Bedrock Quartz Letter Quartz Imports Under Siege

Hello fabricators, importers and distributors: Our industry has been put under siege by one US company: Cambria. You are likely aware that Cambria, by itself, in April 2018 began a process to fight against Chinese imports of quartz. During 2018 and culminating May 9 th the fight has continued and now rests in the hands of the ITC Commissioners for their final vote on June 11 th . The ITC will vote on whether there has been injury to the domestic industry and whether there are “critical circumstances” to justify the imposition of retroactive tariffs for those who imported quartz products. These retroactive tariffs, if imposed, will extract at least $800 million dollars from our industry and put it into government coffers. It will have a significant impact on my company for importing fabricated goods to meet obligations for contracted projects, which were under contract prior to the investigation. Last week the Department of Commerce (DOC) 1. Issued the final rates for the AD (Anti-Dumping) and CVD (Counter Vailing Duty) tariffs, 2. Has expanded the scope to include crushed glass slab products, and 3. Has modified the CVD tariffs to also include retroactive provisions that will also now apply to all imports from China, when previously it had only been on imports sourced from two specific exporters, Fasa and Hero Stone. So, there will now be retroactive AD (336%) and CVD (45.32 up to 190 %) tariffs. Should the ITC rule affirmatively on critical circumstances, not only will former importers of Chinese quartz be subject to retroactive tariffs starting August 22 nd 2018 at 336% of invoice value, but they will also be subject to CVD retroactive tariffs starting June 23 rd 2018 at 45.32% for all Chinese sources, except for imports from Fasa and Hero Stone which will be hit with 190.99% retroactive tariffs. These values cause a tremendous amount of damage to the supply chain that we all depend on. Bankruptcy anyone? Think about it, just last week the DOC changed the rules and the effective date for CVD retroactive tariffs is now June 23 rd of last year! Fair? Hardly. To import quartz from China, an importer now adds estimated costs as follows: ($X material price), + ($1.50 freight Est.), + (AD tariff ($X*336%= $XX)), + (CVD tariff, ($X*45%= $XX)) + (Section 301 tariff ($X*25%= $XX.)) The total wouldn’t include any markup to keep the lights on. Use any material price number to see what the results are but realize that the cost of the material needs to be multiplied by a factor of “5” to see the final costs to the importer. For instance, if an estimated $10 per foot is used then the final landed cost would be estimated at $50 per foot. With these tariffs the final estimated imported prices for Chinese quartz would be significantly more than Cambria is sold for. Given these estimated rates there clearly won’t be any imports coming from China if the ITC goes affirmative on domestic injury. Now Cambria has filed against India and Turkey. What do you think will happen with Chinese imports no longer viable to import and then imports from India and Turkey are no longer viable? Does this help our industry? Maybe if you fabricate mostly Silestone, you figured that this doesn’t really affect you? Have you heard that there’s a real possibility of up to 100% tariffs being applied on quartz imports from Spain? https://www.stoneupdate.com/news-info/latest-stuff/1706-stone-quartz-surfaces-from-eu-may-face-100-tariff My point in all this, is that if we sit by while our possible supplies of quartz, to satisfy our customers’ demands, get obliterated, will it really benefit our industry? Bedrock doesn’t currently fabricate much Silestone, but I don’t want those in the Big Box space (and other segments with Silestone), to have huge tariffs either. The India/Turkey investigation also includes the downstream products created by fabricators and includes glass/quartz or glass-based products. The ITC preliminary hearing for the India/Turkey case is May 29 th . In the Chinese quartz tariff fight, there a few critical things to understand: