Blog Articles

FASH455 Video Discussion: How Team USA’s 2024 Olympic Outfits Were Made by Ralph Lauren

Discussion questions for FASH455:

How does the video enhance your understanding of the complexity of apparel supply chain and sourcing? What is your evaluation of Ferrara Manufacturing’s strategies and best practices for maintaining apparel production in New York? Are high-end luxury brands the only viable opportunity for apparel “Made in the USA”? Feel free to share your thoughts and other reflections on the video.

China’s Textile and Clothing Export: Latest Patterns and Trends (updated August 2024)

The newly released World Trade Organization statistics and data from the United Nations (UNComtrade) suggest several patterns of China’s textile and clothing exports.

Firstly, while China remained the world’s largest clothing exporter in 2023, rising geopolitical tensions and Western fashion companies’ ongoing de-risking efforts pose increasing challenges to its export outlook.

To some extent, 2023 wasn’t too bad for clothing “Made in China.” In value, China’s clothing exports totaled $164 billion, accounting for 31.6% of the world—unchanged from 2022. While China’s clothing exports decreased by 9.7 percent in 2023 compared to the previous year due to weaker market demand, this performance was better than most other top ten suppliers, including Bangladesh (down 16 percent), Vietnam (down 12 percent), India (down 13 percent), and Indonesia (down 17 percent).

However, China’s clothing exporters face significant challenges ahead. Despite maintaining its overall market share, China is losing momentum in nearly all key Western clothing markets, including the United States, the European Union, the UK, and Canada. This trend is primarily driven by perceived heightened sourcing risks associated with China, ranging from concerns over forced labor in the Xinjiang region to escalating geopolitical tensions involving the country.

For example, according to the 2024 Fashion Industry Benchmarking Study released by the US Fashion Industry Association (USFIA) in July, a record 43 percent of surveyed leading US fashion companies reported sourcing less than 10 percent of their apparel products from China in 2024, compared to only 18 percent in 2018. Likewise, nearly 60 percent of respondents no longer use China as their top apparel supplier in 2024, much higher than the 25-30 percent range before the pandemic. Additionally, nearly 80 percent of respondents plan to further reduce their apparel sourcing from China over the next two years through 2026, citing perceived high sourcing risks as the primary concern.

Secondly, China has been diversifying its clothing exports beyond traditional Western markets in response to the “de-risking” movement. For example, the US, EU, UK, and Canada combined accounted for 43-45 percent of China’s clothing exports in 2023, lower than over 50 percent in the past. In comparison, these four Western markets typically accounted for 70 to 90 percent of an Asian country’s clothing exports. Meanwhile, since 2021, Asian economies, especially members of the Regional Comprehensive Economic Partnership (RCEP) and Africa, have become more important export markets for China. Nevertheless, since RCEP members and those in Africa primarily consist of developing economies with ambitions to expand their own clothing production and exports, the long-term growth prospects for their demand for “Made in China” clothing remain uncertain.

Thirdly, China’s weakened economy could lead to an increased supply of low-cost Chinese clothing in the global market.

Despite being known as the world’s largest clothing exporter, between 2013 and 2022 (the latest available data), over 70%–80% of clothing produced in China was consumed domestically, with only about 20%–30% being exported. However, as China’s economic growth has slowed and consumer spending on clothing has stalled, more clothing made in China could enter the international market and intensify the price competition. Notably, between June 2023 and June 2024, the average unit price of US apparel imports from China decreased unusually by 7.6 percent, signaling that an increased supply of Chinese clothing began to suppress market prices. Likewise, it doesn’t seem reasonable that the unit price of U.S. apparel imports from China was 40% lower than that of imports from Bangladesh in the first half of 2024. Thus, the growing influx of cheap Chinese products raises the risk of market disruptions, potentially leading to additional trade tensions and restrictive measures against Chinese products.

Fourthly, there is an early sign that Asian countries have become more cautious about using Chinese yarns and fabrics. China remained a key supplier of textile raw materials to leading apparel-exporting countries in Asia. However, Asian countries appeared to be sourcing fewer yarns and fabrics from China in 2023, possibly due to the enforcement of anti-forced labor laws, such as the Uyghur Forced Labor Prevention Act (UFLPA), and the perceived risks associated with sourcing Chinese cotton. Instead, more Asian countries’ yarns and fabrics now came from regional suppliers other than China.

by Sheng Lu

Additional reading: China has turned inward to sell Xinjiang cotton after a trade ban. Will it be enough? (South China Morning Post, August 11, 2024).

Mega Trade Agreements in the Asia-Pacific Region and Textiles and Apparel Trade (Updated August 2024)

Speaker: Dr. Deborah Elms, Founder and Executive Director of the Asian Trade Centre and the President of the Asia Business Trade Association. The clip was part of the webinar “Asia’s Noodle Bowl Of Trade” (March 2023).

Background

The Asia-Pacific region includes several mega free trade agreements:

ASEAN (Association of Southeast Asian Nations) is a regional intergovernmental organization comprising ten countries in Southeast Asia (Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, and Vietnam). In 2022, ASEAN members have a combined nominal GDP of $3.6 trillion and a population of 671.6 million.

CPTPP (Comprehensive and Progressive Agreement for Trans-Pacific Partnership) is a free trade agreement signed by 11 countries in the Asia-Pacific region, including Japan, Malaysia, Vietnam, Australia, Singapore, Brunei, New Zealand, Canada, Mexico, Peru, and Chile. The CPTPP covers a market of 495 million people with a combined GDP of $13.5 trillion in 2021. The United States was originally a participant in the Trans-Pacific Partnership (TPP) negotiations, but in January 2017, former US President Trump withdrew the US from the agreement. The Biden administration has indicated no interest in rejoining CPTPP. Additionally, China is actively seeking to join CPTPP (as of March 2024).

RCEP (Regional Comprehensive Economic Partnership) is a free trade agreement signed by 15 countries in the Asia-Pacific region, including China, Japan, South Korea, Australia, New Zealand, Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, Vietnam. In 2021, RCEP members collectively represented a market of 2.3 billion people with a combined GDP of $26.3 trillion. India was an RCEP member but withdrew from the agreement due to concerns about import competition with China.

IPEF (Indo-Pacific Economic Framework for Prosperity) is a US-led economic cooperation framework that aims to “link major economies and emerging ones to tackle 21st-century challenges and promote fair and resilient trade for years to come.” IPEF is NOT a traditional free trade agreement, and it does not address market access issues like tariff cuts. Instead, IPEF includes four pillars: trade, supply chains, clean economy, and fair economy. IPEF members in the Asia-Pacific region include the United States, Japan, Australia, New Zealand, South Korea, India, Fiji, Brunei, Indonesia, Malaysia, the Philippines, Singapore, Thailand, and Vietnam. The IPEF is designed to be flexible, meaning that IPEF partners are not required to join all four pillars. For example, India chooses not to join the trade pillar of the framework. In 2021, IPEF countries collectively represented a market of 2.1 billion people with a combined GDP of $23.3 trillion. The potential economic impact of IPEF remains too early to tell.

Notably, ASEAN, CPTPP, RCEP, and IPEF members play significant roles in the world textile and apparel trade. Specifically:

ASEAN and RCEP members have established a highly integrated regional textile and apparel supply chain. For example, a substantial portion of ASEAN and RECP members’ textile imports came from within the region.

ASEAN and RCEP members’ supply chain connection with China has substantially strengthened over the past decade. In contrast, the US barely participated in Asia-based textile and apparel supply chains. For example, other than CPTPP, the US accounted for less than 2% of ASEAN, RCEP, and IPEF members’ textile imports in 2022.

ASEAN and RCEP members also hold significant market shares in the world textile and apparel exports (over 50%). Meanwhile, the US and EU are indispensable export markets for ASEAN and RCEP members.

Because of the inclusion of the United States, IPEF represented one of the world’s largest apparel import markets (i.e., 33.7% in 2021, measured in value). Similarly, in 2022, about 26% of US apparel imports came from current IPEF members. Should IPEF address market access issues, it could offer significant duty-saving opportunities for textile and apparel products.

Additionally, the UK’s membership in CPTPP may have a limited direct impact on the textile and apparel sector, at least in the short to medium terms. For example, current CPTPP members only accounted for about 6% of the UK’s apparel imports in 2022.

2024 USFIA Fashion Industry Benchmarking Study Released

The full report is HERE

Key findings of this year’s report:

#1 Respondents reported growing sourcing risks of various kinds in 2024, from navigating an uncertain U.S. economy, managing forced labor risks, and responding to shipping and supply chain disruptions to facing rising geopolitical tensions and trade protectionism.

