High purity dissolving pulp duties on merchandise from Brazil have reached final affirmative Commerce determinations, creating immediate classification, deposit, and entry-timing concerns. Importers and customs brokers must distinguish the final calculated rates from current cash deposit requirements while preparing for a separate injury decision that will determine whether duty orders are issued.
Final Brazil AD and CVD Rates
Commerce finalized both antidumping and countervailing duty determinations for high purity dissolving pulp from Brazil on October 16, 2026. The antidumping proceeding is identified as A-351-866, while the countervailing duty proceeding is C-351-867.
Bracell and All-Others Rates
For antidumping purposes, Bracell Bahia Specialty Cellulose S.A. and Bracell SP Celulose Ltda. were treated as a single entity. Commerce calculated a final estimated weighted-average dumping margin of 6.50 percent for that entity. The same 6.50 percent margin applies to all other Brazilian producers and exporters covered by the proceeding.
The antidumping cash deposit rate is 6.40 percent for Bracell and all others after the applicable subsidy offset. This distinction matters operationally. The 6.50 percent figure is the final estimated dumping margin, but 6.40 percent is the rate generally used for current antidumping cash deposits.
Commerce also calculated a final countervailing duty subsidy rate of 9.37 percent ad valorem for Bracell Bahia Specialty Cellulose S.A. and all other covered Brazilian producers and exporters. Cross-owned entities associated with Bracell include Bracell Bahia Florestal Ltda., Bracell SP Celulose Limitada, and Bracell SP Florestal Ltda.
If a countervailing duty order is issued and both deposit requirements apply, the stated AD and CVD cash deposit rates would produce a combined nominal deposit exposure of 15.77 percent. That calculation is useful for forecasting, but it should not be treated as a final duty assessment or as confirmation that a CVD order will be issued.
Scope Determines Whether Merchandise Is Covered
The tariff number alone does not determine whether imported pulp is subject to these proceedings. Importers should evaluate the physical and technical characteristics of each product against the complete written scope.
Technical Characteristics of Covered HPDP
Covered high purity dissolving pulp generally has alpha cellulose content of at least 90 percent by weight on an oven dry basis, calculated using the specified ISO 692:1982 formula. It must also have brightness of at least 90 percent under ISO 2470-1:2016.
The pulp may be produced from virgin or recycled cellulose fiber. It may enter in dried form or as a slurry, so packaging, moisture content, or shipment format does not necessarily remove a product from scope. Relevant applications can include cellulose ethers and other specialty cellulose products, but end use generally does not replace a technical scope analysis.
HTSUS subheadings 4702.00.0020 and 4702.00.0040 are useful classification references. Covered merchandise may also enter under 4706.30.0000 or 4706.92.0100. These tariff provisions are provided for customs convenience, while the written product description controls the scope determination.
Exclusions Require Supporting Specifications
The scope excludes certain high purity dissolving pulp with intrinsic viscosity below 455 mL/g under ISO 5351:2010. It also excludes qualifying cotton linters pulp that satisfies the applicable cotton-linters exclusion.
Importers relying on an exclusion should maintain specifications, laboratory data, supplier certifications, purchase records, and product literature that substantiate the relevant characteristics. Product descriptions such as specialty pulp or cellulose pulp are generally insufficient by themselves. Brokers should avoid making scope conclusions based solely on invoice terminology or HTSUS classification.
Entry Dates Control Deposit Treatment
AD/CVD compliance requires more than applying a percentage to entered value. The correct treatment depends on the type of proceeding, the entry date, the producer-exporter combination, and whether suspension of liquidation was active when the merchandise entered.
Antidumping Suspension Continues
For the antidumping proceeding, suspension of liquidation continues for covered entries made on or after May 27, 2026. Cash deposits should be made at the final applicable rate, which is currently 6.40 percent for Bracell and all others after the subsidy offset.
Importers should review entries made on or after that date for scope accuracy, declared manufacturer and exporter information, deposit calculations, and liquidation status. Corrections should be evaluated promptly because antidumping entries can remain suspended for an extended period and may ultimately be assessed at rates different from the deposit rate.
Countervailing Duty Treatment Includes a Gap Period
Countervailing duty deposits were initially collected beginning March 25, 2026. The provisional-measures period later ended. Suspension continued for entries made through July 22, 2026, but Commerce instructed CBP to discontinue suspension for entries made on or after July 23, 2026.
As a result, the 9.37 percent final CVD rate does not automatically mean that every current entry is subject to a CVD cash deposit. If the U.S. International Trade Commission reaches a final affirmative injury determination, a CVD order would generally reinstate suspension of liquidation and cash deposit requirements prospectively.
Customs brokers should therefore build entry-date logic into their review rather than applying the final CVD rate across all transactions. Importers should also preserve records for entries made during the provisional period, the post-provisional gap, and any period following a potential order.
Managing Exposure Before the Injury Decision
Commerce's affirmative determinations do not complete the trade remedy process. The U.S. International Trade Commission must separately determine whether the domestic industry is materially injured or threatened with material injury by the subject imports.
