CBP Rules Jewelry Undergoes Required Double Transformation for GSP Benefits
Gold and silver jewelry produced in Turkey is eligible for Generalized System of Preferences benefits because the goods went through a double transformation within the country, CBP said in an Aug. 7 ruling. Arpas International, represented by Cowan Liebowitz, requested a further review of protest on the entry. GSP eligibility was questioned upon entry due to documentation sufficiency issues, CBP said.
The alloy used in the jewelry is produced in Turkey by "melting the fine gold and base metal alloy to create 10 karat and 14 karat gold shot in solid form," the company told CBP. "The fine gold is converted to shot in solid form for inventory, and not merely molten, poured and cast in a single operation," it said. To support the original GSP claim, the company offered various production records, invoices and video of onsite production at the facility in Turkey. The port questioned whether the documentation was "sufficiently linked to the merchandise at issue in the entry," the agency said.
The company subsequently provided an affidavit "from the Administrative Affairs Manager of the manufacturer that all of the jewelry sold by the importer was manufactured from raw materials at the company’s Istanbul factory," CBP said. The agency accepted the sworn certification and, after review of additional documents, believes the documents are sufficiently linked to the entry, it said.
CBP also agreed that the goods underwent the necessary double transformation for the value of the product to be counted toward the 35 percent value-content requirement for receiving GSP benefits. "The pure metals require alloying with other materials in order to have the strength necessary to be used in production," CBP said. "The alloyed metals are formed into intermediate products, such as shot, sheeting, tubing, that are used in the production of jewelry under several of the methods employed. The submitted videos show the intermediate materials in the form of sheets being processed into jewelry."