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 |
CONTACT US For more information concerning this petition and how it may affect your business, please contact Nithya Nagarajan or Stephen Brophy.