Determining the Country of Origin of Apparel (CBP Webinar)

Watch the recording HERE

Note for FASH455: In our class, we cover the basics of apparel rules of origin in U.S. free trade agreements, which is a crucial topic for apparel sourcing. Although not required for our class, if you want more details about the technical aspects of determining apparel rules of origin, the implications for applied tariff rates, and related U.S. Customs regulations, this webinar recording is recommended. For example, the video explains why a blazer labeled “Made in Cambodia” could use fabrics from China, and even have the fabric cut into component parts in China.

FASH455 Exclusive Interview with Martha Girard, Production Manager at Jay Franco and Sons, about Home Textiles Sourcing

About Martha Girard

My name is Martha Girard, and I am a proud Blue Hen alum. I can’t pinpoint exactly when my passion for fashion began. It has always simply been a part of who I am. Even when I was a toddler, I would wear princess ballgowns and heels to the grocery store (move over, Carrie Bradshaw). When it came time to choose a college, the University of Delaware’s highly regarded fashion program felt like a natural place to pursue that passion.

During my junior year, I had the opportunity to meet Dr. Sheng Lu, who recognized my drive and encouraged me to apply for the UD Summer Scholars research program. Soon after, the COVID-19 pandemic transformed the world as we knew it. While much of life came to a halt, I immersed myself in research, examining how retailers were approaching secondhand product assortment and pricing strategies (note: see the publication based on the summer scholar research). I developed a genuine passion for this work!

That passion for secondhand strategy and sustainable fashion led me to Nuuly, where I joined as a Merchandise Assistant after graduation. As part of a rapidly growing startup, I gained hands-on experience in buying, production, shipping, and planning. This was far more than I ever expected to learn early in my career. I later transitioned to Lilly Pulitzer as an Associate Merchandiser, where I managed women’s pants, shorts, and skirts.

In mid-2024, a personal move brought me to New York City, where I stepped into a new role as a Production Coordinator at Jay Franco. While this position differed from my previous experience—shifting from women’s fashion to licensed children’s home products—it presented an exciting challenge. I was drawn to the team (and my amazing boss, Emily) and trusted my instincts that it was the right opportunity.

Nearly two years later, I can confidently say that decision was the right one. I’ve developed a strong foundation in sourcing, supply chain, and production, and my background in buying and merchandising has strengthened my perspective. Together, these experiences continue to shape me as I grow in my career as a Production Manager.

Disclaimer: The views expressed in this interview are those of Martha Girard and do not reflect the views or positions of her employer or any affiliated organizations.

Sheng: What are your main responsibilities as a production manager? Can you walk us through your typical day? What aspects of the job do you find most interesting, or something you didn’t expect when you took the role?

Martha:My primary responsibility is to ensure that every order meets the buyer’s ship date. While that may sound straightforward, it requires close coordination from the moment a purchase order is issued to when the goods arrive at the warehouse. I serve as the primary point of contact between our factories and internal teams, ensuring all updates are clearly and consistently shared.

I typically start my day by reviewing and updating the status of all open orders. My direct report and I manage approximately 200–300 orders at any given time. These updates include pricing, ship dates, licensor approvals (as all products must be reviewed and approved by their respective licensors), and any factory-related developments. Communicating these updates to our cross-functional partners is critical to ensuring alignment and avoiding delays.

From there, I move on to processing new orders received that day, followed by reviewing shipping reports to confirm that all vessels are on schedule and progressing as expected.

What I find most exciting about my role is the constant variety. No two days are the same. With factors like tariffs and global shipping disruptions, there is always a new challenge to navigate. The role requires strong problem-solving skills and creative thinking to keep operations running smoothly and ensure our buyers’ expectations are consistently met.

Sheng: When deciding where to source home textile products, what are the most important factors you consider (e.g., cost, lead time, quality, supplier reliability)? How do you balance these trade-offs?

