Brazil Initiates Anti-Dumping Investigation on Moroccan Exports of Purified Phosphoric Acid — What Moroccan Exporters Need to Know and Do

Brazil has formally initiated an anti-dumping investigation on imports of purified phosphoric acid (H₃PO₄ concentration >55% and <105%), classified under NCM 2809.20.11, originating from China, Mexico, and Morocco, following Notice of Initiation No. 91/2025. The petition was filed by ICL Aditivos e Ingredientes Ltda, alleging that imports from these countries are being dumped in the Brazilian market at prices causing material injury to domestic producers.

According to the initiation notice, Brazilian authorities calculated an alleged dumping margin for Morocco of 710.98 USD/ton, equivalent to 65%. The periods of examination are:

• Dumping period: April 2024 – March 2025

• Injury period: April 2020 – March 2025

DECOM (BRTA), the Brazilian investigating authority, will now begin evaluating pricing practices, export trends, and injury indicators. This phase includes the possibility of provisional anti-dumping duties if preliminary findings confirm significant dumping and injury.

Key Deadlines Announced by DECOM

The investigation notice establishes several critical deadlines for exporters:

• Registration as an Interested Party: by 15 December 2025

• Submission of Power of Attorney: by 23 February 2026 (non-extendable)

• Submission of Exporter Questionnaire: by 23 January 2026 (extendable once)

• Hearing: 22 April 2026

• Preliminary Determination: no later than 12 June 2026

These steps will determine whether Moroccan companies retain their access to the Brazilian market or face high anti-dumping duties.

What This Means for Moroccan Exporters

For Moroccan producers and exporters of purified phosphoric acid, this investigation marks a critical moment. Brazil is a significant and strategic market, and anti-dumping duties—especially if imposed at the alleged 65% margin—could effectively close the market for Moroccan product.

Because of this, immediate and full cooperation is essential.

Below is a clear action plan for Moroccan companies.

What Moroccan Exporters Should Do Now

1. Register Immediately as an Interested Party

Registration must be completed by 15 December 2025.

Without registration, the exporter loses:

• Access to confidential information

• The right to submit evidence

• The right to defend its pricing

• The right to request hearings or extensions

  Unregistered exporters typically receive very high duties by default.

2. Submit a Valid Power of Attorney (Deadline: 23 February 2026)

This deadline is strict and non-extendable.

If the POA is not filed correctly and on time:

• The exporter is treated as non-cooperative

• Brazil may apply punitive duties based solely on the petitioner’s allegations

Moroccan companies must ensure their legal counsel prepares this document early to avoid administrative errors.

3. Prepare and Submit the Exporter Questionnaire

Due 23 January 2026, extendable once by 30 days.

This questionnaire is detailed and requires information including:

• Sales data for all exports to Brazil

• Cost of production (materials, labor, overheads)

• Corporate structure and related companies

• Domestic sales and third-country sales (if relevant)

• Transaction-level export invoices

• Freight, insurance, and logistics details

Incomplete answers or missing data allow DECOM to apply “facts available,” resulting in much higher calculated margins.

4. Prepare for Verification

If the exporter cooperates effectively, DECOM may conduct a:

• Virtual verification, or

• On-site verification visit

This step is crucial to confirm the accuracy of submitted data. Companies should begin organizing accounting files, sales systems, and cost records early.

5. Develop an Injury and Causation Defense (Where Relevant)

Moroccan exporters may argue, for example, that:

• Their volumes are limited and cannot cause injury

• Price fluctuations reflect global supply-demand conditions

• Factors other than Moroccan imports contributed to Brazilian industry performance

• Competing exporters (China, Mexico) account for a larger share of imports

A well-supported causation argument can significantly reduce duties or eliminate them.

Conclusion

Brazil’s anti-dumping investigation represents a serious development for Moroccan exporters of purified phosphoric acid. However, Moroccan companies that cooperate fully, meet all deadlines, and present strong evidence stand a realistic chance of achieving reduced—or even zero—duty rates.

Early preparation, coordinated data management, and experienced trade remedies counsel are essential to protect access to the Brazilian market.

For further guidance on Brazil’s anti-dumping procedures or support in filing responses, please contact Al Armouti – Trade Remedies Practice:

📧 info@armouti.com 🌐 www.armouti.com

This update is provided for general informational purposes only and does not constitute legal advice. Procedures and deadlines summarized above are based on the official Brazilian initiation notice and may be subject to change during the investigation.

Al Armouti is available to assist exporters and stakeholders wishing to participate in this investigation, including registration, questionnaire support, data preparation, legal submissions, and representation before DECOM.