On November 7, 2025, the European Commission issued an announcement stating that, following an application submitted on September 24, 2025 by the European Thermal Paper Association, an anti-subsidy investigation has been launched against lightweight thermal paper (LWTP) originating in China.
The products under investigation fall under EU CN (Combined Nomenclature) codes ex 4809 90 00, ex 4811 90 00, ex 4816 90 00, and ex 4823 90 85 (EU TARIC codes 4809 90 00 10, 4811 90 00 10, 4816 90 00 10, and 4823 90 85 20).
The subsidy investigation period runs from October 1, 2024 to September 30, 2025, and the injury investigation period spans January 1, 2022 to the end of the subsidy investigation period.
The investigation concerns lightweight thermal paper (LWTP), defined as thermal paper:
- with a basis weight of 65 g/m² or less,
- sold in the form of rolls (“jumbo rolls”) with a width of 20 cm or more,
- a weight of 50 kg or more (including paper), and
- a diameter of 40 cm or more;
- with/without single- or double-sided precoat,
- with single- or double-sided physical or chemical thermal layer (the layer that forms an image under heat),and with or without a topcoat
(collectively referred to as “the product under investigation”).
Earlier this year, European thermal paper manufacturers, represented by the European Thermal Paper Association (ETPA), filed a petition with the European Commission, alleging that imports of thermal paper from China involve unfair trade practices. The industry urged the European Commission to investigate the “large quantities of highly subsidized Lightweight Thermal Paper (LWTP) imported from China” and take action to protect the European sector from what it describes as “unfair competition.”
The thermal paper industry in the European Union is primarily concentrated in Germany, Finland, France, and Spain. According to ETPA, from 2022 to the first quarter of 2025, imports of lightweight thermal paper from China surged by more than 500%. The association also noted that since 2023, prices of Chinese LWTP exports have continued to decline, forcing European producers to cut their own selling prices to remain competitive.
The complaint allegedly submitted by the EU thermal paper industry documented multiple forms of unfair subsidies provided by the Chinese government, including direct financial support, preferential tax policies, and access to raw materials priced below market levels.
As a result, ETPA is calling on the European Commission to impose countervailing duties on thermal paper imported from China in order to restore a fair competitive environment.
