Background: Pursuant to the America First Trade Policy Presidential Memorandum and the Presidential Memorandum on Reciprocal Trade and Tariffs, the Office of the U.S. Trade Representative (USTR) solicited public comments on the proposed “Reciprocal Tariffs” from February to March 2025. Below is a summary of comments submitted by stakeholders in the textile and apparel industry.
The United States Fashion Industry Association (USFIA), whose members include many leading U.S. fashion brands and retailers, opposes raising tariffs and argues for lowering tariffs on textile and apparel products where the U.S. imposes a higher tariff rate than its trading partners. According to USFIA, higher tariffs on apparel and textiles would disproportionately impact lower-income U.S. consumers:
- “A true ‘reciprocal’ trade policy would lower tariffs on the products of trading partners that maintain lower tariffs than the United States.”
- “We recommend that the most successful policy to achieve trade reciprocity would be for the United States to lower the tariff rates of products for which our trading partners apply lower tariff rates. For consumer products such as textiles and apparel, this would help combat inflation and assist consumers who struggle to afford basic necessities.”
The American Apparel and Footwear Association (AAFA), representing U.S.-based “apparel, footwear and other sewn products companies”, opposes broad tariffs on apparel, footwear, and textiles. It is of concern to AAFA that the apparel and footwear sector already faces some of the highest tariffs in the U.S., and tariffs are a “hidden, regressive tax that falls harder on lower-income Americans.” Even worse, AAFA worries that higher tariffs would benefit “Illicit traders” and tariff threats would undermine the regional textile and apparel supply chain in the Western Hemisphere:
- “Illicit traders are better positioned to escape paying proper duties or any duties at all. Higher tariffs end up maximizing the profit and market access they can gain at the expense of legitimate shippers.”
- “Recent tariff threats particularly on our neighbors, Canada and Mexico, are especially concerning as the U.S.-Mexico-Canada Agreement (USMCA) review is about to begin. Canada is a key export market for U.S. made apparel and footwear while Mexico is a major source of a wide variety of apparel, including denim imports. Not only does the threat of tariffs cast uncertainty but it also undermines future investment and nearshoring opportunities.”
National Council of Textile Organizations (NCTO), representing U.S. textile mills, supports targeted tariffs against “unfair trade” but opposes penalties on Western Hemisphere trading partners:
- “We strongly recommend that the Trump administration take a targeted approach to raise tariffs on specific countries that disrupt markets through the use of blatantly unfair and often illegal trade practices, while simultaneously operating in home markets that remain mostly closed to our products.”
- “We must preserve and strengthen existing trade relationships with U.S. free trade agreement (FTA) countries in the Western Hemisphere that offer valuable markets for U.S.-made textiles.”
- “We strongly believe that reciprocity should not mean a race to the bottom with lower tariffs on imports from other countries into our market. Rather, reciprocity should hold bad actors accountable for systemic unfair trade practices that have hurt domestic manufacturers.”
- “We urge the Trump administration to take several actions immediately to make textile and apparel trade more reciprocal and to support the domestic industry…Aggressively raise tariffs on imports of textile and apparel products from China and other trade predators in Asia…Close the de minimis loophole for all countries…”
SMART (Secondary Materials and Recycled Textiles Association), representing businesses engaged in the collection, reuse, conversion, and recycling of textiles and other secondary materials, advocates for addressing trade barriers that affect U.S. secondhand clothing exports. SMART also opposes CAFTA-DR members using the “yarn-forward” rules of origin for imports of secondhand clothing (HTS 6309) from the U.S. under the agreement.
National Retail Federation (NRF), generally representing all types of U.S. retailers, opposes broad-based tariffs, arguing that they increase consumer costs, disrupt supply chains, and hurt retailers. NRF supports targeted measures against unfair trade practices but warns against policies that could lead to unnecessary retaliation from U.S. trading partners.
