Univar USA: The Supplier That Made No Saccharin
Univar USA Inc. agreed to pay $62.5 million over alleged antidumping duty evasion involving a Taiwanese supplier that, according to the Department of Justice, made no saccharin at all. Univar had sent an employee to tour a factory. The government’s case reached past that visit to a harder question: who made the saccharin Univar actually bought?
The Univar USA Saccharin Customs Settlement
The Univar USA saccharin customs settlement, announced April 9, 2019, resolved a customs case brought by the United States in the Court of International Trade. It concerned 36 entries from 2007 through 2012. Univar declared Taiwanese origin, and the government alleged that the saccharin came from China by transshipment through Taiwan.
Saccharin is a sweetener used in foods and beverages, among other products. The court’s account of Univar’s sourcing describes a company looking for non-Chinese manufacturers after an antidumping order made its Chinese supply more expensive. The seller, the claimed manufacturer and the factory Univar visited became different parts of the government’s case.
The Supplier Behind the Taiwanese Origin Claim
Univar’s supplier paperwork identified Lung Huang Trading Company as the seller and Long Hwang Chemical as the manufacturer. The court’s opinion describes the registration Univar completed for them in January 2004, using the same Taiwanese address for both.
In April 2004, a Univar employee visited Taiwan to inspect the new supplier. According to the opinion, Lung Huang Trading’s president told the employee he owned a factory that made saccharin. The factory they toured belonged to High Trans Corporation.
The opinion also describes saccharin production at High Trans. It recounts a government chemist’s April 2010 visit, during which he examined production information and raw-material purchase documents, took a sample and concluded that saccharin was being manufactured there. Univar argued that High Trans made the saccharin in Taiwan and sold it through the supplier to Univar. The government challenged whether the saccharin in the disputed entries came from that plant.
The supplier companies’ registered address raised a different question. A government agent reported visiting the address in June 2010 and finding a residential apartment building, with no manufacturing, industrial activity or distribution visible there or nearby. Univar disputed whether the differently spelled street addresses in the government’s evidence identified the same location. The apartment building was the address investigators associated with the supplier companies. It was separate from the factory Univar’s employee had toured.
A Kosher Certificate Without Access to the Plant
The opinion describes repeated difficulties inspecting the supplier’s claimed plant even while its saccharin continued to carry kosher certification. An Orthodox Union rabbi inspected a plant in 2005, and certification followed. Another rabbi subsequently flew to Taiwan three times to inspect the factory. He testified that he was told he could not inspect the plant, with a different explanation each time: a shutdown, a dangerous flood, then dangerous construction.
According to the opinion, the Orthodox Union could not inspect the supplier’s factory between 2007 and 2012, while continuously certifying its saccharin from 2005 to 2013. Univar’s sourcing director knew about the access problem. For a buyer relying on the supplier’s manufacturing story, the certificate and the ability to see production were telling different stories.
Customers Were Already Asking About Chinese Saccharin
The emails recounted in the court’s opinion show that questions about Chinese origin reached Univar through the trade. In August 2004, domestic producer PMC Specialties Group told Univar it believed the supplier was importing and relabeling Chinese saccharin. A Univar employee asked for proof that could “kill this question.” The response relayed the supplier’s position that the employee’s factory visit was good proof.
The following month, a PepsiCo employee asked Univar:
The Taiwan plant doesn’t make the base saccharin molecule does it? I thought I heard the plant receives the base product from China.
A PepsiCo employee’s September 2004 email, quoted in the Court of International Trade’s opinion
The question went straight to the production process: what arrived at the Taiwanese plant, and what did the plant do to it? In October 2004, the Univar employee asked the supplier to confirm the origin of the original saccharin molecule. He wrote that the “best” answer would come from the supplier’s Japanese source and say that no Chinese raw materials were used to make its acid saccharin. The supplier later replied that it sometimes imported small quantities of saccharin acid from Japan and processed them into sodium saccharin.
Taiwan’s Customs Tables Followed the Supplier’s Purchases
The government’s evidence included Taiwan Customs tables showing both incoming Chinese saccharin and outgoing shipments to Univar. The tables recorded Long Hwang Chemical importing 20 shipments of sodium saccharin from China into Taiwan from 2009 through 2011, and Lung Huang Trading exporting 16 shipments to the United States from 2009 through 2012, with Univar as the importer. The government alleged that the saccharin imported into Taiwan was the same saccharin exported to Univar.
The tables gave the parties more to compare than ports: declaration dates, buyers and sellers, product descriptions, quantities and weights. Univar contested the shipment matches, including the mesh sizes, which describe particle size. The opinion discusses differences between the sizes recorded on imports and exports, alongside customer complaints about mislabeled saccharin that could help explain those differences. The dispute reached the physical specification of what Univar bought. Someone familiar with the product could contribute far more than a shipping route.
Why the Claimed Origin Mattered to the Price
Chinese saccharin carried an antidumping duty that made the claimed manufacturing country central to the cost of these imports. ICE’s announcement explains that the duty responded to injury to the domestic saccharin industry from Chinese dumping.
The antidumping duty on Chinese saccharin described in the Univar settlement announcement.