  • Over half of the respondents ranked “Inflation and economic outlook in the U.S.” and “Managing the forced labor risks in the supply chain” as their top business challenges in 2024.
  • The issues of “Shipping delays and supply chain disruptions” and “Managing geopolitics and other political instability related to sourcing” have newly emerged among respondents’ top five concerns in 2024.
  • About 45 percent of respondents rated “Protectionist trade policy agenda in the United States” as a top five business challenge this year, a jump from only 15 percent in 2023.

#2 U.S. fashion companies leverage sourcing diversification to respond to the growing sourcing risks and market uncertainty in 2024.

  • Nearly 70 percent of large-sized companies with 1,000+ employees reported sourcing from ten or more countries, significantly higher than the 45-55 percent range in the past few years. It also has become more common for medium to small-sized companies with fewer than 1,000 employees to source apparel from six or more countries in 2024 than in the past.
  • Nearly 80 percent of respondents plan to source from the same number of countries or even more countries through 2026, aiming to mitigate sourcing risks more effectively. However, their approaches differ at the firm level—some U.S. fashion companies plan to work with fewer vendors, while others intend to source from more.

#3 Managing the risk of forced labor in the supply chain continues to be a top priority for U.S. fashion companies in 2024.

  • U.S. fashion companies have adopted a comprehensive approach to comply with UFLPA and mitigate forced labor risks. On average, each surveyed company has implemented approximately six distinct practices across various aspects of their business operations this year, up from an average of five in 2023.
  • More than 90 percent of respondents say they are “Making more efforts to map and understand our supply chain, including the sources of fibers and yarns contained in finished products.” Notably, nearly 90 percent of respondents report mapping their entire apparel supply chains from Tier 1 to Tier 3 in 2024, a significant increase from about 40 percent in the past few years.
  • More than 80 percent of respondents say they “intentionally reduce sourcing from high-risk countries” in response to the UFLPA’s implementation. Another 75 percent of respondents explicitly state that their company has “banned the use of Chinese cotton in the apparel products” they carry.
  • About 45 percent of respondents have been actively “exploring sourcing destinations beyond Asia to mitigate forced labor risks.” However, this year, fewer respondents (i.e., under 10 percent) plan to cut apparel sourcing from Asian countries other than China directly, implying a more targeted and balanced approach to mitigating risks and meeting sourcing needs.
  • Based on field experience, respondents call for greater transparency in U.S. Customs and Border Protection (CBP)’s UFLPA enforcement, specifically in shipment detention and release decisions and in targeted entities and commodities information. Respondents also suggested that CBP reduce repeated detentions, focus on “bad actors” only, clarify enforcement on recycled cotton, and continue to partner with U.S. fashion companies on UFLPA enforcement.

#4 U.S. fashion companies remain deeply concerned about the deteriorating U.S.-China bilateral relationship and plan to further “reduce China exposure” to mitigate risks.

  • A record 43 percent of respondents sourced less than 10 percent of their apparel products from China this year, compared to only 18 percent in 2018. Likewise, nearly 60 percent of respondents no longer use China as their top apparel supplier in 2024, much higher than the 25-30 percent range before the pandemic.
  • Respondents rated China as economically competitive as an apparel sourcing base compared to many of its Asian competitors regarding vertical manufacturing capability, relatively low minimum order quantity (MOQ) requirements, flexibility and agility, sourcing costs, and speed to market. However, non-economic factors, particularly the perceived high risks of forced labor and geopolitical tensions, are driving U.S. fashion companies to move sourcing out of China. This trend applies to surveyed U.S. fashion companies selling products in China.
  • Nearly 80 percent of respondents plan to reduce their apparel sourcing from China further over the next two years through 2026. Consistent with last year’s results, large-size U.S. fashion companies with 1,000+ employees currently sourcing more than 10 percent of their apparel products from China are among the most eager to “de-risk.”

#5 U.S. fashion companies are actively exploring new sourcing opportunities, with a particular focus on emerging destinations in Asia and the Western Hemisphere.

  • This year, more respondents reported sourcing from India (89 percent utilization rate) than from Bangladesh (86 percent utilization rate) for the first time since we began the survey. Also, nearly 60 percent of respondents plan to expand apparel sourcing from India over the next two years, exceeding the planned expansion from any other Asian country.
  • For the second year in a row, three non-Asian countries made it to the top ten most utilized apparel sourcing destination list in 2024, including Guatemala (ranked 7th), Mexico (ranked 7th), and Egypt (ranked 10th). All three countries also witnessed an improved utilization rate in 2024 compared to last year’s survey results.
  • This year, a new record 52 percent of respondents plan to expand apparel sourcing from members of the Dominican Republic-Central American Free Trade Agreement (CAFTA-DR), over the next two years, up from 40 percent in 2023. However, most U.S. fashion companies consider expanding near-shoring from the Western Hemisphere as part of their overall sourcing diversification strategy. For example, nearly ALL companies that plan to increase sourcing from CAFTA-DR over the next two years also plan to increase sourcing from Asia.
  • 75 percent of respondents identified the “lack of sufficient access to textile raw materials” as the main bottleneck preventing them from sourcing more apparel from CAFTA-DR members. Respondents say the local manufacturing capability for yarns and fabrics using fiber types other than cotton and polyester, such as spandex, nylon, viscose, rayon, and wool, was modest or low in the CAFTA-DR region, even when including the United States.
  • The U.S.-Mexico-Canada Trade Agreement (USMCA) entered into force on July 1, 2020, replacing the North American Free Trade Agreement (NAFTA). Within the context of expanding nearing-shoring from the Western Hemisphere, in 2024, about 65 percent of respondents reported sourcing from Mexico and Canada (or USMCA members), a noticeable increase from about 40 percent in 2019-2020. About 36 percent of respondents say their companies “expanded apparel sourcing from USMCA members because of the agreement.

#6 Respondents underscore the importance of immediate renewal of AGOA before its expiration in September 2025 and extending the agreement for at least another ten years.

  • This year, respondents reported sourcing from seven AGOA members or countries in Sub-Saharan Africa (SSA), including Lesotho, Ethiopia (note: lost AGOA eligibility in 2022), Kenya, Madagascar, Mauritius, Tanzania, and Ghana, an increase from four countries in 2023, and six countries in 2022. Most respondents sourcing from AGOA in 2024 are typically large-scale U.S. fashion brands or retailers with 1,000+ employees. Generally, these companies treat AGOA as part of their extensive global sourcing network.
  • Over 86 percent of respondents support renewing AGOA for at least another ten years, and none object to the proposal. This reveals U.S. fashion companies’ strong support for the trade preference program and the non-controversial nature of continuing this agreement.
  • Over 70 percent of respondents say another 10-year renewal of AGOA is essential for their company to expand sourcing from the region.
  • About 30 percent of respondents reported that they had already held back sourcing from AGOA members due to the pending renewal of the agreement and associated policy uncertainty. This figure could increase to half of the respondents if AGOA is not renewed by the end of 2024.
  • Another 30 percent of respondents indicate that keeping the flexible rules of origin in AGOA, such as the “third country fabric provision” for least-developed members, is essential for their company to source from the region.

Other topics the report covered include:

  • 5-year outlook for the U.S. fashion industry, including companies’ hiring plan by key positions
  • The competitiveness of major apparel sourcing destinations in 2024 regarding sourcing cost, speed to market, flexibility & agility, minimum order quantity (MOQ), vertical integration and local textile manufacturing capability, social and environmental compliance risks and geopolitical risks (assessed by respondents)
  • Respondents’ detailed sourcing portfolio in 2024 for garments and textile materials (i.e., yarns, fabrics and accessories)
  • Respondents’ latest strategies to mitigate forced labor risks in the supply chain and fashion companies’ suggestions for CBP’s UFLPA enforcement based on field experience
  • U.S. fashion companies’ latest social responsibility and sustainability practices related to sourcing
  • U.S. fashion companies’ trade policy priorities in 2024

About the study

This year’s benchmarking study was based on a survey of executives from 30 leading U.S. fashion companies from April to June 2024. The study incorporated a balanced mix of respondents representing various businesses in the U.S. fashion industry. Approximately 80 percent of respondents were self-identified retailers, 60 percent were self-identified brands, 41 percent were importers/wholesalers, and 3 percent were manufacturers.

