Comment from Metro Stone Works

Metro Stone Works is a family-owned countertop fabrication and installation company serving residential builders throughout Virginia, Maryland, and the Mid-Atlantic region. We employ American workers and fabricate quartz, granite, quartzite, marble, and other countertop materials for new home construction. We are directly impacted by the proposed safeguard because quartz is one of the most commonly selected countertop materials in our market. As a downstream fabricator, we do not manufacture quartz slabs. We purchase material, add value through fabrication and installation, and provide jobs for local employees. Our perspective differs from manufacturers and importers because we experience the direct impact of material cost increases, supply disruptions, and builder pricing pressures. I am commenting on the proposed tariff-rate quota (TRQ) for imported quartz surface products. The proposal would impose a 25% tariff on imports up to 140 million square feet and a 40% tariff on imports exceeding that quota, with the remedy remaining in place for four years. While the intent is to support domestic manufacturing, the proposal will also affect thousands of downstream American businesses that rely on quartz slabs as a raw material. The proposed safeguard would significantly increase costs for fabricators, builders, and ultimately homebuyers. Unlike manufacturers, fabricators have limited ability to absorb sudden cost increases because pricing is often negotiated months in advance and competition within the residential construction industry is extremely aggressive. The proposed tariff structure also creates uncertainty regarding material availability. If import volumes approach the quota threshold, distributors and fabricators may face sudden price increases, allocation restrictions, or inventory shortages. This makes it difficult to quote projects accurately and maintain construction schedules. Additionally, the safeguard could unintentionally harm American jobs. Companies like Metro Stone Works employ template technicians, CAD designers, CNC operators, polishers, installers, project managers, and administrative staff. These are American jobs supported by a stable supply of quartz materials. Higher costs and reduced demand could negatively affect employment and investment throughout the fabrication industry. The proposal also risks increasing housing costs. Builders already face affordability challenges from labor, land, insurance, and material cost increases. Adding a substantial tariff on one of the most popular countertop materials will place additional pressure on new home pricing. Finally, the proposal appears focused primarily on manufacturers while giving limited consideration to downstream fabricators, builders, and consumers. Any evaluation of economic impact should include the businesses that purchase, fabricate, and install quartz products, not solely those that manufacture them. 1. Reduce or phase in the proposed tariff rates to minimize disruption to downstream businesses. 2. Create exclusions or relief mechanisms for domestic fabricators that rely on imported quartz slabs. 3. Distinguish between raw quartz slabs and fully fabricated imported countertops. American fabricators add substantial value and create local jobs. 4. Conduct additional analysis on the impact to housing affordability, construction costs, and downstream employment before implementing the final remedy. 5. Focus enforcement efforts on unfair trade practices and circumvention rather than broad measures that increase costs for the entire supply chain. Metro Stone Works supports fair trade and strong domestic manufacturing. However, the proposed tariff-rate quota is likely to increase costs, reduce supply flexibility, raise housing prices, and negatively impact American fabrication businesses that depend on quartz materials. We respectfully urge the agency to modify the proposal by reducing the tariff burden, protecting downstream fabricators, distinguishing raw materials from finished imports, and fully evaluating the impact on builders, consumers, and American jobs before implementing a final safeguard measure. For context, Metro Stone Works fabricates approximately 200,000 square feet of countertop material annually, of which roughly 140,000 square feet consists of quartz products. This volume demonstrates the significant role quartz plays in our business operations and highlights the substantial impact that increased costs and supply constraints would have on our company, our employees, our builder customers, and ultimately the consumers purchasing new homes.