October 08, 2020

New Antidumping Duty Petitions on Thermal Paper From Germany, Japan, Korea and Spain

On October 7, 2020, Appvion Operations, Inc. and Domtar Corporation (Petitioners) filed antidumping duty (AD) petitions on thermal paper from Germany, Japan, Korea and Spain.

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” For AD duties to be imposed, the U.S. government must determine not only that dumping is occurring, but also that there is “material injury” (or threat thereof) by reason of the dumped imports. Importers are liable for any potential AD duties imposed. In addition, these investigations could impact purchasers by increasing the prices and/or decreasing the supply of thermal paper.

Scope

Per the petitions:

The scope of these investigations covers thermal paper in the form of “jumbo rolls” and certain “converted rolls.” Jumbo rolls are defined as rolls with a nominal width of 4.5 inches or more, a nominal weight of 65 pounds or more, and a nominal diameter of 20 inches or more (“jumbo rolls”). All jumbo rolls are included in the scope regardless of the basis weight of the paper. Also included in the scope are “converted rolls” with a width of less than 4.5 inches, and with a basis weight of 70 grams per square meter (“gsm”) or less. The scope covers jumbo rolls and converted rolls of thermal paper with or without a base coat (typically made of clay and/or latex, and/or like materials) on one or both sides; with thermal active coating(s) (typically made of sensitizer, dye, and co-reactant, and/or like materials) on one or both sides; with or without a top coat (typically made of pigments, polyvinyl alcohol, and/or like materials).

The scope of these investigations covers imports of converted rolls from third countries that are manufactured from jumbo rolls produced in the subject countries.

The merchandise subject to these investigations may be classified in the Harmonized Tariff Schedule of the United States (“HTSUS”) under subheadings 4811.90.8030 for jumbo rolls and HTSUS 4811.90.9030 for converted rolls. Although HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

Estimated Margins

The Petitioners allege the following dumping margins:

  • Germany — 38.99% to 56.75%
  • Japan — 104.66% to 113.91%
  • Korea — 48.42% to 49.98%
  • Spain — 30.76% to 39.41%

Estimated Schedule of Investigations

The following is an estimated schedule of investigations by the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC):

  • October 7, 2020 — Petitions are filed.
  • October 27, 2020 — DOC initiates investigations.
  • October 28, 2020 — ITC staff conference (estimated).
  • November 23, 2020 — Deadline for ITC preliminary injury determination.
  • March 16, 2021 — Deadline for DOC preliminary AD determinations, if deadlines are NOT postponed.
  • May 5, 2021 — Deadline for DOC preliminary AD determinations, if deadlines are fully postponed.
  • September 17, 2021 — Deadline for DOC final AD determinations, if all deadlines are fully postponed.
  • November 1, 2021 — Deadline for ITC final injury determination, if all DOC deadlines are fully postponed.

For further information, contact Douglas J. Heffner, Richard P. Ferrin, or any other member of the Customs and International Trade Team.

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