The United States is the largest market for citric acid products and the country with the most stringent trade defense measures. Since 2000, at the request of the U.S. domestic citric acid industry, the U.S. Department of Commerce has initiated anti-dumping and/or countervailing duty investigations against China, Canada, Europe, Colombia, Thailand, and other countries. Thailand is an important citric acid consumer market in Asia and a key base for some Chinese citric acid enterprises in their global strategic presence. Since local Thai citric acid companies do not export to the United States, Chinese citric acid enterprises represented by Dr. Jian GUAN’s team thus came under scrutiny.

In 2019, Dr. Jian GUAN successfully secured a ruling for the client in the first-instance court that terminated the countervailing duty investigation and imposed a relatively low anti-dumping duty rate. The client subsequently retained Dr. Jian GUAN’s team to provide legal services for the administrative reviews from 2020 to 2025.

The challenges of this case include:

First, throughout the investigation and administrative review process, multiple rounds of supplemental questionnaires and legal deliberations took place, with the legal teams of the petitioner and interested parties engaging in repeated rounds of rebuttals over the factual and legal issues of the case.

Second, the petitioner was well-prepared, distorting in its application and subsequent arguments the relationship between the Chinese enterprises and the Thai government, exaggerating Thailand’s investment promotion policies, and even inflaming the situation by conflating the Chinese background of the enterprises.

In response to the petitioner’s false allegations, Dr. Jian GUAN assisted the Chinese enterprises in responding swiftly, organizing detailed rebuttals in a timely manner to bring the investigation back on track. At the same time, he actively asserted their rights, for example, in the anti-dumping proceeding, proactively explaining the difference in trade levels between domestic sales and export sales, and guiding the investigating authority to fully consider the operational differences of the enterprises in order to achieve a meaningful comparison.

The U.S. trade remedy investigation on Thai citric acid began in 2019. Since then, the United States has conducted multiple rounds of anti-dumping administrative reviews on citric acid products from Thailand. Dr. Jian GUAN represented the Thai citric acid industry in the original proceeding and the administrative reviews, not only helping the client secure a relatively low anti-dumping duty rate and the termination of the countervailing duty investigation in the original case, but also obtaining “zero duty rates” for six consecutive years from 2020 to 2025, thereby maximizing the client’s interests.

This case was extremely challenging to handle. Throughout the investigation and administrative review process, after multiple rounds of supplemental questionnaires and numerous legal reviews, a low duty rate was ultimately achieved in the original investigation and zero duty rates in the administrative reviews. This case stands as a typical success story in the industry. As early as 2022, while this case was being handled, it was honored with the Deal of the Year Award by the internationally renowned legal magazine China Business Law Journal. It was also selected as a Typical Case of “Belt and Road” Dispute Resolution Legal Services by Rule of Law Daily in 2022. In 2025, the case was awarded first prize among the 100 Outstanding Cases in Foreign-Related Rule of Law.

Note: This case belongs to the case portfolio of the legal team mentioned, not to Grandwin Law Firm.