C-570-169: countervailing duty order on Alkyl Phosphate Esters from China
C-570-169 is the US Department of Commerce case number for the countervailing duty order on Alkyl Phosphate Esters from China, in force since 11 June 2025. Goods in scope entered under this case carry a countervailing cash deposit at entry on top of the normal duty.
Reviewed September 2026 against the ITA order list and the Federal Register.
Case numberC-570-169Countervailing duty (CVD)
Companion antidumping duty caseA-570-168 antidumping →the same product from the same country under the other duty law; both deposits apply to one entry
ProductAlkyl Phosphate Esters ITA commodity group: Chemicals and Allied Industries
Next sunset reviewMay 2030 month Commerce is due to initiate the five-year review
Rates in the order notice
91.07%All-others subsidy rate
269.02%China-wide Entity ratecash deposit rate 243.09%marked in the notice as based on facts available with adverse inferences
As printed in the order notice (90 FR 24579, 11 June 2025). The deposit an entry pays today is the rate assigned to the exporter or producer on the invoice in the latest administrative review, which can be higher or lower than this; a company that has never been reviewed keeps the all-others rate. Check the current rate for your supplier in Commerce's ACCESS case record before pricing an order.
HTS numbers named in the scope
The subheadings the notice lists as the ones subject merchandise may enter under. They are given for convenience; the written scope is what decides whether goods are covered, and goods under other numbers can still be in scope.
Scope of the Orders
The products covered by these orders are alkyl phosphate esters,
which are halogenated and non-halogenated phosphorus-based esters
with a phosphorus content of at least 6.5 percent (per weight) and a
viscosity between 1 and 2000 mPa[middot]s (at 20-25 [deg]C).
Merchandise subject to these orders primarily includes tris (2-
chloroisopropyl) phosphate (TCPP), tris (1,3-dichloroisopropyl)
phosphate (TDCP), and triethyl phosphate (TEP)).
TCPP is also known as tris (1-chloro-2- propyl) phosphate, tris
(1-chloropropan-2-yl) phosphate, tris (monochloroisopropyl)
phosphate (TMCP), and tris (2-chloroisopropyl) phosphate (TCIP).
TCPP has the chemical formula
C<INF>9</INF>H<INF>18</INF>C<INF>l3</INF>O<INF>4</INF>P and the
Chemical Abstracts Service (CAS) Nos. 1244733-77-4 and 13674-84-5.
It may also be identified as CAS No. 6145-73-9.
TDCP is also known as tris (1,3-dichloroisopropyl) phosphate,
tris (1,3-dichloro-2-propyl) phosphate, chlorinated tris, tris {2-
chloro-1-(chloromethyl ethyl){time} phosphate, TDCPP, and TDCIPP.
TDCP has the chemical formula
C<INF>9</INF>H<INF>15</INF>C<INF>l6</INF>O<INF>4</INF>P and the CAS
No. 13674-87-8.
TEP is also known as phosphoric acid triethyl ester, phosphoric
ester, flame retardant TEP, tris(ethyl) phosphate,
triethoxyphosphine oxide, and ethyl phosphate (neutral). TEP has the
chemical formula (C<INF>2</INF>H<INF>5</INF>O)<INF>3</INF>PO and the
CAS No. …
Excerpt from 90 FR 24579. Scopes are amended by later scope rulings and circumvention findings; the notice list below has them.
What C-570-169 means when you import
Cash deposit at entry. For every entry of goods in scope, CBP collects an estimated countervailing duty cash deposit at the rate assigned to the exporter or producer on the entry, on top of the Column 1 duty and any Chapter 99 trade-remedy lines. Because a companion antidumping case exists, an entry of Alkyl Phosphate Esters from China carries both deposits. The same product from two plants in China can deposit at different rates, so ask the supplier which legal entity will appear as exporter and as producer on the invoice before you price the order.
Deposit now, final duty later. The deposit is not the final duty. The entry stays unliquidated until Commerce completes the administrative review for the period it was entered in, then CBP liquidates it at the rate that review sets, and bills or refunds the difference with interest. AD/CVD entries therefore stay open for years, and the importer of record carries the difference. Commerce must be asked for a review each anniversary month of the order; if nobody asks, entries liquidate at the deposit rate.
Reimbursement certificate. Before liquidation the importer files a certificate under 19 CFR 351.402(f)(2) stating whether the exporter has paid or reimbursed the antidumping duty. If it is not filed, Commerce may presume reimbursement and deduct the duty a second time in the margin calculation. Brokers file it with the entry summary; make sure yours does.
Entry reporting. The AD/CVD case number goes on the 7501 line alongside the HTS number, and any Chapter 99 lines the goods carry are reported in the order CBP prescribes; the tariff updates tracker carries the current Chapter 99 sequence and the actions behind it. Goods finished, cut or packaged in a third country stay in scope if the notice's written scope covers them, so a change of shipping origin is not a change of AD/CVD origin.
Estimating the stack. The tariff simulator returns the Column 1 rate and the Chapter 99 additional duties for an HTS number and origin; it does not add antidumping or countervailing deposits. Add the deposit at your supplier's current rate on top of what it shows. Airlift USA does not hold a US customs broker licence; entries on cargo we move are filed through our licensed broker network.
Case list: AD/CVD Orders and Suspension Agreements, International Trade Administration, Enforcement and Compliance — ITA dashboard, export of September 2026. Notices, rates and HTS numbers: Federal Register API v1. Both are US Government works in the public domain. This page is a reference, not legal or customs advice.
Importing alkyl phosphate esters from China under C-570-169?
Tell us the product, the exporter and producer named on the invoice, the load port, the US delivery point and the ready date. We come back with the ocean freight, the destination charges and how the entry is filed through our licensed broker network; the AD/CVD cash deposit itself is set by the rate on the entry, not by us.