The survey respondents included large U.S. fashion corporations and medium-sized companies. Around 80 percent of respondents reported having over 1,000 employees; the rest (20 percent) represented medium-sized companies with 100-999 employees.

FASH455 Exclusive Interview with the Office of Trade at U.S. Customs and Border Protection (CBP)

Question 1: We know that nearly 98% of clothing consumed in the U.S. is imported. Can you give our students a quick overview of U.S. Customs and Border Protection (CBP)’s role in regulating international trade, particularly textiles and apparel products?

  • CBP’s Office of Trade facilitates legitimate trade, enforces U.S. trade laws, and protects the United States economy to ensure consumer safety and create a level playing field for American businesses.
  • CBP is responsible for regulating clothing and/or textiles products imported into the United States, ensuring that all trade aspects of the importation are correct at the time of entry. These include, but are not limited to the classification, valuation, country of origin markings, and qualification for preferential duty treatment under a free trade agreement and/or program. 
  • Textiles and wearing apparel are recognized as a Priority Trade Issue as codified in the Trade Facilitation and Trade Enforcement Act (TFTEA) of 2015. As such, this issue is one of the primary drivers for risk-informed investment of CBP resources as well as our enforcement and facilitation efforts. This includes the selection of audit candidates, special enforcement operations, outreach, review of free trade agreements and/or trade preference programs claims, and regulatory initiatives.

Question 2: Ensuring no forced labor in the supply chain is a top priority for U.S. fashion companies. Specifically, the Uyghur Forced Labor Prevention Act (UFLPA) officially came into force in June 2022. For our students who may not be familiar with the UFLPA, what essential information should they know about this legislation and the issue of forced labor? Additionally, could you recommend any helpful online resources?

  • CBP is the leading federal agency in the enforcement of forced labor laws and the UFLPA. The agency achieves this through two approaches – the first is through forced labor investigations and issuance of Withhold Release Orders (WROs) and Findings, which require CBP to prevent the release of goods made with forced labor into the U.S. commerce. The second is through the implementation of the UFLPA rebuttable presumption.
  • CBP enforces U.S. law on forced labor within Section 307 of the Tariff Act of 1930, which says any “goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in any foreign country” by convict or forced labor is not permitted entry into U.S. commerce. 
  • In 2016, the U.S. Government enacted the Trade Facilitation and Trade Enforcement Act (TFTEA), which removed the “consumptive demand” clause that was in the original statute. This change allowed CBP to set up its own investigative unit, where CBP receives allegations of forced labor, investigates them using the 11 indicators of forced labor, and issues WROs or Findings when applicable. CBP issues a WRO if there is a reasonable suspicion of forced labor conditions by a particular foreign manufacturer, and it issues a Finding if there is probable cause that forced labor conditions exist.
  • The relatively recent UFLPA establishes a rebuttable presumption that any goods made wholly or in part from the Xinjiang Uyghur Autonomous Region (XUAR) are prohibited from entry into U.S. commerce, as they are presumed to be made with forced labor unless the importer can provide clear and convincing evidence the goods are not made from forced labor or sourced from the XUAR.
  • When goods are exported directly from the XUAR, CBP applies the rebuttable presumption and excludes the goods from entry. Importers then must prove by clear and convincing evidence that the goods are not made with forced labor before they can be released into U.S. commerce. For goods not imported directly from the XUAR, CBP evaluates the risk that the producer uses inputs from the XUAR in the production of the final product and will stop any shipments it deems as high risk of containing materials produced from the XUAR.
  • CBP is committed to identifying products made by forced labor and preventing them from entering the United States. CBP’s enforcement of 19 U.S.C. § 1307 supports ethical and humane trade while leveling the playing field for U.S. companies that respect fair labor standards. The UFLPA is a major shift for importers as it requires them to know their entire supply chains from the raw materials all the way to the end product and to ensure no materials made with forced labor are included at any step along the way. Information on all of these topics and many more are available on CBP’s Due Diligence in Supply Chains webpage.
  • Students can visit our Forced Labor webpage for updated information and resources on CBP’s efforts to prevent goods produced with forced labor from entering U.S. commerce. There is also a specific UFLPA webpage, which explains CBP’s roles and responsibilities and links to the UFLPA Entity List; an UFLPA Statistics Dashboard with information on the number of shipments stopped by CBP by fiscal year, industry, or country of origin; due diligence documents and reports; CBP’s Operational Guidance for Importers, frequently asked questions on UFLPA enforcement and the Department of Homeland Security (DHS) Strategy; and additional links to the DHS Forced Labor Enforcement Task Force Agency Related Resources.    

Question 3: Our students are also intrigued by the so-called ‘de minimis rule,’ which has been a topic of heated debate in the news. Why was this rule proposed initially, and how does it relate to the fashion and apparel trade?

  • De minimis shipments, also referred to as Section 321 low-value shipments, are goods that are exempt from duty and tax under 19 U.S.C. § 1321(a)(2)(C) and 19 C.F.R. § 10.151. De minimis eligibility is based on the value of all goods imported by one person, in one day. The de minimis exemption allows CBP to pass, free of duty and tax, merchandise imported by one person on one day that has an aggregate fair retail value in the country of shipments of $800 or less. This provision was first enacted in 1938 to avoid administrative expense to the government from inspecting low-value goods disproportionate to the amount of revenue realized and was subsequently raised multiple times.  
  • The passage of the Trade Facilitation and Trade Enforcement Act (TFTEA) in 2016 raised the de minimis threshold from $200 to $800.
  • In 2015, CBP processed 139 million de minimis transactions. By 2023, this increased to more than 1 billion, representing a 662% growth in eight years. Now, in Fiscal Year 2024, nearly 4 million de minimis shipments arrive at CBP facilities for targeting, review, and potential physical examination each day. Although these packages are low value, they pose the same potential health, safety, and economic security risks as larger and more traditional containerized shipments.  
  • As long as a good is not subject to duties, taxes or fees (such as anti-dumping/ countervailing duties, excise taxes such as those required for alcohol and tobacco products, or any interagency fees that have not been waived for informal entries), it is eligible for de minimis clearance.
  • Significant attention is being placed on the de minimis administrative process for new business models, such as those used by e-commerce and fast fashion companies, which leverage the de minimis process for direct-to-consumer shipments. 

Question 4: Building on the previous question, in April 2024, the Department of Homeland Security (DHS) announced its new textile enforcement actions. How will CBP contribute to the new enforcement strategy?  

  • CBP is responsible for the management, control, and protection of U.S. borders and ports of entry, acting on the frontline of textiles and trade agreements enforcement. The U.S. textile industry is a vital domestic industrial base for U.S. national security, health care, and economic priorities. U.S. textile production is the foundation of the western hemisphere textile and apparel co-production chain, representing over 500,000 U.S. jobs, 1.5 million western hemisphere jobs, and $39 billion in annual shipments. Members of the textile industry have raised concerns with CBP regarding a decline in business momentum affecting their ability to maintain productivity and jobs. 
  • In response to these concerns, CBP is increasing its efforts to detect, interdict and deter illicit textiles trade and promote a level playing field for the domestic textiles industry given the ever-changing threat landscape and recent proliferation of allegations.
  • CBP is conducting coordinated and unified intelligence and data-driven operations to target and interdict textile imports that are not compliant with U.S. trade laws. Efforts include, but are not limited to, running special operations, carrying out Textile Production Verification Team visits at foreign factories and raw material providers, examining cargo, conducting compliance reviews and verifications, completing trade audits, and performing laboratory analysis on imported products with a heighted focus on imports that are subject to the U.S.-Mexico-Canada and Dominican Republic – Central America trade agreements, imported under the de minimis provision, and/or potentially in violation of forced labor laws, including the Uyghur Forced Labor Prevention Act.
  • You can learn more about CBP’s textile enforcement work in a recent CBP Reports video. You can also find information on our website.

Question 5: We know technology is significantly affecting and shifting how international trade is conducted. At CBP, there is an initiative called “21st Century Customs Framework.” Can you provide our students with more information about this program? For example, what is it about, what do you plan to achieve, and why does the program matter for fashion apparel companies?

