Notice2025-23823

Hard Empty Capsules From Brazil: Final Affirmative Countervailing Duty Determination

Primary source

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Published
December 29, 2025

Issuing agencies

Commerce DepartmentInternational Trade Administration

Abstract

The U.S. Department of Commerce (Commerce) determines that countervailable subsidies are being provided to producers and exporters of hard empty capsules (capsules) from Brazil. The period of investigation (POI) is January 1, 2023, through December 31, 2023.

Full Text

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<title>Federal Register, Volume 90 Issue 245 (Monday, December 29, 2025)</title>
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[Federal Register Volume 90, Number 245 (Monday, December 29, 2025)]
[Notices]
[Pages 60607-60609]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-23823]


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DEPARTMENT OF COMMERCE

International Trade Administration

[C-351-865]


Hard Empty Capsules From Brazil: Final Affirmative Countervailing 
Duty Determination

AGENCY: Enforcement and Compliance, International Trade Administration, 
Department of Commerce.

SUMMARY: The U.S. Department of Commerce (Commerce) determines that 
countervailable subsidies are being provided to producers and exporters 
of hard empty capsules (capsules) from Brazil. The period of 
investigation (POI) is January 1, 2023, through December 31, 2023.

DATES: Applicable December 29, 2025.

FOR FURTHER INFORMATION CONTACT: Samuel Evans, AD/CVD Operations, 
Office IX, Enforcement and Compliance, International Trade 
Administration, U.S. Department of Commerce, 1401 Constitution Avenue 
NW, Washington, DC 20230; telephone: (202) 482-2420.

SUPPLEMENTARY INFORMATION:

Background

    On March 31, 2025, Commerce published the Preliminary Determination 
in the Federal Register and invited interested parties to comment.\1\ 
In the Preliminary Determination, and in accordance with section 
705(a)(1) of the Tariff Act of

[[Page 60608]]

1930, as amended (the Act), and 19 CFR 351.210(b)(4), Commerce aligned 
the final CVD determination with the final determination in the less-
than-fair-value investigation of capsules from Brazil.\2\
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    \1\ See Hard Empty Capsules from Brazil: Preliminary Affirmative 
Countervailing Duty Determination and Alignment of Final 
Determination with Final Antidumping Duty Determination, 90 FR 14235 
(March 31, 2025) (Preliminary Determination), and accompanying 
Preliminary Decision Memorandum (PDM).
    \2\ Id., 90 FR at 14236.
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    Due to the lapse in appropriations and Federal Government shutdown, 
on November 14, 2025, Commerce tolled all deadlines in administrative 
proceedings by 47 days.\3\ Additionally, due to a backlog of documents 
that were electronically filed via Enforcement and Compliance's 
Antidumping and Countervailing Duty Centralized Electronic Service 
System (ACCESS) during the Federal Government shutdown, on November 24, 
2025, Commerce tolled all deadlines in administrative proceedings by an 
additional 21 days.\4\ Accordingly, the deadline for this final 
determination is now December 18, 2025.
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    \3\ See Memorandum, ``Deadlines Affected by the Shutdown of the 
Federal Government,'' dated November 14, 2025.
    \4\ See Memorandum, ``Tolling of all Case Deadlines,'' dated 
November 24, 2025.
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    For a complete discussion of the events that followed the 
Preliminary Determination, see the Issues and Decision Memorandum.\5\ 
The Issues and Decision Memorandum is a public document and is made 
available to the public via ACCESS. ACCESS is available to registered 
users at <a href="https://access.trade.gov">https://access.trade.gov</a>. In addition, a complete version of 
the Issues and Decision Memorandum can be accessed directly at <a href="https://access.trade.gov/public/FRNoticesListLayout.aspx">https://access.trade.gov/public/FRNoticesListLayout.aspx</a>.
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    \5\ See Memorandum, ``Issues and Decision Memorandum for the 
Final Affirmative Determination of the Countervailing Duty 
Investigation of Hard Empty Capsules from the People's Republic of 
China,'' dated concurrently with, and hereby adopted by, this notice 
(Issues and Decision Memorandum).
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Scope of the Investigation

    The products covered by this investigation are hard empty capsules 
from Brazil. For a complete description of the scope of this 
investigation, see Appendix I.

