On June 28, 2006, Ministry of Commerce of the People’s Republic of China issued Announcement No. 44 of the year, deciding to impose anti-dumping duty against imports of epichlorohydrin originated in Russia, South Korea, Japan and the U.S. for a period of five years starting from June 28, 2006; and the rate of anti-dumping duty of The Dow Chemical Company was 4.3%.
On June 27, 2011, the Ministry of Commerce issued Announcement No. 34 of the year, deciding to conduct expiry review investigation into the anti-dumping measures against imports of epichlorohydrin originated in Russia, South Korea, Japan and the U.S. On June 27, 2012, the Ministry of Commerce issued Announcement No. 32 of the year, deciding to continue the anti-dumping measures against imports of epichlorohydrin originated in Russia, South Korea, Japan and the U.S. for a period of five years since June 28, 2012.

On June 16, 2015, U.S. Blue Cube Operations LLC filed a petition to the Ministry of Commerce, requesting to succeed the anti-dumping duty rate of The Dow Chemical Company applicable in the anti-dumping measures against epichlorohydrin, and submitted relevant evidence such as the merger and acquisition agreement, the board resolutions, the operation and management, the production equipment, supply relation and the lists of customers. On June 16, 2015, the Ministry of Commerce notified the industry of epichlorohydrin in China of the above-mentioned matters, which did not raise any objection within a specified time.

Upon examination, the existing evidentiary materials indicate that Blue Cube Operations LLC is a subsidiary of The Dow Chemical Company, and all the businesses concerning the epichlorohydrin originally operated by The Dow Chemical Company were stripped to Blue Cube Operations LLC in May 2015 for the purpose of merger and acquisition arrangements. After the merger and acquisition, except that the company name changed, the production equipment, production capacity and volume, supply relation, and client base of Blue Cube Operations in connection with the business of epichlorohydrin did not have any substantial changes.

Therefore, the Ministry of Commerce decides that:

1. Blue Cube Operations LLC succeeds to applicable anti-dumping duty rate of 4.3% of The Dow Chemical Company on epichlorohydrin and its other rights and obligations.

2. Epichlorohydrin products to be exported to China in the name of The Dow Chemical Company shall be subject to the anti-dumping duty at a rate applicable to other U.S. companies in the anti-dumping measures against epichlorohydrin, i.e., 71.5%.

This Announcement shall take effect as of September 1, 2015.

Ministry of Commerce of the People’s Republic of China
August 17, 2015

Translated by Hou Zuowei