Introduction

On Jan. 21, 2026, the U.S. citric acid and certain citrate salts industry 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 citric acid and certain citrate salts from Canada and India (the “subject merchandise”).

The period of investigation for both AD and CVD investigations at the DOC covers subject merchandise imported from Canada and India from Jan. 1 to Dec. 31, 2025.

The domestic producers that filed the petition are Archer-Daniels-Midland Company, Cargill Incorporated, and Primary Products Ingredients Americas LLC (the “Petitioners”).

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:

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 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.

The scope does not include calcium citrate that satisfies the standards set forth in the United States Pharmacopeia 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.

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, 3824.99.9397 of the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are classifiable under 3824.99.9397 of the HTSUS. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise is dispositive.

Foreign Producers and Exporters of Subject Merchandise

A list of foreign producers and exporters of citric acid and certain citrate salts, as identified in the petition, is provided in Attachment 1. While most AD/CVD petitions contain a public list of U.S. importers of subject merchandise, this petition names nearly 40 U.S. importers of subject merchandise and treats their names as confidential.

Alleged Dumping Margins

Petitioners allege dumping margins of 62.75% to 97.39% for imports of subject merchandise from Canada and 58.99% to 252.37% for imports of subject merchandise from India.

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

Potential Subsidy Rates

Petitioners allege that one producer in Canada received more than 20 countervailable subsidies and that numerous producers in India received more than 10 countervailable subsidies. The Indian CVD petition also includes a transnational subsidy allegation, which alleges that the Government of China is providing countervailable subsidies to Indian producers of subject merchandise. If DOC concludes that the Canadian producer and Indian producers of subject merchandise received countervailable subsidies, DOC will assign CVD rates to offset the alleged subsidization.

Potential Trade Impact

According to the petition, U.S. imports of citric acid and certain citrate salts from Canada and India totaled $205.834 million in 2023 and $225.067 million in 2024.

Estimated Schedule of AD/CVD Investigations

1/21/2026	Petitions Filed
3/9/2026	ITC Preliminary Injury Determination
4/16/2026	DOC Preliminary CVD Determination (un-extended)
6/22/2026		DOC Preliminary CVD Determination (fully extended)
6/30/2026	DOC Preliminary AD Determination (un-extended)
8/19/2026		DOC Preliminary AD Determination (fully extended)
6/30/2026	DOC Final CVD Determination (un-extended)
1/8/2027		DOC Final CVD Determination (fully extended)
9/21/2026	DOC Final AD Determination (un-extended)
1/8/2027		DOC Final AD Determination (fully extended)
11/5/2026	ITC Final Injury Determination (un-extended)
3/1/2027		ITC Final Injury Determination (fully extended)
11/19/2026	AD and CVD Orders Published (un-extended)
3/8/2027		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 update, please contact Taft’s International Trade Practice.