U.S. Immigration and Customs Enforcement, Univar settlement announcement, April 9, 2019
The government alleged approximately $36 million in unpaid duties. Its settlement announcement puts the government’s demand for those duties and customs penalties together at $84 million. In April 2019, ICE called the agreement the largest recovery under the customs penalty law reached in the Court of International Trade.
The alleged duty evasion cheated the American industry the order protected, importers that paid the duty, and taxpayers owed the revenue. The importer paying the full duty has to compete while carrying a cost the evader avoided.
An extra stop can make commercial sense when the duty avoided is large enough. Measuring Tariff Evasion and Smuggling, published in NBER Reporter Online by the National Bureau of Economic Research in 2009, reported that a larger share of high-tariff goods entering China traveled through Hong Kong, even though that route offered no preferential tax treatment. The article interpreted the pattern as evidence of tariff-evasion motives. In Univar, the government’s allegation was a different route with the same economic attraction: a change in claimed origin that removed a substantial duty from the price.
How to Prove Country of Origin?
The production and purchase records trace the goods to their maker, shipping records follow their movement, and customs entries show the origin and duty treatment declared. Connecting those accounts tests whether the claimed manufacturer supplied the goods attributed to it.
A buyer deals with the seller, a freight forwarder arranges the shipment, and a customs broker handles the entry. Their documents describe different parts of the transaction. U.S. Customs and Border Protection’s Reasonable Care guidance asks whether importers know where and how their goods were made, whether someone knowledgeable reviewed the customs documents, and whether outside advisers received the full transaction facts. In Univar, the opinion describes origin certificates for every disputed entry. The government still questioned the manufacturing account behind them.
The International Monetary Fund’s 2022 book Customs Matters: Strengthening Customs Administration in a Changing World describes how transshipment and processing at trading hubs can make cargo harder to trace. Hubs may handle cleaning, packaging and labeling while information about onward movements is harder for customs authorities to obtain. An employee who knows what actually happens to the product at that stop can connect the shipping account to the manufacturing account.
Ceratizit’s Claimed Taiwanese Production
In Ceratizit‘s case, the whistleblower alleged that Chinese tungsten carbide rods traveled through Taiwan and entered the United States with false Taiwanese origin declarations. The complaint alleged that CB-Ceratizit lacked sufficient manufacturing capacity in Taiwan for the volume of rods entering the United States. It also alleged that Taiwan lacked enough raw materials to produce that volume and that the necessary materials had not been imported. The whistleblower alleged that company representatives had told customers a different story from the one given to Customs:
Moreover, representatives of Ceratizit USA or its affiliates have admitted, in conversations with customers, that the rods are not actually manufactured in Taiwan.
Allegation in the whistleblower’s complaint, United States ex rel. Mark Alan Stover v. Ceratizit USA, Inc., paragraph 23
The complaint describes the whistleblower as an experienced participant in the metalworking-products industry. That is the value of knowing the trade: understanding the capacity a product requires, the material it consumes and what sellers tell customers about its source. The IMF book also identifies domestic producers and distributors, including competitors and whistleblowers, as sources of information about irregular market activity. A purchasing conversation can matter alongside a shipping record.
Ceratizit later agreed to a $54.4 million civil settlement covering origin, classification and marking allegations, as described in the Justice Department’s December 18, 2025 announcement. The claimed Taiwanese production was one part of that case.
What Is the Difference Between Negligence and Fraud?
The Univar government case alleged gross negligence or negligence in failing to establish what the supplier actually did. A False Claims Act customs fraud case turns on knowing duty evasion, which can include deliberately ignoring or recklessly disregarding the truth. The important connection is between the false origin and what the importer knew.
Someone inside an importer may know who chose the origin, approved the declarations or responded when the manufacturing story was questioned. We examine that account with you, including the inquiries, replies and filing instructions, to assess the case those decisions can support.
How Much Is a Whistleblower Claim Worth?
A whistleblower case under the False Claims Act can pay a customs fraud whistleblower reward of 15% to 30% of what the government recovers. Ceratizit’s agreement provided for a $9.75 million whistleblower reward.
Univar’s settlement resolved the government’s own customs-penalty case. It was not a whistleblower case. For someone who recognizes the same sourcing contradiction in another business, the opportunity is to bring the manufacturing story and the origin decisions to us.
Sources
- Department of Justice: Univar USA settlement announcement, April 9, 2019
- Court of International Trade: Univar public opinion on the disputed origin evidence, November 13, 2018
- U.S. Immigration and Customs Enforcement: Univar USA settlement announcement, April 9, 2019
- U.S. Customs and Border Protection: Reasonable Care, September 2017
- U.S. District Court for the Eastern District of Michigan: Ceratizit whistleblower complaint, September 28, 2022
- Department of Justice: Ceratizit settlement agreement, announced December 18, 2025
Bring the Real Manufacturing Story to Light
If you buy chemicals, arrange their imports or compete with a supplier whose manufacturing story does not add up, speak with our whistleblower experts about who really made the goods. We connect your knowledge of the trade with the evidence of unpaid duties, build the case alongside you and bring in customs fraud whistleblower lawyers who understand origin disputes. We stay your partners from that first account through the outcome.
