If the Order Says China, Why Does Your Permanganate Ship From India?

On the first of October this desk wrote itself a line and moved on. Commerce had given advance notice that A-570-001 was due for its sixth five-year review in November, and November's notice would say the rest.

It published this morning.

Potassium permanganate from China, Commerce case A-570-001 and ITC investigation 731-TA-125, sixth review, applicable November 2. The lowest case number Commerce ever assigned to a Chinese product, in force since January 31, 1984, and the only chemical in a November cohort that is otherwise mobile access equipment and four flavours of polyester textured yarn.

Two clocks started with it. Fifteen days for a domestic producer to say it wants the order kept, and if none does, Commerce revokes it without further review.

Thirty days for everyone else to put something on the record.

"If the order lapses, what actually changes on the invoice?"

Less than you would think.

Forty-Two Years and One Rate

The order has been continued five times, and the ITC's own background section lists the effective dates in a row:

• First review, November 24, 1999
• Second, June 21, 2005
• Third, October 25, 2010
• Fourth, March 18, 2016
• Fifth, December 9, 2021

The first one took fifteen years to arrive because A-570-001 is a transition order, an order already in force on January 1, 1995, so its sunset clock only started in November 1998. Commerce called that first review "extraordinarily complicated" on exactly that ground, then ran it expedited in 120 days, because no respondent filed anything.

The same thing happened in 2021. Carus LLC, "a domestic producer of potassium permanganate and the petitioner in the underlying investigation", filed its notice of intent on February 12 and its substantive response on March 3. Commerce "received no substantive responses from any other interested party", nor was a hearing requested, so it expedited again and found the magnitude of margins likely to prevail at up to 128.94 percent.

That number is the thing worth looking at. It is the PRC-wide entity rate, it first attached in the final results Commerce published on April 29, 1991, and the original 1984 order's "all other" rate was 39.63 percent.

So the wall the order puts up today is a thirty-five-year-old figure that Commerce has carried forward through four straight reviews without recalculating it.

And the arithmetic underneath it is older than that sounds. The last completed administrative review of A-570-001 covered calendar 2015, with final results published June 20, 2017.

One respondent appeared, Pacific Accelerator Limited, and after briefs, a hearing and an adjustment to the drum factor of production, it came out at $0.00 per kilogram.

Reviews were requested and then withdrawn for the 2022 and 2023 periods, both rescinded. Nobody asked for 2024 or 2025 at all.