From US Transshipment Investigations to Canadian Anti-Dumping Duties: Three Calculations for China’s Paper Packaging Exporters

The factory is operating in Vietnam or Thailand, equipment has been installed and workers hired. Why might shipments to the United States still face anti-dumping duties?

Genuine overseas manufacturing may change a product’s country of origin, but it does not guarantee that the new origin is free from applicable trade measures.

From the US investigation into Chinese molded fiber products allegedly transshipped through Malaysia to Canadian duties on certain molded tableware and investigations into paperboard cups and containers, businesses must reassess pricing, cash flow and investment returns.

Three calculations belong together: duties, delivery and manufacturing footprint. Once those are clear, a longer-term question remains: when duty differentials change, why will customers keep choosing your products?

Duties: identify your goods before focusing on headline rates

Two Canadian cases provide a practical reminder.

The first concerns thermoformed molded fiber plates, platters and bowls that meet the product definition and originate in or are exported from China. Following the Canadian International Trade Tribunal’s injury finding on June 26, 2026, the related anti-dumping and countervailing measures entered the duty-collection stage.

The Canada Border Services Agency’s measures-in-force page states that, for subject imports from exporters without specific normal values, anti-dumping duty is 332.4% of the export price; for exporters without a specific amount of subsidy, the listed countervailing duty is RMB 4.83 per kilogram.

One is calculated by value and the other by weight. Actual calculations must also account for the treatment applicable to the exporter and rules such as adjustments for export subsidies. These figures are not a common tax bill for every Chinese paper packaging company.

For exporters with normal values, this statutory price benchmark must be compared with the export price under the applicable rules. Dumping margins reported for the investigation period in a final determination cannot simply be treated as the duty rate on every subsequent shipment.

Responding to investigations, identifying product models and managing normal values are directly connected to future quotations and orders. They cannot be treated merely as paperwork to complete before customs clearance.

The second is a separate investigation into certain wound paperboard cups and containers originating in or exported from China. It began on August 17, 2026, followed by a preliminary injury determination on October 16. According to the official schedule checked on October 22, the next milestone is a preliminary determination or termination of the investigations on November 16. The 332.4% figure from the molded tableware measure cannot be applied to this case.

The scope also includes certain die-cut cup and container blanks ready for forming. Printed rolls that have not been die-cut fall outside the product definition. The case also specifies exclusions.

For base paper suppliers, coaters and converters, this distinction matters: raw materials, intermediate products and finished goods within the same supply chain must be described and assessed separately. Tariff classification numbers help locate information, but coverage depends on the written product definition and exclusions.

Accurate product identification is the starting point for calculating duties.

Delivery: duty rates affect margins; collection timing affects cash flow

The US case raises another question: how much funding and documentation must be ready before the goods are released?

In a notice dated September 9, 2026, US Customs and Border Protection announced the initiation of an investigation and interim measures in EAPA Consolidated Case 8308. CBP stated that it had reasonable suspicion that Chinese thermoformed molded fiber products imported by three companies had been transshipped through Malaysia to evade applicable anti-dumping and countervailing duties.

This is an investigation with interim measures, not a final determination of evasion or a prohibition on all legitimate transit trade. The interim measures require the importers concerned to provide appropriate entry documentation and pay duties on covered goods before release, alongside suspension or extension of liquidation and a review of bonding arrangements.

Both parties need to assess funding requirements together with release conditions. Inspections, delivery delays or additional storage may change the economics of an order that initially appeared profitable.

There is also a date to watch in Canada’s paperboard cups and containers case. The statement of reasons for initiation explains that an affirmative preliminary determination could trigger provisional duties on subject imports released from that date onward.

An order must remain commercially viable at release, as well as when it is signed.

Businesses negotiating delivery schedules should clarify responsibilities with customers in advance: who handles import declarations, who funds additional duties and deposits, who bears inspection or delay costs, and which documents must be ready before shipment.

Ordinary customs duties, additional tariffs, anti-dumping and countervailing duties, and other import taxes and charges must each be assessed under their own conditions. Cash deposits under the relevant US measures remain subject to subsequent assessment; they do not necessarily fix the final duty liability.

A contract can allocate costs between the parties, but cannot alter statutory liability. Clear responsibilities and timing are essential to judging whether the margin in a quotation can actually be realized.

Manufacturing footprint: why can an overseas factory still face anti-dumping duties?

The US anti-dumping and countervailing duty orders on thermoformed molded fiber products published on January 27, 2026, explicitly cover China and Vietnam. Goods genuinely manufactured in Vietnam and legally determined to be of Vietnamese origin may therefore still fall under the measures applicable to Vietnam if they are within scope.

