# High Purity Dissolving Pulp From Brazil and Norway: Initiation of Less-Than-Fair-Value Investigations
**AGENCY:**
Enforcement and Compliance, International Trade Administration, Department of Commerce.
**DATES:**
Applicable September 2, 2025.
**FOR FURTHER INFORMATION CONTACT:**
Ashley Cossaart (Brazil) at (202) 482-0462, and Rachel Jennings (Norway) at (202) 482-1110, AD/CVD Operations, Enforcement and Compliance, International Trade Administration, U.S. Department of Commerce, 1401 Constitution Avenue NW, Washington, DC 20230.
**SUPPLEMENTARY INFORMATION:**
**The Petitions**
On August 12, 2025, the U.S. Department of Commerce (Commerce) received antidumping duty (AD) petitions concerning imports of high purity dissolving pulp from Brazil and Norway filed in proper form on behalf of 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) (the petitioners), a domestic producer of high purity dissolving pulp and a certified union, which represents workers engaged in the production of high purity dissolving pulp in the United States. [^1] The AD Petitions were accompanied by a countervailing duty (CVD) petition concerning imports of high purity dissolving pulp from Brazil. [^2]
[^1]*See* Petitioners' Letter, “Antidumping and Countervailing Duty Petitions,” dated August 12, 2025 (Petitions).
[^2]*Id.*
Between August 14 and 29, 2025, Commerce requested supplemental information pertaining to certain aspects of the Petitions in supplemental questionnaires. [^3] The petitioners responded to Commerce's supplemental questionnaires between August 18 and September 2, 2025. [^4]
[^3]*See* Commerce's Letters, “Supplemental Questions,” dated August 14, 2025 (First General Issues Questionnaire); *see also* First Country-Specific AD Supplemental Questionnaires: Brazil Supplemental and Norway Supplemental, dated August 15, 2025; “Second General Issues Supplemental Questions,” dated August 21, 2025 (Second General Issues Questionnaire); Country-Specific Memoranda, “Teleconference with Counsel to the Petitioners,” dated August 22, 2025; Norway-Specific Memoranda, “Teleconference with Counsel to the Petitioners,” dated August 27, 2025; and Commerce's Letter, “Fourth Norway Supplemental Questions,” dated August 29, 2025.
[^4]*See* Petitioners' Letters, “Antidumping and Countervailing Duty Supplemental Questionnaire Response,” dated August 18, 2025 (First General Issues Supplement); *see also* First Country-Specific AD Supplemental Responses: Brazil AD Supplement and Norway AD Supplement, dated August 21, 2025; “Response to Second General Issues Supplemental Questions,” dated August 22, 2025 (Second General Issues Supplement); Second Country-Specific AD Supplemental Responses: Second Brazil AD Supplement and Second Norway AD Supplement, dated August 25, 2025; “Third Antidumping Duty Supplemental Questionnaire Response,” dated August 28, 2025; and “Fourth Antidumping Duty Supplemental Questionnaire Response,” dated September 2, 2025.
In accordance with section 732(b) of the Tariff Act of 1930, as amended (the Act), the petitioners allege that imports of high purity dissolving pulp from Brazil and Norway are being, or are likely to be, sold in the United States at less than fair value (LTFV) within the meaning of section 731 of the Act, and that imports of such products are materially injuring, or threatening material injury to, the high purity dissolving pulp industry in the United States. Consistent with section 732(b)(1) of the Act, the Petitions were accompanied by information reasonably available to the petitioners supporting their allegations.
Commerce finds that the petitioners filed the Petitions on behalf of the domestic industry, because the petitioners are interested parties, as defined in sections 771(9)(C) and (D) of the Act. Commerce also finds that the petitioners demonstrated sufficient industry support for the initiation of the requested LTFV investigations. [^5]
[^5]*See* section on “Determination of Industry Support for the Petitions,” *infra.*
**Periods of Investigation**
Because the Petitions were filed on August 12, 2025, pursuant to 19 CFR 351.204(b)(1), the period of investigation (POI) for the Brazil and Norway LTFV investigations is July 1, 2024, through June 30, 2025.