- “We believe that high, across-the-board tariffs will undermine the economic growth signaled by the other features of the president’s agenda and have lasting negative consequences for consumers and workers. If the goal of reciprocal tariffs is to enter into negotiations to remove barriers to trade, this will unlock economic growth and reduce prices for consumers. However, if the goal is primarily to raise tariffs, then the opposite is true.”
- “There are plenty of areas where U.S. tariffs are actually much higher than our trading partners, for example, especially when you look at U.S. tariffs on low value apparel and footwear. These regressive tariffs hurt low- and middle-income consumers the most.”
- “The administration should also consider the potential for retaliation from our trading partners on any reciprocal tariffs that are established. We are already witnessing our trading partners respond to strong tariff actions by the administration. This will further impact our farmers and manufacturers who are looking to gain access to those foreign markets.”
- “We need to focus on key high-priority sectors where it makes sense to return manufacturing home or areas where there is strategic competition. High tariffs on everyday household goods, which could raise consumer prices, should not be the focus of such a policy.”
Parkdale Mills, a leading producer of spun yarns based in North Carolina, expressed concerns about “unfair trade practices” from its Asian competitors. Parkadel also calls for closing the “De minimis” loophole.
- “Each week millions of pounds of product move through our free trade agreement partner countries illegally causing significant damage to the domestic textile industry. Non qualifying goods are shipped using false HTS codes, False Certificates of Origin, and illegal inputs to circumvent the required duty for US entry.”
- “Section 321 De Minimis (imports)…are shipped into the US each day without inspection or any type of customs enforcement causing millions in lost revenue and again, thousands of lost jobs. This loophole must be closed.”
FASH455 Global Apparel & Textile Trade and Sourcing 
This article really highlights the opposing viewpoints of the stakeholders, in response to the current administration’s idea to impose “reciprocal tariffs.” On one hand, these tariffs (like many stakeholders in the industry have expressed) will negatively impact lower-income families specifically, creating a regressive tax form; families who already are struggling to make purchases, will be affected if tariffs are imposed more so because this would increase prices for garments and other consumer goods. In addition to this, is the idea that imposing higher tariffs will affect the supply chain. On the other hand, some stakeholders do feel that these tariffs would urge Western countries to form better connections, for the sake of trading; they also suspect that this would enforce stricter regulations against unfair practices. These concerns im sure is what a lot of people, especially in the fashion industry, are debating, as the current administration continues to implement regulations. One thing that this makes me think of is the class activity we did on March 6th where we were analyzing graphs that related to the economic state of the US in the fashion industry. In doing this, one thing that me and my group found was that the value of imports (based on the graphs presented) was higher for us because we tend to rely on other countries more heavily for goods, than what we can produce on our own. This relates to the idea of tariffs because if the US imposes tariffs on imported fashion goods, it could impact the overall cost of those goods for consumers and businesses (similar to what stakeholders who are against the tariffs expressed). Seeing the way in which these things can impact us from all aspects (whether we are industry professionals or not) is key in better understanding the economic and social implications of current trade policies.
Overall, this blog post provides an interesting perspective on the differences between various retail associations viewpoints on tariffs. In class, we learned that the US textile industry wants more tariffs, but the apparel industry wants less tariffs due to manufacturing patterns and locations. Parkdale Mills, which is a textile producer, is supportive of high tariffs due to unfair trade practices that affect its’ domestic production and hurt the US producers. However, the apparel industry relies more on global practices, in which they want lower tariffs so it can be more affordable for the end consumer and more profitable for the company. Both viewpoints are valid because it generates the most money and affordability for their respective sector. However, I find it interesting how almost all of the apparel associations support tariffs on targeted countries that encourage unfair trading practices, as it is portrayed that all apparel companies do not support tariffs. This approach seems realistic and intelligent, especially to minimize the disadvantage of unfair trade practices from overseas. Furthermore, the de minimis policy on imports often falls into the unfair trade practices umbrella as companies take advantage of this, so this policy may be affected if taxes are heavily applied onto certain countries. In turn, this can end up hurting small businesses that may have small amounts of imports (under $800 to qualify for de minimis), and they may have to start paying taxes and import fees, which will harm their profitability. All in all, it is crucial for policy makers and T&A business professionals to look at an overall view of how policies will affect ALL aspects of the apparel industry and choose to implement policies that are the least harmful overall, whether that is overall tariffs, de minimis adjustments, targeted tariffs, more or less free trade agreements, or simple restructuring of international trade. It is clear that there is no win-win scenario for every player in the supply chain, but there can be efforts to reduce costs and ensuring trade practices given proper policies and targeting.
