ANTICIRCUMVENTION WORKING GROUP OF THE AMERICAN PAPER PLATE COALITION WELCOMES INITIATION OF COUNTRY-WIDE INVESTIGATIONS OF CIRCUMVENTION BY MALAYSIAN AND CAMBODIAN PRODUCERS AND EXPORTERS
In March 2025, Commerce imposed substantial AD and CVD duties on all imports of paper plates from China, Thailand, and Vietnam. These duties were imposed after the APPC petitioned Commerce for help in January 2024. On July 8, 2025, the AWG requested these new investigations because, within weeks of Commerce starting the AD and CVD investigations, Chinese companies began moving paper plate finishing operations to Cambodia and Malaysia in order to circumvent the AD and CVD duties arising from those investigations.
The AWG's circumvention inquiry requests provided extensive evidence of circumvention, including public statements by Malaysian and Cambodian companies admitting that they moved paper plate production from China to circumvent the AD and CVD duties.
After careful review of the AWG's requests, Commerce found not only that they provided sufficient evidence of circumvention to warrant formal investigations, but that they provided enough evidence to justify investigating all producers and exporters in both Malaysia and Cambodia. Commerce also expressly left open the possibility of retroactive application of duties if it concludes that papers plates from Malaysia and Cambodia indeed are circumventing the AD and CVD orders.
“We welcome initiation of these investigations and thank the hard-working Commerce staff who are working on these important proceedings,” said Robert Epstein, President and CEO of AJM Packaging Corporation, a member of the AWG and APPC. “We are confident that the evidence to be collected and extensive audits to be conducted will support a favorable outcome for the American paper plate industry.”
Under the U.S. trade laws, if Commerce finds that Malaysian and Cambodian producers are circumventing, Commerce may extend the China AD and CVD duties to cover those imports. Moreover, the AWG has asked Commerce to impose duties on Malaysian and Cambodian imports retroactively on circumventing imports, which Commerce has the power to do. As noted above, Commerce has expressly left open the possibility of retroactive duty application.
“Our clients look forward to probing investigations of the Malaysian and Cambodian producers that will be examined by Commerce,” said Adam H. Gordon of The Bristol Group PLLC, counsel to the AWG and APPC . “Reflecting our strong commitment to using the full force of the trade laws to expose and stop such schemes, we will be actively involved at every step of this process and will seek the retroactive application of duties on all entities found circumventing.”
Commerce will gather detailed information from Malaysian and Cambodian companies it selects for individual examination, and will issue preliminary determinations in the coming months. Commerce has until mid-June 2026 to issue final determinations in both investigations.
About the Anticircumvention Working Group of the American Paper Plate Coalition
The Anticircumvention Working Group of the American Paper Plate Coalition, representing leading U.S. producers of paper plates, is comprised of AJM Packaging Corporation of Bloomfield Hills, MI; Aspen Products, Inc. of Kansas City, MO; Dart Container Corporation of Mason, MI; Hoffmaster Group, Inc. of Oshkosh, WI; and Unique Industries, Inc. of Philadelphia, PA.
For more information, visit /; /; , /; and .
The Anticircumvention Working Group of the American Paper Plate Coalition is represented by Adam H. Gordon, Esq. of The Bristol Group PLLC, a Washington, D.C. international trade law firm specializing in defending American industry, agriculture and jobs from unfair trade.
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