Petition QMAA 15 Sept | Page 63

PUBLIC VERSION
3. Imports Are the Most Important Factor Causing Serious Injury to the Domestic Industry
No other factor besides low-priced imports can adequately explain the serious injury experienced by the domestic industry. As documented above, the substantial loss in market share the domestic industry suffered to imports over the 2020 to 2024 period, the closures and idling of productive facilities and lost jobs as a result of competition from low-priced imports, and the financial performance of the U. S. industry due to surging volumes of low-priced imports, all provide compelling evidence that imports are the most important factor causing serious injury to the domestic industry.
Declining demand due to tepid activity in the construction and home renovation sectors of the economy cannot explain the deteriorating operations and financial performance of the domestic industry. Because consumers have been steadily switching to QSP as the material of choice for their countertops and other surface applications, the market and demand for QSP have continued their trajectory of high growth over the last five years. Indeed, apparent consumption increased by an incredible [ ] between 2020 and 2024.
Nor is there any evidence that the serious injury to the domestic industry was caused by a lack of investment or an inability to supply customers. The domestic industry engaged in substantial capital expenditures immediately prior to and during the POI, as three new U. S. producers— Dal- Tile, Guidoni, and Elite Quartz— opened facilities and entered the market. In addition, the established producers Cambria and LX Hausys invested in new production lines during the POI to increase their capabilities to supply QSP to the U. S. market. That these companies were unable to earn adequate returns on their investments is a direct result of increasing volumes of imports, which undercut U. S. prices and captured sales from the domestic industry. Further, these imports were not drawn into the U. S. market to fill a supply gap. The domestic industry maintained ample idle
56