Scope Comments

    In the Preliminary Scope Memorandum, we set aside a period of time 
for parties to raise issues regarding product coverage (i.e., scope) in 
scope-specific case briefs or other written comments.\6\ We received 
scope case and rebuttal briefs from multiple interested parties. For a 
summary of the product coverage comments and rebuttal responses 
submitted to the record for this final determination, and accompanying 
discussion and analysis of all comments timely received, see the Final 
Scope Memorandum.\7\ In the Final Scope Memorandum, Commerce determined 
that it is modifying the scope language as it appeared in the 
Initiation Notice.\8\ See Appendix I.
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    \6\ See Memorandum, ``Less-Than-Fair-Value Investigations of 
Hard Empty Capsules from Brazil, the People's Republic of China, 
India, and the Socialist Republic of Vietnam and Countervailing Duty 
Investigations from Brazil, the People's Republic of China, India, 
and the Socialist Republic of Vietnam: Preliminary Scope Decision 
Memorandum,'' dated March 24, 2025 (Preliminary Scope Memorandum).
    \7\ See Memorandum, ``Less-Than-Fair-Value and Countervailing 
Duty Investigations of Hard Empty Capsules from Brazil, the People's 
Republic of China, India, and the Socialist Republic of Vietnam: 
Final Scope Decision Memorandum,'' dated concurrently with this 
notice (Final Scope Memorandum).
    \8\ See Hard Empty Capsules from Brazil, the People's Republic 
of China, India, and the Socialist Republic of Vietnam: Initiation 
of Countervailing Duty Investigations, 89 FR 91680 (November 20, 
2024) (Initiation Notice).
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Verification

    As provided in section 782(i) of the Act, in May 2025, Commerce 
verified the information reported by ACG do Brasil S.A. (ACG Brazil) 
for use in our final determination. We used standard verification 
procedures, including an examination of relevant accounting records and 
original source documents provided at verification.\9\
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    \9\ See Memorandum, ``Verification of the Questionnaire 
Responses of ACG do Brasil S.A.,'' dated June 3, 2025.
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Analysis of Subsidy Programs and Comments Received

    The subsidy programs under investigation and the issues raised in 
the case and rebuttal briefs that were submitted by interested parties 
in this investigation are discussed in the Issues and Decision 
Memorandum. For a list of the issues raised by interested parties and 
addressed in the Issues and Decision Memorandum, see Appendix II.

Methodology

    Commerce conducted this investigation in accordance with section 
701 of the Act. For each of the subsidy programs found to be 
countervailable, Commerce determines that there is a subsidy, i.e., a 
financial contribution by an ``authority'' that gives rise to a benefit 
to the recipient, and that the subsidy is specific. For a full 
description of the methodology underlying our final determination, see 
the Issues and Decision Memorandum.
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    \10\ See sections 771(5)(B) and (D) of the Act regarding 
financial contribution; see also section 771(5)(E) of the Act 
regarding benefit; and section 771(5A) of the Act regarding 
specificity.
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    In making this final determination, Commerce relied, in part, on 
facts otherwise available, including with an adverse inference, 
pursuant to sections 776(a) and (b) of the Act. For a further 
discussion of our application of adverse facts available (AFA), see the 
Issues and Decision Memorandum.

Changes Since the Preliminary Determination

    Based on our findings at verification, we made changes to our 
subsidy rate calculations for ACG Brazil for the provision of 
electricity for less-than-adequate-remuneration program, as well as the 
Ex-Tarif[aacute]rio program. For a discussion of these changes, see the 
Issues and Decision Memorandum.

