GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
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ADD/CVD Investigations and Annual Reviews at the DOC


U.S. Customs and Border Protection (CBP) issued a decision on February 9, 2024 in Enforce and Protect Act (EAPA) Cons. Investigation 7809, finding that Vanity Art LLC did not evade the antidumping duty (AD) order A-570-084 and countervailing duty (CVD) order C-570-085 on quartz surface products (QSP or covered merchandise) from the People’s Republic of China.  Vanity Art was represented by GDLSK LLP in the EAPA investigation.

The case was initiated in early 2023 based on allegations filed by Cambria Company, LLC (Cambria), a domestic manufacturer of QSP, that Vanity Art and another importer were importing Vietnamese-origin vanity cabinets with attached countertops made of Chinese QSP.  According to this allegation, Vanity Art imported the Vietnamese-origin vanities without separately declaring attached Chinese-origin QSP and without paying applicable AD/CVD duties.  CBP issued multiple questionnaires to Vanity Art and its suppliers throughout this proceeding, and CBP conducted on-site verifications of three of Vanity Art’s main suppliers.   GDLSK demonstrated that the countertops on Vanity Art’s products were not made with quartz and CBP ultimately concluded that the products did not fall within the scope of the AD/CVD orders on QSP from China.  As a consequence of this decision, it is anticipated that Vanity Art’s past imports of vanities will be liquidated without an assessment of AD/CVD.

Separately, CBP determined that there was substantial evidence that the other importer, Legion Furniture, imported countertops consisting of Chinese-origin QSP attached to wooden furniture from Vietnam without declaring the QSP as Chinese-origin.  This EAPA determination against Legion Furniture may be subject to an administrative review within CBP before becoming final.

Vanity Art LLC was represented by GDLSK attorneys Erik Smithweiss, John Schoenig and Dalanee Hester.  If you have questions about this CBP EAPA determination please contact one of the attorneys at our firm.


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