Introduction

On January 28, 2026, Vantage Specialty Chemicals, Inc. (the “Petitioner”) filed a petition with the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC) seeking the imposition of antidumping duties (AD) and countervailing duties (CVD) on imports of certain fatty acids from Indonesia and Malaysia (the “subject merchandise”).

The period of investigation for both AD and CVD investigations at DOC covers subject merchandise imported from Indonesia and Malaysia from January 1 to December 31, 2025.

Under U.S. law, a domestic industry may petition the U.S. government to initiate AD or CVD investigations into imports alleged to injure the domestic industry. In an AD investigation, DOC determines whether subject imports are sold in the United States at less than fair value (i.e., dumped), while in a CVD investigation, DOC determines whether foreign producers and/or exporters of subject imports received countervailable subsidies. If DOC makes affirmative determinations and the ITC further finds material injury or threat thereof by reason of the subject imports, additional duties may be imposed to offset the dumping or subsidization.

If DOC and the ITC both issue affirmative preliminary determinations, U.S. importers may be required to post cash deposits equal to the estimated AD and CVD duties on all subject imports entered into the United States on or after the dates DOC publishes its preliminary determinations in the Federal Register. Such duties may be imposed 90 days prior to the date of publication of the preliminary determinations if both the DOC and ITC make affirmative critical circumstances determinations. The preliminary AD and CVD rates may be revised or eliminated in the final phase of the DOC proceeding, particularly where foreign producers/exporters fully participate in the investigation.

Scope

The following describes the imported merchandise that is included within the scope of these investigations:

The merchandise subject to these Petitions is certain fatty acids (CFA), which are organic acids made of a hydrocarbon chain with a carboxylic acid group (i.e., an organic acid that contains a carboxyl group (-C(=O)-OH) attached to an R-group, sometimes also written as R-COOH, R-C(O)OH, or R-CO2H) at one end with a carbon chain length (i.e., the number of carbon atoms in the fatty acid chain) of C6, C8, Cl0, C12, C14, C16, or C18, with an iodine value below 105g/100 g and with a ratio of free fatty acids to triglycerides (also known as the “degree of split” or “DoS”)) of at least 97 percent, including single fatty acid (also referred to as “pure cut”), and blends containing a combination of two or more carbon chain lengths.

CFA is also commonly called pure, pure cut, fractionated, or distilled fatty acid or mixed, mixed cut, or blended fatty acid, with the terms pure, pure cut, fractionated, and distilled typically referring to specific single-chain fatty acids that have been separated from a mixed natural source such as animal fat or vegetable oil using processes like hydrolysis (the breakdown of fat molecules by water, catalyzed by acid, base, or enzymes (lipases) to yield glycerol and free fatty acids), distillation, and crystallization, and the terms mixed or mixed cut referring to combinations, blends or mixtures of different single-chain fatty acids also derived from a natural source such as animal fat or vegetable oil using processes like hydrolysis, distillation, and crystallization. Common names for pure, pure cut, fractionated, or distilled fatty acids forms include stearic acid and oleic acid. Common names for mixed or mixed cut fatty acids include coconut fatty acid, hardened coconut fatty acid, topped coconut fatty acid, topped hardened coconut fatty acid, palm kernel fatty acid, hardened palm kernel fatty acid, topped palm kernel fatty acid, topped hardened palm kernel fatty acid, palm fatty acid, palm stearin fatty acid, palm fatty acid distillate, and palm olein fatty acid.

CFA is normally associated with Chemical Abstracts Service (CAS) registry numbers 57-11-4, 112-80-1, 61790-38-3, 67701-05-7, 67701-06-8, 67707-01-3, 68938-15-8, 101403-98-9, 91771-90-3, 90990-15-1, 68440-15-3, 84238-17-5, 98106-68-4, 98106-66-2, 84238-17-5, 90990-08-1, and 90990-08-2 but several others may also be used.