In this situation, the issue is that Vietnam itself is covered by the orders, rather than an investigation into transshipment.

Thailand also requires product-specific assessment. The US anti-dumping order on certain paper plates published on March 20, 2025, covers China, Thailand and Vietnam. It expressly excludes paper plates molded or pressed directly from pulp, so it must not be confused with the thermoformed molded fiber products case.

Within one country, paper plates, molded tableware, paper cups and paper bags may face different measures. Each assessment should consider the specific product, origin, destination market, and producer–exporter combination.

Adding a processing step in a third country does not replace this assessment. The relevant US molded fiber orders already cover certain further processing in third countries, including coating, laminating, printing and repackaging. Origin and scope must be checked against the actual manufacturing operations, applicable rules and production records.

This does not mean overseas factories lack investment value. Proximity to customers, shorter lead times, access to local markets and supply-chain diversification can still create value. Actual duties may also differ by origin and company.

However, if a project’s returns depend mainly on the assumption that relocation will provide lasting avoidance of these duties, that assumption needs to be tested again:

If the duty advantage narrows, will the factory remain competitive in customers, efficiency, quality and service?

Local materials, labor, energy, yield, logistics, taxes, duties and working capital must be assessed together to determine whether additional capacity is viable over the long term. A key risk is adding fixed costs while overestimating how long a duty advantage will last.

Choosing an export market also requires more than a single tariff headline.

Mexico’s tariff reform text published on December 29, 2025, effective January 1, 2026, lists a 25% rate for specified tariff lines covering corrugated cartons, non-corrugated folding cartons, and certain paper tableware and molded pulp articles. This is the rate for those tariff lines, not an additional 25 percentage points on top of an existing rate. Actual transactions still require checks for later amendments and preferential arrangements.

Australia offers preferences under the China–Australia Free Trade Agreement for qualifying goods. Official guidance states that ordinary customs duties under the agreement have been eliminated for goods meeting Chinese origin and documentation requirements. Other taxes and any applicable trade remedies must be checked separately.

The EU and UK also impose product and responsibility requirements beyond tariffs. The EU Packaging and Packaging Waste Regulation (PPWR) began applying in phases on August 12, 2026, including limits on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. In the UK, qualifying packaging suppliers, importers and other businesses have extended producer responsibility obligations, including data reporting and applicable fees.

Exporters and customers therefore need to prepare information on material composition, packaging weight, intended use and test documentation together. Market requirements vary, and opportunities must be assessed product by product and market by market.

When duty advantages change, why will customers keep choosing you?

These three calculations help identify markets worth investing in. The next challenge is to make the packaging customers need and deliver it reliably and economically.

Hot-drink paper cups require secure bottom and side-seam seals. Food wrapping paper must combine grease resistance with barrier performance after folding. Meal containers must also withstand forming, transport and actual use. Packaging requirements in different markets ultimately depend on how materials, base paper, coatings and finished products work together.

As manufacturing crosses borders, product capabilities must travel with it.

This is where BIOTEN’s PHA water-based barrier technology can create long-term value. Based on bio-based materials and aqueous coating processes, it connects base paper, barrier layers, processing conditions and end-use needs, helping partners develop paper-based packaging with defined applications, stable processes and supporting product documentation.

For paper mills, this means matching fiber blends, paper strength and surface properties to specific applications. For coaters, it means developing stable processes around dry coat weight, drying, line speed and subsequent converting. For paper cup and foodservice packaging manufacturers, it means delivering barrier, heat-sealing and forming performance in the complete article, while assessing economics through yield and total cost per thousand conforming packs.

In material sourcing, bio-based PHA components offer an option for reducing reliance on fossil feedstocks. In product design, material use can be optimized for the application, while appropriate fiber-recycling or composting pathways are developed with the complete paper product and target market in mind. This reflects BIOTEN’s application approach: reduction at source, recovery at end of life, and biodegradation where appropriate.

These capabilities address lasting customer needs rather than a temporary duty differential. They must develop alongside trade compliance: material solutions are evaluated for the finished product’s intended use, while tariff treatment is assessed against the specific product, origin and applicable measures.

BIOTEN welcomes joint development with paper mills, coaters, paper cup makers and foodservice packaging manufacturers, starting with one target market, one representative product and actual production-line conditions. Whether manufacturing is based in China or overseas, the aim is to build shared product specifications, process knowledge, quality requirements and documentation that support further applications.

All three calculations must reconcile within the same order. Technical and production teams define the product; trade, compliance and import partners verify the rules; finance and commercial teams assess returns together. First identify the business worth pursuing, then use materials and application innovation to make it more valuable.

As China’s paper packaging industry expands globally, it should bring more than production capacity: products customers choose repeatedly, and the ability to keep solving new problems.