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Buenos Aires, August 31st, 2006 Supports Argentina Aluminum Products – not have CNLWs From: Ivan Poklepovic [[email protected]] Sent: Thursday, August 31, 2006 4:03 PM To: FN-USTR-FR0052 Subject: 2006 GSP Eligibility and CNL Waiver Review Dear Sirs, Please find attached our petition. Sincerely Ivan Poklepovic Chief Foreign Trade Officer ALUAR Aluminio Argentino SAIC [email protected] phone: (54 11) 4725 8067 fax (54 11) 4725 8091 www.aluar.com.ar ALUAR Aluminio Argentino SAIC–Sede Social: Marcelo T. de Alvear 590- 3er. Piso–(1058) Capital Federal Tel /Fax: (54-11)4313-7593/4311-9026 Administración: Pasteur 4600 – (1644) Victoria B –Prov. De Buenos Aires – Tel.: (54-11) 4725-8000 Fax: (54-11) 4725-8087 Planta Industrial: Puerto Madryn – Provincia de Chubut – Argentina – Tel. Conmutador (2965) 459000 Telefax (2965) 451501 To: The Office of the United States Trade Representative Subject: 2006 GSP Eligibility and CNL Waiver Review In regard to the 2006 GSP Eligibility and CNL Waiver Review, Aluar Aluminio Argentino S.A.I.C., also known as Aluar, being a producer of Primary Aluminum with some extent into downstream activities, wish to take this opportunity to respectfully submit our comments herewith below in connection with and consideration of the re authorization of the GSP program by Congress. In particular, our comments and beliefs focus on the need for the continuance of the GSP program for the importation into the United States of some aluminum articles included in the Chapter 76 of the HTSUS, produced in Argentina. We believe that the beneficiaries of the current GSP system for mentioned aluminum articles from Argentina have not just been the country and people of Argentina but also for workers of many U.S. aluminum manufacturers and fabricators. If imports of aluminum from Argentina were to lose their current GSP status then, in our opinion, there would be a significant raw material cost escalation. U.S. manufacturer’s and fabricator's costs would rise significantly and to such an extent that many would be eventually threatened with having to cease operations as a result of cheaper fabricated aluminum products which would be imported into the United States from other regions. The current GSP Duty Free program is vital and necessary to continue not only for the further development of Argentina, it's people and economy, but also the importation into the United States of these products (some listed below) helps to keep aluminum raw material costs down for U.S. manufacturers and fabricators which in turn allows the cost to the U.S. consumer to remain lower. The products we are actually selling under GSP program and the ones we are considering for the near future development are: Primary Aluminum Wire Rod (Unalloyed/Alloyed) shipped in coils – Harmonized Tariff Schedule of the United States (2006) – Supplement 1 (Rev. 1) 7605.11.00.30 7605.11.00.90 7605.19.00.00 7605.21.00.30 7605.21.00.90 7605.29.00.00 End use in USA: production of electrical wire and cables for residential and commercial buildings, automotive radiators and climate control systems. Aluar’s current importers in USA: SouthWire Co., Carrollton, Ga; Prysmian, Abbeville, SC; Visteon, El Paso, Tx. Aluminum bars, rods and profiles / Extrusions – ALUAR Aluminio Argentino SAIC–Sede Social: Marcelo T. de Alvear 590- 3er. Piso–(1058) Capital Federal Tel /Fax: (54-11)4313-7593/4311-9026 Administración: Pasteur 4600 – (1644) Victoria B –Prov. De Buenos Aires – Tel.: (54-11) 4725-8000 Fax: (54-11) 4725-8087 Planta Industrial: Puerto Madryn – Provincia de Chubut – Argentina – Tel. Conmutador (2965) 459000 Telefax (2965) 451501 Harmonized Tariff Schedule of the United States (2006) – Supplement 1 (Rev. 1) 7604.10.10.00 7604.10.30.10 7604.10.30.50 7604.10.50.30 7604.10.50.60 7604.21.00.00 7604.29.10.00 7604.29.30.10 7604.29.30.50 7604.29.50.30 7604.29.50.60 End use in USA: Building and Construction, assembling and installation in architectural applications such as hurricane shutters, windows/doors, Automotive and Electronic applications such as bumpers and trim, ABS brakes, computer housings, heat sinks. Aluar’s actual importers in USA: Indalex Aluminum Solutions, Lincolnshire.Il. Additionally, Indalex and Aluar have technology exchanges as a direct result of the long term supply of Primary Aluminum billets by Aluar to Indalex for importation into the United States and use at Indalex's various U.S. plants. This technology exchange also involves the possibility of joint developments for both markets taking advantage of the different size of the countries economies, final customer’s preferences and regional needs. We have seen that there are small segments of the market that can not be supplied in one country while production for it does exist in the other. This means that cooperation between companies could give rise to better service and lower costs to