The ITC Outcome Remains Open
The final injury determination is due within 45 days of the Commerce determinations. An affirmative result would generally lead to issuance of AD and CVD orders, subject to the applicable procedural requirements. A negative result would terminate the investigations, lift suspension, and result in the return of relevant cash deposits.
Importers should not assume either outcome. Forecasts should model at least two scenarios: one in which orders are issued and ongoing deposits continue or resume, and another in which the proceedings terminate without orders.
Practical Controls for Importers and Brokers
A defensible compliance plan should begin with SKU-level scope mapping. Each imported product should be matched to alpha cellulose content, brightness, intrinsic viscosity, fiber source, and any claimed exclusion. Supplier and manufacturer identities should also be normalized across purchase orders, invoices, entry summaries, and technical records.
Financial models should separate the 6.40 percent AD cash deposit rate from the 9.37 percent CVD rate. If both apply after an affirmative injury determination, the combined nominal deposit is 15.77 percent of the relevant entered value. Importers should also account for the possibility that final assessed liability may differ from deposits because AD/CVD rates can be reviewed administratively.
Brokers should identify entries on or after May 27, 2026 for AD treatment, entries from March 25 through July 22, 2026 for the CVD provisional period, and entries on or after July 23, 2026 for the CVD gap period. Exception reporting can help prevent a single blanket rate from being applied to entries with different legal treatment.
- Commerce published final affirmative AD (A-351-866) and CVD (C-351-867) determinations for high purity dissolving pulp from Brazil on October 16, 2026 (dated October 9), with Bracell Bahia Specialty Cellulose S.A. and Bracell SP Celulose Ltda. treated as a single entity.* AD estimated weighted-average dumping margin is 6.50 percent for Bracell and all others (cash deposit rate 6.40 percent after subsidy offsets). CVD subsidy rate is 9.37 percent ad valorem for Bracell (including certain cross-owned affiliates) and all others. Suspension of liquidation continues for AD (from May 27, 2026 prelim); CVD provisional measures ended around July 23, 2026. ITC final injury determinations are due within 45 days (around late November 2026). Do not assume ITC outcome.
- ITC held its final-phase hearing on October 8, 2026.* Petitioners (Rayonier Advanced Materials and United Steelworkers) argued that dumped/subsidized imports from Brazil (and Norway) injure the U.S. industry. Respondents including Bracell and Borregaard contested the injury claims. Trade press (MLex) covered the testimony the same day.
- Trade media reported the Commerce finals promptly.* Law360 (October 15) and MLex (October 14) noted the 6.50 percent Brazil AD rate, 6.51 percent Norway AD rate, and 9.37 percent Brazil CVD rate, highlighting potential duties if ITC finds injury. Brazilian outlet VEJA (October 13) discussed Bracell’s exposure and possible higher export costs to the U.S. market.
- Limited recent practitioner discussion on X.* Searches for Bracell, HPDP, AD/CVD, dumping, or subsidy terms since mid-September 2026 returned no relevant posts. Earlier 2026 mentions were sparse and mostly recaps of ITC scheduling or prelims.
- No other major regulatory changes, policy updates, or industry announcements (e.g., on scope, verification outcomes, or related Section 301/232 overlays) appeared in the past 30 days beyond the above. Cash deposits and liquidation instructions remain in effect pending ITC.
Frequently Asked Questions
What Is the Final Bracell Antidumping Rate?
The final estimated weighted-average dumping margin is 6.50 percent. The applicable antidumping cash deposit rate is 6.40 percent after the subsidy offset. Bracell Bahia Specialty Cellulose S.A. and Bracell SP Celulose Ltda. are treated as a single entity for the antidumping determination.
What Is the Final Countervailing Duty Rate?
The final CVD subsidy rate is 9.37 percent ad valorem for Bracell and all other covered Brazilian producers and exporters. Current collection depends on the entry date and procedural status because the provisional-measures period ended before the final determination.
Do the AD and CVD Rates Apply to Every Brazilian Pulp Product?
No. The proceedings cover merchandise that meets the written description for high purity dissolving pulp. Alpha cellulose content, brightness, intrinsic viscosity, fiber type, and applicable exclusions should be evaluated. HTSUS classification can support screening, but it does not control the scope.
Is the Combined Deposit Rate 15.77 Percent?
The 6.40 percent AD cash deposit rate plus the 9.37 percent CVD rate equals a combined nominal exposure of 15.77 percent when both deposits apply. However, CVD collection is affected by the provisional-measures gap and the pending injury determination. The figure should therefore be used as a scenario assumption, not a universal rate for every entry.
What Happens if the ITC Makes a Negative Determination?
A negative final injury determination would generally terminate the investigations. Suspension of liquidation would be lifted, and cash deposits collected under the investigations would generally be refunded. Importers should still maintain complete entry and payment records until CBP implements the resulting instructions.
How Stable Software Can Help
Supporting Broker-Led Duty Drawback Programs
New AD/CVD exposure increases the importance of accurate import records, product matching, and duty data across the customs lifecycle. Customs brokers serving affected importers may also need to evaluate whether eligible duties associated with exported or destroyed merchandise can support a duty drawback claim, subject to applicable rules and exclusions.
DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating drawback opportunities can use this model to retain control of the client relationship and filing process without surrendering a share of recoveries.
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