How Has the Apparel Trade Flow Reacted to the Section 301 Tariff Action against China? (updated November 2018)

While apparel products are not subject to the Section 301 tariff yet, the trade action nevertheless has created huge market uncertainties for U.S. fashion brands and apparel retailers. Here is how the monthly trade flow of U.S. apparel imports has reflected the impacts of the U.S.-China tariff war:

First, U.S. companies did NOT stop importing from China. Seasonally adjusted data shows that between January and September 2018, the value of U.S. apparel imports from China decreased by 0.6 percent in volume and 0.05 percent in value year on year. Despite the decline, China remained the No.1 apparel supplier for the U.S. market in the first nine months of 2018, accounting for 32.3 percent market share in value and 41.3 percent shares in quantity, only marginally dropped by 1 and 0.7 percentage points from a year earlier respectively .

Second, apparel “Made in China” are becoming even cheaper. Notably, the average unit price of U.S. apparel imports from China dropped from $2.5/SME in 2016,$2.38/SME in 2017 to $2.36/SME in the first nine months of 2018. On the one hand, this result suggests that cost concern is not the most influential factor that drives U.S. companies to source less from China. However, it is also likely that Chinese exporters are intentionally reducing their price to keep their orders and overcome the challenges caused by the Section 301.

Third, there is no perfect replacement for “Made in China”. In response to the market uncertainty created by the Section 301 trade action, U.S. apparel importers are diversifying their sourcing base. That being said, it is difficult to identify a single largest beneficiary–notably, the market shares of apparel exports from Vietnam, Bangladesh, NAFTA, and CAFTA regions only marginally increased in the first nine months of 2018 compared with a year ago.

Additionally, it remains unclear whether the section 301 trade action has benefited U.S. textile and apparel manufacturing. Data shows that in the first ten months of 2018, the production index (2012=100) of textile manufacturing in the United States slightly increased from 92.8 in 2017to 94.3. However, over the same period, the index of apparel manufacturing decreased from 73.6 to 72.4.

Looking ahead, the volume of US textile and apparel imports from China is likely to increase in the short run since U.S. importers are eager to complete their sourcing orders before the new tariff hit.  Usually, companies place sourcing orders several months ahead of the selling season. However, it will be interesting to see if the trade data in the first half of 2019 will reveal the negative impact of the Section 301 action on China’s apparel exports to the U.S. market.

Data source: Office of Textiles and Apparel (OTEXA), US Department of Commerce

by Sheng Lu

U.S. Textile and Apparel Industry Provided Assessment of the Impacts of USMCA (NAFTA2.0)

On November 16, 2018, leading U.S. textile and apparel associations testified before the U.S. International Trade Commission (USITC) to provide industry assessments of the U.S. Mexico Canada Agreement (USMCA, or commonly called “NAFTA2.0”). Below is a summary of these associations’ comments:

First, both the U.S. textile industry and the U.S. apparel industry expressed overall support for USMCA, which is regarded as critical for maintaining the Western-Hemisphere textile and apparel supply chain.

National Council of Textile Organizations (NCTO): “In an overarching fashion, the new agreement is an improvement over the original NAFTA in many areas.”… “The United States, Canada and Mexico have built a vibrant and prosperous textile production chain over the 24 years through NAFTA.”

U.S. Fashion Industry Association (USFIA): “We reviewed the details of the USMCA, and we were pleased to find much we can support in it.” “USMCA remains a trilateral agreement, and “does no harm” to existing U.S.-Mexico-Canada supply chains.”

American Apparel and Footwear Association (AAFA): “…state our very strong support of the North American Free Trade Agreement (NAFTA). NAFTA serves as an important anchor for the U.S. textile, apparel, and footwear industry. Much of the textile manufacturing in the United States is tied directly to NAFTA through U.S. exports to NAFTA partners.”…” The USMCA appears to have largely met the goal of “do no harm”. We were pleased to see the USMCA retain this essential trilateral feature.”

