COVID-19 and U.S. Apparel Imports (Updated: July 2020)

The latest statistics from the Office of Textiles and Apparel (OTEXA) show that COVID-19 continued to enlarge its negative impact on U.S. apparel imports in May 2020, and the path to recovery will NOT be straightforward and quick. Specifically:

The value of U.S. apparel imports decreased by more than 60% in May 2020 from a year ago, setting a new record of single-month loss in trade volumes. Between January and May 2020, the value of U.S. apparel imports decreased by 27.8% year over year, which has been much worse than the performance during the 2008-2009 global financial crisis (down 11.8%).

As the first country hit by Covid-19, China’s apparel exports to the U.S. dropped by 60.2% in May 2020 from a year ago, close to its performance in April 2020 (down 59% YoY). While the figure itself is far from exciting, it suggests the sinking of China’s apparel exports could have hit bottom. As an important sign, China regained its position as the largest apparel supplier to the U.S. in May 2020, with 27.2% market shares in value and 41.4% market shares in quantity. Notably, this is a significant rebound from only 11% market shares back in February 2020. Overall, it seems U.S. fashion brands and retailers continue to treat China as an essential and probably indispensable apparel sourcing base, despite a new low of U.S.-China relations and companies’ sourcing diversification strategy. Meanwhile, the official Chinese statistics report a 20.3% drop in China’s apparel exports in the first five months of 2020.

Despite Covid-19, Asia as a whole remains the single largest source of apparel for the U.S. market. Other than China, Vietnam (20.1% YTD in 2020 vs. 16.2% in 2019), ASEAN (34.6% YTD in 2020 and vs. 27.4% in 2019) and Bangladesh (9.4% YTD in 2020 vs.7.1% in 2019) all gain additional market shares in 2020 from a year ago.

However, no clear evidence has suggested that U.S. fashion brands and retailers are giving more apparel sourcing orders to suppliers from the Western Hemisphere. In the first five months of 2020, still, only 9.1% of U.S. apparel imports came from CAFTA-DR members (down from 10.3% in 2019) and 4.0% from NAFTA members (down from 4.5% in 2019). Two factors might explain the pattern: 1) Due to factory lock-down, the production capacity in the Western Hemisphere is affected negatively; 2) With an unrepresented high level of unemployment, U.S. consumers are becoming ever more price sensitive.  However, apparel produced in the Western Hemisphere, in general, are less price competitive than those made in Asia.

As a reflection of weak demand, the unit price of U.S. apparel imports was lower in the first five months of 2020 (price index =101.5) compared with 2019 (price index =104.7).  Imports from China have seen the most notable price decrease so far (price index =71.0 YTD in 2020 vs. 83.5 in 2019).

by Sheng Lu

USTR Factsheet: Textiles and Apparel and the US-Mexico-Canada Free Trade Agreement (USMCA)

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The factsheet is available in PDF

Background

On December 10, 2019, the United States, Mexico and Canada reached an updated U.S.-Mexico-Canada Free Trade Agreement (USMCA). USMCA officially enters into force on 1 July 2020. Compared with the version signed in September 2018, the new USMCA includes even higher labor and environmental standards and stronger enforcement mechanisms for these rules. According to the released protocol of amendment, no change has been made to the Textiles Chapter, however.

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Textiles and Apparel and USMCA

First, in general, USMCA still adopts the so-called “yarn-forward” rules of origin. This means that fibers may be produced anywhere, but each component starting with the yarn used to make the garments must be formed within the free trade area – that is, by USMCA members.

Second, other than the source of yarns and fabrics, USMCA now requires that some specific parts of an apparel item (such as pocket bag fabric) need to use inputs made in the USMCA region so that the finished apparel item can qualify for the import duty-free treatment.

Third, USMCA allows a relatively more generous De minimis than NAFTA 1.0.

Fourth, USMCA seems to be a “balanced deal” that has accommodated the arguments from all sides regarding the tariff preference level (TPL) mechanism:

  • Compared with NAFTA, USMCA will cut the TPL level, but only to those product categories with a low TPL utilization rate;
  • Compared with NAFTA, USMCA will expand the TPL level for a few product categories with a high TPL utilization rate.

Fifth, USMCA will make no change to the Commercial availability/short supply list mechanism in NAFTA 1.0.

Sixth, it remains to be seen whether USMCA will boost “Made in the USA” fibers, yarns and fabrics by limiting the use of non-USMCA textile inputs. For example, while the new agreement expands the TPL level for U.S. cotton/man-made fiber apparel exports to Canada (currently with a 100 percent utilization rate), these apparel products are NOT required to use U.S.-made yarns and fabrics. The utilization rate of USMCA will also be important to watch in the future.

(Additional reading: Apparel-specific rules of origin in USMCA)

Economic Impacts of USMCA on the Textile and Apparel Sector

According to an independent assessment by the U.S. International Trade Commission (USITC) released on April 19, 2019:

First, USMCA overall is a balanced deal for the textile and apparel sector, particularly regarding the rules of origin (RoO) debate. As USITC noted, USMCA eases the requirements for duty-free treatment for certain textile and apparel products, but tighten the requirements for other products.

Second, the USMCA changes to the Tariff Preference Level (TPLs) would not have much effect on related trade flows. As USITC noted in its report, where USMCA would cut the TPL level on particular U.S. imports from Canada or Mexico, the quantitative limit for these product categories was not fully utilized in the past.  Meanwhile, the TPL level for product categories typically fully used would remain unchanged under USMCA. The only trade flow that might enjoy a notable increase is the U.S. cotton and man-made fiber (MMF) apparel exports to Canada—the TPL is increased to 20million SME annually under USMCA from 9 million under NAFTA.

Third, USITC suggested that in aggregate, the changes under USMCA for the textile and apparel sector will more or less balance each other out and USMCA would NOT affect the overall utilization of USMCA’s duty-free provisions significantly. Notably, the under-utilization of free trade agreements (FTAs) by U.S. companies in apparel sourcing has been a long-time issue. Data from the Office of Textiles and Apparel (OTEXA) shows that of the total $4,163 million U.S. apparel imports from the NAFTA region in 2019, around $3,742 million (or 89.9%) claimed the preferential duty benefits under the agreement. As noted in the U.S. Fashion Industry Benchmarking Study, some U.S. fashion companies do not claim the duty savings largely because of the restrictive RoO and the onerous documentation requirements.

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