Martha:All of our products are custom-made for each buyer or retailer, so it is ultimately up to our customers to decide on the perfect balance of these trade-offs. The needs of a large department store may focus on classic home assortments, which differ significantly from those of a value-driven retailer like a dollar store. We are well-positioned to support both.

For example, a dollar store partner may collaborate with our product team to develop a cost-efficient item that can move from concept to shelf in as little as 120 days. In contrast, a large department store may work with us to design a premium throw blanket at a higher price point, with a longer development timeline of up to six months to ensure the final product meets their standards. This flexibility allows us to tailor our sourcing approach and deliver solutions that align with each customer’s unique strategy.

Sheng:  How have recent tariffs and policy uncertainties affected home textile production and sourcing? What is your observation?

Martha: Unfortunately, the tariffs had a huge negative impact on U.S.-based fashion apparel companies. Many buyers canceled orders from China due to rising costs, prompting companies to explore sourcing options in countries with lower tariff exposure. This shift has been challenging, not only because companies have built strong, long-standing relationships with our manufacturing partners in China, but also because transitioning to new sourcing regions is both time-consuming and costly. It requires extensive research and development to evaluate whether alternative countries can meet our quality, pricing, and production standards.

Sheng: Sustainability is becoming increasingly important in the textile and apparel industry. How is this affecting the home textiles sector and your job? For example, are there changes in materials, sourcing practices, or supplier requirements?

Martha:We are finding that many of our licensors and customers are placing a strong emphasis on sustainability and eco-friendly materials. For example, one major customer (note: a well-known toy brand) only allows us to use 100% recycled polyester for their items and strives for eco-friendly packaging. As a company, we are happy to follow industry trends and advocate for more sustainable materials and practices, even if it could make sourcing and production more complex.

Sheng: Looking ahead, what industry trends will you be keeping a close eye on in the next 1-2 years, and why?

Martha: TikTok (which already seems like old news in 2026) has been one of the biggest game changers for our business. Our products frequently gain traction on the platform, making it an incredibly valuable tool for real-time customer feedback. It’s exciting to see what resonates with consumers to quickly adapt based on those insights. We’ve also introduced TikTok Live events, which have proven highly successful at driving engagement and visibility for our products.

Sheng: Reflecting on your time at UD and in FASH, what experiences helped prepare you for your career? What advice would you give to current students as they plan their career paths, especially in the sourcing field?

Martha: The most influential experiences I had at UD were my involvement with UDress, studying abroad in Paris, and participating in the Summer Scholars program. Each of these opportunities helped shape my perspective, build my confidence, and further define my career path.

My biggest advice is to put yourself out there and take advantage of every opportunity available to you. Try new things, trust your instincts, and don’t be afraid to step outside of your comfort zone. Most importantly, stay committed and work hard. You are all capable of achieving great things!

–The End–

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Textile-to-Textile Recycling and the Future of Apparel Supply Chains: Can It Revive U.S. Manufacturing? (Video discussion)

For FASH455: You must watch the video before commenting on the post. When writing your comment, you may consider addressing the following aspects.

  • Based on the video and the lessons from Reju, how would textile-to-textile recycling reshape the traditional global apparel supply chain? Which stages of the supply chain are most likely to relocate back to the U.S., and which will remain global?
  • Based on the video and the lessons from Reju, what are the biggest barriers to scaling textile-to-textile recycling? What risks may investors face when funding capital-intensive recycling plants in the US?
  • Will textile-to-textile recycling enable a meaningful revival of the U.S. textile and apparel industry and why?
  • Would “Made with recycled U.S. waste” be as valuable to consumers as “Made in USA”? Why?