Second, not surprisingly, the U.S. textile industry and U.S. fashion brands and apparel retailers hold divided views on the textile and apparel specific rules of origin provision in USMCA—particularly the tariff preference level (TPL). In general, the U.S. textile industry welcomes the changes that limit the usage of-USMCA originating textile inputs, whereas U.S. fashion brands and retailers ask for more flexibilities. Further, even though the agreement seems to be a balanced deal, both the two sides expressed “dissatisfactions” for what they did not get.

Regarding the yarn-forward rules of origin

NCTO: “We are pleased that the basic textile origin rules adopted originally in NAFTA were essentially reaffirmed in USMCA. Commend the creation of a separate textile chapter, which recognized the sensitivities associated with trade in this sector and allows for unique provisions.”

USFIA: “The yarn-forward rule of origin already discourages trade in our sector—and some companies have told us that they don’t claim the duty savings on eligible products from the region because the compliance requirements are simply too onerous and expensive.”

Regarding the tariff preference level (TPL)

NCTO: “While USMCA did reduce the size of some specific TPLs, the reductions will not cut into existing trade levels. This outcome is frustrating given the President’s stated goals of increasing benefits for U.S. manufacturers and eliminating provisions that have helped non-signatory countries, such as China, taking advantage of tariff preferences intended for North American producers.”

USFIA: “The agreement maintains the Tariff Preference Levels (TPLs) for apparel to and from all three countries. This is one of the most important elements of the agreement for our industry, and according to some of our members, the only way they can source textiles and apparel with these trading partners.”… “We also applaud the elimination of the requirement that visible linings for tailored clothing come from the NAFTA region. The maintenance of the TPLs and the elimination of the visible linings requirement–will help companies continue and expand business with our trading partners Canada and Mexico.”

AAFA: “we are discouraged that… the changes made to the rules of origin were to introduce more restrictive approaches. For example, many tariff preference levels (TPLs) were lowered…”

“As we argued throughout the talks, the best way to encourage more U.S. content is to weave in more flexibility into the rules. Such flexibilities provide additional opportunities for business to be conducted under the agreement. For example, the USMCA dramatically increases the TPLs that will enable more U.S. apparel and made up goods to be exported to Canada. Even though such articles don’t have to be made with U.S. textiles, the mere presence of their production in the U.S. will mean more customers for U.S. textile firms.”

Sewing thread, pocketing, narrow elastics and coated fabrics requirements

NCTO: ”We are very supportive of revisions that will require the use of USMCA-origin sewing thread, pocketing, narrow elastics and coated fabrics in certain end items—which will offer a boost for U.S. producers formerly left out of the origin rules in the original NAFTA ($250 million annual demand for sewing thread and $70 million for pocketing in the USMCA market).”

USFIA: “the USMCA creates new technical requirements –for example, the addition of requirements for originating sewing thread, pocketing and narrow elastic bands—which will result in higher costs for inputs and higher costs for brands and retailers (as well as their suppliers in Mexico and Canada) to administer the agreement.”

“We are concerned that the addition of more regulatory requirements to qualify for duty-free market access may hold back the ability of some companies to expand their sourcing with Mexico and Canada.”…”There will be some companies who shift operations out of the Western Hemisphere, or decide not to move new orders to Canada or Mexico because of these cost increases. The new regulations WILL make it more expensive and complicated for American brands and retailers to use the agreement.”

AAFA: “we are discouraged that – with few exceptions – the changes made to the rules of origin were to introduce more restrictive approaches. For example, many tariff preference levels (TPLs) were lowered and the USMCA now includes new requirements that sewing thread, elastic strips, and pocketing originate. While we understand U.S. negotiators were attempting to legislate more U.S. content into North American textile and apparel supply chains, the result, unfortunately, may be the opposite.”

Additionally, theU.S. textile industry is pleased with the changes to the government procurement provision, which closed a “loophole” regarding the Kissell Amendment.

NCTO: “We are also appreciative of a key change made in the Government Procurement Chapter of USMCA regarding the Kissell Amendment, which is a Buy American statute for textiles that applies to the Department of Homeland Security (DHS).  Kissell requires 100% U.S. content, with very limited exceptions, for purchases by the Coast Guard and Transportation Security Administration (TSA).

Regarding TSA procurement, Kissell has a problematic loophole tied to NAFTA that has allowed Mexico to supply these contracts.  As a result, under the terms of NAFTA, Mexico can supply TSA uniforms made from Mexican fiber, yarn, and/or fabric.  The TSA Mexico loophole translates to a significant weakening of U.S. Buy American statutes.  Noting that DHS spent $34million on clothing and textiles for TSA in FY2017, closing the Kissellloophole was a substantive change from NCTO’s perspective.”

[Note: Not like NAFTA, USMCAwill exclude FSC 83 (Textiles, Leather, Furs, Apparel, Shoe Findings, Tents, and flags) and FSC 84 (Clothing, Individual Equipment, and Insignia and Jewelry)from the procurement list of the Department of Homeland Security (DHS) that opens to Mexico and Canada.]


Why is the used clothing trade such a hot-button issue?

Shannon Brady and Sheng Lu (2018). Why is the used clothing trade such a hot-button issue? Just-Style [full article available]

Key Findings:

First, the world used clothing trade has grown significantly over the past ten years. Statistics from the United Nations show that the value of world used clothing trade (HS code 630900) has quickly increased from $1.8bn in 2006 to $3.7bn in 2016, an increase of 106 percent. Between 2006 and 2016, the value of world used clothing trade enjoyed a 7.6 percent compound annual growth rate (CAGR), which was almost double the pace of 3.4 percent CAGR for new clothing trade (HS chapters 61 and 62) over the same period.

Second, the world used clothing trade flow is highly unbalanced. On the one hand, the developed economies are the dominant suppliers of used clothing to the world. In 2016, nearly 40 percent of the world’s used clothing exports came from three countries alone: the United States (15 percent), the United Kingdom (13 percent) and Germany (11 percent). Data also shows that the European Union and the United States together stably accounted for as much as 65 percent of the value of world clothing exports between 2006 and 2016. The other country worth mentioning is China, which is quickly becoming another leading used clothing exporter in the world. In 2016, China’s used clothing exports totaled US$218m from only US$0.32m in 2006, an increase of more than 684 percent!

On the other hand, most of the world used clothing exports end up sold in the developing countries, especially the least developed ones. For example, in 2016, Sub-Saharan Africa (SSA) as a whole imported approximately 20 percent of the world’s used clothing, far more than any other regions in the world. By value, the top three individual importers of used clothing in 2016 are all developing countries as well, namely Pakistan (6.0 percent), Malaysia (5.8 percent) and Ukraine (4.9 percent).

Third, trade policies regulating used clothing trade often raise controversies. While trade barriers on new clothing attract much of the public attention, the used clothing trade is facing even heavier and trickier restrictions of various kinds. The World Trade Organization (WTO) data shows that in 2016 the average applied tariff rate for used clothing imports was 19.3 percent, higher than 15.4 percent of new clothing (HS Chapters 61 and 62). Of the total 180 countries covered by the WTO tariff database, 115 (or 64 percent) set an equal or higher tariff rate for used clothing than the new one. Further, it is not rare to see extremely high import tariff rates and other quantitative restrictions applied to used clothing trade. For example, in 2016 the applied most-favored-nation (MFN) ad valorem equivalent tariff rate for used clothing was as high as 356.9 percent in Uzbekistan, 167.3 percent in Zimbabwe, 149.2 percent in South Africa, 116.8 percent in Rwanda and 100 percent in Vietnam.

After all, because of the complicated social, economic and political factors involved, how to regulate and manage used clothing trade remains a key challenge facing the world community.

