interpreting 23.3a (...the entire shaping and forming of such product from raw materials and its finishing and decoration were accomplished by hand labor... etc.):
e.g. I carve a wax (“raw material… by hand labor”) I mix up
investment by hand and make a mould. After I burn out the mould, I
melt up 18ct yellow gold “raw material”. I manually control my
centrifugal or vacuum caster and pour the gold. I clean up my
casting, filing by hand. I decorate with a hand engraved texture. I
finish off polishing, holding it with my fingers against the buffs.
Voila! A hand made cast piece of jewellery, surely?
I can’t see that I would be violating any part of 23.3b. or any FTC
restriction. But then again, I’m just a simple jeweller, not a
bureaucrat. Kind regards, Rex (in unstifled Australia)