 351.301, or as otherwise specified by Commerce.^[43] For submissions that are due from multiple parties simultaneously, an extension request will be considered untimely if it is filed after 10:00 a.m. ET on the due date. Under certain circumstances, Commerce may elect to specify a different time limit by which extension requests will be considered untimely for submissions which are due from multiple parties simultaneously. In such a case, we will inform parties in a letter or memorandum of the deadline (including a specified time) by which extension requests must be filed to be considered ( printed page 45245) timely. An extension request must be made in a separate, standalone submission; under limited circumstances we will grant untimely filed requests for the extension of time limits, where we determine, based on 19 CFR 351.302, that extraordinary circumstances exist. Parties should review Commerce's regulations concerning the extension of time limits and the Time Limits Final Rule prior to submitting factual information in this investigation.^[44]

Certification Requirements

Any party submitting factual information in an AD or CVD proceeding must certify to the accuracy and completeness of that information.^[45] Parties must use the certification formats provided in 19 CFR 351.303(g).^[46] Commerce intends to reject factual submissions if the submitting party does not comply with the applicable certification requirements.

Notification to Interested Parties

Interested parties must submit applications for disclosure under APO in accordance with 19 CFR 351.305. Parties wishing to participate in this investigation should ensure that they meet the requirements of 19 CFR 351.103(d) ( e.g., by filing the required letter of appearance). Note that Commerce has amended certain of its requirements pertaining to the service of documents in 19 CFR 351.303(f).^[47]

This notice is issued and published pursuant to sections 732(c)(2) and 777(i) of the Act, and 19 CFR 351.203(c).

Appendix

Scope of the Investigation

The merchandise covered by this investigation is certain choline salts, in all forms and purities, that are capable of delivering the nutrient choline. Subject choline salts may or may not contain additives such as a vegetable or mineral carrier or an anti-caking agent and may or may not be coated or encapsulated, such as in a lipid. For choline salts that contain non-choline salt components, such as a carrier or coating, the entire article is covered, including the non-choline salt content, provided that the choline salt content constitutes at least 30 percent by weight.

Choline salts are organic compounds and quaternary ammonium salts. Subject merchandise includes, but is not limited to, the following choline salts in their aqueous, crystallized, dried, or encapsulated forms:

• Choline chloride, which exists as a colorless aqueous solution and as a white, crystalline powder which may or may not be mixed with vegetable, inorganic, or fat-based carriers. It has the molecular formula [(CH₃)₃ NCH₂ CH₂ OH]⁺ Cl⁻ . It may also be referred to as (2-hydroxyethyl) trimethylammonium chloride, and its molecular formula may also be expressed as C₅ H₁₄ NO.Cl or C₅ H₁₄ ClNO. The Chemical Abstracts Service (CAS) registry number for choline chloride is 67-48-1; the Flavoring Extract Manufacturers' Association (FEMA) number is 4500; the PubChem number is 6209; and the European Community (EC) number is 200-655-4;
• Choline bitartrate, which is a white crystalline powder with the molecular formula (CH₃)₃ NCH₂ CH₂ OH⁺ HOOC⁻ CH(OH)⁻ CH(OH)⁻ COO⁻ . It may be referred to as (2-hydroxyethyl) trimethylammonium-L-(+)-tartrate salt, and its molecular formula may also be expressed as C₅ H₁₄ NO.C₄ H₅ O₆ or C₉ H₁₉ NO₇. Choline bitartrate has the CAS registry number 87-67-2; the PubChem number 6900; and the EC number 201-763-4;
• Choline dihydrogen citrate, which is a white crystalline powder with the molecular formula C₁₁ H₂₁ NO₈ and may be referred to as (2-hydroxyethyl) trimethylammonium citrate. Choline dihydrogen citrate has the CAS registry number 77-91-8; the PubChem number 66170; and the EC number 201-068-6.

This investigation covers choline salts for which the reaction of trimethylamine and ethylene oxide occurs in the subject country. The merchandise subject to this investigation includes choline salts in their aqueous or dried form that are processed in a third country, including, but not limited to, refining, drying, encapsulating, blending, or any other processing that would not otherwise remove the merchandise from the scope of this investigation if performed in the country of manufacture of the in-scope choline salt. Choline salts subject to this investigation are not excluded when commingled with choline salts from sources not subject to this investigation. Only the subject component of such commingled products is covered by the scope of this investigation.

Excluded from the scope of this investigation is choline hydroxide, which has the molecular formula C₅ H₁₅ NO₂, the CAS registry number 123-41-1, the PubChem number 31255, and the EC number 204-625-1. Also excluded is choline salicylate, which has the molecular formula C₁₂ H₁₉ NO₄, the CAS registry number 2016-36-6, the PubChem number 54686350, and the EC number 217-948-8.

Also excluded from the scope of the investigation are any products already covered by the scope of any extant antidumping and/or countervailing duty orders, including 2,4-Dichlorophenoxyacetic Acid from India and the People's Republic of China: Antidumping Duty Orders,90 FR 22243 (May 27, 2025), and including 2,4-Dichlorophenoxyacetic Acid from the People's Republic of China and India: Countervailing Duty Orders,90 FR 22232 (May 27, 2025).

The choline salts subject to this investigation are classified under the Harmonized Tariff Schedule of the United States (HTSUS) subheading 2923.10.0000. Subject choline salts of dried choline chloride may also enter under HTSUS subheadings 2309.90.1005, 2309.90.1015, 2309.90.1020, 2309.90.1030, 2309.90.1032, 2309.90.1035, 2309.90.1045, 2309.90.1050, 2309.90.9500, and 3824.99.9397. Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs purposes, the written description of the scope of this investigation is dispositive.

91 FR 45241