Korean Thermal Paper AD Review: 1.69% Margin

The Korean thermal paper antidumping review has produced a preliminary 1.69 percent margin for Hansol Paper Company, but importers should not adjust current cash deposits yet. The partial rescission for 16 companies also creates distinct assessment, liquidation, and supplier verification considerations for brokers and compliance teams.

Preliminary Results and Scope of the Review

Hansol Receives a Preliminary 1.69 Percent Margin

The 2024-2025 administrative review covers thermal paper from the Republic of Korea entered during the period from November 1, 2024, through October 31, 2025. Commerce selected Hansol Paper Company as the sole mandatory respondent and preliminarily calculated a weighted-average dumping margin of 1.69 percent using constructed export price methodology.

This rate remains preliminary. It does not immediately replace the cash deposit rate currently applied to new entries of Hansol merchandise. Cash deposit requirements generally change only after Commerce publishes the final results and issues the corresponding instructions to U.S. Customs and Border Protection.

Importers should therefore distinguish between two separate financial effects. The first is the potential assessment rate applied when entries from the period of review liquidate. The second is the prospective cash deposit rate applied to entries made after the final results become effective. Although both may ultimately reflect the final calculated margin, they affect different entry populations and different accounting periods.

Review Rescinded for 16 Companies

Commerce rescinded the review for 16 companies after the parties that requested review withdrew those requests. The affected entities include companies such as Sailing Paper (Malaysia) Sdn. Bhd., ShenZhen Sailing Paper Co., Ltd., Kooka Paper Manufacturing Sdn. Bhd., and Formas para Negocios, S.A. de C.V.

Entries associated with rescinded companies are generally assessed at the antidumping cash deposit rate in effect on the date of entry. They do not receive Hansol's preliminary 1.69 percent margin merely because Hansol was the mandatory respondent in the remaining portion of the review.

This distinction makes accurate manufacturer, exporter, intermediary, and case-number data essential. Importers should not rely solely on the commercial seller's name when determining which rate treatment may apply.

Importer, Distributor, and Broker Implications

Current Cash Deposits Remain Unchanged

The preliminary results do not change current antidumping duty deposit requirements. The all-others cash deposit rate remains 6.19 percent, and other company-specific rates generally continue until superseded by final instructions or another applicable determination.

Importers should avoid changing duty accruals solely because Hansol's preliminary margin is lower than the rate deposited at entry. A preliminary result can change before the final determination due to briefing, corrections, verification issues, methodological revisions, or other administrative developments. Any expected refund should remain a contingent receivable rather than a settled recovery.

For entries produced or exported by Hansol during the review period, compliance teams can model liquidation using the 1.69 percent preliminary margin and compare that amount with deposits paid. The resulting variance can help with financial planning, but it should not be treated as a final refund or liability.

Reseller Transactions Require Additional Review

Thermal paper frequently moves through trading companies, distributors, and converters before reaching the United States. These structures can complicate antidumping duty assessment because the producer may not always know that the merchandise is destined for the U.S. market.

Under the reseller policy applicable to this review, Hansol-produced merchandise may liquidate at the investigation all-others rate when Hansol did not know the U.S. destination and no applicable intermediary rate exists. Importers should examine purchase orders, mill documentation, invoices, shipping records, and communications showing whether the producer knew the ultimate destination.

The name shown as the foreign seller on an entry summary does not necessarily establish the manufacturer, exporter, or applicable assessment rate. Brokers should preserve the party chain at the line level and flag inconsistencies before liquidation instructions are issued.

Sunset Reviews Are a Separate Process

The five-year sunset reviews covering thermal paper orders from Germany, Japan, Korea, and Spain proceed separately from this administrative review. The sunset process addresses whether an order should remain in place. It does not suspend current deposit requirements or determine the assessment rate for the 2024-2025 review period.

Compliance Priorities Before the Final Results

Validate Supplier and Entry Populations

Importers should first identify every entry of Korean thermal paper made from November 1, 2024, through October 31, 2025. The review should separate Hansol transactions, entries involving any of the 16 rescinded companies, and transactions involving intermediaries or unidentified mills.

