Commerce finalizes dumping margins of 6.50 percent on Brazilian and 6.51 percent on Norwegian high purity dissolving pulp, plus a 9.37 percent subsidy rate on Brazil, coming in far below the margins petitioners alleged. One methodological issue in the record addresses how invalidated IEEPA tariffs are treated in the dumping calculation.
WASHINGTON, October 16, 2026 – The Commerce Department published three final determinations in the Federal Register on Friday covering high purity dissolving pulp from Brazil and Norway, finding dumping in both markets and countervailable subsidization in Brazil, at rates substantially below those the petitioners had alleged when they filed in August 2025.
For Brazil, Commerce calculated a final weighted-average dumping margin of 6.50 percent for Bracell Bahia Specialty Celulose S.A. and Bracell SP Celulose Ltda., treated as a single entity, with the same rate applying to all other producers and exporters. After adjustment for export subsidy offsets, the cash deposit rate is 6.40 percent. In the parallel countervailing duty proceeding, Commerce found a net subsidy rate of 9.37 percent ad valorem for Bracell Bahia Specialty Cellulose S.A. and for all other Brazilian producers and exporters.
For Norway, Commerce found a final dumping margin of 6.51 percent for Borregaard AS, the only individually examined respondent, with the same rate extended to all other producers and exporters.
The combined Brazilian exposure, at roughly 16 percent before offsets, is a fraction of what the petition contemplated. Rayonier Advanced Materials and the United Steelworkers, which filed the petitions on August 12, 2025, had alleged dumping margins of 168.09 percent for Brazil and 226.88 percent for Norway.
A commercially survivable outcome
That gap between alleged and calculated margins is the headline for anyone buying or selling this product.
Dumping petitions routinely allege margins far above what Commerce eventually calculates, because the petition stage relies on constructed value estimates built from publicly available information rather than on respondent cost and sales databases. A twenty-fold reduction between allegation and final determination is at the larger end of that normal range, but it is within it.
The practical consequence is that these orders, if the International Trade Commission finds injury, will not close the American market to Brazilian or Norwegian dissolving pulp. A duty of six to sixteen percent on a commodity input is a material cost, and it will shift purchasing at the margin, but it is not the kind of prohibitive rate that terminates a trade flow. Compare the figures to the 123 percent dumping margin and 126 percent subsidy rate that Commerce finalized on Indian solar cells last month, where the stated intention and the practical effect are exclusion.
Buyers of high purity dissolving pulp should therefore plan for a price adjustment rather than a supply disruption.
What the product is and why it matters
High purity dissolving pulp is a specialty cellulose, not a papermaking pulp. The scope as defined in the petitions covers material with an alpha cellulose content of 90 percent or higher on an oven dry basis and a brightness of 90 percent or higher, produced from any virgin or recycled cellulose source by either kraft or sulfite pulping, in any form. Material with an intrinsic viscosity under 455 milliliters per gram, measured under ISO 5351:2010, is excluded.
It enters the United States under HTSUS subheadings 4702.00.0020 and 4702.00.0040.
Downstream, the product is the feedstock for cellulose derivatives used across a wide range of industries: cellulose acetate for filters and textiles, ethers used as thickeners and binders in construction materials, food and pharmaceutical applications, microcrystalline cellulose for tablet excipients, and high-tenacity viscose and lyocell fibers. The customer base is therefore not a single sector but a set of specialty chemical converters, each of which qualifies its pulp supply tightly and does not switch sources casually.
That qualification friction is the operational reality behind these cases. A converter that has validated Bracell or Borregaard material into a regulated pharmaceutical or food application cannot substitute another supplier in a quarter. A duty in the single digits to low teens is more likely to be absorbed or passed through than to trigger resourcing.
The investigation record
The antidumping period of investigation ran from July 1, 2024 through June 30, 2025. The countervailing duty period of investigation covered calendar year 2024.
Commerce initiated both proceedings in early September 2025. It issued a preliminary affirmative countervailing duty determination in March 2026 and aligned the final countervailing duty determination with the final antidumping determination, a procedural step that keeps the two cases on a single schedule and lets the commission consider them together. Preliminary antidumping determinations published on May 27, 2026, and suspension of liquidation has run from that date.
In both final determinations, Commerce relied in part on adverse facts available, the methodology it applies when a respondent fails to provide requested information or fails verification on a particular point. In the Brazilian antidumping case, the Issues and Decision Memorandum addresses six contested issues: partial adverse facts available for packing expenses, the deduction of IEEPA tariffs from United States price, inventory carrying costs in the United States, treatment of certain indirect selling expenses, cost allocation, and minor corrections identified at verification.
Commerce made changes to Bracell’s margin calculation between the preliminary and final determinations but did not enumerate them in the Federal Register notice, referring instead to the decision memorandum.
The IEEPA question inside the calculation
The second item on that list of issues is the one with implications well beyond this case.
