The American Forest & Paper Association (AF&PA) is calling on the Office of the United States Trade Representative (USTR) to exempt Brazilian bleached eucalyptus kraft pulp (HTS code: 4703.29) from potential Section 301 tariffs, arguing that the material is indispensable to the U.S. tissue industry and cannot be sourced domestically at commercial scale. The group submitted its formal comments as part of USTR's ongoing investigation into Brazil's trade practices.
The Section 301 investigation, launched in July, examines whether Brazil's policies related to digital trade, electronic payments, preferential tariffs, corruption enforcement, intellectual property, ethanol access, and illegal deforestation are discriminatory or burdensome to U.S. commerce. On September 3, USTR will hold a public hearing to gather further testimony on these issues and assess how Brazilian laws may be restricting fair market access for American firms.
AF&PA's comments focus on the U.S. paper manufacturing sector's reliance on bleached eucalyptus kraft pulp (BEK), which is sourced almost exclusively from Brazil due to the country's ideal growing conditions and established supply chains. The pulp's unique fiber qualities, particularly its softness, strength, and absorbency, make it critical for producing high-quality tissue products used daily by U.S. consumers. Domestic eucalyptus production is extremely limited, with viable growing areas confined to small regions in coastal California and Hawaii, which cannot meet industrial-scale demand.
The association argues that imposing tariffs on Brazilian pulp would harm U.S. manufacturers by raising input costs, reducing profitability, and undermining the competitiveness of American-made tissue products both at home and abroad. It warned that this could shift market share toward foreign producers and jeopardize jobs in a sector that employs more than 925,000 workers across rural America. According to AF&PA, each forest products job supports an additional 3.25 jobs in supplier industries and local communities.
AF&PA also defended the sustainability of Brazilian eucalyptus pulp, stating that member companies source only from responsibly managed plantations certified by programs such as the Sustainable Forestry Initiative and the Forest Stewardship Council. The group stressed that these plantations are not linked to illegal deforestation, which is one of the issues under review in the Section 301 probe.
In addition, the association expressed strong support for the 2008 amendments to the Lacey Act, which make it illegal to trade wood or plant products harvested in violation of any U.S. or foreign laws. AF&PA emphasized that this law promotes supply chain transparency and responsible sourcing and noted that it works closely with the U.S. Department of Agriculture to ensure timely enforcement and implementation.
The association referenced President Donald Trump's Executive Order 14323, under which eucalyptus wood pulp was previously excluded from a 40% tariff list, and urged USTR to maintain consistency with that policy to protect U.S. industry and supply chain integrity, according to the American Forest & Paper Association.