All-Others Rate

    Section 705(c)(5)(A)(i) of the Act states that, for companies not 
individually investigated, Commerce will determine an all-others rate 
equal to the weighted-average countervailable subsidy rates established 
for exporters and/or producers individually investigated, excluding any 
zero and de minimis countervailable subsidy rates, and any rates 
determined entirely under section 776 of the Act.
    Commerce calculated an individual estimated countervailable subsidy 
rate for ACG Brazil, the only individually examined exporter/producer 
in this investigation. Because the only individually calculated rate is 
not zero, de minimis, or based entirely on facts otherwise available, 
the estimated countervailable subsidy rate calculated for ACG Brazil is 
the rate assigned to all other producers and exporters, pursuant to 
section 705(c)(5)(A)(i) of the Act.

Final Determination

    Commerce determines that the following estimated countervailable 
subsidy rates exist for the period January 1, 2023, through December 
31, 2023:

------------------------------------------------------------------------
                                                           Subsidy rate
                         Company                            (percent ad
                                                             valorem)
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ACG do Brasil S.A.......................................           10.67
All Others..............................................           10.67
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Disclosure

    Commerce intends to disclose its calculations performed to 
interested parties in this final determination within five days of its 
public announcement or, if there is no public announcement, within five 
days of the date of the publication of this notice in the Federal 
Register, in accordance with 19 CFR 351.224(b).

[[Page 60609]]

Suspension of Liquidation

    As a result of our Preliminary Determination, and pursuant to 
sections 703(d)(1)(B) and (d)(2) of the Act, we instructed U.S. Customs 
and Border Protection (CBP) to collect cash deposits and suspend 
liquidation of entries of subject merchandise from Brazil that were 
entered, or withdrawn from warehouse, for consumption, on or after 
March 31, 2025, the date of the publication of the Preliminary 
Determination in the Federal Register.\11\ In accordance with section 
703(d) of the Act, we instructed CBP to discontinue the suspension of 
liquidation of all entries of subject merchandise entered or withdrawn 
from warehouse, on or after July 29, 2025, but to continue the 
suspension of liquidation of all entries of subject merchandise on or 
before July 28, 2025.
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    \11\ See Preliminary Determination, 90 FR at 14236.
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    If the U.S. International Trade Commission (ITC) issues a final 
affirmative injury determination, we will issue a countervailing duty 
(CVD) order, reinstate the suspension of liquidation under section 
706(a) of the Act, and require a cash deposit of estimated 
countervailing duties for entries of subject merchandise in the amounts 
indicated above. Pursuant to section 705(c)(2) of the Act, if the ITC 
determines that material injury, or threat of material injury, does not 
exist, this proceeding will be terminated, and all estimated duties 
deposited or securities posted as a result of the suspension of 
liquidation will be refunded or cancelled.

ITC Notification

    In accordance with section 705(d) of the Act, Commerce will notify 
the ITC of its final affirmative determination that countervailable 
subsidies are being provided to producers and exporters of capsules 
from Brazil. As Commerce's final determination is affirmative, in 
accordance with section 705(b) of the Act, the ITC will determine, 
within 45 days, whether the domestic industry in the United States is 
materially injured, or threatened with material injury, by reason of 
import of capsules from Brazil. In addition, we are making available to 
the ITC all non-privileged and non-proprietary information in our 
files, provided the ITC confirms that it will not disclose such 
information, either publicly or under administrative protective order 
(APO), without the written consent of the Assistant Secretary for 
Enforcement and Compliance.
    If the ITC determines that material injury or threat of material 
injury does not exist, this proceeding will be terminated, and all cash 
deposits will be refunded. If the ITC determines that such injury does 
exist, Commerce will issue a CVD order directing CBP to assess, upon 
further instruction by Commerce, countervailing duties on all imports 
of the subject merchandise that are entered, or withdrawn from 
warehouse, for consumption on or after the effective date of the 
suspension of liquidation, as discussed above in the ``Suspension of 
Liquidation'' section.

