Canada’s inquiry NQ-2025-004 examined whether dumped and subsidized thermal paper rolls from China injured Canadian producers. This article covers the complaint, the public testimony of Éric Bernard and Justin Bernard, the manufacture of finished thermal rolls, and the resulting Canadian trade remedies. Media Cash Register Inc., the company behind the MediaJab brand and known in French as Média de Caisses Enregistreuses Inc., was one of the three complainants.
A complaint brought by three Canadian producers
The CBSA’s statement of reasons for initiating the investigations names McDermid Paper Converters Limited, Media Cash Register Inc. and Custom Paper Ltd. The complaint received on April 22, 2025 alleged dumping, subsidizing and injury. The CBSA opened its investigations on June 12, 2025. A complaint presents a position for examination; it is not itself an official determination.
Key dates
- April 22, 2025: the CBSA received the complaint.
- June 12, 2025: the CBSA initiated its investigations.
- September 10, 2025: the CBSA made preliminary determinations and provisional duties began to apply.
- November 12, 2025: the complainants’ public case brief and the public joint witness statement of Éric Bernard and Justin Bernard.
- December 9, 2025: the CBSA made final determinations of dumping and subsidizing. The related statement of reasons is dated December 24, 2025.
- January 8, 2026: the CITT issued findings that the subject dumping and subsidizing caused injury to the domestic industry.
- January 23, 2026: the CITT issued a corrigendum correcting plural wording in the findings and the reference to the CBSA’s determinations. It did not open a new inquiry or change the injury conclusion.
What Éric and Justin Bernard’s testimony describes
The public joint witness statement, Exhibit C-03 dated November 12, 2025, describes the family business, its facility in Saint-Laurent, Montréal, and its production process. PDF pages 2–7 — printed pages 1–6 — distinguish roll characteristics, purchased inputs and factory operations. This is evidence presented by the company in the proceedings and should be distinguished from the Tribunal’s findings.
The statement discusses width, length, basis weight, caliper and cored or coreless construction. Width alone cannot establish compatibility with a printer: outside diameter, paper thickness and the equipment’s requirements also matter.
How we manufacture finished rolls in Montréal
1. Select jumbo paper rolls
We purchase paper in jumbo rolls from specialized suppliers. For thermal paper, the base paper and thermal coating are produced upstream. Our manufacturing activity converts that material into finished rolls. Paper grade, basis weight and coating are selected for the application.
2. Print when the project requires it
The 2025 testimony describes custom printing before conversion to the final roll size. Our current flexographic printing capability is up to three colours. Depending on the paper, artwork and configuration, printing can be on the front, back or both sides. Colour allocation is confirmed for each project. This printing is separate from the coating that makes the paper heat-sensitive.
3. Slit and rewind
Circular knives divide the paper web into widths suitable for finished rolls. The strips are rewound to the specified lengths, with or without a core depending on the product and equipment requirements. These operations give the paper a form and dimensions the customer can use.
4. Finish and package
The process described in 2025 includes end-of-roll marking, securing the paper end and pressing rolls to make their sides flush. Applicable operations depend on the roll’s construction. Finished rolls are then packaged and prepared for distribution. Historical press speeds and other figures in the statement are not current production commitments.
Converting is a production activity
The complainants’ public case brief of November 12, 2025 explains why converting jumbo rolls into finished thermal rolls constitutes Canadian production for the purposes of SIMA. It draws on the Tribunal’s preliminary decision. The CBSA also describes converting as the production step carried out in Canada. A finished roll is a transformed product for printers and terminals; a jumbo roll is an industrial input.
This distinction defines our role: we manufacture finished rolls, while base-paper manufacturing and thermal coating occur upstream. The trade proceedings are not a general certification of our products or an approval of every item we sell.
The CITT’s January 2026 findings
Following the CBSA’s final determinations of December 9, 2025, the CITT found on January 8, 2026 that dumping and subsidizing of the subject goods caused injury to the domestic industry. The Tribunal’s official announcement and NQ-2025-004 findings set out the outcome.
