The U.S. Department of Commerce has issued a final antidumping duty order covering specified multifunctional acrylate and methacrylate monomers and epoxy-acrylate oligomers from the Republic of Korea. The order follows affirmative final determinations by both Commerce and the International Trade Commission.

The order covers specified multifunctional acrylate and methacrylate monomers and epoxy-acrylate oligomers from South Korea. These are UV-curable raw materials used in:

• Radiation-curable coatings (wood, metal, plastic, paper)
• UV-curable inks and printing applications
• Adhesives and sealants
• Electronics and optical fiber coatings
• Dental materials
• 3D printing resins

Importers should verify the specific CAS numbers and HTS classifications of their Korean-origin products against the scope of the order. Products that fall within the scope but are not clearly identified may be subject to scope rulings from Commerce.

Unliquidated entries made on or after January 5, 2026 may be assessed antidumping duties, subject to the provisional-measures gap described in the order. Importers with unliquidated entries from this period should assess their potential duty exposure and consider whether to post additional bonds or cash deposits.

The ITC rejected critical circumstances findings in this investigation. As a result, entries made during the provisional-measures gap — between approximately October 7, 2025 and January 4, 2026 — are entitled to refunds of any cash deposits collected during that period. Importers who posted cash deposits on entries during this window should file for refunds through U.S. Customs and Border Protection.

For entries made on or after the publication date of the final order, importers must post cash deposits at the applicable antidumping duty rate at the time of entry. The cash deposit rate is subject to adjustment in annual administrative reviews.

Importers of UV-curable raw materials from South Korea should immediately:

1. Identify all Korean-origin acrylate monomers, methacrylate monomers, and epoxy-acrylate oligomers in their supply chains
2. Verify the producer and exporter of each product — the applicable duty rate depends on the specific producer/exporter combination
3. Confirm HTS classifications and CAS numbers against the scope of the order
4. Calculate potential duty exposure on unliquidated entries since January 5, 2026

Importers facing 65.72% or 155.42% duty rates should evaluate alternative sources for covered products, including:

• Domestic U.S. producers — the antidumping petition was filed by domestic producers, who are now the intended beneficiaries of the order
• Third-country sources — Taiwan, Japan, China, and European producers supply similar UV-curable raw materials, though some may be subject to separate trade remedy orders
• Product reformulation — in some applications, alternative chemistries may reduce dependence on covered Korean products

The significant difference between the Green Chemical rate (65.72%) and the Miwon/Kukdo rate (155.42%) creates strong incentives for importers to verify the identity of their Korean suppliers. Importers should obtain and retain documentation — including mill certificates, producer declarations, and shipping records — confirming the identity of the producer and exporter for each shipment.

Existing supply agreements with Korean producers or distributors of covered products should be reviewed for:

1. Duty allocation clauses — Who bears the cost of antidumping duties? Many supply agreements are silent on this point or allocate duties to the buyer by default.
2. Price adjustment mechanisms — Does the contract permit price adjustments to reflect changes in duty rates?
3. Force majeure or material adverse change provisions — Does the imposition of antidumping duties trigger any contractual rights?
4. Termination rights — Does the buyer have the right to terminate if duties make the product commercially unviable?

Manufacturers and distributors who purchase covered Korean products and incorporate them into downstream products should review their customer contracts for:

1. Cost pass-through provisions — Can increased input costs be passed through to customers?
2. Price escalation clauses — Do contracts include mechanisms for adjusting prices to reflect raw material cost increases?
3. Delivery and specification obligations — If the manufacturer switches to a non-Korean supplier, does the customer contract require approval of alternative sources?

Supply agreements should include provisions requiring Korean suppliers to:

• Cooperate with Commerce in any administrative review of the antidumping order
• Provide accurate cost and pricing information to Commerce
• Notify the importer of any change in producer or exporter identity
• Indemnify the importer for duties assessed as a result of the supplier's failure to cooperate with Commerce

Antidumping duty orders are subject to annual administrative reviews by Commerce, which can result in changes to the duty rates for individual producers and exporters. Key points:

• Any interested party — including importers — may request an administrative review for a given period
• If no review is requested, the cash deposit rate remains in effect
• Duty rates established in administrative reviews apply retroactively to entries made during the review period
• Importers should monitor Commerce's Federal Register notices for annual review initiation notices and consider whether to request reviews for their specific suppliers

Turkish companies that import UV-curable coatings, inks, adhesives, or other products containing covered Korean monomers or oligomers — either directly or as components of finished goods — should assess their exposure to the antidumping order. Key considerations:

• Downstream products: The antidumping order covers the monomers and oligomers themselves, not finished products containing them. However, if a Turkish company imports Korean-origin monomers into the United States, the order applies directly.
• Third-country processing: If Korean monomers are processed in a third country before importation into the United States, the country of origin determination depends on whether the processing constitutes a substantial transformation. This is a fact-specific analysis that should be reviewed with customs counsel.
• Supply chain documentation: Turkish companies should maintain documentation of the origin of UV-curable raw materials in their supply chains to support country-of-origin determinations and potential scope exclusion requests.

This article is based on publicly available Commerce Department and Federal Register materials. It does not constitute legal advice. Importers with specific questions about antidumping duty liability or scope determinations should consult qualified trade counsel.