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Textiles & Apparel
March 13, 2008

U.S. Customs and Border Protection has issued a fact sheet announcing that due to the high-risk nature of imports of textile and apparel products, CBP has designated the industry as a \\\"priority trade issue\\\" for fiscal year 2008.

(According to CBP sources, the textile and apparel industry has been a priority trade issue for the past few years.)

The following are highlights of CBP's fact sheet:

Numerous Requirements on Textile & Apparel Products Entering U.S.

CBP states that there are numerous requirements placed on textile and apparel products entering the U.S. under various free trade agreements and legislative preference programs. In addition, the U.S. maintains quantitative limits (quotas) on the amount of textile products that may enter the U.S. from China through December 31, 2008.

(CBP notes that approximately 42% of all duties collected by CBP are from textile imports.)

Schemes Used to Evade Duties/Quotas Include Transshipment, Misdescription

Many different schemes are used to evade duties or quotas on imported textiles and apparel being brought into the U.S. For example, some importers circumvent quotas by transshipment - changing the country of origin of their goods, while others use false documents or labels or provide incorrect descriptions of the merchandise.

(CBP states that it has initiated operations to address the misdescription of merchandise: import specialists have identified schemes to circumvent safeguards by misdescribing merchandise at a much lower rate of duty and import specialists have identified significant intellectual property rights (IPR) violations.)

CBP Uses a Multi-Faceted/Layered Approach to Enforce Trade Laws

CBP uses a multi-faceted/layered but complementary approach consisting of trade pattern analysis, on-site verification, review of production records, audits, and laboratory analysis to enforce U.S. trade laws and to ensure that appropriate revenue is collected. Import specialists in CBP with specialized commodity knowledge analyze and review textile and apparel imports for possible violations.


CBP Has Seized More Than $100 Million in Textiles and Apparel Since 2006

CBP's focus on textile and apparel violations has led to seizures of major shipments. CBP has seized more than $100 million in textiles and apparel since the beginning of calendar year 2006 and close to $50 million in 2007 for violations of the China quota agreement. In addition, CBP issued 68 penalty actions valued at $50.1 million. More than 13,000 physical examinations were performed, 1,527 fiber samples analyzed by the laboratories and 66 audits conducted.

CBP Uses On-Site Verifications as Enforcement Tool

According to CBP, one of the enforcement tools being used is on-site verification of manufacturers. CBP Textile Production Verification teams (TPVTs) travel to foreign factories to review and verify that wearing apparel that is shipped to the U.S. is produced at those facilities.

As a result of these site visits, CBP import specialists will target shipments that are in violation. Sites are selected after extensive trade analysis. In FY 2007, TPVTs visited 15 countries and approximately 671 factories, a 57% increase in the numbers over the previous year.