  • The 21st Century Customs Framework (21CCF) is CBP’s effort to update its Title 19 authorities and underlying statutes, which have not seen comprehensive updates in more than 30 years.
  • Since 1993, trade volumes have increased dramatically, trade practices have changed, and new threats have emerged, which means CBP needs new tools and capabilities to do its job.
  • 21CCF matters for fashion apparel companies in two key ways: (1) the framework identifies updates that would better enable CBP to facilitate lawful trade more efficiently, so that goods can get to consumers, warehouses, stores, and other destinations as quickly as possible; and (2) the framework identifies updates that would enable CBP to bolster detection and enforcement against goods that threaten the well-being of American businesses and consumers—counterfeits, goods produced with forced labor, anti-competitively priced goods, and goods that violate environmental or consumer safety laws.
  • For example, 21CCF includes concepts that would authorize CBP to furnish industry stakeholders with information generated by market platforms regarding compliance with intellectual property rights laws—such as product origin and manufacturer—in importations where intellectual property violations are suspected. 
  • By sharing additional information with the private sector, CBP will be able to utilize its private sector partnerships to more readily identify illicit sellers using online marketplaces to import intellectual property rights-infringing goods into the United States.
  • Additionally, these proposed updates would better position the private sector to make more informed business decisions and eliminate high-risk actors from their supply chains.
  • Overall, in pursuing 21CCF, CBP envisions a trading system where legitimate goods move swiftly and securely; ethical production methods are used throughout the global supply chain; domestic industries compete on a level playing field; and the United States helps lead the world with innovative trade practices.
  • Private sector input has been instrumental throughout the development of the 21CCF statutory concepts, and the framework is now undergoing an interagency review process before eventually being cleared to be formally transmitted to Congress for consideration.

Question 6: As members of Generation Z, our students deeply care about fashion sustainability. Studies also show that fashion companies are increasingly concerned about climate change and its significant business implications. In your view, how can international trade contribute to sustainability and foster a more sustainable fashion industry? How might CBP support and assist in these efforts?

  • Sustainability in fashion concerns more than just addressing textiles or products. It involves the entire product lifecycle process, which includes the way the clothing is produced, consumed, and disposed of in landfills.
  • Sustainability in fashion encompasses a wide range of factors, including cutting carbon dioxide emissions, addressing overproduction, reducing pollution and waste, and supporting biodiversity.
  • CBP has a responsibility, as part of our mission, to keep people safe and protect the economy; that includes supporting the fashion industry. As noted, the fashion, textile, and apparel industries are crucial parts of the U.S. economy. The work CBP does is key in seizing suspect and potentially illegal fashion goods at the border, issuing penalties to bad actors, and protecting the health and safety of the American people.  
  • Due to CBP’s direct influence over trade processes, we see ourselves as a facilitator across the government to start conversations about sustainability and where government can remove barriers or add value to existing environmental efforts in trade.
  • CBP has developed strategies aimed at promoting environmental sustainability within trade. CBP’s Green Trade Strategy, for instance, is designed to champion the reduction of pollution and waste while encouraging the adoption of green technologies and practices. Such initiatives reflect a broader commitment to advancing circularity, recycling, and reuse in the fashion industry that can enable fashion companies to produce and sell their products more sustainably.
  • CBP launched the Green Trade Strategy in 2022 to further enable CBP to fight the negative impacts of climate change and environmental degradation in the context of the trade mission.
  • The strategy focuses on four main pillars:

o Incentivize Green Trade;
o Strengthen Environmental Enforcement Posture;
o Accelerate Green Innovation; and
o Improve Climate Resiliency and Resource Efficiency.

  • Thousands of CBP employees work toward making international trade more sustainable and transparent. The strategy touches every office and every employee at CBP.
  • With these four pillars, the strategy provides a framework for future action. Success requires buy-in and collaboration with all our stakeholders, including the fashion industry, and especially you, the future of fashion. We want your help because we cannot do this alone, and you offer unique perspectives that we need in order to fight and mitigate climate change.
  • Students who are interested in learning more about CBP’s green trade efforts can visit our Green Trade Strategy webpage.

Question 7: Additionally, some of our students are considering a career in international trade. What career opportunities at CBP might be a fit for our undergraduate and graduate students? 

  • There are a number of paths for college students and recent graduates to gain experience and begin to build their careers at CBP, including our recent graduate programs and the Pathways Program.
  • Some positions that recent graduates can pursue include the following:
  • Administrative – CBP has administrative roles in various business functions, such as finance, budget, personnel, logistics, and asset management. Position titles include Staff Assistant and Management and Program Analyst.
  • Law Clerks – This role is for those with recent JDs that expect to pass the Bar Exam within 14 months.
  • Auditors – This is for students pursuing the auditor career (Interns) or those expecting to complete the required unit of Auditor courses (Auditor, GS-11).
  • CBP prioritizes facilitating legitimate trade in textiles and wearing apparel and protecting the intellectual property rights of fashion and apparel brands as a part of its trade mission.
  • CBP employees help protect the wearing and apparel industry from counterfeit merchandise and other unfair or harmful trade practices.
  • Learn more about career opportunities at CBP on our careers page.

–END–

Disclaimer: This interview is intended exclusively for educational purposes in the FASH455 class and shall not be considered an official policy statement of the U.S. Customs and Border Protection (CBP).

New Study: Is Sub-Saharan Africa Ready to Serve as an Alternative Apparel Sourcing Destination to Asia for U.S. Fashion Companies? A Product-Level Analysis

Full paper: Lu, S. (2024), “Is Sub-Saharan Africa ready to serve as an alternative apparel-sourcing destination to Asia for US Fashion companies? A product-level analysis“, Competitiveness Review, Vol. ahead-of-print No. ahead-of-print. https://doi.org/10.1108/CR-03-2024-0041

Summary:

The prospect of Sub-Saharan Africa (SSA) as an apparel-sourcing base for U.S. fashion companies has been a growing heated debate. On the one hand, U.S. fashion companies, driven by increasing geopolitical concerns and other market factors, were eager to diversify apparel sourcing away from Asia. The SSA region was often regarded as one of the most popular alternative sourcing destinations thanks to its large population, relatively low labor costs, and shorter shipping distance to U.S. ports compared to most Asian. The African Growth and Opportunity Act (AGOA), a trade preference program enacted in 2000, in particular, allowed eligible apparel exports from SSA countries to enter the United States import duty-free, creating substantial financial incentives for U.S. fashion companies to source from the SSA region.

However, empirical trade data shows that U.S. apparel imports from SSA members have stagnated over the past decades without evident growth. Notably, with little change from 2010, SSA countries collectively accounted for only 1.8% of U.S. apparel imports in 2023, with no single SSA member achieving a market share of more than 1%. In contrast, over the same period, despite China’s declining market shares, the following five largest Asian suppliers—Vietnam, Bangladesh, India, Indonesia, and Cambodia—jointly accounted for 43.0% of U.S. apparel imports in 2023, a notable increase from 27.4% in 2010.

This study aims to evaluate SSA countries’ capacity to serve as an alternative apparel sourcing destination to Asian suppliers for US fashion companies. Specifically, the study examined the detailed product information of a total of 10,000 stock keeping units (SKUs) of clothing items sold in the U.S. retail market from January 2021 to December 2023. Half of these items were sourced from the six largest apparel-exporting countries in SSA: Lesotho, Kenya, Mauritius, Ethiopia, Madagascar, and Tanzania. Together, these countries accounted for over 96% of the value of U.S. apparel imports from the SSA region between 2021 and 2023. The remaining half came from China, Vietnam, Bangladesh, Cambodia, India, and Indonesia, the six largest Asian apparel exporters, which stably accounted for approximately 90% of U.S. apparel imports from Asia over the past decade.

Key findings:

First, the results revealed that U.S. fashion companies’ sourcing strategies for SSA countries appeared more subtle and complicated than simply treating the region as another low-cost sourcing destination, as suggested by previous studies. Instead, according to the results, U.S. fashion companies seemed to leverage SSA countries as suppliers of “niche products,” such as those relatively simple and basic apparel categories containing African cultural elements and targeting the luxury and premium market segment. Meanwhile, the demand for such products could be much smaller than regular apparel items sold in the value and mass market. This allows SSA countries to fulfill these smaller orders despite their limited production capacity, often family-owned or involving handmade processes.

Second, the study’s findings identified significant challenges for SSA countries serving as immediate alternatives to sourcing from Asia for U.S. fashion companies. While SSA countries could offer relatively low sourcing costs, the range of apparel products available for U.S. fashion companies to source from the SSA region remained significantly more limited than those from Asia. For example, results show that U.S. fashion companies preferred sourcing relatively basic and technologically simple categories like knitwear, T-shirts, and bottoms from SSA countries. However, imports from SSA countries offered more limited sizing and color choices and were less likely to include womenswear and relatively more sophisticated or specialized product categories such as outerwear and swimwear. As another example, U.S. apparel imports from SSA countries were primarily made of cotton and polyester, with less use of other fiber types, including nylon, rayon, viscose, wool, and those made from recycled textile materials (see table below).