**Scope of the Investigations**
The product covered by these investigations is high purity dissolving pulp from Brazil and Norway. For a full description of the scope of these investigations, *see* the appendix to this notice.
**Comments on the Scope of the Investigations**
Between August 14 and 21, 2025, Commerce requested information and clarification from the petitioners regarding the proposed scope to ensure that the scope language in the Petitions is an accurate reflection of the products for which the domestic industry is seeking relief. [^6] Between August 18 and 22, 2025, the petitioners provided clarifications and revised the scope. [^7] The description of the merchandise covered by these investigations, as described in the appendix to this notice, reflects these clarifications.
[^6]*See* First General Issues Supplemental Questionnaire at 3-4; *see also* Second General Issues Supplemental Questionnaire at 3.
[^7]*See* First General Issues Supplement at 3-6 and Exhibits I-Supp-2; *see also* Second General Issues Supplement at 2-6.
As discussed in the *Preamble* to Commerce's regulations, we are setting aside a period for interested parties to raise issues regarding product coverage ( *i.e.,* scope). [^8] Commerce will consider all scope comments received from interested parties and, if necessary, will consult with interested parties prior to the issuance of the preliminary determinations. If scope comments include factual information, all such factual information should be limited to public information. [^9] Commerce requests that interested parties provide at the beginning of their scope comments a public executive summary for each comment or issue raised in their submission. Commerce further requests that interested parties limit their public executive summary of each comment or issue to no more than 450 words, not including citations. Commerce intends to use the public executive summaries as the basis of the comment summaries included in the analysis of scope comments. To facilitate preparation of its questionnaires, Commerce requests that scope comments be submitted by 5:00 p.m. Eastern Time (ET) on September 22, 2025, which is 20 calendar days from the signature date of this notice. Any rebuttal comments must be filed by 5:00 p.m. ET on October 2, 2025, which is 10 calendar days from the initial comment deadline.
[^8]*See Antidumping Duties; Countervailing Duties, Final Rule,* 62 FR 27296, 27323 (May 19, 1997) ( *Preamble* ); *see also* 19 CFR 351.312.
[^9]*See* 19 CFR 351.102(b)(21) (defining “factual information”).
Commerce requests that any factual information that parties consider relevant to the scope of these investigations be submitted during that period. However, if a party subsequently finds that additional factual information pertaining to the scope of the investigations may be relevant, the party must contact Commerce and request permission to submit the additional information. All scope comments must be filed simultaneously on the records of the concurrent LTFV and CVD investigations.
**Filing Requirements**
All submissions to Commerce must be filed electronically via Enforcement and Compliance's Antidumping Duty and Countervailing Duty Centralized Electronic Service System (ACCESS), unless an exception applies. [^10] An electronically filed document must be received successfully in its entirety by the time and date it is due.
[^10]*See Antidumping and Countervailing Duty Proceedings: Electronic Filing Procedures; Administrative Protective Order Procedures,* 76 FR 39263 (July 6, 2011); *see also Enforcement and Compliance: Change of Electronic Filing System Name,* 79 FR 69046 (November 20, 2014) for details of Commerce's electronic filing requirements, effective August 5, 2011. Information on using ACCESS can be found at *https://access.trade.gov/help.aspx* and a handbook can be found at *https://access.trade.gov/help/Handbook_on_Electronic_Filing_Procedures.pdf.*
**Comments on Product Characteristics**
Commerce is providing interested parties an opportunity to comment on the appropriate physical characteristics of high purity dissolving pulp to be reported in response to Commerce's AD questionnaires. This information will be used to identify the key physical characteristics of the subject merchandise in order to report the relevant cost of production (COP) accurately, as well as to develop appropriate product comparison criteria.