Additional reading: 2026 Textile Recycling Expo USA Interview Series

[Discussion is closed for this post]

Tariffs Impact U.S. Apparel Sourcing and Trade Beyond Just Price (updated March 2026)

The average tariff rate for U.S. apparel imports (HS Chapters 61 and 62) reached 35.1% in December 2025, hitting a new high in decades and a sharp rise from 14.7% in January 2025, before President Trump’s second term. According to statistics from the Office of Textiles and Apparel (OTEXA), the U.S. International Trade Commission (USITC), and other government agencies, the hiking of tariffs and associated policy uncertainty has affected U.S. apparel sourcing and trade in multiple ways. [click here for detailed tariff data]

Impacts on apparel import price

Apparel sourcing cost pressure increased in 2025, although price changes varied by fiber type. Data from OTEXA shows that, measured in dollars per square meter equivalent (SME), the unit price of US apparel imports increased from $3.08/SME in 2024 to $3.14/SME in 2025, a 2% year-over-year increase. Notably, due to an overall downward trend in world cotton prices, the unit price of US cotton apparel imports was almost flat in 2025, after a 5% decline in 2024.

In contrast, amid ongoing geopolitical tensions and rising oil prices, the unit price of US man-made fiber (MMF) apparel imports increased more noticeably by 2.4% in 2025. Still, in absolute terms, the unit price of US MMF apparel at $2.58/SME in 2025 was only about two-thirds of the price of cotton apparel at $3.59/SME.

Additionally, due to weaker demand for relatively more expensive clothing, the unit price of US wool apparel increased from $21.6/SME to only $20.68/SME, or down 4.2%.

Amid higher tariffs, the unit import price for over half of the apparel import categories increased in 2025. Specifically, of the 106 apparel types categorized by OTEXA, 55 types (or 51.9%) saw a price increase between 2024 and 2025. This includes 22 categories (or 20.8%) with a price increase of more than 10 percent. Likewise, among the top ten largest apparel import categories by value in 2025, eight (80%) experienced price increases between 2024 and 2025, with an average increase of 2.5%.  This result suggests that the upward price pressure was embedded in core, high-volume products rather than niche items. Particularly, as fashion companies navigate rising tariffs and policy uncertainty through more frequent adjustments to their original shipping schedules, it could increase their production and logistics costs more than usual. [Click here for detailed top ten U.S. apparel imports price data]

Impact on clothing retail price

While the average U.S. apparel tariff rate rose from 14.7% in December 2024 to 31.5% in December 2025, the average U.S. clothing retail price increased only slightly by 0.3% during that time. This price rise was also much less than the 2.7% increase in the overall U.S. Consumer Price Index (CPI) during the same period. Since many apparel items are considered discretionary spending, higher inflation may lead consumers to reduce clothing purchases. [Click here for detailed U.S. apparel retail price index and CPI data]

Related, according to the Bureau of Economic Analysis (BEA), apparel accounted for 2.08% of U.S. consumers’ total personal spending in 2025, down from 2.10% in 2023 and 2.23% in 2021. As apparel retailers struggled to increase prices, younger generations, such as Gen Z, have turned to the secondhand clothing market.

Additionally, data collected from industry sources show that the average retail price for necessities (e.g., men’s underwear) experienced the highest increase during September 2025 and February 2026 compared with the same period a year earlier (i.e., September 2024 and February 2025). In comparison, discretionary spending items such as women’s swimwear and dresses, as well as products with near-shoring opportunity (i.e., T-shirts), experienced the smallest increase over the same period.

Impact on fiber usage and sourcing base

The U.S. tariff rates not only vary by sourcing origin but also by fiber composition. Generally, apparel made with cotton fibers will face a lower tariff rate (i.e., around 8-16% Most-favored-Nation, MFN tariff rates) than apparel made only from man-made fibers (i.e., around 16-32% MFN tariff rates).

