New Antidumping Duty and Countervailing Duty Petitions on High Purity Dissolving Pulp From Brazil and Norway

At a Glance

• Rayonier Advanced Materials, Inc. and the United Steelworkers filed antidumping and countervailing duty petitions on high purity dissolving pulp from Brazil (AD & CVD) and Norway (AD only).
• Investigations related to these petitions could result in increased prices and/or decreased supply of high purity dissolving pulp.
• The U.S. Department of Commerce is expected to begin investigations on September 2, 2025.

On August 12, 2025, antidumping (AD) and countervailing duty (CVD) petitions were filed on high purity dissolving pulp from (HPDP) from Brazil (AD & CVD) and Norway (AD only). The petitions were filed by Rayonier Advanced Materials, Inc., and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC (USW) (collectively Petitioners). HPDP is used as a raw material in various applications from eyeglass frames, excipient in pharmaceutical products, and bulking agent in food, to cellulose film and filtration products. 

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

Scope

Please note that this section was not written by our authors but is taken verbatim from the petition.

The merchandise subject to this investigation is high purity dissolving pulp (“HPDP”), which is a dissolving pulp with an alpha cellulose percentage of 90 percent by weight or higher on an oven dry basis, as calculated by: alpha cellulose percentage = (100-S10) + 0.5*(S10-S18) where S10 and S18 values are determined by International Organization for Standardization (“ISO”) 692:1982, and having a brightness level of 90 percent or higher, as measured by ISO 2470-1:2016. HPDP may be derived from any virgin or recycled cellulose fiber source (including, but not limited to, those sourced from hardwoods, softwoods, woody crops, agricultural crops/byproducts/residue, and agricultural/industrial/other waste). HPDP may be produced from a chemical pulping process including without limitation a kraft (sulfate) pulping and/or sulfite pulping process.

HPDP can be shipped in any form, including, but not limited to, a liquid slurry or in any dried form such as flakes, powder, granules, pellets, shreds, rolls and sheets.

The scope includes merchandise matching the above description that has been finished, packaged, or otherwise processed in a third country, including but not limited to processes such as commingling, blending, diluting, repackaging, or any other process that would not otherwise remove the merchandise from the scope of the investigation if performed in the subject country.

Excluded from the scope are HPDP with an intrinsic viscosity under 455 milliliters per gram (“mL/g”), as measured by ISO 5351:2010.

HPDP products are classified under subheadings 4702.00.0020 and 4702.00.0040, of the Harmonized Tariff Schedule of the United States (“HTSUS”). References to the HTSUS classification are provided for convenience and customs purposes, and the written description of the merchandise under investigation is dispositive.

Estimated Dumping Margins

The Petitioners allege a dumping margin of 168.09% for imports from Brazil, and 226.88% for imports from Norway.

The Petitioners also allege subsidies with respect to imports from Brazil, although the petition does not quantify the alleged net subsidy margin. 

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):