In an antidumping calculation, Commerce constructs an export price or a constructed export price by taking the price at which the subject merchandise is first sold in the United States and deducting the expenses associated with bringing it there. United States import duties are among the deductions, on the logic that the duty is a cost of selling into the American market and is not part of the price comparison.
The complication is that a very large share of the duties paid on 2024 and 2025 entries were assessed under the International Emergency Economic Powers Act, and the Supreme Court invalidated those tariffs in February 2026. Roughly 166 billion dollars was collected under the invalidated measures. More than 100 billion dollars has reportedly been refunded through Customs and Border Protection’s refund processing, with the Court of International Trade estimating that approximately 30 billion dollars could remain unrecovered absent a broader mechanism.
So the question Commerce had to answer is a genuinely difficult one: should a duty that was collected during the period of investigation, but that has since been held unlawful and is being refunded, be deducted from United States price in the dumping calculation?
Deducting it lowers United States price and therefore raises the dumping margin. Not deducting it does the opposite. And whichever way Commerce resolved it, the answer will recur in every antidumping proceeding with a period of investigation overlapping the IEEPA tariff window, which is to say in essentially every case Commerce will decide over the next two years.
The Federal Register notice does not state the resolution, and practitioners will need to read the decision memorandum. But the fact that the issue was briefed and decided here makes this otherwise modest pulp case a reference point. Respondents and petitioners in pending cases should expect the Brazilian memorandum to be cited on both sides.
Next steps and timing
Commerce has notified the International Trade Commission of the affirmative final determinations. The commission must reach its final injury determination within 45 days of Commerce’s final determination. Counting from the publication date, that places the vote in the second half of November or early December 2026, though practitioners should confirm the date against the commission’s own published schedule rather than calculating from the Federal Register.
Commerce has instructed Customs and Border Protection to continue suspending liquidation of entries made on or after May 27, 2026, and to require cash deposits at the final rates effective on publication.
If the commission finds material injury or a threat of material injury, Commerce will issue antidumping duty orders covering Brazil and Norway and a countervailing duty order covering Brazil. If the commission reaches a negative determination, the proceedings terminate and all cash deposits collected since May are refunded with interest.
Commerce said it would disclose its calculations to interested parties within five days of publication, which starts the clock for any ministerial error allegations.
What importers should do
The compliance steps here are straightforward but time-sensitive.
Importers of record bringing in Brazilian or Norwegian high purity dissolving pulp need to confirm that their customs broker has the correct case numbers and deposit rates loaded before the next entry. The Brazilian antidumping case is A-351-866. Deposits at 6.40 percent for Brazilian merchandise, 6.51 percent for Norwegian merchandise and 9.37 percent on the countervailing duty side for Brazil apply from the publication date.
Entries made on or after May 27, 2026 remain suspended. Importers should identify those entries now and calculate the potential liability at final rates against the deposits already posted, because the difference will be assessed at liquidation. Where preliminary rates differed from final rates, there will be either an additional assessment or a refund, and the cash flow timing of that should be in the forecast.
Contract review is the other immediate task. Supply agreements written before August 2025 are unlikely to allocate trade remedy duty risk explicitly. Agreements written since then often do, and the allocation language should be read against the specific rates now determined rather than against the petition allegations. Where a contract passes duties through to the buyer, the buyer should verify that the pass-through is limited to duties actually assessed rather than to deposits posted, since the two can diverge for several years.
Scope is worth a second look as well. The intrinsic viscosity exclusion at 455 milliliters per gram and the alpha cellulose and brightness thresholds are the boundaries of the order. Material that falls outside them is not covered, and a scope ruling request is available to importers who believe their product sits outside. That is a slow process, but it is the correct one, and self-classifying out of scope without a ruling is an enforcement exposure in an environment where the Justice Department has elevated customs fraud to a core priority of its Fraud Division.
How adverse facts available shaped the numbers
Commerce’s use of adverse facts available in both proceedings deserves attention, because it is one of the few levers that can move a rate materially and it is almost entirely within a respondent’s control.
Adverse facts available is the methodology Commerce applies when an interested party withholds requested information, fails to provide it in the form and manner requested, significantly impedes the proceeding, or provides information that cannot be verified. Rather than drawing a neutral inference, the statute permits Commerce to select from among the facts otherwise available an inference adverse to that party’s interest, which in practice usually means using the highest rate on the record for the affected element.
In the Brazilian antidumping case, Commerce applied partial adverse facts available to packing expenses. Partial application means the adverse inference is confined to one element of the calculation rather than applied to the respondent’s entire margin, which is why the resulting figure remains modest. Had Commerce applied total adverse facts available, the rate would have looked like the petition allegation rather than like the calculated margin.
Commerce also noted that it relied in part on adverse facts available in the Brazilian countervailing duty determination. In subsidy cases, that typically arises where a government respondent fails to provide complete information about a program’s administration or about a respondent’s usage, and Commerce fills the gap with an adverse assumption about benefit.