Administrative Protective Order

    This notice will serve as the final reminder to parties subject to 
an APO of their responsibility concerning the destruction of 
proprietary information disclosed under APO, in accordance with 19 CFR 
351.305(a)(3). Timely written notification of the return or destruction 
of APO materials or conversion to judicial protective order is hereby 
requested. Failure to comply with the regulations and terms of an APO 
is a violation which is subject to sanction.

Notification to Interested Parties

    This determination is issued and published in accordance with 
sections 705(d) and 777(i) of the Act, and 19 CFR 351.210(c).

    Dated: December 18, 2025.
Christopher Abbott,
Deputy Assistant Secretary for Policy and Negotiations, performing the 
non-exclusive functions and duties of the Assistant Secretary for 
Enforcement and Compliance.

Appendix I

Scope of the Investigation

    The merchandise subject to the scope of this investigation is 
hard empty capsules, which are comprised of two prefabricated, 
hollowed cylindrical sections (cap and body). The cap and body 
pieces each have one closed and rounded end and one open end, and 
are constructed with different or equal diameters at their open 
ends.
    Hard empty capsules are unfilled cylindrical shells composed of 
at least 80 percent by weight of a water soluble polymer that is 
considered non-toxic and appropriate for human or animal consumption 
by the United States Pharmacopeia--National Formulary (USP-NF), Food 
Chemical Codex (FCC), or equivalent standards. The most common 
polymer materials in hard empty capsules are gelatin derived from 
animal collagen (including, but not limited to, pig, cow, or fish 
collagen), hydroxypropyl methylcellulose (HPMC), and pullulan.
    Hard empty capsules may also contain water and additives, such 
as opacifiers, colorants, processing aids, controlled release 
agents, plasticizers, and preservatives. Hard empty capsules may 
also be imprinted or otherwise decorated with markings.
    Hard empty capsules are covered by the scope of this 
investigation regardless of polymer material, additives, 
transparency, opacity, color, imprinting, or other markings.
    Hard empty capsules are also covered by the scope of this 
investigation regardless of their size, weight, length, diameter, 
thickness, and filling capacity.
    Cap and body pieces of hard empty capsules are covered by the 
scope of this investigation regardless of whether they are imported 
together or separately, and regardless of whether they are imported 
in attached or detached form.
    Hard empty capsules covered by the scope of this investigation 
are those that disintegrate in water, simulated intestinal fluid, 
simulated gastric fluid, or other similar water-based (i.e., 
aqueous) fluids within 2 hours under tests specified in Chapter 701 
of the USP-NF, or equivalent disintegration tests.
    Hard empty capsules are classifiable under subheadings 
9602.00.1040 and 9602.00.5010 of the Harmonized Tariff Schedule of 
the United States (HTSUS). In addition, hard empty capsules may be 
imported under HTSUS subheading 1905.90.9090; gelatin hard empty 
capsules may be imported under HTSUS subheading 3503.00.5510; HPMC 
hard empty capsules may be imported under HTSUS subheading 
3923.90.0080; and pullulan hard empty capsules may be imported under 
HTSUS subheading 2106.90.9998. Although the HTSUS subheadings are 
provided for convenience and customs purposes, the written 
description of the merchandise covered by this investigation is 
dispositive.

Appendix II

List of Topics Discussed in the Issues and Decision Memorandum

I. Summary
II. Background
III. Use of Facts Available and Adverse Inferences
IV. Subsidies Valuation
V. Analysis of Programs
VI. Discussion of the Issues
    Comment 1: Whether to Apply Adverse Facts Available to 
Countervail the Access Road Funding--Pouso Alegre Municipality 
Program
    Comment 2: Whether the Government of Brazil Provided Electricity 
for Less Than Adequate Remuneration (LTAR) to ACG Brazil
    Comment 3: Whether to Modify the Benchmark for the Provision of 
Electricity for LTAR Program
VII. Recommendation

[FR Doc. 2025-23823 Filed 12-23-25; 8:45 am]
BILLING CODE 3510-DS-P


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Indexed from Federal Register on December 29, 2025.

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.