Petition Summary: High Dissolving Pulp from Brazil and Norway

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On August 11, 2025, Rayonier Advanced Materials, Inc. (“RYAM”) and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO (“USW”) (collectively “Petitioners”), filed a petition for the imposition of antidumping duties on the U.S. imports of High Dissolving Pulp from Brazil and Norway and countervailing duties on U.S. imports from Brazil.

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from Brazil and Norway that is within the scope of this 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.

PETITIONERS

Rayonier Advanced Materials, Inc. 1301 Riverplace Blvd., Suite 2300 Jacksonville, Florida 32207 Website: https://ryam.com/ Contact: R. Colby Slaughter General Counsel Phone: 904-357-9154 Email: colby.slaughter@ryam.com United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO (“USW”) 1155 Connecticut Avenue NW, #500 Washington, DC 20001 Website: https://m.usw.org/ Contact: Roy Houseman Legislative Director Phone: 202‐288‐2573 Email: rhouseman@usw.org

COUNSEL FOR PETITIONERS

CASSIDY LEVY KENT (USA) LLP

2112 Pennsylvania Ave, Suite 300

Washington, DC 20037

Tel.: 202-567-2300

NAMED PRODUCERS/EXPORTERS

For a list of foreign producers/exporters alleged by Petitioners, please see Attachment I.

NAMED IMPORTERS

For a list of importers alleged by the Petitioner, please see Attachment II.

ESTIMATED SCHEDULE

Event Earliest Date
Petition Filed August 11, 2025
DOC Initiation August 31, 2025
   
ITC Preliminary Investigation:  
Questionnaires Due August 25, 2025
Request to appear at hearing                                      August 30, 2025
Hearing September 1, 2025
Briefs September 4, 2025
ITC Vote September 25, 2025
   
DOC Investigation Schedule:  
DOC Preliminary Antidumping Determination January 18, 2026
DOC Final Antidumping Determination April 3, 2026
DOC Preliminary Countervailing Determination November 4, 2025
DOC Final Countervailing Determination January 18, 2026
   
ITC Final Investigation:  
ITC Final AD Determination                  May 18, 2026
ITC Final CVD Determination               March 4, 2026

ALLEGED DUMPING MARGINS

Brazil:              142.96%

Norway:          226.88%

ALLEGED COUNTERVAILING DUTY MARGINS

Above de minimis

ALLEGED SUBSIDIES

For a list of alleged subsidies by the Petitioner, please see Attachment III.

IMPORTS OF SUBJECT MERCHANDISE

  2022 2023 2024 Q1-Q2 2024 Q1-Q2 2025
Brazil          
Quantity in Component Tons 230,795 198,455 218,344 108,484 111,800
Landed, Duty-Paid Value 2 14,997,738 184,839,969 214,047,804 106,323,942 113,998,500
$/Component Ton 932 931 980 980 1020
Norway          
Quantity in Component Tons 4,770 10,317 31,658 19,376 12,204
Landed, Duty-Paid Value 6,871,099 8,655,110 2 2,758,931 11,237,062 10,506,621
$/Component Ton 1,440 839 719 580 861

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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