This article identifies a clear split within the textile and apparel industry over the proposed Reciprocal Tariffs. Most industry groups, like USFIA, AAFA, and NRF, argue against broad tariff increases, warning that they would raise prices for consumers—especially those with lower incomes—and disrupt key supply chains with partners like Mexico and Canada. On the other hand, organizations like NCTO and Parkdale Mills support targeted tariffs on countries they believe are engaging in unfair trade practices, particularly in Asia. Overall, the article shows how complex it is to create a trade policy that protects U.S. industries without harming consumers or damaging global partnerships.
After reading all of the responses to the “Reciprocal Tariffs”, we can see that different textile and apparel industries have mixed feelings. The U.S. Fashion Industry Association, SMART, National Retail Federation, and the American Apparel & Footwear Association are against higher tariffs on clothing and textiles. Some reasons include that high tariffs hurt lower-income U.S. consumers, raises prices, and hurts the supply chain. I believe that all of these are true and these companies oppose higher tariffs for many reasons. The Comparative Advantage Theory claims that “countries should specialize in producing goods they can make efficiently and trade what others produce more efficiently”. These apparel companies rely on importing textiles and apparel from different countries where it is cheaper to produce but with the increase in tariff prices, costs, efficiency, and competitiveness is being taken away. U.S. companies like the ones in this response are being hurt by these tariffs and disagree with Trump’s “Reciprocal Tariffs”.
After reading this, it’s pretty clear how complicated the whole reciprocal tariff situation is. There’s a huge divide between the textile and apparel sides of the industry. Textile companies like Parkdale Mills want more tariffs to protect U.S. production, but apparel brands and retailers are against it because they depend on global sourcing to keep prices down. I get why apparel companies are worried that higher tariffs would just make everything more expensive for consumers, especially for lower-income families who are already dealing with rising costs. It would also mess up supply chains that are already fragile. I thought it was interesting that some groups support targeted tariffs to fight unfair trade practices, though. It shows they’re not against all tariffs, just the ones that would do more harm than good. Honestly, there’s no easy fix here, but if policymakers don’t really think about how these decisions impact prices, jobs, and businesses across the whole industry, it’s just going to create even bigger problems.
I find a lot of the points made in this article important. Especially the point made by the USFIA that higher tariffs would impact lower-income U.S. consumers. This is important to think about because a lot of consumers that purchase from brands that will be most affected by tariffs such as those that source in China cannot afford price increases. Fashion should be available to everyone and raising tariffs only makes the price of a basic shirt more expensive which affects those who need lower prices the most. It is unfair and showcases how apparel items are not a choice but a necessity. Everyone needs clothing and raising tariffs on these items makes it a lot harder for families to properly dress their children. In addition, the retail industry employs many people and as stores let people go because they are not making the same profit many families will be affected monetarily. I think it makes sense that the NCTO wants targeted tariffs for textiles in order to boost U.S. textiles. Perhaps the targeted tariffs could push for more near shoring but, it is important to remember that U.S. textiles are often more expensive which would still lead to an increase in the price of apparel affecting low income families. This article showcases what a difficult situation this is and how many different opinions there are. No section of the apparel industry is in full agreement which makes it clear that there is no one solution to this problem but I believe the solution that allows for the least affect on low-income American families is the greatest option.
