PUBLIC VERSION
Tel:( 954) 266‐6793 Email: krichardson @ rdhllc. com
Caesarstone USA, Inc. 88 1401 W. Morehead Charlotte, NC 282208 Website: www. ceasarstoneus. com Tel:( 818 779-0999 Email: info @ caeasarstoneus. com
IV.
QSP IS BEING IMPORTED IN INCREASED QUANTITIES A.
Legal Standard
The statute first requires the Commission to determine whether QSP is being imported into the United States in such“ increased quantities” as to be a substantial cause of serious injury, or the threat thereof. 90 Under Section 202 of the Trade Act, the increase in imports may be“ either actual or relative to domestic production.” 91 As detailed below, this statutory criterion is satisfied because imports of QSP increased significantly from 2020 to 2024, both in absolute terms and relative to domestic production, as well as relative to U. S. consumption.
B.
The Volume of U. S. Imports of QSP Increased Significantly Over the 2020 to 2024 Period in Both Absolute and Relative Terms
In absolute terms, the quantity and value of imports of QSP increased significantly over the past five years. In terms of quantity, total imports of QSP increased by 73.4 % from 135 million SQF in 2020 to 234 million SQF in 2024.
88 As discussed throughout this petition, while Caesarstone was active during the POI as a U. S. producer, it ceased its production operations in the United States in 2023.
90 See 19 U. S. C. § 2252( b)( 1)( A).
91 Id. § 2252( c)( 1)( C).
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