Patterns of Canada’s Apparel Sourcing and Trade

canada sourcing.jpg

The full article is available HERE

Key findings:

First, Canada is one of the largest and fastest growing apparel import markets in the world. Data from the UN Comtrade show that the value of Canada’s apparel imports totaled $10.7bn in 2017, which ranked the fifth in the world, only after the European Union (EU), the United States, Japan, and Hong Kong.

Second, the Asian region as a whole is the dominant apparel supplier for Canada. Measured in value, as much as 80.9 percent of Canada’s apparel imports in 2017 came from Asia. Specifically, China (40.6 percent), Bangladesh (11.1 percent), Cambodia (8.1 percent) and Vietnam (7.7 percent) were the top individual supplier for Canada in 2017, and all of them are located in Asia. Meanwhile, Canadian apparel companies are gradually diversifying their sourcing base: the Herfindahl Index (HHI), a commonly adopted measure of market concentration, declined from 0.3 in 2010 to 0.19 in 2017.

Third, the NAFTA-region remains an important apparel-sourcing base for Canada, but its overall influence is in decline. Measured in value, the United States and Mexico were the 6th and 9th top apparel supplier for Canada in 2017 respectively. However, facing the competition from Asia, the United States and Mexico combined accounted for only 6.4 percent of Canada’s apparel imports in 2017, a significant drop from 9.8 percent back in 2007.

Fourth, free trade agreements and trade preference programs provide duty-saving opportunities for apparel sourcing in Canada. In 2017, Canada applied an average tariff rate of 17.1 percent on imports of knitted apparel (HS Chapter 61) and 15.9 percent on woven apparel (HS chapter 62). As of August 2018, Canada has 17 free trade agreements (FTAs) and trade preference programs (TPAs) in force, offering preferential or duty-free market access to Canada. Traditionally, a substantial portion of Canada’s FTA partners come from the Western Hemisphere, such as Chile, Costa Rica, Colombia, Peru, Honduras, and Panama. However, in recent years, Canada has been actively negotiating and reaching new FTAs with countries in Asia (such as South Korea, India, and Japan) and Europe (including the European Union and Ukraine). 

Compared with the United States, in general, Canada adopts more liberal rules of origin (RoO) for apparel products. Quite a few Canada FTAs allow companies to source yarns or even fabrics from anywhere in the world – with the finished products still enjoying duty-free treatment when exported to Canada.

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China’s Changing Role in the World Textile and Apparel Supply Chain (updated October 2018)

china market share


Following the steps of many countries in history, China is gradually shifting its role in the world textile and apparel supply chain. While China unshakably remains the world’s largest apparel exporter, its market shares measured by value fell from 38.6 percent in 2015 to 33.7 percent in 2017.  China’s market shares in the world’s top three largest apparel import markets, namely the United States, EU, and Japan, also indicate a clear downward trend in the past five years. This result is consistent with several recent survey studies, which find that fashion brands and retailers are actively seeking alternative apparel sourcing bases to China. Indeed, no country, including China, can forever keep its comparative advantage in making labor-intensive garments when its economy becomes more industrialized and advanced.

However, it is also important to recognize that China is playing an increasingly important role as a textile supplier for apparel-exporting countries in Asia. For example, measured by value, 47 percent of Bangladesh’s textile imports came from China in 2017, up from 39 percent in 2005. We observe similar trends in Cambodia (up from 30 percent to 65 percent), Vietnam (up from 23 percent to 50 percent), Pakistan (up from 32 percent to 71 percent), Malaysia (up from 25 percent to 54 percent), Indonesia (up from 28 percent to 46 percent), Philippines (up from 19 percent to 41 percent) and Sri Lanka (up from 15 percent to 39 percent) over the same time frame. 

So maybe the right question to ask in the future is: how much value of “Made in China” actually contains in Asian countries’ apparel exports to the world?

China’s Textile and Apparel Factories Today

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