CBP Initial Determination Malaysia Transshipping February 2022 | Page 17

they are imported ; ( d ) complete factory production records , including stamped timecards and work orders , as well as packaging costs and information ; ( e ) a demonstration as to how the manufacturer ties the raw materials to the finished products , for example , a purchase order or invoice number which appears on production documents ; ( f ) the name of the factory owner and all corporate officers ; and ( g ) whether the foreign producer / exporter has a relationship with Big D , and if so , whether this affects the price paid or payable . ¹²⁹

The few CF28 questions concerning production Big D and MSI answered contain false information . In Big D ’ s CF28 Response , MSI claimed that it is only a trading company , and that the manufacturer is Sanctuary Stone Sdn . Bhd . ( Sanctuary Stone ). ¹³⁰ An examination of the website for Sanctuary Stone indicates it primarily sells natural stone , and the website contains photographs of its factory and the products it sells . ¹³¹ The photographs provided by MSI to demonstrate Sanctuary Stone ’ s production do not match those found on Sanctuary Stone ’ s website . ¹³² The purported photographs of Sanctuary Stone submitted in the CF28 response , for example , appear to be of a large , enclosed factory with space between machines , whereas Sanctuary Stone ’ s website indicates it has a mostly open aired factory , takes up a smaller space , and does not contain the machines from the photos provided by MSI . ¹³³

An internet search for the production photographs provided by MSI indicates that many of them are from a Chinese QSP company , Vemy Quartz Surface Co ., Ltd . ( Vemy Stone ). ¹³⁴ Vemy Stone operates two factories which appear to be comprised of several large buildings at each location . ¹³⁵ Big D ’ s CF28 Request solicited information on the machines used in production and their capacities , and the photographs submitted by MSI for the mixing machine , vulcanizing machine and calibrating machine may be found on Vemy Stone ’ s website . ¹³⁶ CBP notes that the name “ Vemy ” has been removed from some of the pieces of equipment in the photographs submitted by MSI . ¹³⁷ Moreover , when asked for a manufacturing process flow chart and narrative description of the production process , MSI only submitted a list of production steps and a photograph of each step . ¹³⁸ CBP notes several of the photographs accompanying these

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See Big D ’ s CF28 Request .

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See Big D ’ s CF28 Response .

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See Memo to the File , “ Consolidated EAPA Investigation 7657 : Information Pertaining to Malaysian Exporters ,” dated February 8 , 2022 ( Malaysian Companies Memo ) at “ Sanctuary Stone .”

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See Big D ’ s CF28 Response and the Malaysian Companies Memo at Sanctuary Stone for a comparison of the two factories and the production equipment found in each .

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See Big D ’ s CF28 Response ; Malaysian Companies Memo at Sanctuary Stone .

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See Malaysian Companies Memo at “ Vemy Stone .”

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Sanctuary Stone ’ s factory and warehouse appear to be comprised of one building , which , coupled with the fact that it primarily sells natural stone and is not a producer of artificial stone , may indicate why it appears dissimilar to Vemy Stone ’ s factories .

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Id . CBP also included larger versions of the photographs in the Malaysian Companies Memo at Vemy Stone for an easier comparison .

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See Big D ’ s CF28 Response and the Malaysian Companies Memo at Vemy Stone for a comparison of the photographs .

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See Big D ’ s CF28 Response .

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