As U.S. fashion companies leverage “tariff engineering” to mitigate the import duty increase, U.S. apparel imports in 2025 included more cotton apparel and fewer of those made from man-made fiber (MMF). Specifically, measured by quantity, cotton apparel (OTEXA category 31) accounted for 39.9% of total US apparel imports in 2025, higher than 38.5% in 2024 and 37.8% in 2023. In comparison, man-made fiber (MMF) apparel accounted for 56.6% of total U.S. apparel imports in 2025, a noticeable decline from 57.9% in 2024 and 59% in 2023. [Click here for detailed U.S. apparel imports by fiber content data]

Furthermore, while Asian countries had demonstrated greater competitiveness in man-made fiber (MMF) clothing, higher tariffs on such products in 2025 led U.S. fashion companies to source fewer MMF clothing from Asia. Notably, in value terms, 73.6% of U.S. MMF clothing came from Asia in 2025, a noticeable decline from 75.1% a year earlier. In comparison, 73.1% of U.S. cotton apparel imports came from Asia in 2025, up from 71.8% in 2024. [Click here for Asia market share data]

In comparison, it is interesting to note that while CAFTA-DR and USMCA members are perceived as more competitive in making and exporting cotton apparel products, due to tariff advantages, U.S. fashion companies import more man-made fiber (MMF) apparel from the regions in 2025. The same trend applied to wool apparel imports from the USMCA, which grew by 11.6%.  These results suggest that if the tariff gap between U.S. apparel imports from CAFTA-DR and USMCA members and those from Asian countries continues in 2026, it may further incentivize U.S. fashion companies to explore additional MMF apparel sourcing opportunities in the Western Hemisphere. This incentive could be reinforced by the fact that, since February 2026, apparel imports from many Asian suppliers have been subject to the new Section 122 tariffs, while qualifying apparel products from CAFTA-DR and USMCA remain exempt. It may also represent a historic opportunity to expand investment in MMF textile manufacturing in CAFTA-DR and USMCA countries, thereby increasing regional production capacity and diversifying product offerings. [Click here for CAFTA-DR and USMCA market share data]

Impact on Free Trade Agreement utilization

While there is no clear evidence from trade data showing that U.S. fashion companies expanded near-shoring from the Western Hemisphere in 2025, as a silver lining, the utilization of free trade agreements significantly improved. Specifically, measured in value, about 75.7% of U.S. apparel imports from members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) claimed duty-free benefits under the agreement, up from 73.0% in 2024 and 70.5% in 2023. Improved CAFTA-DR utilization in 2025 was driven by a higher volume of imports that met the yarn-forward rules of origin (i.e., up 1.5%). However, the utilization rate of the agreement’s short-supply mechanism decreased from 2.7% to 1.2%, despite more products being added to the list. [Click here for CAFTA-DR utilization data]

Similarly, in value, about 88.7% of U.S. apparel imports from Mexico and Canada claimed duty-free benefits under the U.S.-Mexico-Canada Agreement (USMCA), up from 86.1% in 2024 and 85.7% in 2023. Notably, in the past, only around 20% of U.S. apparel imports from Canada met the yarn-forward rules of origin; however, this percentage increased dramatically to 69.9% in 2025. Since March 2025, USMCA-qualifying products have been exempt from the “reciprocal tariffs” imposed by the Trump administration, which likely encouraged more U.S. apparel imports from Canada to take advantage of the rules. [Click here for USMCA utilization data]

By Sheng Lu

Read the full paper: Lu, Sheng (2026). US Apparel Import and Sourcing Patterns in 2025. Global Textile Academy, International Trade Centre (ITC). Geneva, Switzerland

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2026 WITA Academy: Pathways – Careers in Trade, Fashion & Apparel

The Washington International Trade Association (WITA) Academy Pathways program aims to expose students to exciting career opportunities in the textile and apparel trade, sourcing, supply chain, trade policy, compliance, sustainability, and more. The event is hosted in partnership with the University of Delaware, Department of Fashion and Apparel Studies, and the Fashion Institute of Technology.

Registration is free for students and faculty – must use university email to register (click here). [Note: Registration is NOT required for students enrolled in FASH455 this spring semester. We will participate in the event from the classroom.]