The scope is specific: thermal paper rolls in nominal widths up to and including 15 cm, with a nominal paper weight of 70 g/m² or less and a thermal active coating on one or both sides comprising a dye and a developer that react to form an image when heat is applied, excluding rolls with an adhesive backing, originating in or exported from China. The 15 cm threshold measures paper width. Outside roll diameter is a different measurement.
The findings should not be extended to all basis weights, all thermal paper or all imports. An 80 g/m² product does not automatically fall within this definition. The full official product definition governs the scope of the proceedings.
Anti-dumping and countervailing duties in force
The CBSA’s measures-in-force page, checked on October 20, 2026, specifies the following amounts for covered imports where the exporter has not been issued a specific rate:
- Anti-dumping duty: 282.1% of the export price. Multiply the export price determined under SIMA by 2.821. For an export price of CAD 1,000, this duty alone is CAD 2,821.
- Countervailing duty: CNY 10,134.87 per metric tonne. Multiply that amount by the weight of the subject goods in metric tonnes. One metric tonne therefore attracts CNY 10,134.87 before the required conversion into Canadian dollars.
These two duties can apply to the same covered import: one addresses dumping and the other subsidizing. Their calculation bases differ, so they cannot simply be added as two percentages. Exporter-specific rates must be checked where applicable. The 77.0% subsidy amount expressed in the 2025 final investigation results is not a third duty to add to these amounts. Use the current measures-in-force page to identify the applicable assessment basis and the SIMA self-assessment guide for the calculation rules.
The Canadian importer’s responsibilities
The Canadian importer must correctly describe and account for the goods, verify the duties assessed through CARM, and pay the amounts owing within the prescribed time. The export price is a SIMA calculation; it should not automatically be equated with a retail price or an invoice total including freight.
A declaration can subsequently be reviewed. Memorandum D14-1-7 explains determinations and re-determinations, including the power described in paragraph 39 to re-determine within two years of a determination under section 56 of SIMA. Underpaid duties may be recovered. Late payment can attract interest, and incorrect declarations can attract administrative penalties under the applicable rules.
Tariff classification does not replace the product definition
On October 20, 2026, the measures-in-force page lists 4811.90.00.90 as the usual tariff classification. The official product definition determines whether the goods are covered. A different declared tariff code does not remove duties from goods meeting that definition. Conversely, goods using the same code are not necessarily covered. Classification numbers can change, so the current customs tariff and the CBSA’s notices must be checked for the relevant import date.
The practical effect of the findings
The CITT’s injury findings provide the basis for the CBSA to collect the applicable anti-dumping and countervailing duties on the subject imports. They affect the import cost and declaration obligations for goods within the defined scope. They are not a ban on all thermal paper from China and do not establish a universal duty on every Chinese paper product.
For supply comparisons, the relevant facts include origin, paper width, basis weight, coating, adhesive backing, and the applicable exporter information. The proceedings also document the Canadian production stage: converting jumbo paper rolls into finished thermal rolls. The findings address injury to the domestic industry; they do not certify a manufacturer’s entire catalog or promise a particular commercial outcome.
Sources and public documents
- CBSA — Thermal paper rolls: measures in force.
- CBSA — Preliminary determinations, September 10, 2025.
- CBSA — Guide for self-assessing SIMA duties.
- CBSA — Memorandum D14-1-7: assessment and payment of duties.
- CBSA — Initiation of investigations, statement of reasons dated June 27, 2025.
- CBSA — Final determinations, statement of reasons dated December 24, 2025.
- CITT — January 8, 2026 announcement; NQ-2025-004 findings of January 8, 2026 and corrigendum of January 23, 2026.
- Complainants’ Public Case Brief, Exhibit A/B/C-01, November 12, 2025, section II.B–C, printed pages 4–8.
- Public Joint Witness Statement of Éric Bernard and Justin Bernard, Exhibit C-03, November 12, 2025, printed pages 1–6.