Third, building on the previous point, the results call for new thinking on strengthening SSA countries’ genuine competitiveness as an apparel-sourcing destination. Over the past decades, trade preference programs such as AGOA have mainly focused on improving the price competitiveness of SSA countries’ apparel exports. However, as this study’s findings illustrate, AGOA and other trade preference programs seemed inadequate in assisting SSA countries in developing capacity beyond basic apparel categories and securing a sufficient variety of textile materials. As U.S. fashion companies have placed greater emphasis on factors beyond price in their sourcing decisions, such as flexibility, agility, sustainability, and vendors’ capability to make a wide variety of products, this could put SSA countries at even more significant disadvantages down the road to being considered alternatives to Asia for apparel sourcing.

The results also reminded us that AGOA’s liberal rules of origin, which allowed least-developed SSA countries to use textile materials from anywhere worldwide, cannot replace the crucial need to develop the local textile manufacturing capacity within the SSA region. Without a robust local textile manufacturing sector, SSA countries would encounter significant challenges in diversifying their product offerings to include more complex and versatile clothing categories, such as outerwear and women’s dresses. These categories typically require a wide variety of raw textile materials and accessories, making it highly impractical and inefficient to rely solely on imports for their supply.

On the other hand, the findings reveal the necessity of creating a stable and foreseeable business environment, such as the long-term renewal of AGOA, to attract more long-term investments in SSA. For example, investing in and strengthening SSA countries’ local supply of sustainable textile materials, such as recycled or organic fibers, could strategically enhance SSA countries’ competitiveness in meeting the increasing demand from U.S. fashion companies for sustainable apparel products.

Additional reading:

Explore Egypt, Morocco, and Tunisia as a Sourcing Base for Clothing Made from Recycled Cotton

The full article is available HERE and below is the summary:

With consumers’ growing demand for sustainable apparel products, fashion companies increasingly carry clothing made from recycled textile materials and seek additional supply bases. Recycled cotton has great potential for use in garments because of the wide availability of cotton-made secondhand clothing and the perceived positive environmental impacts of effectively recycling post-consumption cotton waste.

This study explores Egypt, Morocco, and Tunisia’s potential as sourcing bases for clothing made from recycled cotton. North African countries, including Egypt, Morocco, and Tunisia, have a long history of making and exporting cotton and cotton-made finished garments. The “developing country” status and membership in trade agreements or trade preference programs, such as the African Growth and Opportunity Act (AGOA) and the EU-Mediterranean Association Agreement, allow apparel products from these three countries to enjoy preferential duty benefits in the world’s top import markets. Therefore, there is great potential to capitalize on recycled cotton apparel and “green exports” to further promote economic development in the region.

About 13,000 Stock Keeping Units (SKUs) of clothing items made by these three countries newly launched to the world retail market between January 2022 and April 2024 were randomly captured from fashion brands and retailers’ websites. About half of the items were made of regular cotton, and the other half explicitly mentioned using “recycled cotton” in the product label or description. The results show that:

#1: Egypt, Morocco, and Tunisia have gradually expanded their clothing exports made from recycled cotton since 2022. For example, as estimated, about 1,300 SKUs of clothing using recycled cotton from these three countries were newly launched to the US and EU retail markets in 2023, a substantial increase from only 150 SKUs back in 2022 (or a sevenfold increase). Similarly, in the first four months of 2024, clothing using recycled cotton accounted for 10.2% of total cotton apparel from the three countries in the US and EU markets, a substantial increase from only 1.1% in 2022.

#2: Of the collected samples, apparel using recycled cotton from Egypt, Morocco, and Tunisia was destined for as many as 49 countries, reflecting the global demand for such products. However, possibly restrained by the limited supply, the export market for clothing using recycled cotton remained less diverse than that for clothing made of regular cotton, which spanned 72 countries.

#3: Geographically, the European Union (EU) was the top clothing export market for Egypt, Morocco, and Tunisia, accounting for over 75% of these countries’ export value in 2022, according to UN trade statistics (UNComtrade). This was also the case for recycled cotton products. Specifically, the EU accounted for 65% of these three countries’ total recycled cotton clothing exports measured in SKUs in the collected samples, higher than 59.4% of regular cotton clothing products.

#4: Egypt, Morocco, and Tunisia focused on different product categories for clothing using recycled cotton than those made from regular cotton. Specifically, of the sampled items, clothing using recycled cotton had a notable concentration on bottoms (52.9%), followed by tops other than T-shirts (23.8%). Recycled cotton clothing also was more commonly used for outerwear (7.5%) than those using regular cotton (3.8%). In comparison, only about 7.9% of clothing using recycled cotton were T-shirts, much fewer than nearly 30% of those using regular cotton. Similarly, specific product categories, such as underwear and hosiery, rarely use recycled cotton. Likely, the concerns for quality and durability and the difficulty of absorbing higher production costs make using recycled cotton for these relatively simple categories more challenging.

#5: Even though cotton apparel made in Egypt, Morocco, and Tunisia already commonly mentioned their sustainability attributes (86%), phrases such as “sustainability” and “sustainable” appeared even more frequently in clothing using recycled cotton (94.6%). For example, some producers highlighted that they “worked with suppliers, workers, unions and international organizations” to ensure their recycled cotton clothing contributed to “the United Nations Sustainable Development Goals.” Likewise, some labels intentionally remind consumers about the positive environmental impact of using recycled cotton, “The use of recycled cotton helps to limit the consumption of raw materials.” Another added, “The production of recycled cotton recovered cotton, mainly from the production of other garments, thus reducing the production of virgin spring and water consumption, energy and natural resources.”  

Meanwhile, compared to clothing using regular cotton, those made with recycled cotton in Egypt, Morocco, and Tunisia reported much higher participation in certification programs, such as the Recycled Claim Standard (RCS), which verifies the recycled content and tracks it from source to final product.

#6: Reflecting the technical limitations of the fiber property, it remains rare to have clothing that is 100% made from recycled cotton. According to industry experts, longer cotton fibers generally indicate higher quality. Since the recycling process shortens cotton fibers, regular virgin cotton or other fibers like polyester are typically used alongside recycled cotton to make fabrics smoother, stronger, and more durable. For example, common labels include descriptions such as “80% virgin cotton, 20% RCS certified recycled cotton” and “55% RCS certified recycled polyester, 45% RCS certified recycled cotton.”

#7: Except for T-shirts, in most cases, clothing made from recycled cotton in Egypt, Morocco, and Tunisia was priced lower than their equivalent using virgin fiber in the market. This is particularly the case for the premium and luxury market segments, where clothing using recycled fiber typically was 20-30% lower priced than regular clothing. The results echo the findings of numerous studies indicating that consumers are generally unwilling to pay higher prices for recycled fiber clothing as they perceive such products as lower quality and less “valuable.” Also, more needs to be done to create more financial incentives for producers in Egypt, Morocco, and Tunisia to expand the production scale and increase the use of recycled cotton in their products.

By Emilie Delaye and Sheng Lu

New Report: Reimagining the Apparel Value Chain amid Volatility

The new study released by Mckinsey & Co. was based on a survey of chief procurement officers (CPOs) from “apparel companies that collectively spend about $110 billion annually on sourcing” and follow-up in-depth interviews with 25 CPOs conducted in late 2023. Key findings:

#1 Fashion companies face increasingly challenging sourcing scenarios complicated by “ongoing supply disruptions caused by shifting demand, material price volatility, geopolitics, global trade issues, rising competition, and regulatory changes.” Compared to many other sectors, the apparel supply chain is particularly volatile, and disruptions can have amplified ripple effects throughout the supply chain. For example, an 11% decline in yarn exports could lead to a 30% drop in the production utilization rate of fabric mills.

#2 Fashion companies further prioritized “end-to-end” process efficiency in response to the shifting sourcing environment. For example, nearly 70 percent of respondents expect to “improve sourcing cost in the near term,” they plan to “improve efficiency across all facets of sourcing, including lower product costs, reduced sourcing expenses, and accelerated go-to-market processes.” Other practices to control sourcing costs include “using analytics to examine product cost breakdowns and identifying opportunities to improve fabric unit costs and material consumption,” “using digital platforms and data-driven insights to inform sourcing decisions and collaborating with suppliers to pinpoint cost savings opportunities.”