the U.S. consumers. Aluar started directly exporting aluminum to the USA market in 1996 and it took several years to achieve the position of being a reliable and competitive supplier to American companies. In the last few years we have been able to go deeper and expand our commercial relationships with American companies. We were very glad to receive cooperation and proposals for technical provisions as well as advice about our provisions for such specific aluminum products. If we loose the GSP program all the time and efforts already made will be lost in favor of imports from other countries. American companies would have to start the process all over again. Based on the above said we could foresee additional possibilities of new joint developments for products like aluminum plates, sheets and strips HTSUS 7606, aluminum foil HTSUS 7607, aluminum tubes and pipes HTSUS 7608, aluminum tube or pipe fittings HTSUS 7609 and aluminum structures HTSUS 7610. Currently Argentina (Aluar) imports about 7,000 MT per month of Primary Aluminum into the United States. The majority of these imports are landed at Port Manatee, FL. ALUAR Aluminio Argentino SAIC–Sede Social: Marcelo T. de Alvear 590- 3er. Piso–(1058) Capital Federal Tel /Fax: (54-11)4313-7593/4311-9026 Administración: Pasteur 4600 – (1644) Victoria B –Prov. De Buenos Aires – Tel.: (54-11) 4725-8000 Fax: (54-11) 4725-8087 Planta Industrial: Puerto Madryn – Provincia de Chubut – Argentina – Tel. Conmutador (2965) 459000 Telefax (2965) 451501 In the past the aluminum had been imported through Gulfport, Ms. however since Hurricane Katrina the port facility at Gulfport no longer exists. Monthly Aluar Aluminum imports into Gulfport were considered by local Gulfport authorities as extremely important to the local Gulfport economy. The change to Port Manatee in Manatee county Florida has positively contributed to the development of that newly established Port and its facilities. Port Manatee has seen tremendous growth in imports partly as a result of the monthly shipments of Primary Aluminum from Argentina (Aluar). Increases in local employment at Port Manatee related to those services catering to Aluar’s aluminum imports would include stevedores, warehousemen, trucking and railroad personnel as well as freight forwarding. The shipping company which has been serving Aluar, Gearbulk, has its offices located north of the port in Tampa, FL. Aluar's future plans include increasing monthly shipment quantities of Aluminum products to the U.S. market. A shift in World production of Primary Aluminum away from areas of high cost power such as the United States to areas of lower power costs such as Argentina has been occurring over the last 20 years. The United States has been losing production yearly. There were over 30 Primary aluminum smelters in the United States at the end of the 1970's while today there are less than a dozen that are fully operational. The United States is now a country highly dependent on imports of Primary Aluminum products (about 5 Million tons annually and growing every year). Without the GSP program, the consumers in the United States would likely see cost increases for goods containing aluminum as U.S. manufacturers and fabricators would not be competitive compared to imported finished goods containing Aluminum. We will appreciate your kind consideration for our comments above and a continuance of the GSP program for imports of Aluminum products from Argentina. Sincerely, Ivan Poklepovic Chief Foreign Trade Officer ALUAR Aluminio Argentino SAIC–Sede Social: Marcelo T. de Alvear 590- 3er. Piso–(1058) Capital Federal Tel /Fax: (54-11)4313-7593/4311-9026 Administración: Pasteur 4600 – (1644) Victoria B –Prov. De Buenos Aires – Tel.: (54-11) 4725-8000 Fax: (54-11) 4725-8087 Planta Industrial: Puerto Madryn – Provincia de Chubut – Argentina – Tel. Conmutador (2965) 459000 Telefax (2965) 451501 Supports Argentina Re Upholstery Leather 4107.11.50 which not have CNLW From: Luis Moreno [[email protected]] Sent: Thursday, August 31, 2006 4:56 PM To: FN-USTR-FR0052 Subject: 2006 GSP Eligibility and CNL Waiver Review To Whom It May Concern Arpel Leather Company is an American Company that has been in business for 18 years and whose main activity is the purchase of finished leather for furniture upholstery. This leather enters the US under the Custom’s code 4107-11-5000. These hides come from Argentina, from tanneries with which we have been working, in an uninterrupted way, for several years. We are aware that a modification of the SGP for Argentina is being under study. This modification would entail the reduction of certain concessions and/or the implementation of taxes applied to products imported from that country. We understand that this change would create an increase in the sale prices of leather to the US furniture factories, who are our clients.
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