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CBSA INVESTIGATING THERMAL PAPER

DUMPING OF THERMAL PAPER FROM CHINA

On June 12, 2025, the Canada Border Services Agency (“CBSA”) issued a Notice of Initiation of Investigation under the Special Import Measures Act (“SIMA”) in respect of the alleged dumping of certain thermal paper rolls originating in or exported from the People’s Republic of China (“China”).  This investigation was prompted by a complaint filed by three Canadian manufacturers.

The investigation continues a trend by the CBSA of scrutinizing imports from China, which continues to be the jurisdiction with highest number of Anti-Dumping and Countervailing duty orders.

The Subject Goods

The goods under investigation are more specifically described as:

Thermal paper rolls in nominal widths up to and including 15 centimetres, with a nominal paper weight of 70 grams per square meter (“gsm”) or less and a thermal active coating on one or both sides comprised of a dye and a developer that react and form an image when heat is applied, excluding thermal paper rolls with an adhesive backing, originating in or exported from the People’s Republic of China (the “Subject Goods”).

Parallel CITT Investigation

On June 13, 2025, the CITT issued a notice initiating a preliminary injury inquiry in respect of the same Subject Goods, which is a parallel process to determine whether the alleged dumping has caused or is threatening to cause injury to the Canadian industry.

Why Do I Care?

If the CBSA and CITT ultimately conclude that dumping of the Subject Goods has caused injury or is threatening to cause injury to the Canadian industry, Anti-Dumping Duties (“ADDs”) or Countervailing Duties (“CVD”) will be imposed, effectively increasing the costs of the Subject Goods.

Anti-dumping investigations offer Canadian importers and foreign exporters and producers the opportunity to participate in the CBSA investigation and obtain their own specific Normal Values, which are preferable to the ADDs payable on imports from producers who do not have Normal Values.

It may  also be possible to request a product exclusion from the CITT on the basis that certain goods are unique and the Canadian industry is incapable of manufacturing a substitutable product.

What is the Timeline for Next Steps?

Under the Special Import Measures Act (“SIMA”), the matter will proceed along two parallel tracks:

• The CBSA will send out Requests for Information: Importer must respond by July 2nd and exporters by July 21; and
• The CITT requires any interest participants and their counsel to file Forms with the CITT by June 25, and any opposing submissions must be filed by noon on July 11.

The CITT’s preliminary determination is expected by August 11, 2025, and CBSA’s preliminary determination is expected by September 10, 2025, each followed by a Statement of Reasons 15 days later.

How Do I Get Involved?

Specialized legal advice is generally required. Given the strict timelines, and amount of work involved in responding to CBSA and CITT questionnaires, any parties potentially impacted should contact their lawyers immediately to discuss next steps – regardless of whether you have received a questionnaire!

For help with a Dumping Investigation, please click here.

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