#3 Strengthening relationships with key suppliers remains critical. About 71 percent of surveyed brands consider “consolidating the supplier base” a medium to high priority for their strategy in the next five years. Surveyed fashion companies also indicate that deeper relationships, including “long-term volume commitments, shared strategic three- to five-year plans, and collaboration partnerships,” accounted for 43 percent of their total apparel supplier base in 2023, up from 26 percent in 2019. In comparison, suppliers based on “transactional relationships” only accounted for 3% of the total in 2023, a substantial decrease from 22% in 2019.

As the report noted, building strategic partnerships with core suppliers and “innovative niche suppliers” based on trust and transparency “resulted in a more robust, resilient, and agile supplier base” for fashion companies. More importantly, deeper importer-supplier partnerships extend beyond cost-saving measures but increasingly emphasize “sustained value creation.”

#4 Fashion companies continue to diversify their sourcing base geographically and pursue nearshoring to “improve speed, cost, and agility.” Specifically, between 2019 and 2023, respondents reduced their sourcing value from China (down from 30% to 22%) and sourced more from South Asia (up from 23% to 34%). At the country level, more than 40 percent of respondents plan to further increase sourcing from Bangladesh, India, and Vietnam. That being said, the report found that nearshoring remains “flat” in sourcing value in the US (about 17%) and in the EU (about 25%) from 2019 to 2023.

#5 To expand apparel nearshoring, several bottlenecks remain to be solved: 1) lower labor productivity in the region resulting in higher “total landed costs,” 2) challenges with yarn and fabric availability, and 3) the supplier bases in nearshoring countries can manufacture a more limited array of products.

The report also noted that “both local suppliers and Asian companies with a presence in Central America and Mexico have invested in improving their productivity and building local capacity for making yarns and fabrics,” which is helpful in addressing the challenges.

#6 Sustainability will continue to affect fashion companies’ sourcing decisions. For example, 80 percent of respondents said that “environmental, social, and governance certifications; transparency and traceability; and sustainable material usage have become prerequisites in supplier selection.” Fashion companies commonly used scorecards (92 percent) and third-party audits (78 percent) to ensure suppliers’ compliance with sustainability requirements. There is also an increasing need for data transparency on sustainability. However, “data is important, but organizations must understand how to use it to create value.”

Further, 86 percent and 70 percent of respondents said they would use recycled polyester and recycled cotton in their apparel products over the next five years.

#7 Digital innovation will deepen further in the sourcing and product development area. Popular tools include 3D modeling and digital sampling, Fabric libraries, and Product Lifecycle Management (PLM) system. However, prioritizing process redesign, data quality enhancement, and the integration of systems are essential to enable efficient operations. For example, one company developed a single material ID library with more than 30,000 materials from approximately 300 suppliers, allowing the company to aggregate more than 6,000 cost sheets in less than a minute.

Event Recap: Biden 2.0 or Trump 2.0? What We Might Expect on Trade Policy in a Second Term (April 2024)

The event was hosted by the Washington International Trade Association (WITA)

Key takeaways from the panel discussion:

The new punitive tariffs on Chinese steel and aluminum: The overcapacity problem in the steel industry globally could raise national security concerns. While the Biden Administration is more focused on outreach to allies and partners to address the issue collectively, the Trump Administration took a different approach with the Section 232 tariffs specifically targeting China. However, the impact of China-targeted measures could be muted due to the limited amount of US steel imported from China today. The next administration is expected to face the challenge of addressing global overcapacity in various industries. Like it or not, tariffs seem to be one of the few tools available to the US government to tackle these issues directly.

Currency debate:  “Currency manipulation” refers to the deliberate actions taken by a country’s government or central bank to artificially influence the value of its currency in the foreign exchange market. When a foreign government deliberately lowers the value of its currency, it could result in more US imports from that country and hurt the price competitiveness of US exports. While currency manipulation has not been a significant concern in recent years, the recent strength of the US dollar against other currencies, such as the Japanese yen, Chinese yuan, and Vietnamese dong, may reignite debate over the issue. The Biden Administration struggles to fight high inflation using high-interest rates, making it extremely challenging to “devalue the US dollar” in a macro sense. In comparison, the second Trump administration could designate countries of concern as currency manipulators, followed by new retaliatory measures, including tariffs or other trade barriers.

Industrial policy and subsidy: The Biden administration has packaged industrial policy as a core pillar of “Bidenomics,” which has pledged more than $805 billion in new subsidies for semiconductor manufacturing and research, climate and energy investments, and infrastructure spending. In comparison, the Republicans would be more inclined to let market forces determine the outcome of these policies rather than funding them through the government. It is also likely that the second Trump administration will tighten certain rules related to foreign entities taking advantage of US tax credits. However, there could be coordinated investments and supply chain resilience efforts in Biden and Trump’s second term, such as tactical coordination to prevent global subsidy races and disruptions in supply chains.

Trade policy as a tool for other issues: Reviving the Trans-Pacific Partnership (TPP) or similar mid-2010s era trade agreements was slim during the Biden administration. Instead, the Biden administration prioritizes a climate and trade agenda, as evidenced by the launch of a new White House Climate and Trade Task Force. Biden administration will continue to prioritize investments in domestic production capacity while looking outward to use trade to support other non-trade objectives.

In comparison, the Trump administration was more aggressive in pushing back against protectionist trade measures against US products but also less optimistic about the willingness of other countries to engage in good-faith negotiations with the US. Further, Trump 2.0 will likely return to trade policies similar to his first term, including potential tariffs of up to 60% on Chinese imports and an across-the-board tariff of 10% on all imports. Further, there is bipartisan support for increasing tariffs on Chinese goods, considering the deteriorating bilateral relationship. However, a 10% global tariff on imports from countries like Switzerland and Ireland could be more controversial due to potential consumer price impacts and damage to US alliances.

Discussion questions:

  1. Any of the aforementioned issues could potentially impact fashion apparel companies? Why?
  2. In your view, is it preferable for the textile and apparel industry not to be a focus of US trade policy? Why?
  3. What are your top 1-2 takeaways from the panel discussion?

2024 WITA Academy Pathways To Opportunity: Textiles and Apparel-University of Delaware

On April 30, 2024 (Tuesday) from 2:15 pm. to 3:45 p.m, the Washington International Trade Association (WITA) Academy, in partnership with UD’s Fashion and Apparel Studies Department, will host a virtual workshop (on Zoom) exploring career opportunities in textiles and apparel trade, sourcing, supply chain, and sustainability.

This event is free and open to ALL UD students (undergraduate and graduate) and faculty, but registration is required (please use UD email address): https://www.wita.org/events/pathways-april30-2024/

Note: Students in FASH455 do not need to register for the event. We will attend the workshop and participate in the live Q&A session in the classroom.

Confirmed speakers include:

  • Katherine White, Chief Textiles and Apparel Negotiator, Office of the U.S. Trade Representative (USTR)
  • Nate Herman, Senior Vice President, Policy, American Apparel & Footwear Association (AAFA)
  • Felicia Pullam, Executive Director, Office of Trade Relations, U.S. Customs and Border Protection (CBP); former Deputy Assistant Secretary of Commerce for Textiles, U.S. Department of Commerce
  • Stephanie Lester, Vice President, Head of Government Affairs, Gap Inc.
  • Maristella Iacobello, VP of Global Customs and Trade, PVH Corporation
  • Sarah Thorn, Senior Director, Global Government Affairs, Walmart

FASH455 Exclusive Interview with Tricia Carey, Chief Commercial Officer of Renewcell, about Textile Recycling and Implications for Apparel Sourcing and Supply Chain

About Tricia Carey

Throughout her career, Tricia believes in ‘progress over perfection’.  As an advocate for innovation and circularity in the textile and apparel industry, she recently joined Renewcell to accelerate the commercial development of CIRCULOSE®, making fashion circular. With a vast global network, as well as experience in brand building, storytelling, and business development, she is an invaluable partner to close the loop and optimize the benefits of CIRCULOSE®.

For more than twenty years, Tricia held various commercial management positions at Lenzing Fibers to establish the TENCEL™ brand, build mill partners, and set retailer specifications.  Her roles comprised marketing, Americas business development, and global denim segment expansion, including the creation of the Carved in Blue platform and numerous collaborative collections with mills and brands.

Tricia holds a bachelor’s degree in Fashion Merchandising from The Fashion Institute of Technology, as well as certificates in Digital Marketing and Strategy from Cornell University and MIT.

