Final USITC Report on Chinese Quartz Imports June 2019 | Page 193

Conversion costs
With respect to integrated operations, other factory costs (“OFC”) were the second
largest component of COGS, ranging from *** percent (in interim 2018) to *** percent (in
2017) of total COGS, while direct labor costs ranged from *** percent (in interim 2018) to ***
percent (in 2015) of total COGS (see table VI-1). 14 For independent fabricators, direct labor
costs and OFC were at a similar proportion of COGS, ranging from *** percent (in 2015) to ***
percent (in 2017) and from *** percent (in interim 2017) to *** percent (in 2015) of total
COGS, respectively (see table VI-3).
As shown in table VI-7, the average unit OFC for integrated operations increased from
$*** in 2015 to $*** in 2017 and were lower between the comparable interim periods. The
average unit OFC for independent fabricators declined from $*** in 2015 to $*** in 2017 and
were higher between the comparable interim periods. On a company-specific basis, ***. 15
14
In regards to the labor activities in the automated manufacturing process, Cambria testified that
“there are some aspects where labors are physically intervening on the product, but mostly, they're
operating computer interface and activating technology and equipment, different unit operations,
whether it be distributors or presses or ovens or cooling towers, these types of things and they're
monitoring that throughout and intervening appropriately through the production line. And then there's
the removal of the slab. It weighs you know 600 pounds, so there's removing of the slab with cranes and
forklifts and this type of thing, so there's the warehousing handling teams that are driving fork trucks
and moving cranes and this type of things. And then there's crews to do loading and the physical work to
load the products on the trucks and this type of thing, so it's a combination”. Conference transcript, pp.
83-84 (Davis).
15
***. Email from ***, April 9, 2019.
VI-19