Comment from Excel Cabinets & Countertops

As a business owner in Salt Lake City, Utah, I have a public Comment on Section 201 Safeguard Measures – Quartz Surface Products To the Trade Policy Staff Committee and the U.S. International Trade Commission: I am submitting this formal comment to express significant concerns regarding the proposed Safeguard tariffs and Tariff-Rate Quotas (TRQ) on imported Quartz Surface Products (QSP). While the goal of supporting domestic manufacturing is noted, the proposed remedy—including a 25% to 40% duty—will have a disproportionately negative impact on the U.S. housing market and the thousands of small businesses that form the backbone of the stone fabrication industry. I. Impact on the Affordable Housing Crisis The United States is currently facing a critical shortage of affordable housing. Construction costs have surged over the last several years, and the inclusion of high tariffs on essential finishing materials like quartz will only worsen this trend. •Standardization of Quartz: Quartz is no longer a luxury item; it is the industry standard for durable, hygienic, and low-maintenance surfaces in modern residential construction. •Cost Transfers to Consumers: Research indicates that every $1,000 increase in the price of a new home priced at the national median can price over 100,000 households out of the market. Adding 25% or more to the cost of countertops directly inflates the final sale price or monthly rent of new units, effectively acting as a regressive tax on first-time homebuyers and low-to-middle-income families. II. Increased Cost of Doing Business for U.S. Fabricators The burden of these tariffs does not fall on foreign exporters alone; it is heavily borne by the American "downstream" workforce—specifically the independent fabricators and installers. •Operational Instability: Most fabrication shops are small businesses with tight profit margins. Sudden, steep increases in raw material costs force these businesses to either operate at a loss to honor existing contracts or pass massive price hikes onto their local customers, which can lead to a drop in demand and local layoffs. •Market Volatility and Quotas: The proposed quarterly quota system introduces unnecessary risk. If a quarterly cap is met, the sudden jump to a 40% tariff creates a "price cliff" that makes it impossible for fabricators to provide accurate long-term bids for commercial or multi-family projects. This uncertainty stifles business growth and complicates project planning across the construction sector. III. Conclusion and Recommendations The net economic harm caused by these Safeguard measures likely outweighs the benefits to the limited number of domestic slab producers. To protect the broader economy, I urge the following: 1.Lower the Tariff Rates: A more modest duty would provide protection without crippling the downstream industry. 2.Flexible Quotas: Replace rigid quarterly caps with annual totals to prevent artificial supply shortages. 3.Broad Exclusions: Grant exclusions for specific colors, patterns, and jumbo slab sizes that are not currently produced in sufficient quantities by U.S. manufacturers. Protecting one segment of the industry should not come at the cost of housing affordability and the survival of thousands of American small businesses. Thank you for your attention to this critical issue. I trust that the administration will weigh the heavy economic burden these tariffs place on small businesses and hardworking families against the intended benefits of the safeguard. I look forward to your thoughtful resolution on this matter.