The lesson for respondents in pending cases is familiar to practitioners and still routinely ignored. The difference between a six percent margin and a prohibitive one is frequently a matter of questionnaire response quality and verification preparation rather than of commercial behavior. Packing expense reporting is an unglamorous part of a Section D response, and it cost Bracell something here.
Where the commission’s injury analysis will turn
The commission’s vote is the remaining contingency, and it is not a formality.
Negative final injury determinations are uncommon but not rare, and they are most likely where import volumes are modest, where the domestic industry’s difficulties have causes other than imports, and where the price effects are weak. All three of those conditions bear examination here.
On volume, the commission will look at absolute import quantities and at import penetration relative to apparent domestic consumption over the three-year period of investigation. Dissolving pulp is a globally traded commodity with a limited number of producers, and the Brazilian and Norwegian shares will be measured against a market that also takes material from other origins not covered by these petitions.
On price, the commission examines underselling, price depression and price suppression. With final dumping margins in the six percent range, the pricing story is necessarily a subtle one. A margin that size does not describe a producer selling far below its own cost; it describes a modest spread between home market or constructed value and American price. Petitioners will argue that even modest underselling in a commodity market drives price, which is a conventional and often successful argument. Respondents will argue that the price trajectory reflects global capacity additions and demand conditions in the derivative markets rather than the subject imports.
On causation, respondents will point to the broader state of the specialty cellulose market, including capacity expansions outside the subject countries and demand shifts in textiles and acetate tow.
The commission’s determination, when it issues, will be accompanied by views that set out this analysis in detail, and those views are the document that matters for anyone trying to anticipate how similar cases will be decided.
The domestic industry side
Rayonier Advanced Materials, the petitioner, is the principal American producer of high purity dissolving pulp and has operated in a difficult market for several years. Global dissolving pulp capacity expanded substantially through the last decade, much of it in Brazil, and prices have reflected that.
Bracell, the Brazilian respondent, is among the largest dissolving pulp producers in the world, with cross-owned affiliates that Commerce identified in the subsidy proceeding as Bracell Bahia Florestal Ltda., Bracell SP Celulose Limitada and Bracell SP Florestal Ltda. Borregaard, the Norwegian respondent, operates a biorefinery model in which specialty cellulose is one output among several.
A duty in the single digits to low teens improves the American producer’s relative position without resetting the market. Whether that is enough to change the economics of a domestic mill is a question the commission will effectively answer in its injury vote, since a negative determination would terminate the cases entirely.
The United Steelworkers’ participation as co-petitioner is characteristic of trade cases in capital-intensive process industries, where the union has standing as an interested party and where employment at a small number of mills is the most legible measure of injury.
Norway, and the question of allied treatment
The Norwegian side of this case sits oddly against the broader architecture of American trade policy in 2026.
Norway is a close security partner, and the tariff frameworks the administration has negotiated over the past eighteen months have generally extended preferential treatment to allied jurisdictions. The Section 232 polysilicon proclamation issued in August caps the combined rate at 15 percent for the European Union, Japan, Korea, Taiwan, Switzerland and Liechtenstein, and sets 10 percent for the United Kingdom. Pharmaceutical tariffs under Section 232 carry similar carve-outs for allied origins.
Antidumping and countervailing duty law does not work that way, and that is by design. These are unfair trade remedies administered by Commerce and the commission on a statutory record, not instruments of presidential discretion. There is no allied exception, no national security carve-out and no negotiated cap. A Norwegian producer found to have dumped is subject to the same remedy as any other.
That distinction is worth holding onto, because the public conversation about tariffs has increasingly blurred the two categories. Importers that have grown accustomed to tracking proclamations, annexes and framework agreements should remember that the trade remedy docket runs on its own track, is driven by private petitioners rather than by the executive, and is largely insulated from diplomatic considerations. A trade deal does not dispose of an antidumping order.
For Borregaard, the practical consequence is a 6.51 percent cash deposit obligation on its American sales, pending the commission’s vote. For American buyers of Norwegian specialty cellulose, it is a cost increase that is unwelcome but manageable.
The broader read
This case will not move markets. Its interest for trade practitioners lies in two places.
The first is as a reminder that most trade remedy outcomes are ordinary. The cases that dominate coverage are the ones with triple-digit rates and geopolitical subtext. The larger part of the docket produces single-digit and low-double-digit margins on industrial inputs, adjusts relative costs modestly, and is managed through contract terms rather than through supply chain reconstruction.
The second is the IEEPA deduction question. The Supreme Court’s February decision invalidating those tariffs created a set of second-order problems that are only now surfacing in administrative practice, and this is one of them. Every dumping calculation with a 2024 or 2025 period of investigation touches it. The resolution Commerce reached here, whatever it is, will be argued about in a great many proceedings over the next two years, and the firms that read the decision memorandum early will have the advantage in briefing it.
For importers across all sectors, the practical lesson is narrower. The refund architecture now taking shape around the invalidated IEEPA tariffs is not only about getting money back. Those duties were a line in a great many cost calculations, customs valuations and transfer pricing positions, and unwinding them has consequences that run in several directions at once.