Tricia serves on the board of Accelerating Circularity, as well as the Transformers Foundation and the Fashion Impact Fund.  She was Vice Chair at Textile Exchange from 2014-2018.  In 2020 she was nominated as B2B Content Marketer of the Year by Content Marketing Institute, as well as top 100 Denim Legends by WeAr Magazine.  In 2019 Tricia was awarded the RIVET 50 for influential denim industry leaders.  She has been a speaker at various industry events, including the Conscious Fashion and Lifestyle Network at the United Nations, Transformers, Kingpins Show, Southern Textile Association, Texworld, Premiere Vision, Wear Conference, and more.

Tracia lives in New York City and can be seen dashing on the Peloton leaderboard.  The best way to connect with Tricia is through LinkedIn.

The interview was moderated by Emilie Delaye, UD’s entrepreneurship major and fashion management minor. Emilie has been involved in several research projects on the textile and apparel trade, sourcing, and sustainability issues, including authoring a paper on US fashion companies’ evolving sourcing strateiges published in Just-Style. Emilie is also the recipient of the 2024 Warner and Taylor Awards for Outstanding Seniors, the highest recognition for UD’s graduating seniors.

The Puzzling US Apparel Import Data…

The latest US apparel import data raises several puzzles that deserve to be investigated further.

Question 1: Why did imports suddenly surge, and is this surge sustainable?

Unexpectedly, US apparel imports experienced a significant surge in February 2024. This surge was marked by a 12.9% increase in quantity and a 2.9% increase in value compared to the previous year. Seasonally adjusted US apparel imports in February 2024 were also nearly 10% higher than in January 2024. The import surge was particularly surprising given that the value of US clothing sales in February 2024 was only 1.3% higher than a year ago and even 0.5% lower than in January 2024 (seasonally adjusted).

That being said, US total merchandise imports also enjoyed a 2.2% increase year over year in February 2024, the best performance since last fall. Meanwhile, the World Trade Organization (WTO)’s latest April 2024 forecast predicted the world merchandise trade volume to grow by 2.6% in 2024 as opposed to a 1.2% decline in 2023.

Therefore, it will be important to watch whether the US apparel trade has indeed reached a turning point and will continue growing in the coming months and throughout the year.

Question 2: Could the volume of US apparel imports in 2023 have been underreported?

With over 98% of clothing sold in the US retail market being imported today, there exists a strong correlation between US apparel retail sales (NAICS code 4481) and the volume of apparel imports. Between 2015 and 2022, the US clothing sales to clothing import ratio remained consistently around 3.0-3.2 (seasonally adjusted). In other words, the value of retail sales was approximately three times the value of apparel imports. However, in 2023, this ratio increased to 4.0-4.5.

One suspicion is that as more apparel imports came into the US through the de minimis, the official US apparel import data in 2023 was somewhat underreported. Notably, according to Euromonitor, about 40% of US apparel retail sales were achieved through e-commerce in 2023, a substantial increase from 9.4% in 2010. Likewise, with US customs tightening controls on “small package shipments” and enhancing UFLPA enforcement, more imports likely began entering through the standard procedure in recent months, which explains why the US apparel sales to import rato fell back to 3.8 in February 2024.

On the other hand, some say the lowered US apparel import volume in 2023 was due to retailers’ efforts to control inventory levels. Data shows that US clothing stores’ stock-to-sales ratio in the last quarter of 2023 averaged 2.34, slightly lower than 2.43 from 2015 to 2019, but was higher than 2.19 back in 2021. In other words, while there was some effort by retailers to control inventory (as seen by the ratio being lower than pre-pandemic levels), it wasn’t a significant enough change to have a large impact on import demand. Also, considering that apparel is a seasonal product, it doesn’t seem too likely that retailers would risk losing sales opportunities during the most critical selling season of the year (i.e., 4th quarter) by promoting outdated items instead of stocking new ones on the shelf.

Question 3: Why did Asian countries export more apparel to Mexico?

As a developing country, Mexico is not traditionally a leading apparel import market due to consumers’ limited purchasing power and the sufficient local apparel supply. Take China, Vietnam, Bangladesh, and Cambodia, the four top Asian apparel exporting countries (Asia4), for instance. Between 2018 and 2020, Mexico typically accounted for 0.4%-0.7% of Asia4’s total apparel exports. However, since 2022, Asia4 has almost doubled its apparel exports to Mexico (i.e., increased to 1.5%-2.0%). Moreover, during the same period, the percentage of Asia4’s apparel exports to the United States declined from 27% to below 20%, especially in the last quarter of 2023.   

What’s behind the increase in Asian countries’ apparel exports to Mexico needs to be investigated further. As noted earlier, Mexico itself is a leading apparel-producing country. Also, according to Euromonitor, the clothing market in Mexico stayed relatively stable at around 7.6%-7.9% of the size of the US from 2017 to 2023 (in quantity). In other words, Mexico’s increased import demand for Asian clothing doesn’t make much sense.

Others suspect some Asian apparel exports to Mexico eventually entered the US market either by taking advantage of the de minimis rule or the US-Mexico-Canda (USMCA) trade agreement. However, the exact size of this particular trade flow calls for further investigation.

By Sheng Lu

Current Event Discussion: U.S. Customs and Border Protection (CBP) and Textile Enforcement

#1: On April 5, 2024, the US Department of Homeland Security (DHS) released its new enhanced strategy to combat illicit trade and level the playing field for the American textile industry and the estimated over 500,000 US textile jobs*. *note: according to the Bureau of Labor Statistics, as of December 2023, the US textile and apparel manufacturing sector employed about 272,400 workers (seasonally adjusted), including 89.3K in NACIS313 textile mills, 95.6K in NAICS314 textile product mills and 87.5K in NAICS315 apparel manufacturing. As of December 2023, NAICS 4482 apparel retail stores employed about 850,000 workers (seasonally adjusted).

According to DHS, the new enforcement plan will focus on the following areas:

  • Cracking down on small package shipments to prohibit illicit goods from U.S. markets by improving screening of packages claiming the Section 321 de minimis exemption for textile, Uyghur Forced Labor Prevention Act (UFLPA), and other violations, including expanded targeting, laboratory and isotopic testing, and focused enforcement operations.
  • Conducting joint Customs and Border Protection (CBP)-Homeland Security Investigation (HIS) HSI trade special operations to ensure cargo compliance. This includes physical inspections; country-of-origin, isotopic, and composition testing; and in-depth reviews of documentation. CBP will issue civil penalties for violations of U.S. laws and coordinate with HSI to develop and conduct criminal investigations when warranted.
  • Better assessing risk by expanding customs audits and increasing foreign verifications. DHS personnel will conduct comprehensive audits and textile production verification team visits to high-risk foreign facilities to ensure that textiles qualify under the U.S.-Mexico-Canada Agreement (USMCA) or the Central America-Dominican Republic Free Trade Agreement (CAFTA-DR). (note: As CBP noted, most US free trade agreements and trade preference programs have complex textiles and apparel-specific rules of origin requirements. CBP is “responsible for ensuring that the trade community complies with all statutory, regulatory, policy, and procedural requirements that pertain to importations under free trade agreements and other trade preference programs.”)
  • Building stakeholder awareness by engaging in an education campaign to ensure that importers and suppliers in the CAFTA-DR and USMCA region understand compliance requirements and are aware of CBP’s enforcement efforts.
  • Leveraging U.S. and Central American industry partnerships to improve facilitation for legitimate trade. (note: The Biden Administration aims to leverage textile and apparel trade as part of the solution to address “root causes of migration in Central America. According to the White House Fact Sheet released in March 2024, the Office of the U.S. Trade Representative and Central American Trade Agencies and textiles and apparel industry stakeholders will work together to build a directory with detailed profiles of manufacturing and sourcing companies in the region, including information on business practices and production capabilities, to facilitate transparent sourcing, and bolster the region’s supply chain.)
  • Expanding the Uyghur Forced Labor Prevention Act (UFLPA) Entity List to identify malign suppliers for the trade community through review of additional entities in the high-priority textile sector for inclusion in the UFLPA Entity List. (note: Once an entity is on this list, in general, it is prohibited from exporting its goods to the United States. Importers are required to ensure the supply chains of their imported products are free from entities on the Entity List).

#2: Several US textile and apparel industry stakeholders have publicly responded to DHS’s new strategy.:

 The National Council of Textile Organizations (NCTO), representing the US textile manufacturing sector, made several points in its statement:

We strongly commend DHS for the release of a robust textile and apparel enforcement plan today. We also greatly appreciate Secretary Mayorkas’ personal engagement in this urgent effort and believe it’s a strong step forward to addressing pervasive customs fraud that is harming the U.S. textile industry.”

