Capacity Ledger

One Letter Separated Melamine From Violet 23

Commerce files final results tomorrow assessing 2.81 percent on 2023 entries of carbazole violet 23, an order it revoked in August because nobody answered the sunset notice. The melamine reviews opened the same day in June and are heading the other way. Also on the file: BCP moved its own choline deadline to November 23, the tank car petition bought twenty more days, and California logged nothing at all.


December 29, 2004 put three duty orders on one purple pigment.

Two of them covered India, one covered China, and they held for twenty-one and a half years.

All three died on August 7 because nobody wrote back.

"What is an order worth once the last domestic producer stops answering the mail?"

Friday's filings produced no US closure and no force majeure in writing. They produced a natural experiment instead.

The Review Outlived the Order

Commerce filed the final results of the 2023 countervailing duty review on carbazole violet 23 from India on Friday morning, for publication tomorrow. Case C-533-839, one respondent, Navpad Pigments Private Limited, at 2.81 percent ad valorem.

The order those duties enforce no longer exists.

Commerce revoked it on August 7, retroactive to June 15, under section 751(c)(3)(A), which gives the agency no discretion: if no domestic interested party responds to the sunset notice, it "shall issue a final determination... revoking the order."

So the assessment lands 80 days after the revocation published and 133 days after it took effect. The review itself ran 637 days from initiation to final (chart below).

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