We are particularly knowledgeable about the textile and apparel sector. The era of quotas on textile and apparel imports may have ended, but the sector remains politically sensitive. U.S. textile and apparel duty rates are among the highest in the U.S. tariff schedule, an average of 16 percent, accounting for 40 percent of annual U.S. duty collections.
Not surprisingly, therefore, textiles and apparel trade is still a “priority trade issue” for CBP, which closely scrutinizes preferential duty claims under free trade agreements (for which the origin rules can be particularly complicated) and other preference programs (such as the Qualified Industrial Zones in Jordan and Egypt and the African Growth and Opportunity Act).
Textile and apparel imports are also targeted for counterfeiting and forced labor scrutiny. Plus, there are reports that in 2019 the Trump administration may seek renegotiation of the Dominican Republic-Central America Free Trade Agreement (DR-CAFTA), with a goal of changing the rules of origin to make it more difficult to use Chinese-origin inputs and still qualify for duty-free treatment.
Jacobs Global Trade advises foreign manufacturers of apparel products as well as U.S. manufacturers, importers and retailers on classification issues, origin rules and due diligence measures to ensure that supply chains are compliant with legal requirements, such as marking, product safety, and endangered species protection, as well as expanding consumer expectations regarding sustainability and good corporate citizenship, such as worker rights and safe working conditions.
We also advise on Federal Trade Commission rules related to internet advertising and the Green Guides for environmental claims.