Lucy, you made some great points on this article that I completely agree with. We have learned both in FASH455 and from this article that these rise in tariffs will cause a significant price increase, specifically for the American consumers. Families that are purchasing apparel for more inexpensive prices will be left having to completely rethink their consumption habits, and may not be able to afford necessary basic apparel. I like that you pointed out retail employment as well. This is an instance of cause and effect that will hurt many involved. If companies cannot maintain an increase in sales, employment level for these brands will decrease. One again, resulting in more issues for the American consumer. These tariffs present a complex and uncertain situation for American consumers, with no solution in sight.
This article sheds light on the negative responses of members of the USFIA, SMART, AAFA and NRF, showing how damaging these reciprocal tariffs are to the textile and apparel industry. While NCTO, supports these tariffs on “unfair trade”, stakeholders hope that Trump will take a targeted approach and not penalize Western Hemisphere trading. The textile and apparel industry relies on the global market to provide affordable prices for manufacturers and free trade allows for easier and cheaper access to consumers. Consumers are also feeling the weight with higher prices and and limiting selection as retailers are raising prices and reducing stock to compensate import prices. Overall, it seems that targeted tariffs can be more harm than good and many trade organizations agree that it could be damaging for the world fashion industry.
This article held very similar sentiments to our case study from this year and did a great job at identifying and explaining the key players in opposition or support of the tariff policies. It enhanced what we know about the NTCO and USFIA and represented the The American Apparel and Footwear Association (AAFA), Parkdale Mills, and SMART (Secondary Materials and Recycled Textiles Association) as well. Like many others in this comment section, I agree that this article makes the split between the textile industry and U.S. based fashion brands very evident. While the textile industry is in support of tariffs that promote mercantilist views on global policy as well as brings production to the CAFTA-DR region, the fashion brands are in opposition because it increases costs for themselves and consumers and does not take advantage of comparative advantage.
The comments submitted to the USTR highlight how complex and divided the T&A industry’s response is to the proposed “reciprocal tariffs.” A key point that stands out is how the tariffs could unintentionally harm the industries and consumers they aim to protect. Organizations like the AAFA, USFIA, and NRF make a compelling case that increases in blanket tariffs would act as a regressive tax on American consumers, predominantly middle and low-income households. These associations display that apparel and footwear already face some of the highest tariffs in the US, and increasing them can reduce access to affordable clothing. There is a fear of unintended consequences. From the AAFA’s and NRF’s point of view, the across-the-board tariff increases could disrupt carefully built supply chains and hinder nearshoring efforts. There is a significant concern for companies trying to invest in regional partnerships and ethical sourcing.
The overall industry response to the proposed “reciprocal tariffs” makes one thing clear: most stakeholders in the textile and apparel space are not on board. Organizations like the USFIA and AAFA emphasize that higher tariffs on apparel and footwear would disproportionately impact lower-income consumers, acting as a regressive tax on everyday necessities. Rather than leveling the playing field, these policies risk increasing prices, disrupting supply chains, and making U.S. brands less competitive all without necessarily achieving true reciprocity.
While there’s broad agreement on the need to strengthen trade policy, there’s little support for blunt, across the board tariffs. The fashion industry is calling for solutions that balance domestic interests, consumer protection, and global competitiveness, because if the goal is fair trade, then the strategy needs to be just as thoughtful as it is bold.
This article does a good job of highlighting how divided the textile and apparel industry is over the reciprocal tariffs. On one hand, some argue that reciprocal tariffs, especially if carefully targeted, could help protect U.S. manufacturing and address some unfair trade practices. However,e others argue that broad tariff increases will increase the costs for consumers and disrupt fragile supply chains unnecessarily. While I do understand both arguments, I think that adding extreme tariffs on an essential such as clothing will ultimately do more harm than good. However, I do think it is possible to find a solution that can balance both protection of domestic, U.S. production without reducing affordability, and I think this article does a good job of highlighting both sides of the argument.