New AD/CVD Petition: Paper File Folders from China, India, and Vietnam

On October 12, 2022, the Coalition of Domestic Folder Manufacturers, comprised of two U.S. producers, Smead Manufacturing Co, Inc. and TOPS Products, LLC, filed antidumping (AD) and countervailing duty (CVD) petitions against U.S. imports of certain paper file folders (“folders”) from China, India, and Vietnam.

The paper file folders from China are already subject to 25 percent tariffs that were imposed on Chinese imports by President Trump. The domestic producers now seek additional protection in the form of AD and CVD duties to be imposed on paper file folders imported from the three named countries.

Although the coronavirus pandemic caused weaker demand for office products, including paper file folders, the petition notes that demand for paper file folders has rebounded since 2021. Imports have sharply increased in 2022 and have taken market share from U.S. producers due to significant underselling, according to the petition.

The U.S. Department of Commerce (“DOC”) and U.S. International Trade Commission (“ITC”) will conduct investigations to further examine the allegations made in the petition. DOC will investigate whether the named subject imports are being sold to the United States at less than fair value (“dumping”) or benefit from unfair government subsidies. The ITC will investigate whether the subject imports are causing “material injury” or “threat of material injury” to the domestic industry.


The petition proposes the scope of the merchandise to be covered by these AD/CVD investigations as “file folders consisting primarily of paper, paperboard, pressboard, or other cellulose material,” and “typically are used to hold letter and legal size documents, have the following dimensions in their folded and closed position: a length and width of at least 8 inches and no greater than 17 inches, regardless of depth.” There are certain exclusions for products not meant to be covered by this AD/CVD investigation, including certain mailing envelopes, binders, non-expanding folders, fashion folders, portfolios, and report covers.

See the proposed scope definition for a complete description of the physical characteristics of the covered and excluded merchandise, and the HTS numbers that may be used to import the subject merchandise.

Alleged AD/CVD Margins

Petitioner provided one estimated dumping margin of 84.51% to 202.26% for Chinese folders, 120.50% to 227.88% for Indian folders, 182.67% to 236.38% for Vietnamese folders.

Although Petitioner alleged numerous government subsidy programs that benefitted the Chinese and Indian paper file folder industries, Petitioner did not allege any specific subsidy rates.

Named Exporters/ Producers

Petitioner included a list of companies that it believes are producers and exporters of the subject merchandise. See attached list here.

Named U.S. Importers

Petitioner included a list of companies that it believes are U.S. importers of the subject merchandise. See attached list here.

Investigations Schedule 

October 12, 2022 – Petitions filed

November 1, 2022 – DOC initiates investigation

November 2, 2022 – ITC Staff Conference

November 26, 2022 – ITC preliminary determination

March 11, 2023 – DOC CVD preliminary determination (assuming extended deadline) (1/5/23 – unextended)

May 10, 2023 – DOC AD preliminary determination (assuming extended deadline) (3/21/23 – unextended)

September 22, 2023 – DOC AD/CVD final determination (extended)

November 6, 2023 – ITC final determination (extended)

November 13, 2023 – DOC AD/CVD orders issued (extended)