Trade news
Certain Choline Salts From China: Postponement of Preliminary Determination
Commerce pushed its preliminary dumping decision on choline salts from China to January 20, 2027, in the case that could bring new choline tariffs. The subsidy decision comes first: it is due by November 23, 2026, and could start cash deposits on Chinese choline chloride and other salts.
Choline tariffs on China: the key numbers
BCP Ingredients, a US producer of choline salts, filed antidumping and countervailing duty petitions on June 24, 2026.
November 23, 2026: subsidy decision due
Commerce postponed its preliminary countervailing duty decision to this date in September. An affirmative finding would start subsidy deposits.
January 20, 2027: dumping decision due
Commerce delayed the preliminary antidumping decision by 50 days, from December 1, 2026. It called the case extraordinarily complicated.
73.39% to 313.82%: alleged dumping margins
These are the petitioner's estimates, which vary with the comparison country Commerce uses. They are not duty rates; Commerce will calculate its own.
92 Chinese companies named
The petition listed 92 Chinese producers and exporters. Commerce is examining Shandong FY Feed Technology and Zhengzhou Longgu Trading in detail.
Countervailing duty: a duty that offsets subsidies a foreign government gives its producers. An antidumping duty offsets sales below normal value.
Which choline salts are covered: HTS 2923.10.0000
The case covers choline salts in all forms and purities that can deliver the nutrient choline, made from trimethylamine and ethylene oxide reacted in China.
Named salts: choline chloride, choline bitartrate and choline dihydrogen citrate, in liquid, crystal, dried or encapsulated form.
Blends: products with carriers, anti-caking agents or coatings are covered in full if choline salt is at least 30% by weight.
Third-country processing: Chinese choline salt refined, dried, encapsulated or blended in another country stays covered.
Excluded: choline hydroxide, choline salicylate and products already under the 2,4-D duty orders on China and India.
HTS numbers: mainly 2923.10.0000. Dried choline chloride may also enter under 2309.90 animal feed subheadings or 3824.99.9397.
The written scope, not the HTS number, decides coverage. Check it against your product's chemistry and choline content.
Why the choline salts case matters
Choline chloride is widely used in animal feed, and choline bitartrate and citrate are common supplement ingredients. Importers of both could face deposits.
The ITC has already found a reasonable indication that Chinese imports injure the US industry. That let Commerce's investigations continue.
No new duties apply yet. Deposits would start only after an affirmative preliminary decision from Commerce.
What comes next for choline tariffs
The subsidy decision is due by November 23, 2026. If it is affirmative, CBP would collect deposits on entries from its publication date.
The dumping decision follows by January 20, 2027. The final dumping decision is due 75 days later, about April 5, 2027 (an estimate), unless postponed.
The ITC then makes its final injury vote. Duty orders issue only if both agencies' final decisions are affirmative.
Key dates
June 24, 2026: petitions filed. BCP Ingredients asks for antidumping and countervailing duties on Chinese choline salts.
July 14, 2026: investigations start. Commerce initiates both cases.
August 13, 2026: ITC preliminary yes. The ITC finds a reasonable indication of injury.
November 23, 2026: subsidy decision due. Commerce's preliminary countervailing duty decision.
January 20, 2027: dumping decision due. Commerce's postponed preliminary antidumping decision.
About April 5, 2027: final dumping decision. 75 days after the preliminary decision (an estimate).
How to prepare for choline tariffs
Check the chemistry. Confirm whether you import choline chloride, bitartrate, citrate or an excluded salt.
Check the choline content. Blends and coated products are covered in full at 30% or more choline salt by weight.
Trace the reaction step. Find where trimethylamine and ethylene oxide were reacted, even if the salt was finished elsewhere.
Check every HTS number. Look beyond 2923.10.0000 to the 2309.90 feed lines and 3824.99.9397.
Budget for deposits. Plan for subsidy deposits after November 23 if Commerce's decision is affirmative.
Frequently asked questions
What is choline chloride?
It is a choline salt that comes as a colorless liquid solution or a dried form. It is one of the main products named in the case.
Are there choline tariffs on China now?
Not from this case yet. Deposits would start only after an affirmative preliminary decision, the first due by November 23, 2026.
Does the case cover choline supplements?
It covers choline bitartrate and citrate, common supplement ingredients, including coated forms at 30% or more choline salt by weight. Check the scope for finished products.
What is countervailing duty?
It is a duty that offsets subsidies a foreign government gives its exporters. Commerce sets the rate and CBP collects it at entry.
This article is informational and is not legal or customs advice.