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Paper Receipts Association Combats Illegal Importer Duty Invasion

Paper Receipts Association

Paper Receipts Association Combats Illegal Importer Duty Invasion

The Paper Receipts Converting Association (PRCA) announced progress in initiatives to combat illegal evasion of antidumping and countervailing duties on the part of imports of thermal paper into the United States. The U.S Customs and Border Protection’s (CPB) decision to investigate and to impose interim measures on both Gorilla Paper Inc. and WHP Associates is another milestone in PRCA’s efforts to promote a fair and thriving U.S. paper receipts market.  

On June 28, 2022, PRCA filed allegations against WHP Associates under Title IV, Section 421 of the Trade Facilitation and Trade Enforcement Act of 2015, commonly known as the Enforce and Protect Act (EAPA). The allegations demonstrate that WHP Associates imported converted thermal paper rolls from Malaysia that were made with thermal paper produced in China and Korea, without paying the requisite antidumping and countervailing duties.  WHP Associates sells the imported converted rolls online under the name ThermalKing.  In October, CBP issued an interim affirmative determination of evasion and imposed duties on all WHP Associates imports from Actan, a Malaysian paper converter. 

On June 13, 2022, PRCA filed EAPA allegations against Gorilla Paper, an importer and online supplier who imports from three Turkish converters Umur Basim, Engin Kagit, and Dor Etiket.  These companies import thermal rolls from Germany and Korea for conversion in Turkey.  In October, CBP issued an interim affirmative determination of evasion and imposed duties on all Gorilla Paper imports from Turkey.   

“PRCA is committed to protecting the integrity of the U.S. paper receipt industry and ensuring that all organizations conduct the supply and delivery of products in compliance with the law,” said Mike Rapier, President of PRCA. “The association is in strong support of the CBP’s investigations and will continue to monitor importers that raise suspicion, and will not hesitate to file additional EAPA allegations if evasion is suspected.” 

Bryan Eovaldi, PRCA Vice President, added, “unfortunately there are importers out there who try to avoid the imposition of duties on thermal paper converted rolls by claiming the wrong country of origin.  As found by CBP, the correct origin is the country where the thermal paper is made, not the country where it is converted.”   

“Under U.S. law, It is the responsibility of every importer to perform the due diligence to determine the correct country of origin, and to pay any duties owed,” added Eovaldi.  “Ignorance of the law is not a defense.”        

Both of these investigations are still pending and final determinations are expected later in 2023.   

In addition to the allegations of evasion by ThermalKing and Gorilla Paper, PRCA has filed allegations of evasion with respect to imports from Mexico and Taiwan.  Both are pending initiation.   

In addition to supporting aggressive enforcement of antidumping and countervailing duty orders, PRCA maintains that the use of Good Manufacturing Practices (GMPs) is essential to ensuring that purchasers receive precisely what they have ordered. The association believes that imported converted rolls are often shorter than advertised and/or may be manufactured with improperly identified paper. PRCA has developed a set of GMPs to which its members subscribe precisely to address this issue. 

To learn more about PRCA and their contributions to the U.S. thermal paper industry, visit 


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