Petition Summary: Thermal Paper From Germany, Japan, Korea, And Spain

Husch Blackwell LLP

On October 7, 2020, Appvion Operations, Inc, (“Appvion”) and Domtar Corporation (“Domtar”) (“Petitioners”), filed a petition for the imposition of antidumping duties on thermal paper from Germany, Japan, Korea, and Spain.


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.



Appvion Operations, Inc.

825 E. Wisconsin Avenue

P.O. Box 359

Appleton, WI 54912-0359

Contact: Graeme Hodson

(920) 991-9841

Domtar Corporation

234 Kingsley Park Drive

Fort Mill, SC 29715

Contact: Curtis Correll

(803) 820-7500



Stephen J. Orava


1700 Pennsylvania Avenue N.W.

Suite 200

Washington, DC 20006

(202) 737-0500



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


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


Event Earliest Date
Petition Filed October 7, 2020
DOC Initiation October 27, 2020
ITC Preliminary Investigation:  
Questionnaires Due October 21, 2020
Request to appear at hearing October 26, 2020
Hearing October 28, 2020
Briefs November 2, 2020
ITC Vote November 23, 2020
DOC Investigation Schedule:  
DOC Preliminary Antidumping Determination March 16, 2021
DOC Final Antidumping Determination May 31, 2021
ITC Final Investigation:  
ITC Final AD Determination July 14, 2021



Germany: 39.99% – 56.75%

Japan: 104.66% – 113.91%

Korea: 48.42% – 49.98%

Spain: 30.76% – 39.41%%



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  2017 2018 2019 Jan – Jun 2019 2020
Quantity(Short Tons) 50,546 62,558 70,296 34,166 27,095
Value ($) 71,528,549 126,366,187 133,998,448 71,220,523 42,465,719
AUV ($/Short Tons) 1,415 2,020 1,906 2,085 1,567
Quantity(Short Tons) 64,043 72,369 64,996 34,698 31,457
Value ($) 106,212,512 143,036,154 134,579,423 75,606,784 58,149,214
AUV ($/Short Tons) 1,658 1,976 2,071 2,179 1,849
Quantity(Short Tons) 42,029 38,242 38,513 20,266 17,700
Value ($) 27,863,585 43,933,089 35,110,715 18,903,957 13,770,386
AUV ($/Short Tons) 663 1,149 912 933 778
Quantity(Short Tons) 3,107 3,698 15,198 10,989 8,879
Value ($) 13,636,706 15,901,351 30,158,693 19,554,804 15,520,936
AUV ($/Short Tons) 4,389 4,299 1,985 1,779 1,748
--> Scroll to see full table data

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Husch Blackwell LLP

Husch Blackwell LLP on:

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