On January 16th, 2026, the publication of SECEX Ordinance nº 2/2026, initiated an anti-dumping investigation on Brazilian imports of phenolic resins originating from China. The product is usually classified under subheadings 3909.40.11, 3909.40.19, 3909.40.91 and 3909.40.99 of the Mercosur Common Nomenclature (NCM).
The opening of the investigation was motivated by a petition filed on April 29th, 2025, by ASK Crios Produtos Químicos Ltda (“ASK”). After a preliminary analysis, the Foreign Trade Secretariat (SECEX), through the Department of Trade Remedies (DECOM), found sufficient evidence of dumping, injury to the domestic industry, and a causal link between them.
The main information regarding the investigation is summarized below:
- Petitioner: ASK.
- Origin: China.
- Period of investigation:
Dumping: January 2024 to December 2024; and
Injury: January 2020 to December 2024.
- Product under investigation:
Classification: usually classified in subheadings 3909.40.11, 3909.40.19, 3909.40.91 and 3909.40.99 of the NCM; and
Description: Phenolic resins, in solid form, including resins ground into powder, flakes (flakers), scales, pellets, crushed materials, among others, whether modified or not, produced from phenol and formaldehyde or paraformaldehyde, with or without the use of a catalyst, and with or without a curing agent. The phenolic resin subject to the investigation may contain a curing agent, among the most common of which is hexamethylenetetramine. The phenolic resin may also be modified or unmodified with cashew nutshell oil and/or nitrile rubber and/or epoxy resin, as well as with other types of modifications.
- Dumping margins for initiation purposes:
China: It was considered that market economy conditions do not prevail in the phenolic resins production sector in China. The normal value was determined based on the price of the like product in a third market economy country (United States of America).
Absolute dumping margin: US$ 1,667.24/t; and
Relative dumping margin: not available.
The participation of interested parties — including domestic producers, importers, exporters and governments of the countries under investigation — must necessarily be carried out through petitions in the Electronic Information System (SEI) of the Ministry of Development, Industry, Trade and Services (MDIC).
Questionnaires will be sent to the identified interested parties, who will have 30 days from the date of the notification to send their responses. Parties not initially identified at the beginning of the proceeding, but whoever considers themselves interested, may request to be admitted to the case by February 9th, 2026.
During the investigation, provisional antidumping measures may be applied if sufficient evidence of unfair trade practices is found and if it is understood that such measures are necessary to prevent injury to the domestic industry during the investigation.
The investigation must be completed within 10 months, extendable for up to 8 additional months. If the initial claims are confirmed, definitive antidumping measures may be applied for a period of up to 5 years.