Interested parties may provide any information or comments that they feel are relevant to the development of an accurate list of physical characteristics. Specifically, they may provide comments as to which characteristics are appropriate to use as: (1) general product characteristics; and (2) product comparison criteria. We note that it is not always appropriate to use all product characteristics as product comparison criteria. We base product comparison criteria on meaningful commercial differences among products. In other words, although there may be some physical product characteristics utilized by manufacturers to describe high purity dissolving pulp, it may be that only a select few product characteristics take into account commercially meaningful physical characteristics. In addition, interested parties may comment on the order in which the physical characteristics should be used in matching products. Generally, Commerce attempts to list the most important physical characteristics first and the least important characteristics last.
In order to consider the suggestions of interested parties in developing and issuing the AD questionnaires, all product characteristics comments must be filed by 5:00 p.m. ET on September 22, 2025, which is 20 calendar days from the signature date of this notice. Any rebuttal comments must be filed by 5:00 p.m. ET on October 2, 2025, which is 10 calendar days from the initial comment deadline. All comments and submissions to Commerce must be filed electronically using ACCESS, as explained above, on the record of each of the LTFV investigations.
**Determination of Industry Support for the Petitions**
Section 732(b)(1) of the Act requires that a petition be filed on behalf of the domestic industry. Section 732(c)(4)(A) of the Act provides that a petition meets this requirement if the domestic producers or workers who support the petition account for: (i) at least 25 percent of the total production of the domestic like product; and (ii) more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the petition. Moreover, section 732(c)(4)(D) of the Act provides that, if the petition does not establish support of domestic producers or workers accounting for more than 50 percent of the total production of the domestic like product, Commerce shall: (i) poll the industry or rely on other information in order to determine if there is support for the petition, as required by subparagraph (A); or (ii) determine industry support using a statistically valid sampling method to poll the “industry.”
Section 771(4)(A) of the Act defines the “industry” as the producers as a whole of a domestic like product. Thus, to determine whether a petition has the requisite industry support, the statute directs Commerce to look to producers and workers who produce the domestic like product. The U.S. International Trade Commission (ITC), which is responsible for determining whether “the domestic industry” has been injured, must also determine what constitutes a domestic like product in order to define the industry. While both Commerce and the ITC must apply the same statutory definition regarding the domestic like product, [^11] they do so for different purposes and pursuant to a separate and distinct authority. In addition, Commerce's determination is subject to limitations of time and information. Although this may result in different definitions of the like product, such differences do not render the decision of either agency contrary to law. [^12]
[^11]*See* section 771(10) of the Act.
[^12]*See USEC, Inc.* v. *United States,* 132 F.Supp.2d 1, 8 (CIT 2001) (citing *Algoma Steel Corp., Ltd.* v. *United States,* 688 F.Supp.639, 644 (CIT 1988), *aff'd Algoma Steel Corp., Ltd.* v. *United States,* 865 F.2d 240 (Fed. Cir. 1989)).
Section 771(10) of the Act defines the domestic like product as “a product which is like, or in the absence of like, most similar in characteristics and uses with, the article subject to an investigation under this title.” Thus, the reference point from which the domestic like product analysis begins is “the article subject to an investigation” ( *i.e.,* the class or kind of merchandise to be investigated, which normally will be the scope as defined in the petition).
With regard to the domestic like product, the petitioners do not offer a definition of the domestic like product distinct from the scope of the investigations. [^13] Based on our analysis of the information submitted on the record, we have determined that high purity dissolving pulp, as defined in the scope, constitutes a single domestic like product, and we have analyzed industry support in terms of that domestic like product. [^14]
[^13] For a discussion of the domestic like product analysis as applied to these cases and information regarding industry support, *see* Checklists, “Antidumping Duty Investigation Initiation Checklists: High Purity Dissolving Pulp from Brazil and Norway,” dated concurrently with, and hereby adopted by, this notice (Country-Specific AD Initiation Checklists), at Attachment II, Analysis of Industry Support for the Antidumping and Countervailing Duty Petitions Covering High Purity Dissolving Pulp from Brazil and Norway (Attachment II). These checklists are on file electronically via ACCESS.
