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Petition for the Imposition of Antidumping Duties on Thermal Paper from Germany, Japan, Korea and Spain

Case Summary

I.  Type of Action: Antidumping Duty (“AD”): Thermal Paper from Germany, Japan, Korea and Spain

II.  Product:

Thermal paper is a paper coated with chemicals that react to form images when exposed to heat. Thermal paper can be used in special printers to create an image without ribbons or other consumables (other than the paper itself). When imaging, the thermal paper containing the dye is passed between the thermal print head and the platen roll in the printer. The thermal head consists of tiny heating elements lying side-by-side across the width of the paper. As the paper passes under the head, the computer instructs certain heater elements to heat up. Where the heat is in contact with the paper, the dye is activated to produce an image. As the paper steps forward, heater elements heat up and cool down each time, creating a colored or black microdot on the paper. The arrangement of elements and paper movement create flexible graphic images on the thermal paper.

Thermal paper comes in a variety of basis weights measured in grams per square meter (“g/m2” or “gsm”) and in a variety of calipers (thicknesses). It may or may not be top-coated. It does not have an adhesive backing.

Thermal paper is used to make point-of-sale (“POS”) products, such as ATM receipts, coupons, credit card receipts, gas pump receipts, kiosk receipts/output, parking receipts, POS receipts, portable printer receipts, prescription receipts, and retail receipts. Thermal paper used in POS applications tends to be in basis weight ranges of 44 to 75 gsm.

Thermal paper is also used to produce thermal labels. Thermal label paper is generally sold to laminators who apply a self-adhesive material to the back side of the thermal paper to create a sandwich of face stock, liner, and adhesive. Laminators are sometimes referred to as pressure-sensitive adhesive (or “PSA”) coaters. Thermal labels are used in a variety of end uses including (but not limited to) address labels, distribution labels, product labels, pharmaceuticals warehouse labels, and deli and bakery labels. Thermal label paper is typically sold in basis ranges of 70 to 85 gsm. Thermal labels used in high moisture environments, such as wristbands and parking tickets, are typically printed on plastic film rather than paper. Thermal film is not thermal paper and is not included in the scope of these investigations.

Thermal paper is also used to produce a broad variety of tickets and tags. For example, tickets for lotteries, casino coinless slot machines, sports betting, parking violations, movie theaters, amusement parks, and ski lifts all use thermal paper. Thermal paper is used to make airline tickets/boarding passes, baggage tags, and retail hang tags. It is also used in a number of medical/healthcare applications, including pharmacy labels, test tube labels, medical charts/records, and prescriptions. Thermal paper used in ticket and tag applications is typically sold in basis ranges of 80 to 220 gsm.

III.  HTS classifications: HTSUS 4811.90.8030 for jumbo rolls and HTSUS 4811.90.9030 for converted rolls.

IV.  Date of Filing: October 8, 2020

V.  Petitioners: Appvion Operations, Inc. and Domtar Corporation

VI.  Foreign Producers/Exporters

Please contact our office for a list filed with the petition.

VII.  US Importers named.

Please contact our office for a list filed with the petition.    

VIII.  Alleged Dumping Margins:
Germany:       38.99 – 56.75%
Japan:            104.66 – 113.91%
Korea:            48.42 – 49.98%
Spain:             30.76 – 39.41%

IX.  Comments:

A.  Projected date of ITC Preliminary Conference: October 29, 2020.

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is December 17, 2020.
Please contact our office for a complete projected schedule for the AD investigations.

C. Volume and Value of Imports:
Please contact our office for a summary of the data filed with the petition.

If you have questions regarding how this investigation may impact future imports of scope merchandise or whether a particular product is within the scope of the investigation, please contact one of our attorneys.

Type of Action
HTS Classifications
Date of Filing
Foreign Producers and Exporters
US Named Importers
Alleged Dumping Margins
Additional Notes