Agenda:

Tuesday, March 10, 2026

2:30 – 2:35 PM – Welcome & Opening Remarks

  • Kenneth Levinson, Chief Executive Officer, WITA – The International Trade Membership Association
  • Diego Anez, WITA Academy Executive Director, WITA Managing Director, WITA – The International Trade Membership Association

2:35 – 2:55 PM – One-on-One Career Conversation

  • Stephen Lamar, President & CEO, American Apparel & Footwear Association
  • Moderator: Kenneth Levinson, Chief Executive Officer, WITA – The International Trade Membership Association

2:55 – 3:45 PM – Panel 1: How Trade Shapes the Fashion & Apparel Industry

  • Yusra Siddique, Attorney, ArentFox Schiff
  • Julia Hughes, President, United States Fashion Industry Association
  • Katherine Stubblefield, Acting Division Chief, Chemicals and Textiles, Office of Industries and Competitiveness Analysis, U.S. International Trade Commission
  • Moderator: Alyson Demirdjian, International Trade Specialist, International Trade Administration, Office of Textiles and Apparel, U.S. Department of Commerce (Note: M.S. in Fashion and Apparel Studies, University of Delaware) 

3:45 – 3:55 PM – Break

3:55 – 4:15 PM – One-on-One Career Conversation

  • Ed Gresser, Vice President & Director for Trade & Global Markets, Progressive Policy Institute; author of the Trade Fact of the Week; former Assistant U.S. Trade Representative for Trade Policy and Economics
  • Moderator: Nicole Bivens Collinson, Managing Principal, Operating Committee, International Trade & Government Relations Practice Leader, Sandler, Travis & Rosenberg, P.A.

4:15 – 5:00 PM – Panel 2: Careers in Fashion, Trade & Policy 

  • Frank Chioccola, Vice President, Global Trade, Customs & Product Compliance, Tapestry
  • Erin Ickes, Senior Vice President, General Counsel and Human Resources, American Textile Company
  • Marin Weaver, Chief of the Services Division, Office of Industry and Competitiveness Analysis, U.S. International Trade Commission
  • Moderator: Sheng Lu, Professor and Graduate Director, Fashion and Apparel Studies, University of Delaware

FASH455 Exclusive Interview with Dr. Christian Schindler, Director General, International Textile Manufacturers Federation (ITMF)

About the interview

When studying global textile and apparel sourcing, our students often focus on fashion brands and retailers—but what happens on the manufacturing side is equally critical. From tariffs and trade policies to sustainability requirements, geopolitical tensions, and technological disruption, manufacturers face complex challenges that shape the global textile and apparel supply chain.

We are fortunate to have Dr. Christian Schindler, Director General of the International Textile Manufacturers Federation (ITMF), join us for this interview. He shared invaluable insights into how manufacturers are navigating today’s dynamic environment, including:

  • How rising tariffs and trade policy uncertainty are affecting textile and apparel manufacturers
  • China’s evolving role in the textile and apparel trade, and the implications for other critical textile and apparel supplying countries
  • The impact of geopolitical tensions on textile and apparel production, trade patterns, and manufacturers’ risk management strategies
  • Near-shoring: its prospects, limitations, and the factors influencing regional textile and apparel manufacturing shifts
  • Sustainability, recycling, and circularity: whether textile and apparel manufacturers see these trends as compliance, opportunity, or burden
  • How purchasing practices by fashion brands influence labor standards, compliance, and responsible sourcing at the factory level
  • The growing role of AI and digitalization in textile and apparel production, and the potential impacts on workers and supply chain efficiency

Additional data from the International Textile Manufacturers Federation (ITMF) survey about the latest industry trends (updated March 2026).

About Dr. Christian Schindler

Dr. Christian P. Schindler serves as Director General of the International Textile Manufacturers Federation (ITMF), the global federation representing the full textile value chain from fibres to finished apparel and home textiles. He leads ITMF’s strategy, research publications, industry conferences, and global dialogues on trade, sustainability, and technological change in textiles.

About Emilie Delaye (moderator)

Emilie Delaye is a master’s student & graduate instructor in Fashion and Apparel Studies at the University of Delaware, with a specific interest in supply chain, global sourcing, and sustainability. Emilie is also a member of the Fair Labor Association (FLA) 2025-2026 Student Committee and the University of Delaware President’s Student Advisory Council.