[^14] For further discussion, *see* Attachment II of the Country-Specific AD Initiation Checklists.
In determining whether the petitioners have standing under section 732(c)(4)(A) of the Act, we considered the industry support data contained in the Petitions with reference to the domestic like product as defined in the “Scope of the Investigations,” in the appendix to this notice. To establish industry support, the petitioners provided their own production of the domestic like product in 2024. [^15] The petitioners identified RYAM as the sole remaining producer of the domestic like product; therefore, the Petitions are supported by 100 percent of the U.S. industry. [^16] We relied on data provided by the petitioners for purposes of measuring industry support. [^17]
[^15]*Id.*
[^16]*Id.*
[^17]*Id.*
Our review of the data provided in the Petitions, the First General Issues Supplement, and other information readily available to Commerce indicates that the petitioners have established industry support for the Petitions. [^18] First, the Petitions established support from domestic producers (or workers) accounting for more than 50 percent of the total production of the domestic like product and, as such, Commerce is not required to take further action in order to evaluate industry support ( *e.g.,* polling). [^19] Second, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(i) of the Act because the domestic producers (or workers) who support the Petitions account for at least 25 percent of the total production of the domestic like product. [^20] Finally, the domestic producers (or workers) have met the statutory criteria for industry support under section 732(c)(4)(A)(ii) of the Act because the domestic producers (or workers) who support the Petitions account for more than 50 percent of the production of the domestic like product produced by that portion of the industry expressing support for, or opposition to, the Petitions. [^21] Accordingly, Commerce determines that the Petitions were filed on behalf of the domestic industry within the meaning of section 732(b)(1) of the Act. [^22]
[^18]*Id.*
[^19]*Id.; see also* section 732(c)(4)(D) of the Act.
[^20]*See* Attachment II of the Country-Specific AD Initiation Checklists.
[^21]*Id.*
[^22]*Id.*
**Allegations and Evidence of Material Injury and Causation**
The petitioners allege that the U.S. industry producing the domestic like product is being materially injured, or is threatened with material injury, by reason of the imports of the subject merchandise sold at LTFV. In addition, the petitioners allege that subject imports exceed the negligibility threshold provided for under section 771(24)(A) of the Act. [^23]
[^23] For further information regarding negligibility and the injury allegation, *see* Country-Specific AD Initiation Checklists at Attachment III, Analysis of Allegations and Evidence of Material Injury and Causation for the Antidumping and Countervailing Duty Petitions Covering High Purity Dissolving Pulp from Brazil and Norway.
The petitioners contend that the industry's injured condition is illustrated by the significant volume of subject imports; increased market share of subject imports; underselling and price depression and/or suppression; lost sales and revenue; negative impact on financial performance; and adverse impact on production, capacity utilization, U.S. shipments, and employment variables. [^24] We assessed the allegations and supporting evidence regarding material injury, threat of material injury, causation, cumulation, as well as negligibility, and we have determined that these allegations are properly supported by adequate evidence, and meet the statutory requirements for initiation. [^25]
[^24]*Id.*
[^25]*Id.*
**Allegations of Sales at LTFV**
The following is a description of the allegations of sales at LTFV upon which Commerce based its decision to initiate LTFV investigations of imports of high purity dissolving pulp from Brazil and Norway. The sources of data for the deductions and adjustments relating to U.S. price and normal value (NV) are discussed in greater detail in the Country-Specific AD Initiation Checklists.
**U.S. Price**
For Brazil, the petitioners based export price (EP) on a transaction-specific average unit value (AUV) ( *i.e.,* month- and port-specific AUV) derived from official import statistics and tied to ship manifest data. [^26] For Norway, the petitioners based EP on pricing information for high purity dissolving pulp produced in Norway and sold or offered for sale in the U.S. market during the POI. [^27] For each country, the petitioners made certain adjustments to U.S. price to calculate a net ex-factory U.S price, where applicable. [^28]
[^26]*See* Country-Specific AD Initiation Checklists.
