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High Purity Dissolving Pulp: New AD/CVD Investigations Deadlines & Scope

The Commerce Department issued notices in the Federal Register on its recently initiated antidumping duty investigations on high purity dissolving pulp from Brazil (A-351-866) and Norway (A-403-808), as well as its countervailing duty investigation on high purity dissolving pulp from Brazil (C-351-867). The CVD investigation covers entries for calendar year 2024. The AD investigations cover entries July 1, 2024, through June 30, 2025.

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The International Trade Commission will conduct a concurrent investigation to determine whether imports of dumped and illegally subsidized high purity dissolving pulp are injuring U.S. industry. If the ITC finds no injury in its preliminary injury determination, due Sept. 26, the investigations will immediately end. If Commerce finds dumping or illegal subsidization in the preliminary determinations of these investigations, due in November for CVD and January for AD, it will set AD and/or CVD cash deposit requirements for imports of merchandise subject to the investigation. If both Commerce and the ITC reach affirmative final determinations, Commerce will issue AD and/or CVD orders making duties permanent and beginning a process of annual administrative reviews to set final assessments of AD/CVD on importers and potentially change AD/CVD cash deposit rates.

AD/CVD Respondent Selection

For its AD investigations on Brazil and Norway, as well as its CVD investigation on Brazil, Commerce has identified only one company from each country that produces or exports high purity dissolving pulp, and will select those companies as the respondents. The companies are Bracell Bahia Specialty Celulose SA for the AD/CVD investigations on Brazil, and Borregaard ASA for the AD investigation on Norway. Comments on the selection of these companies are due Sept. 11.

Scope of the AD/CVD Investigations

"The merchandise subject to these investigations is high purity dissolving pulp, 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. High purity dissolving pulp 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). High purity dissolving pulp may be produced from a chemical pulping process including without limitation a kraft (sulfate) pulping and/or sulfite pulping process.

"High purity dissolving pulp 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 investigations if performed in the subject country. The scope also includes high purity dissolving pulp that is commingled or blended with high purity dissolving pulp from sources not subject to these investigations. Only the subject component of such commingled or blended products is covered by the scope of these investigations.

"Excluded from the scope is high purity dissolving pulp with an intrinsic viscosity under 455 milliliters per gram (mL/g), as measured by ISO 5351:2010.

"Also excluded from the scope is cotton linters pulp that consists of at least 90 percent by weight, on an oven-dried basis, of cotton linters fibers.

"High purity dissolving pulp products are classified under subheadings 4702.00.0020 and 4702.00.0040, of the Harmonized Tariff Schedule of the United States (HTSUS). High purity dissolving pulp products may also enter under subheadings 4706.30.0000 or 4706.92.0100. Reference to the HTSUS classifications is provided for convenience and customs purposes, and the written description of the merchandise under investigation is dispositive."

Comments on the scope of the orders are due by 5 p.m. EDT on Sept. 22.

The Commerce Department fact sheet on the initiation of these investigations is (here). See 2509040016 for a summary of the petition requesting these investigations.