Relevant data should include manufacturer identification, exporter name, seller name, entry date, entered value, antidumping duty deposit, ordinary customs duty, and current liquidation status. Product descriptions should also be checked against the scope language rather than relying exclusively on tariff classification or commercial terminology.

Model Potential Assessment Outcomes

For Hansol entries, companies can compare deposits paid with a preliminary assessment scenario based on 1.69 percent. Models should also include alternative outcomes, such as a revised final margin or an importer-specific assessment rate where applicable.

If Hansol's final weighted-average margin is zero or de minimis, generally below 0.50 percent for this type of proceeding, qualifying entries may liquidate without antidumping duties. That possibility should not be assumed while the result remains preliminary.

For rescinded companies, the model should generally retain the cash deposit rate in effect at entry. Rescission instructions are expected no earlier than 35 days after publication, which produces a calculated earliest date of November 23, 2026.

Calendar Briefing and Certification Deadlines

Case briefs are due no later than 21 days after the October 19, 2026 publication date, producing a calculated date of November 9, 2026. Rebuttal briefs are due five days after case briefs, and hearing requests are due within 30 days of publication, producing calculated dates of November 14 and November 18, respectively. Parties should verify exact filing deadlines and any deadline adjustments in Commerce's electronic filing system.

Importers must also address the required reimbursement certification. Failure to provide the appropriate certification can generally lead to the presumption that antidumping duties were reimbursed, potentially resulting in double assessment.

Finally, accounting teams should keep antidumping and countervailing duties separate from ordinary customs duties. AD/CVD duties are not eligible for duty drawback under 19 U.S.C. 1677h, although ordinary customs duties on the same entries may still qualify when the merchandise is exported or destroyed and all other drawback requirements are satisfied.

Frequently Asked Questions

Does the 1.69 Percent Preliminary Margin Change Deposits Now?

No. The preliminary margin does not immediately change cash deposits on new entries. Existing deposit requirements generally remain in effect until Commerce publishes final results and U.S. Customs and Border Protection receives updated instructions.

Which Entries Are Covered by This Administrative Review?

The review covers subject thermal paper from Korea entered from November 1, 2024, through October 31, 2025. Whether a particular entry receives Hansol's result depends on the manufacturer, exporter, sales chain, review status, and final assessment instructions.

What Happens to Entries From the 16 Rescinded Companies?

Those entries are generally assessed at the antidumping duty cash deposit rate that applied on the entry date. The rescinded companies do not automatically receive Hansol's preliminary or final rate.

What If Hansol Did Not Know the Goods Were Destined for the United States?

Hansol-produced merchandise may be subject to the investigation all-others rate when Hansol lacked knowledge of the U.S. destination and no intermediary-specific rate applies. Documentation of the complete sales and shipping chain is critical to evaluating this risk.

Can Antidumping Duties Be Recovered Through Duty Drawback?

No. Antidumping and countervailing duties are not eligible for drawback. Ordinary customs duties paid on the same entry may remain eligible if the goods are subsequently exported or destroyed and the claim satisfies the applicable drawback requirements.

Could the Preliminary Margin Change in the Final Results?

Yes. Commerce may revise calculations or methodology after reviewing case briefs, rebuttal arguments, factual corrections, and other issues. Importers should model the 1.69 percent rate without treating it as a final assessment or guaranteed refund.

How Stable Software Can Help

Separate Drawback-Eligible Duties From AD/CVD Amounts

The Korean thermal paper review illustrates why importers and customs brokers need to distinguish ordinary customs duties from antidumping and countervailing duty deposits at the entry-line level. AD/CVD amounts cannot be included in drawback claims, even when ordinary duties on the same merchandise may qualify after exportation or destruction.

DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file claims under their own filer code. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating ordinary-duty recovery opportunities can explore whether DrawbackAI fits their drawback service model while maintaining the necessary separation from non-eligible AD/CVD deposits.

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