[^27]*Id.*
[^28]*Id.*
**Normal Value
29**
[^29] In accordance with section 773(b)(2) of the Act, for these investigations, Commerce will request information necessary to calculate the constructed value (CV) and COP to determine whether there are reasonable grounds to believe or suspect that sales of the foreign like product have been made at prices that represent less than the COP of the product.
For Brazil and Norway, the petitioners stated that they were unable to obtain home market or third-county pricing information for high purity dissolving pulp produced in the respective countries to use as the basis for NV. [^30] Therefore, for both countries, the petitioners calculated NV based on CV. For further discussion of CV, *see* the section “Normal Value Based on Constructed Value.”
[^30]*See* Country-Specific AD Initiation Checklists.
**Normal Value Based on Constructed Value**
As noted above for Brazil and Norway, the petitioners stated that they were unable to obtain home market or third-country prices for high purity dissolving pulp to use as a basis for NV. Therefore, for both countries, the petitioners calculated NV based on CV. [^31]
[^31]*Id.*
Pursuant to section 773(e) of the Act, the petitioners calculated CV as the sum of the cost of manufacturing, selling, general, and administrative (SG&A) expenses, financial expenses, and profit. [^32] In calculating the cost of manufacturing, the petitioners relied on the production experience and input consumption rates for a U.S. producer of high purity dissolving pulp, valued using publicly available information applicable to Brazil and Norway. [^33] For calculating SG&A expenses, financial expenses, and profit ratios, the petitioners relied on the financial statements of a producer of comparable or identical merchandise domiciled in the respective countries. [^34]
[^32]*Id.*
[^33]*Id.*
[^34]*Id.*
**Fair Value Comparison**
Based on the data provided by the petitioners, there is reason to believe that imports of high purity dissolving pulp from Brazil and Norway are being, or are likely to be, sold in the United States at LTFV. Based on comparisons of EP to NV in accordance with sections 772 and 773 of the Act, the estimated dumping margins for high purity dissolving pulp for each of the countries covered by this initiation are as follows: (1) Brazil—62.08 percent; (2) Norway—110.04 percent. [^35]
[^35]*Id.*
**Initiation of LTFV Investigations**
Based upon the examination of the Petitions and supplemental responses, we find that they meet the requirements of section 732 of the Act. Therefore, we are initiating LTFV investigations to determine whether imports of high purity dissolving pulp from Brazil and Norway are being, or are likely to be, sold in the United States at LTFV. In accordance with section 733(b)(1)(A) of the Act and 19 CFR 351.205(b)(1), unless postponed, we will make our preliminary determinations no later than 140 days after the date of this initiation.
**Respondent Selection**
**Brazil and Norway**
In the Petitions, the petitioners identified one company in Brazil ( *i.e.,* Bracell Bahia Specialty Celulose SA (Bracell)), and one company in Norway ( *i.e.,* Borregaard ASA (Borregaard)) as producers/exporters of high purity dissolving pulp. [^36] We currently know of no additional producers/exporters of high purity dissolving pulp from Brazil and Norway.
[^36]*See* Petitions at Volume I (page 11 and Exhibit I-4); *see also* First General Issues Supplement at 1 and Exhibits I-Supp-1 through I-Supp-4.
Accordingly, Commerce intends to individually examine the only known producers/exporters in the investigations from Brazil and Norway ( *i.e.,* the companies cited above). We invite interested parties to comment on this issue. Such comments may include factual information within the meaning of 19 CFR 351.102(b)(21). Parties wishing to comment must do so within three business days of the publication of this notice in the *Federal Register* . Comments must be filed electronically using ACCESS. An electronically filed document must be received successfully in its entirety via ACCESS by 5:00 p.m. ET on the specified deadline. Because we intend to examine the only known producers/exporters in Brazil and Norway, if no comments are received, or if comments received further support the existence of only these producers/exporters, we do not intend to conduct respondent selection and will proceed to issuing the initial AD questionnaires to the identified companies. However, if comments are received which create a need for a respondent selection process, we intend to finalize our decision regarding respondent selection for Brazil and Norway within 20 days of publication of this notice.
