Congress and Administration
Monitor and maintain close involvement with the Administration regarding the implementation of the special import monitoring program for apparel imports from Vietnam.
Work with allies in the Administration and Congress to curtail the scope of the special monitoring program for imports from Vietnam.
Prepare and assess options to limit the scope of future anti-dumping investigations and to limit cases to those with domestic producers of like products that publicly support the anti-dumping measures. Possible recommendations include industry studies and analysis, as well as litigation options.
Develop strategy to counter efforts to expand the Vietnam program to other countries, particularly as a precedent when quotas are lifted from China on January 1, 2009.
Support expansion of duty-free access for textile and apparel imports. Goal is a single, uniform, duty-free program that includes full benefits for apparel and home furnishings under business-friendly origin rules. Includes support for legislative expansion of the Generalized System of Preferences (GSP) program and the Millennium Growth and Opportunity Act, as well as through the World Trade Organization Doha negotiations and the duty-free-quota-free initiative.
Monitor and oppose efforts to impose new trade restrictions on China. Participate in business coalitions active on China issues. Measures already actively under consideration include: bills to define alleged currency manipulation or misalignment as a countervailable subsidy, to remove Presidential discretion in product-specific safeguard investigations (Section 421), to make non-market economies (including Vietnam) subject to CVD investigations, and to require Congressional approval of graduations from NME to market economy status.
Support Congressional action in 2007 to approve Free Trade Agreements with Colombia, Panama and Peru.
Support Congressional extension of ATPDEA for all four countries for no less than two years. This will cover any delays in implementation of the FTAs with Colombia and Peru, as well as maintain benefits with Bolivia and Ecuador until those negotiations are completed.
Support negotiation of meaningful Free Trade Agreements with Korea and Malaysia. Press for commercially viable FTAs, particularly with respect to preferential origin rules and customs compliance/cooperation provisions. The Rules of Origin should support the expansion of current business practices by including either Tariff Preference Levels or an expanded single transformation Rule of Origin for apparel. All FTAs should also include Cumulation benefits for all countries that are FTA partners with the U.S.
Support full implementation of the Cumulation benefits in the CAFTA agreement as soon as possible.
Support full implementation of benefits for Haiti under the HOPE Act.
Support development of Reconstruction Opportunity Zones (ROZ) in Pakistan. Work to ensure that all apparel, home furnishings and leather products are included in the duty-free benefits, and that the program contains easy-to-use provisions.
Support Congressional action to modify the AGOA Abundant Supply provisions.
Support extension of Trade Promotion Authority for the Bush Administration, and work with Congressional allies to ensure there are no restrictions on the negotiation of reduced tariffs on textile and apparel products.
Oppose attempts in Congress to enact unworkable and unnecessary port security requirements, particularly regarding the scanning of imports. Work with the Administration and Congress to ensure that security measures do not unnecessarily restrict trade by increasing costs and creating delays.
Support funding for Customs automation; but oppose efforts to impose new user fees to pay for automation.
Monitor and oppose efforts to impose new trade restrictions through revisions to U.S. trade remedy law (anti-dumping and countervailing measures).
Monitor and oppose efforts to impose new anti-transshipment penalties on textiles and apparel products.
Support negotiations in the Doha Development Agenda Round to eliminate tariffs on consumer products, particularly textiles, apparel and footwear.
Monitor debate on labor and worker rights' issues. Oppose Dorgan-Graham bill to place Federal Trade Commission in charge of identifying labor violations and creating private right of action to allow private parties to harass importers with allegations of labor violations.
Oppose Dole-Graham bill to elevate the textile negotiator to Ambassador. The legislation would mark a return to the past when there were bilateral and multilateral agreements that required constant renegotiation.
Monitor and respond as necessary to Congressional or Administration initiatives undermining business certainty or sourcing options, such as the bills to revise the rules of origin for window shades to place them under China quotas and to make the Northern Mariana Islands subject to U.S. minimum wage rules.
U.S. Customs
Actively pursue strategies to facilitate the release of merchandise.
Continue efforts to persuade CBP that requiring production documents is time- and resource-consuming and not effective, because it only measures recordkeeping ability. Work with CBP to develop alternatives, such as recognizing the efforts of highly-compliant importers who monitor the factories who serve them. Press sourcing countries not to enter into unlimited customs cooperation (production verification) agreements.
Continue to work with other industry groups on Customs Entry Revision Project to ensure that textiles and apparel receive level treatment in all statutory and regulatory change
Improve the compliance dynamic between the industry and Customs
Educate Customs about the high cost of compliance and push for simplification and materiality
Ensure that the focus on security does not impair trade facilitation. Work with Customs to ensure a sufficient transition period for the 10+2 changes in order to avoid delays in entry and harm to business.
Pursue a strategy to rationalize ambiguities in classification based on use and other subjective considerations (where we cant win), including sleepwear, jackets vs. shirts, lingerie
Rationalize origin verification requirements, including streamlining documentation definition of a reasonable care standard
Improve the environment for informed compliance by seeking more timely and accurate information from Customs
Capture and report on uniformity issues across ports, and push for effective direction to the Field and uniform implementation of HQ directives
Continue efforts to seek uniformity and transparency in the production document review process
Seek agreement with Customs on reasonable care in respect of LDP and DDP transactions
Continue to seek rationalization of the Mandatory Advanced Electronic Cargo Information regime
Rules of Origin
Monitor and provide advice regarding International harmonization of the Rules of Origin by the World Trade Organization (WTO)
International Negotiations
Participate in World Trade Organization activities and the Doha Development Agenda.
Support inclusion of textiles and apparel in U.S. proposal to the WTO to eliminate tariffs on goods by 2015.
Monitor and be prepared for a quick response to any efforts to try to reintroduce special textile protection through the WTO Doha negotiations.
Committee for the Implementation of Textile Agreements
Represent interests of textile and apparel importers at CITA briefings
Participate in CITA decision-making and provide recommendations for negotiation and policy determinations
Press for increased transparency for CITA actions
Agriculture Department
Press for increased transparency and oversight of the cotton marketing and promotion program
Labor Department
Monitor Apparel Industry Partnership and other initiatives to impose Codes of Conduct or labeling requirements for apparel imports
Sept 17, 2008
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June 25, 2008
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