CFA ranges in physical form from low viscosity liquids to solids. CFA is covered by the scope of these Petitions irrespective of whether it has gone through a distillation process and regardless of acid content, reactivity, functionality, freeze stability, heat stability, physical form, viscosity, grade, purity, molecular weight, or packaging.

CFA may contain additives, such as catalysts, solvents, antioxidants, fire retardants, colorants, pigments, diluents, thickeners, fillers, softeners, and toughening agents.

Specifically excluded from the scope are CFA containing 90 percent or more, by weight, of fatty acids with carbon chain lengths of C6, C8, or C10 (or any combination thereof).

The scope also does not include mixtures of CFA with other materials, when the combined CFA component comprises less than 80 percent of the total weight of the mixture.

The scope includes merchandise matching the above description that has been processed in a third country, including by commingling, diluting, introducing or removing additives, or performing any other processing that would not otherwise remove the merchandise from the scope of the Petitions if performed in the subject country.

The scope also includes CFA that is comingled or blended with CFA from sources not subject to these Petitions. Only the subject component of such comingled products is covered by the scope of these Petitions.

The merchandise is currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings 2915.70.01.20, 2915.70.01.50, 2915.90.10.50, 2916.15.10.00, 2916.15.51.00, 3823.11.00.00, 3823.12.00.00, 3823.19.20.00, and 3823.19.40.00, and may also enter under 2915.70.01.10 and 2915.90.10.10.

The HTSUS subheadings set forth above are provided for convenience and customs purposes only. The written description of the scope is dispositive.

Foreign Producers and Exporters of Subject Merchandise

A list of foreign producers and exporters of subject merchandise, as identified in the petition, is provided in Attachment 1.

U.S. Importers of Subject Merchandise

A list of U.S. importers of subject merchandise, as identified in the petition, is provided in Attachment 2.

Alleged Dumping Margins and Countervailable Subsidies

Petitioners allege dumping margins of 64.67% to 94.41% for imports of subject merchandise from Malaysia and 20.08% to 72.03% for imports of subject merchandise from Indonesia.

Petitioners allege that producers from Malaysia received 16 countervailable subsidies and that producers from Indonesia received 28 countervailable subsidies. Both the Indonesia and Malaysia CVD petitions includes transnational subsidy allegations, which allege that the Government of China is providing countervailable subsidies to Indonesian and Malaysian producers of subject merchandise. If DOC concludes that Indonesian and Malaysian producers/exporters of subject merchandise received countervailable subsidies, DOC will assign CVD rates to offset the alleged subsidization.

DOC generally assigns duties at the margins and rates alleged by the petitioners to foreign producers and exporters that fail to participate and cooperate during the investigations.

Potential Trade Impact

According to the petition, U.S. imports of subject merchandise from Malaysia and Indonesia totaled $548.728 million from November 1, 2023, through October 31, 2024, and $828.205 million from November 1, 2024, through October 31, 2025.

Estimated Schedule of AD/CVD Investigations

1/28/2026	Petitions Filed
3/16/2026	ITC Preliminary Injury Determination
4/23/2026	DOC Preliminary CVD Determination (un-extended)
6/29/2026		DOC Preliminary CVD Determination (fully extended)
7/7/2026	DOC Preliminary AD Determination (un-extended)
8/26/2026		DOC Preliminary AD Determination (fully extended)
7/7/2026	DOC Final CVD Determination (un-extended)
1/15/2027		DOC Final CVD Determination (fully extended)
9/28/2026	DOC Final AD Determination (un-extended)
1/15/2027		DOC Final AD Determination (fully extended)
11/12/2026	ITC Final Injury Determination (un-extended)
3/1/2027		ITC Final Injury Determination (fully extended)
11/27/2026	AD and CVD Orders Published (un-extended)
3/15/2027		AD and CVD Orders Published (fully extended)

If you are a foreign producer/exporter or U.S. importer or purchaser of subject merchandise or have any questions about this case, please contact Taft’s International Trade Practice.