**Distribution of Copies of the Petitions**
In accordance with section 732(b)(3)(A) of the Act and 19 CFR 351.202(f), a copy of the public version of the Petitions has been provided to the governments of Brazil and Norway via ACCESS. To the extent practicable, we will attempt to provide a copy of the public version of the Petitions to each exporter named in the Petitions, as provided under 19 CFR 351.203(c)(2).
**ITC Notification**
Commerce will notify the ITC of our initiation, as required by section 732(d) of the Act.
**Preliminary Determinations by the ITC**
The ITC will preliminarily determine, within 45 days after the date on which the Petitions were filed, whether there is a reasonable indication that imports of high purity dissolving pulp from Brazil and/or Norway are materially injuring, or threatening material injury to, a U.S. industry. [^37] A negative ITC determination for any country will result in the investigation being terminated with respect to that country. [^38] Otherwise, these LTFV investigations will proceed according to statutory and regulatory time limits.
[^37]*See* section 733(a) of the Act.
[^38]*Id.*
**Submission of Factual Information**
Factual information is defined in 19 CFR 351.102(b)(21) as: (i) evidence submitted in response to questionnaires; (ii) evidence submitted in support of allegations; (iii) publicly available information to value factors under 19 CFR 351.408(c) or to measure the adequacy of remuneration under 19 CFR 351.511(a)(2); (iv) evidence placed on the record by Commerce; and (v) evidence other than factual information described in (i)-(iv). Section 351.301(b) of Commerce's regulations requires any party, when submitting factual information, to specify under which subsection of 19 CFR 351.102(b)(21) the information is being submitted [^39] and, if the information is submitted to rebut, clarify, or correct factual information already on the record, to provide an explanation identifying the information already on the record that the factual information seeks to rebut, clarify, or correct. [^40] Time limits for the submission of factual information are addressed in 19 CFR 351.301, which provides specific time limits based on the type of factual information being submitted. Interested parties should review the regulations prior to submitting factual information in these investigations.
[^39]*See* 19 CFR 351.301(b).
[^40]*See* 19 CFR 351.301(b)(2).
**Particular Market Situation Allegation**
Section 773(e) of the Act addresses the concept of particular market situation (PMS) for purposes of CV, stating that “if a particular market situation exists such that the cost of materials and fabrication or other processing of any kind does not accurately reflect the cost of production in the ordinary course of trade, the administering authority may use another calculation methodology under this subtitle or any other calculation methodology.” When an interested party submits a PMS allegation pursuant to section 773(e) of the Act ( *i.e.,* a cost-based PMS allegation), the submission must be filed in accordance with the requirements of 19 CFR 351.416(b), and Commerce will respond to such a submission consistent with 19 CFR 351.301(c)(2)(v). If Commerce finds that a cost-based PMS exists under section 773(e) of the Act, then it will modify its dumping calculations appropriately.
Neither section 773(e) of the Act, nor 19 CFR 351.301(c)(2)(v), sets a deadline for the submission of cost-based PMS allegations and supporting factual information. However, in order to administer section 773(e) of the Act, Commerce must receive PMS allegations and supporting factual information with enough time to consider the submission. Thus, should an interested party wish to submit a cost-based PMS allegation and supporting new factual information pursuant to section 773(e) of the Act, it must do so no later than 20 days after submission of a respondent's initial section D questionnaire response.
We note that a PMS allegation filed pursuant to sections 773(a)(1)(B)(ii)(III) or 773(a)(1)(C)(iii) of the Act ( *i.e.,* a sales-based PMS allegation) must be filed within 10 days of submission of a respondent's initial section B questionnaire response, in accordance with 19 CFR 351.301(c)(2)(i) and 19 CFR 351.404(c)(2).
