Case A-428-850

Koehler's dumping margin on German thermal paper came out at zero, and the rate everybody else deposits stays at 6.27 percent

Money & World

The Editorial Team · August 1, 2026

Photo: Jessica Lewis / Pexels

What it changes

If you import thermal paper, the practical content of this notice is two different numbers doing two different jobs, and confusing them is expensive. Koehler Paper SE and Koehler Kehl GmbH come out of the 2023 to 2024 review at 0.00 percent, so Commerce will instruct Customs to liquidate the appropriate entries for that period without regard to antidumping duties, and the cash deposit rate going forward for those companies is the rate established in these final results. That is the specific number and it belongs to specific parties. The general number did not move. For all other producers and exporters the cash deposit rate continues at 6.27 percent, the all-others rate from the amended final determination that followed a court decision in December 2025, and the notice says those requirements remain in effect until further notice. A zero for the examined respondent does not open the door for anybody else, and the two companies Commerce did not examine individually were assigned 0.76 percent rather than zero precisely because the statute normally excludes zero margins when a rate is built for non-examined parties. The timing matters if entries are sitting unliquidated. Commerce intends to issue assessment instructions no earlier than 35 days after publication, and publication is set for 3 August. If somebody files a timely summons at the Court of International Trade, the instructions will tell Customs to hold liquidation until the window for requesting a statutory injunction closes, within 90 days of publication. Importers also get the standard reminder that a reimbursement certificate must be filed before liquidation, and that failing to file it can lead Commerce to presume reimbursement occurred and to assess double duties. One detail is worth noticing rather than explaining. Two of the three companies in the table, Convertidoras PCM and Papeles y Conversiones de Mexico, are Mexican companies appearing in an order on paper from Germany, listed by Commerce under the heading Exporter and Producer. The notice does not describe their role, and nothing here fills that in. The quietest fact in the document is that nobody objected: no interested party commented on the preliminary results, so there were no changes, no decision memorandum, and no calculations to disclose.

Zero.

That is the weighted-average dumping margin Commerce has assigned to Koehler Paper SE and Koehler Kehl GmbH for thermal paper entering the United States between 1 November 2023 and 31 October 2024. The finding is stated flatly in the summary of the notice: thermal paper from Germany was not sold in the United States at less than normal value during the period. Nobody argued about it. Commerce published preliminary results on 27 March, invited comment, received none from any interested party, made no changes, and issued the final result with no decision memorandum attached and no new calculations to disclose.

The other two names

The table carries three entries and only one of them is German.

Convertidoras PCM, S.A. de C.V. and Papeles y Conversiones de Mexico, S.A. de C.V. are listed under the heading Exporter and Producer at 0.76 percent each. Commerce identifies them as companies not selected for individual examination. Their rate is built rather than calculated: because Koehler's rate came out at zero, and because section 735(c)(5)(A) normally excludes zero and de minimis margins when a rate is set for non-examined parties, Commerce reached back for the most recent above-de minimis figure in the proceeding, which was 0.76 percent from the 2021 to 2022 review.

The notice does not say what the two Mexican companies do in an order on German paper.

What stays

The all-others cash deposit rate is untouched at 6.27 percent.

That figure comes from the amended final determination issued on 29 December 2025, after a Court of International Trade decision the notice describes as not in harmony with the original final determination of the investigation. The underlying orders, covering Germany, Japan, Korea and Spain, date to November 2021. Commerce intends to issue assessment instructions to Customs no earlier than 35 days after publication, which is set for 3 August, unless a summons at the trade court holds liquidation open.

The document: Department of Commerce, International Trade Administration, Enforcement and Compliance, case A-428-850, Thermal Paper from Germany: Final Results of Antidumping Duty Administrative Review; 2023-2024. FR Doc. 2026-15664, filed for public inspection at 08:45 on 31 July 2026, publication date 3 August 2026, signed by Christopher Abbott, Deputy Assistant Secretary for Policy and Negotiations, performing the non-exclusive functions and duties of the Assistant Secretary for Enforcement and Compliance, dated 27 July 2026. The raw text of the notice was fetched from federalregister.gov and read in full here; no fetch-tool summary was relied on, and every figure, date, company name and citation below was matched against that text. Verified: Commerce determines that thermal paper from Germany was not sold in the United States at less than normal value during the period of review 1 November 2023 through 31 October 2024. Procedural history as verified: Commerce published the Preliminary Results on 27 March 2026 at 91 FR 14809 and invited comment; no comments were received from interested parties; Commerce therefore made no changes from the Preliminary Results and there is no decision memorandum accompanying the notice; and because no changes were made there are no new calculations to disclose under 19 CFR 351.224(b). The review was conducted under section 751 of the Tariff Act of 1930, as amended. The margin table as verified, reproduced exactly: Koehler Paper SE and Koehler Kehl GmbH, 0.00 percent; Convertidoras PCM, S.A. de C.V., 0.76 percent; Papeles y Conversiones de Mexico, S.A. de C.V., 0.76 percent. The notice heads that column Exporter/Producer and identifies Convertidoras and Papeles as companies not selected for individual examination. Reasoning as verified: because the rate calculated for Koehler in this review is zero, Commerce looked to section 735(c)(5)(A) of the Act, under which the all-others rate normally excludes zero and de minimis margins, and assigned the non-examined companies the most recent above-de minimis rate calculated in the proceeding, 0.76 percent, citing Thermal Paper From the Federal Republic of Germany: Final Results of Antidumping Duty Administrative Review; 2021-2022, 89 FR 47517, 47518, 3 June 2024. Assessment as verified: because Koehler's weighted-average dumping margin is zero, Commerce will instruct Customs and Border Protection to liquidate the appropriate entries without regard to antidumping duties, and the automatic assessment practice at 68 FR 23954, 6 May 2003, applies to entries produced by Koehler for which the reviewed company did not know the merchandise sold to an intermediary was destined for the United States; Convertidoras and Papeles are assessed at the 0.76 percent review-specific rate; Commerce intends to issue assessment instructions no earlier than 35 days after publication; and if a timely summons is filed at the Court of International Trade the instructions will direct Customs not to liquidate relevant entries until the time to request a statutory injunction has expired, within 90 days of publication. Cash deposit requirements as verified: effective on publication, the cash deposit rate for the companies listed is the weighted-average dumping margin established in these final results; for previously investigated or reviewed companies not listed, the company-specific rate from the most recently completed segment in which the company participated; where the exporter is not covered but the producer is, the producer's rate; and for all other producers and exporters the rate continues to be 6.27 percent, the all-others rate established in the Amended Final Determination. The underlying order is Thermal Paper from Germany, Japan, the Republic of Korea, and Spain: Antidumping Duty Orders, 86 FR 66284, 22 November 2021. The Amended Final Determination is cited in the notice as Thermal Paper from Germany: Notice of Court Decision Not in Harmony with the Final Determination of Antidumping Investigation; Notice of Amended Final Determination; Notice of Amended Order, In Part, 90 FR 60617, 29 December 2025. The notice states no reason why no interested party commented, gives no import volumes or values, and contains no allegation of conduct against any party; none of those things is asserted below..

Koehler's dumping margin on German thermal paper came out at zero, and the rate everybody else deposits stays at 6.27 percent

The other two names

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