On June 13^th, 2025, the publication of SECEX Circular No. 43/2025 initiated a sunset review of the anti-dumping duties on Brazilian imports of sodium acid pyrophosphate (SAPP) originating from Canada, China and the United States. The product under investigation is usually classified under subheadings 2835.39.20 of the Mercosur Common Nomenclature (“NCM”).

The antidumping duties on imports of sodium acid pyrophosphate (SAPP) were originally applied by CAMEX Resolution No. 67, of August 14^th, 2014, and renewed by CAMEX Resolution No. 50, of June 12^th, 2020. The current review was motivated by a petition filed by ICL Aditivos e Ingredientes Ltda. After a preliminary analysis, the Foreign Trade Secretariat (SECEX), through the Department of Trade Remedies (DECOM), recommended the initiation of the sunset review to verify the need for the extension of the antidumping duties applied to imports of SAPP, in light of evidence suggesting that the termination of the measure would most likely lead to the resumption of dumping in exports originating from Canada, China, and the United States, and the recurrence of injury the resulting therefrom.
The main information of the process is summarized below:

• Petitioner: ICL Aditivos e Ingredientes Ltda.
• Origins: Canada, China and the United States
• Period of Investigation:

Continuation/resumption of dumping: January to December 2024
Continuation/resumption of injury to domestic industry: January 2020 to December 2024

• Product under investigation:

Classification: Usually classified in subheadings 2835.39.20 of the NCM.
Description: Sodium acid pyrophosphate (SAPP), food grade, used as a chemical leaven, stabilizer, acidity regulator, emulsifier and/or sequestrant in various products of the food industry.

• Comparison between the normal value internalized in the Brazilian market and the price of the domestic industry:

Canada: Absolute difference of R$ 1,329.90/t
China: Absolute difference of R$ 3,877.26/t
United States: Absolute difference of R$ 14,505.66/t

The participation of interested parties — including domestic producers, importers, exporters and governments of the countries under investigation — must necessarily be carried out through petitions in the Electronic Information System (SEI) of the Ministry of Development, Industry, Trade and Services (MDIC).

Questionnaires will be sent to the identified interested parties, who will have 30 (thirty) days from the date of the notification to send their responses. Parties not initially identified at the beginning of the proceeding, but who consider themselves interested may request to be admitted to the case by July 3, 2025.

The sunset review must be completed within 10 (ten) months, extendable for up to 2 (two) additional months. The anti-dumping duties remain in force until the conclusion of the review and, if the initial claims are confirmed, may be renewed for another 5 (five) years.

The team of specialists at Nasser Advogados is available to clarify any questions.