AFI Association of Food Industries

AFI Serving the U.S. Food Import Sector

2022 NHPDA Report

Andy Sargeantson
Sunland Trading Inc.

The National Honey Packers and Dealers Association and the honey industry as whole are in the middle of ongoing antidumping and countervailing duties investigation against four countries – Argentina, Brazil, India and Vietnam.

Honey from these four countries makes up the vast majority of U.S. imports. Final Department of Commerce duties were announced in early April and in early May the International Trade Commission announced an affirmative determination in its final injury investigation. The ITC will publish its final report by the end of May and the first period of review ends in May 2023. In addition, the industry is facing an affirmative critical circumstances decision from both the DOC and ITC for Vietnamese honey. The NHPDA has put enormous time and resources into defending imported honey and will continue to do so.

Antidumping and countervailing duties add a layer of significant risk for importers. Duty deposits are held by CBP at time of entry based on the announced duty rate. The DOC then reviews entries during a defined period, taking almost a year to do so - and then can liquidate your entry at a revised rate that could be higher than the original deposit rate. It can be years until an importer knows its actual costs. The actual cost basis could be far higher than expected, potentially so high that paying the final duty would put their firm out of business. In order to mitgate this risk, importers and exporters work with lawyers and consultants to ensure that it is unlikely the DOC will make upward duty revisions.

As bad as the antidumping duty situation is, it could be a lot worse without an industry trade association in place. It’s unfortunate fellow AFI members in the Processed Foods Section are faced with a new antidumping filing – this one on preserved mushrooms. They, too, benefitted from having an association in place that facilitated the education and coordinated effort needed to address these filings.

As evident by what I wrote above, the coordinated effort is needed on an ongoing basis. There are ongoing steps in the process – some that repeat year after year and most or all with very tight deadlines.

Unfortunately, the antidumping duty process – whether in the U.S. or any other country – is meant to protect or give the impression of protecting domestic producers. That means outside factors that have a direct impact on the subject product often carry little or no weight when government agencies set the punitive duty rates.

Case in point: sunflower honey from Ukraine is a significant source of honey for both Europe and the United States. The summer 2022 sunflower crop is expected to be down by 50% or more and the same is expected for honey production. As a result of the duties imposed by the antidumping duty case, the war in Ukraine, a short U.S. domestic crop in 2021 and supply chain issues, honey prices paid by U.S. packers are at an all-time high.

This all comes at a time when consumers are faced with dramatic price increases across the board. Now they’ll be paying higher prices for honey and honey-containing products for years to come.

Association of Food Industries: Serving the U.S. Food Import Trade Since 1906
3301 Route 66, Ste. 205, Bldg. C • Neptune, NJ 07753
(732) 922-3008 • Fax: (732) 922-3590 • •