The only Indian producer in a citric acid dumping case walked out of it, and the rate Commerce put on it is one nobody calculated
One hundred and fifty one point seven three percent.
That is the preliminary dumping margin the Commerce Department put on citric acid from India on Wednesday, and no part of it was calculated from the company it applies to. Daffodil Pharmachem Private Limited was the sole mandatory respondent in the investigation. On 29 June it filed a letter titled "Withdrawal from the Investigations" and stopped taking part.
Commerce did what the statute lets it do when that happens. It went to the petition, took the highest margin alleged in it, and made that the rate.
Two countries, one product, opposite answers
The two notices published in Wednesday's Federal Register come out of a single investigation opened on 17 February and cover the same calendar year, 1 January to 31 December 2025. Both were signed on 19 August by Christopher Abbott at Enforcement and Compliance. They reach opposite conclusions.
India, case A-533-946, is affirmative. Daffodil draws 151.73 percent, marked in the rate table as based on facts available with adverse inferences. Every other Indian producer and exporter draws 100.21 percent, which is the lowest margin the petition alleged. Commerce reached for that figure because the only company it examined individually got a rate determined entirely under the adverse-inference provision, which under section 735(c)(5)(B) lets it use any reasonable method for everybody else.
Canada, case A-122-877, is negative. Jungbunzlauer Canada Inc came out at 0.00 percent. Commerce disregards zero and de minimis rates, so it calculated no all-others rate at all, and it will not tell Customs to suspend liquidation or collect a deposit on anything Canadian.
Cash deposits on Indian entries are slightly below the margins: 149.74 percent for Daffodil and 98.22 percent for all others. The gap is a 1.99 percent export subsidy offset carried over from the companion countervailing duty case decided in June. Subtract it from each margin and the published deposit rates reconcile exactly.
The part that shows what withdrawing costs
Because Daffodil did not supply what Commerce asked for, there is no verification in the India case. The notice says so, and it says there are no calculations to disclose, because there was nothing to calculate. Commerce records its preliminary view that the respondent was uncooperative.
The Canada notice says the reverse in the same week. There, Commerce intends to verify the information it relied on before making a final determination.
Both cases were slowed down, by opposite parties
The final determination in each case is now due no later than 135 days after publication. The requests came from different sides.
In India it was Daffodil, on 1 July, asking for postponement and for provisional measures to run to six months instead of four. Commerce granted it, recording that the preliminary determination is affirmative, that the exporter accounts for a significant proportion of exports, and that no compelling reason to refuse exists. So the company that stopped participating in the case still shaped its timetable.
In Canada it was the petitioners, on 14 July. They are Archer-Daniels-Midland Company, Cargill, Incorporated, and Primary Ingredients Americas LLC.
If a final determination is affirmative, the injury question goes to the International Trade Commission, and even that clock differs. For India the ITC decides before the later of 120 days after this preliminary determination or 45 days after the final one. For Canada it is 75 days after the final.
One sentence in the India notice does not match the case
The paragraph directing Customs to suspend liquidation reads, in the published text, that Commerce will suspend liquidation of "all entries of melamine, as described in Appendix I".
Appendix I to that notice describes citric acid, sodium citrate, potassium citrate and crude calcium citrate, in their unblended and blended forms, under Harmonized Tariff Schedule subheadings 2918.14.0000, 2918.15.1000 and 2918.15.5000. Melamine appears nowhere in it. The scope is what Appendix I says it is, and importers reading the notice for what is covered should read the appendix rather than that sentence.
Case briefs are due 14 days after publication. Rebuttals follow five days after that.
