Petition QMAA 15 Sept | Page 43

PUBLIC VERSION
The presence or absence of any factor the Commission is required to evaluate is not“ necessarily dispositive” of whether the increased imports are a substantial cause of serious injury, or the threat of serious injury, to the domestic industry. 97
B.
The Domestic Industry Is Seriously Injured Under the Safeguard Standard The evidence across all of the factors analyzed by the Commission – capacity and production trends, financial performance, and employment – demonstrates that the domestic QSP industry has sustained serious injury over the POI to the extent that safeguard relief is appropriate and necessary.
1. Significant Idling of Production Facilities( 19 C. F. R. § 206.14( e)( 1)( i))
The massive surge of imports of QSP into the U. S. market over the last five years has led to the idling of U. S. production facilities. Indeed, because of the negative impact of imports, two U. S. producers have stopped producing QSP in the United States entirely.
� Caesarstone announced in December 2023 that it was closing its Richmond Hill, Georgia slab plant, eliminating approximately 129 jobs. 98 The company stated the closure was needed to“ optimiz { e } its global manufacturing footprint,” saving $ 20 million annually – a clear sign that operating its U. S. facility had become unsustainable in the face of cheaper imports and that the company would turn to importing QSP rather than producing it in the United States. 99
�
In the wake of the relief granted against imports of QSP from China, USA Quartz opened a QSP manufacturing plant in Jacksonville, FL. However, USA Quartz was subsequently closed as it was unable to compete with the surge of low-priced imports. 100
97 Id. § 2252( c)( 3).
98 WTOC, Caesarstone Technologies announces closure of Richmond Hill Manufacturing Facility
impacting over 100 employees( Dec. 18, 2023), attached as Exhibit 10; Caesarstone Provides Business Updates( Dec. 13, 2023), attached as Exhibit 11.
99 Id.
100 QSP from China First Review, USITC Pub. 5578 at I-16.
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