**Extensions of Time Limits**
Parties may request an extension of time limits before the expiration of a time limit established under 19 CFR 351.301, or as otherwise specified by Commerce. In general, an extension request will be considered untimely if it is filed after the expiration of the time limit established under 19 CFR 351.301, or as otherwise specified by Commerce. [^41] For submissions that are due from multiple parties simultaneously, an extension request will be considered untimely if it is filed after 10:00 a.m. ET on the due date. Under certain circumstances, Commerce may elect to specify a different time limit by which extension requests will be considered untimely for submissions which are due from multiple parties simultaneously. In such a case, we will inform parties in a letter or memorandum of the deadline (including a specified time) by which extension requests must be filed to be considered timely. An extension request must be made in a separate, standalone submission; under limited circumstances we will grant untimely filed requests for the extension of time limits, where we determine, based on 19 CFR 351.302, that extraordinary circumstances exist. Parties should review Commerce's regulations concerning the extension of time limits and the *Time Limits Final Rule* prior to submitting factual information in these investigations. [^42]
[^41]*See* 19 CFR 351.301; *see also Extension of Time Limits; Final Rule,* 78 FR 57790 (September 20, 2013) ( *Time Limits Final Rule* ), available at *https://www.gpo.gov/fdsys/pkg/FR-2013-09-20/html/2013-22853.htm.*
[^42]*See* 19 CFR 351.302; *see also, e.g., Time Limits Final Rule.*
**Certification Requirements**
Any party submitting factual information in an AD or countervailing duty proceeding must certify to the accuracy and completeness of that information. [^43] Parties must use the certification formats provided in 19 CFR 351.303(g). [^44] Commerce intends to reject factual submissions if the submitting party does not comply with the applicable certification requirements.
[^43]*See* section 782(b) of the Act.
[^44]*See Certification of Factual Information to Import Administration During Antidumping and Countervailing Duty Proceedings,* 78 FR 42678 (July 17, 2013) ( *Final Rule* ). Additional information regarding the *Final Rule* is available at *https://access.trade.gov/Resources/filing/index.html.*
**Notification to Interested Parties**
Interested parties must submit applications for disclosure under APO in accordance with 19 CFR 351.305. Parties wishing to participate in these investigations should ensure that they meet the requirements of 19 CFR 351.103(d) ( *e.g.,* by filing the required letter of appearance). Note that Commerce has amended certain of its requirements pertaining to the service of documents in 19 CFR 351.303(f). [^45]
[^45]*See Administrative Protective Order, Service, and Other Procedures in Antidumping and Countervailing Duty Proceedings,* 88 FR 67069 (September 29, 2023).
This notice is issued and published pursuant to sections 732(c)(2) and 777(i) of the Act, and 19 CFR 351.203(c).
Dated: September 2, 2025.
Christopher Abbott,
Deputy Assistant Secretary for Policy and Negotiations, performing the non-exclusive functions and duties of the Assistant Secretary for Enforcement and Compliance.
**Appendix**
**Scope of the Investigations**
The merchandise subject to these investigations is high purity dissolving pulp, 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. High purity dissolving pulp 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). High purity dissolving pulp may be produced from a chemical pulping process including without limitation a kraft (sulfate) pulping and/or sulfite pulping process.
High purity dissolving pulp 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 investigations if performed in the subject country. The scope also includes high purity dissolving pulp that is commingled or blended with high purity dissolving pulp from sources not subject to these investigations. Only the subject component of such commingled or blended products is covered by the scope of these investigations.
Excluded from the scope is high purity dissolving pulp with an intrinsic viscosity under 455 milliliters per gram (mL/g), as measured by ISO 5351:2010.
Also excluded from the scope is cotton linters pulp that consists of at least 90 percent by weight, on an oven-dried basis, of cotton linters fibers.
High purity dissolving pulp products are classified under subheadings 4702.00.0020 and 4702.00.0040, of the Harmonized Tariff Schedule of the United States (HTSUS). High purity dissolving pulp products may also enter under subheadings 4706.30.0000 or 4706.92.0100. Reference to the HTSUS classifications is provided for convenience and customs purposes, and the written description of the merchandise under investigation is dispositive.