Thermal paper AD: four-country first sunset reviews

The ITC instituted first five-year reviews of the antidumping duty orders on thermal paper from Germany, Japan, South Korea, and Spain (91 FR 62555-62558; FR Doc. 2026-20136; Inv. Nos. 731-TA-1546-1549 (Review)), published October 1, 2026. The same day, Commerce automatically initiated matching sunset reviews (91 FR 62467-62468; FR Doc. 2026-20161). Commerce issued the underlying AD orders on November 22, 2021 (86 FR 66284).

First thermal paper AD sunsets for Germany, Japan, Korea, and Spain. ITC responses due Nov 2, 2026; adequacy comments Dec 8, 2026. Orders stay in force unless later revoked.

Orders and like product

In its original determinations, the Commission defined the Domestic Like Product as a single domestic like product including all jumbo rolls of thermal paper, in-scope converted light-weight thermal paper, and out-of-scope converted heavy-weight thermal paper (one Commissioner defined it differently). The Domestic Industry was defined as all domestic producers and converters of thermal paper jumbo rolls (one Commissioner defined it differently). Subject countries: Germany, Japan, South Korea, and/or Spain. Order Date: November 22, 2021.

Deadlines that matter

• ITC responses: due by 5:15 p.m. on November 2, 2026. Comments on adequacy due by 5:15 p.m. on December 8, 2026.
• ITC entry of appearance / APO: no later than 21 days after publication (by our count, October 22, 2026).
• Commerce intent to participate: domestic interested parties must file within 15 days of publication (by our count, October 16, 2026), or Commerce automatically revokes the order without further review.
• Commerce substantive responses: if intent is received, complete substantive responses are due 30 days after publication (by our count, October 31, 2026, a Saturday; under 19 CFR 351.303(b)(1) that moves to Monday, November 2, 2026).
• Commerce appearance / APO: entry of appearance requested within 10 days; APO applications immediately following publication.

ITC responses must identify the filer's interest (producer, importer, foreign producer/exporter, or other), describe the likely effects of revocation, and provide the production, capacity, shipment, inventory, and financial data the notice requests for the Domestic Like Product or Subject Merchandise. Read FR Doc. 2026-20136 for the full questionnaire-style list.

Action items

• Map sourcing by country: point-of-sale, label, and receipt paper importers and converters should identify Germany, Japan, Korea, and Spain origin.
• Decide on ITC participation: foreign producers and U.S. importers decide whether to respond by November 2, 2026.
• Watch Commerce intent filings: a domestic no-show by the 15-day deadline (by our count October 16, 2026) triggers automatic revocation.
• Keep deposits in landed cost: cash deposit rates stay in place while orders remain in effect. Do not assume revocation or continuation.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.