1. On 05/09/2025, Commerce issued a preliminary determination that acidic (non-neutralized) concentrations of 1-hydroxyethylidene-1, 1-disphosphonic acid, also referred to as hydroxyethylidenendiphosphonic acid, hydroxyethanediphosphonic acid, acetodiphosphonic acid, and etidronic acid, in solid or powdered form (acidic solid HEDP), are circumventing the antidumping and countervailing duty orders on 1-hydroxyethylidene-1, 1-disphosphonic acid (HEDP) from the People's Republic of China (China) (A-570-045; C-570-046). See 90 FR 19668. 2. Specifically, Commerce preliminarily determined that acidic solid HEDP is covered by the scope of the orders because the product covered by the inquiry is an article altered in form or appearance in minor respects. 3. This preliminary circumvention determination is applicable on a country-wide basis, regardless of foreign producer, exporter, or importer. 4. Suspension of Liquidation 4a. Continue to suspend liquidation of entries of acidic solid HEDP that are already subject to the suspension of liquidation under the antidumping and countervailing duty orders on HEDP from China in accordance with message 4362402, dated 12/27/2024. 4b. For all entries of acidic solid HEDP not already subject to the suspension of liquidation, CBP shall suspend liquidation, of shipments entered, or withdrawn from warehouse, for consumption on or after 12/19/2024. CBP shall require, for such entries, a cash deposit at the applicable rates in effect on the date of entry. 4c. Entries of products covered by subparagraphs 4a and 4b should not be liquidated until specific liquidation instructions are issued. Any entries which are set for liquidation must be unset immediately. 5. In accordance with 19 CFR 351.226(l)(5), this instruction does not affect or otherwise limit CBP's independent authority to take any additional action with respect to the suspension of liquidation or related measures. 6. If there are any questions by the importing public regarding this message, please contact the Call Center for the Office of AD/CVD Operations, Enforcement and Compliance, International Trade Administration, U.S. Department of Commerce, at (202) 482-0984. CBP ports should submit their inquiries through authorized CBP channels only. (This message was generated by E&C's Office of Policy: CV.) 7. There are no restrictions on the release of this information. Alexander Amdur