New Trade Case Could Raise Costs for Corrugated Pizza Boxes from China, Malaysia, and Turkey

The Petitions

Antidumping (“AD”) petitions have been filed with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) concerning imports into the United States of corrugated pizza boxes from the People’s Republic of China (“China”), Malaysia, and the Republic of Türkiye (“Türkiye”). A countervailing duty (“CVD”) petition was also filed concerning imports from Türkiye. The petitions allege that subject imports are being, or are likely to be, sold in the United States at less than normal value, and that imports from Türkiye benefit from countervailable subsidies, causing material injury to the U.S. industry. If the federal agencies agree, these imports could become subject to significant additional duties.

The subject merchandise consists of certain corrugated food service boxes, commonly referred to as pizza boxes. The covered products are made from corrugated paper, paperboard, and/or cardboard and are used in the food service industry, primarily to hold pizza pies. They are often shipped flat as die-cut blanks that can be folded by the end user into ready-to-use boxes. The petitions state that approximately 95% of the covered food service boxes are pizza boxes, with the remainder largely consisting of certain side, sandwich, and catering boxes.

For importers, distributors, restaurant suppliers, pizza chains, food service companies, and other purchasers, these petitions are important because these investigations and the corresponding trade landscape move quickly. If Commerce issues affirmative preliminary determinations, U.S. importers may be required to post cash deposits on covered imports within months, potentially affecting pricing, sourcing decisions, contracts, and product availability.

Scope of the Investigations

The following language describes the imported merchandise that Petitioner intends to cover in these investigations:

The merchandise covered by these investigations is certain corrugated food service boxes, which are commonly referred to as pizza boxes. Corrugated food service boxes are a type of box or carton manufactured from paper, paperboard, and/or cardboard for use in the food service industry, including to hold pizza pies. Corrugated food service boxes are often shipped or delivered flat in bundles of corrugated cardboard die-cut blanks, which are in a ready-to-assemble state such that they can be easily folded by the end user into a ready-to-use food service box. The corrugated food service boxes covered by these investigations include corrugated cardboard die-cut blanks, whether finished or unfinished and assembled or unassembled.

Corrugated food service boxes are produced from corrugated cardboard sheets that are made from recycled or virgin paper or paperboard materials, which may be bleached or unbleached. These cardboard sheets are “corrugated” or “fluted,” which means that they contain at least two outer layers (i.e., top and bottom) of paper or paperboard and an inside layer of fluted paper or paperboard in between the outer layers, such that the inside layer contains channels or pockets of air which makes the cardboard sheet lightweight while retaining strength and durability. The subject merchandise includes corrugated food service boxes of B-flute, C-flute, D-flute, and E-flute design, as well as any equivalent types of corrugation or fluting.

The country of origin of a subject corrugated food service box is determined by where the corrugated cardboard sheet is produced. Corrugated cardboard die-cut blanks are typically formed from corrugated cardboard sheets that are cut to length, die cut into specific box shapes, and/or scored to allow the box to be folded into shape. Subject corrugated food service boxes are typically assembled by the end user by folding a corrugated cardboard die-cut blank into its final shape. Subject corrugated die-cut blanks are not typically glued into their final shape. The scope covers both corrugated food service boxes and corrugated cardboard die-cut blanks, regardless of whether they are finished or assembled at the time of importation.

The subject merchandise includes corrugated food service boxes regardless of shape. When assembled, subject corrugated food service boxes are often rectangular or square in shape when viewed from above, but they may take on other shapes, such as round, hexagonal, or octagonal. A finished and assembled subject corrugated food service box has a length (i.e., the longest dimension) that is at least five inches and a width that is at least five inches. There is no maximum length or width for subject merchandise. The height (i.e., the shortest dimension) of a finished and assembled subject corrugated food service box is no greater than four inches.

