PUBLIC VERSION
resin, pigments, and other additives. QSP is typically manufactured into slabs of standard sizes and thicknesses but may also be cut into various shapes for end uses. Because of these uniform characteristics, QSP – regardless of origin – exhibits substantially identical durability, hardness, and aesthetic appeal. The Commission continued to define a single domestic like product in its first sunset review of the AD / CVD Orders on QSP from China. 70
Domestic QSP also has the same essential physical characteristics as imported crushed glass surface products. In the AD / CVD investigations of QSP from China, Commerce rejected claims that QSP made of crushed glass are distinct from QSP made of crushed quartz. Commerce found that crushed glass, like crushed quartz, is made predominantly of silica. 71 Quartz is made from crystalline silica, whereas crushed glass is made from non-crystalline amorphous silica. Both are silica in a solid form. This difference in the type of silica is not commercially significant and does not demonstrate a clear dividing line between domestic QSP and imported crushed glass surface products. Like all QSP, crushed glass surface products are produced from a mixture that is predominantly silica bound together with resin, pigments, and other additives.
QSP from both domestic and foreign sources competes directly in the same end-use applications, including countertops, vanities, wall panels, flooring, and other decorative or functional surfaces in residential, commercial, and industrial properties. Importantly, the high degree of substitutability means purchasers view domestic and imported QSP as interchangeable, selecting between them based on price, color, design, or availability rather than any functional distinctions.
70 QSP from China First Review, USITC Pub. 5578 at 4-9.
71 See Commerce Memo re: Scope Modification Determination in AD / CVD Investigations on QSP from China( Dep’ t Commerce May 14, 2019) at 20-21, attached as Exhibit 3.
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