Is Your B-Side Twenty Percent Esters?
Commerce opened two more circumvention inquiries on the alkyl phosphate ester orders this morning, and three of the four now open reach past the molecule into finished spray-foam systems. Also on the file: a court pulls nitrogen-15 back out of the ammonium sulfate orders, Chemours gets its India case, and chemicals is one of only two industries the ISM has contracting.
The scope of the alkyl phosphate ester orders covers blends "where the alkyl phosphate esters account for 20 percent or more of the blend by weight."
Read that line as a formulator and you have already found the problem.
Commerce published two more circumvention initiations against those orders this morning, and both of them are aimed at spray foam rather than at the chemical.
"How far past the molecule can an order on one chemical actually reach?"
Four separate proceedings on one pair of orders in forty days, and three of them are pointed at the B side of a two-part system (chart below).

Here is the file.
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