The corrugated food service boxes covered by the scope include merchandise with or without color or printing, whether decorated, printed, or blank; regardless of paper, paperboard, or cardboard color; and whether graphical images are printed directly or overlaid. The merchandise is covered regardless of whether coated or lined, including with materials to increase grease resistance; with or without ventilation holes, perforations, or features for holding condiments or other foods; and whether or not accompanied by other parts or materials. The addition of non-paper, non-paperboard, or non-cardboard materials, such as liners, inserts, or holders, does not remove the box from the scope.

The scope also includes products subjected to further processing in a third country, including but not limited to printing, coating, trimming, cutting, punching, assembling, folding, and/or perforating, or any other processing that would not otherwise remove the merchandise from the scope if performed in the country of manufacture.

The subject merchandise is typically classified under Harmonized Tariff Schedule of the United States (“HTSUS”) subheading 4819.10.0020. The HTSUS subheading is provided for convenience and customs purposes only; the written description of the merchandise is dispositive.

Key Facts

Foreign Producers/Exporters and U.S. Importers: The petitions identify a number of companies. Businesses that may be affected should review the petitions carefully and assess whether they are named directly or implicated through supply-chain relationships. Please contact Clark Hill’s International Trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins: The Petitioner alleged the following AD and CVD margins:

• China: AD margins ranging from 96.62% to 568.50% ad valorem;
• Malaysia: AD margin of 110.73% ad valorem;
• Türkiye: AD margins ranging from 120.65% to 210.37% ad valorem, and CVD margins above de minimis.

The Investigations

The DOC and ITC will conduct parallel investigations. The ITC examines whether the domestic industry is materially injured or threatened with material injury. The DOC determines whether dumping or subsidization exists and, if so, calculates the duty rates that importers must deposit.

If the DOC issues an affirmative preliminary determination, importers will be required to deposit the estimated AD and/or CVD duties on covered imports as of the date Commerce publishes its affirmative preliminary determination in the Federal Register. Based on the statutory schedule and the September 8, 2026, filing date shown on the petition, preliminary determinations are currently expected by approximately December 2, 2026, for the Türkiye CVD investigation and February 16, 2027, for the AD investigations of all countries, subject to extensions and other schedule changes. Importers should also be alert to the possibility of a critical circumstances finding, which in some cases may result in retroactive duty liability.

Next Steps

Given the strict statutory deadlines, governing AD, and CVD investigations, U.S. importers and foreign producers may want to prepare as soon as possible.

If this product is of interest to your business, please contact Clark Hill’s International Trade team for additional details and strategic guidance.

A schedule of approximate key dates is below.

Approximate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/08/2026
DOC Initiation Date	20	9/28/2026
DOC Separate Rate Applications	41	10/19/2026
DOC Q&V Questionnaires	44	10/22/2026
ITC Preliminary Determination	45	10/23/2026
DOC Preliminary AD Determination	160	2/16/2027
DOC Final AD Determination	235	5/03/2027
ITC Final AD Determination	280	6/15/2027
DOC AD Publication of Order	287	6/22/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	9/08/2026
DOC Initiation Date	20	9/28/2026
DOC Q&V Questionnaires	44	10/22/2026
ITC Preliminary Determination	45	10/23/2026
DOC Preliminary CVD Determination	85	12/02/2026
Request for a DOC Hearing	122	1/08/2027
DOC Final CVD Determination	160	2/16/2027
ITC Final CVD Determination	205	4/02/2027
DOC CVD Publication of Order	212	4/09/2027

 

* All deadlines are approximate and are subject to change throughout the course of an investigation. Deadlines that fall on a weekend or Federal holiday are extended to the next business day, as shown above. Contact Clark Hill for current updates and details.

Contact Clark Hill

If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice:

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202.640.6680)
• Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202.230.9889)
• Aristeo Lopez (alopez@clarkhill.com; 202.552.2366)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
• Onjoly Purification (opurification@clarkhill.com; 202.552.2361)

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