“The essential and vital domestic textile supply chain has lost 14 plants in recent months. The industry is facing severe economic harm due to a combination of factors, exacerbated by customs fraud and predatory trade practices by China and other countries, which has resulted in these devastating layoffs and plant closures. DHS immediately understood the economic harms facing the industry and deployed the development of a critical action plan.”

The industry requests include

  • Ramped up textile and apparel enforcement with regard to Western Hemisphere trade partner countries, including onsite visits and other targeted verification measures to enforce rules of origin as well as to address any backdoor Uyghur Forced Labor Prevention Act (UFLPA) violations.
  • Increased UFLPA enforcement to prevent textile and apparel goods made with forced labor from entering our market, including in the de minimis environment.
  • Immediate expansion of the UFLPA Entity List, isotopic testing, and other targeting tools. Intensified scrutiny of Section 321 de minimis imports and a review of all existing Executive Branch authorities under current law to institute basic reforms to this outdated tariff waiver mechanism. “

Joint Association Statement on New DHS Textile Trade Enforcement from the American Apparel & Footwear Association, the National Retail Federation, the Retail Industry Leaders Association, and the United States Fashion Industry Association:

We appreciate the Department of Homeland Security (DHS)’s announcement today outlining enhanced enforcement activities to prevent illicit trade in textiles. Our members support 55 million (more than one in four) American jobs and invest considerable time and resources in their customs compliance programs. Many of our members are Tier 3 participants in Customs-Trade Partnership Against Terrorism (C-TPAT). They are trusted traders and meet the high standards required to receive that designation by U.S. Customs and Border Protection and DHS. Our members are on the front lines for ensuring that they have safe and secure supply chains.

 “While DHS launches this enforcement plan, we urge it to partner with our associations and our associations’ members. A successful enforcement plan must include input from all stakeholders, clear communication with the trade, and coordinated activities with importers, especially if DHS finds illicit activity happening in the supply chain. The results of any illicit activities must be shared so that our members and other importers can act quickly to address the issue. As our members look to diversify their supply chains, especially back to the Western Hemisphere, we must make sure efforts are included to incentivize and not deter new investments.

#3 Comments: Overall, the new DHS textile enforcement plan suggests several key US textile and apparel trade policy directions: 1) revisit the current de minimis rules that are used by many e-commerce businesses; 2) further strengthen the UFLPA and forced labor enforcement; 3) expand the Western hemisphere textile and apparel supply chain and encourage more US apparel sourcing from CAFTA-DR members; 4) scrutinize US apparel imports from China and imports from other Asian countries that heavily use textile raw material from China.

Discussion questions for FASH455 (please answer them all):

  1. How do the perspectives of the US textile industry and US fashion brands and retailers diverge concerning CBP’s new strategy? What are the areas in which they share common ground?
  2. Building on the previous question, how can the difference between the US textile industry and US fashion brands and retailers be explained regarding their response to DHS’s new enforcement strategy?
  3. As a sourcing manager for a major US apparel brand with global operations, how do you plan to adjust your company’s sourcing practices in light of DHS’s new strategy? You can list 1-2 detailed action plans and provide your analysis.

Background

The U.S. Customs and Border Protection (CBP) is an agency within the Department of Homeland Security (DHS), responsible for “regulating and facilitating international trade, collecting import duties, enforcing U.S. trade laws, and protecting the nation’s borders.”  

Homeland Security Investigations (HSI) is also a division within the Department of Homeland Security (DHS), responsible for “investigating transnational crime and threats, specifically those criminal organizations that exploit the global infrastructure through which international trade, travel and finance move.”

Product Development and Apparel Sourcing: FASH455 Exclusive Interview with Abby Edge, Product Development Associate at Eileen Fisher

About Abby Edge

Abby Edge is the Product Development associate at Eileen Fisher, where she supports key initiatives in sourcing and sustainability. She graduated from the University of Delaware (UD) in 2020 with a degree in Fashion Merchandising. During her time at UD, she developed a passion for sustainable sourcing and social responsibility, which led her to pursue a career with a company that aligns with these values. Abby also served as a teaching assistant for FASH455 in Spring 2020 and was the co-author of How will EU Trade Curb Affect Cambodia’s Apparel Industry published in Just-Style.

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

Sheng: What does a Product Development Associate do? Can you walk us through your typical day at Eileen Fisher? Also, what makes you love your job?

Abby: Product development can mean different things at different companies, but at Eileen Fisher (EF) it means costing and development prior to product development (PO). All samples, fabrics, and costs need to be approved during the Product Development period before the business teams place their buys. Every day, I communicate with our vendors to cost styles and create time & action plans so that delivery will be met. We work with our vendors and fabric mills to align and finalize pricing to achieve our margin goals. We also must think strategically about material and vendor allocation to improve lead times and mitigate carbon footprint.

I work hybrid, and our beautiful office is on the Hudson River in Irvington, New York. I enjoy going into the office to spend time with my team and review the product in person. I love my job because I am exposed to so many new and exciting sustainability initiatives every day. I admire everything that EF stands for and that we can promote a “less is more” wardrobe.

Sheng: What are the key steps involved in product development, and how do you collaborate with your sourcing team throughout this process?

Abby: At Eileen Fisher, there are two main stages of the product development process before “commitment”: “development” and “dupe.” At the development stage, we focus on any new materials that are being added to the line. We make sure the costing, testing, and lead times are workable. Then, at the dupe stage, we cost and sample the entire product line so that the merchandising and buying teams have all the information they need to place their buys. After commitment, we pass the baton to the Production team to finalize quantities, issue purchase orders, and track orders. Together, the Product Development

Sheng: Sustainability is a key focus in the fashion apparel industry today. From the product development perspective, what notable improvements have been made in recent years, and where do opportunities lie for further progress?

Abby: Eileen Fisher is leading the way in sustainability within the fashion industry, and it has been incredibly rewarding to be a part of a team where this principle is integrated into every aspect. For example, materials are at the core of EF. We focus on natural, organic, and regenerative materials and steer away from synthetics. Regenerative organic cotton is a new material that I’m really excited about. It all starts with the health of the farm and the people growing our cotton. The regenerative organic certification means that the cotton is grown holistically and healthily, contributing to the soil’s health and mitigating the impacts of climate change.

Additionally, the certification has strict social responsibility guidelines, requiring a living wage and safe working conditions for all farmers. This is just one example of innovative improvements that are being made in the material sector. Others include Lenzing Tencel lyocell, regenerative responsible wool, and organic linen.

Another key initiative at Eileen Fisher is our take-back program called “Renew,” where customers bring back their old EF garments in exchange for a $5 store credit. Since the program started in 2009, 2 million garments have been collected. Of the 2 million, 660,885 have been re-sold in stores, and the rest have been donated, repurposed, or downcycled. Some of my favorite EF pieces have actually been purchased from the store’s renewal section! It is also great to see other brands following suit and creating take-back and recycling programs. Clothing waste is an industry-wide problem; we need all hands on deck to make a difference.

Sheng: From your observation, how has the adoption of digital technologies transformed the practices of product development and apparel sourcing?

Abby: Our Product lifecycle management (PLM) system— Centric— has helped streamline the design and product development process tremendously. All teams have access to the PLM system, which allows everyone to be on the same page and easily access any information they might need. For example, designers use the system to set up styles and tech packs, whereas the merchandising team uses the system to line plan and set retails. In my role, I use PLM to enter and land costs and analyze margins. It is dynamic and provides everyone the key tools to succeed while working on multiple seasons at once.

Sheng: Are there any other major trends in the fashion industry that we should closely monitor in the next 1-2 years, particularly in product development and sourcing?

Abby: Traceability and transparency have become increasingly important in the industry. Technology platforms are emerging that can ensure transparency throughout all supply chain tiers using a digital “fiber coin.” The specific platform we use— Textile Genesis—maps the supply chain from fiber to retail to verify any sustainable fibers so that all claims we make are valid. In other words, they ensure the “transactions” between each supply chain step (fiber to yarn to fabric to garment) are authentic. It has been very exciting to see this project come to life, and I feel that platforms like this will become increasingly more prominent in the coming years.

Sheng: What reflections can you share from your experiences at UD and FASH? what advice would you offer to current students preparing for a career in product development and apparel sourcing?

Abby: I am so grateful for my time at UD in the FASH program. I made so many connections with my peers, professors, and alums that have helped me get to where I am now. My advice to current students is to get involved as much as possible, whether through study abroad programs, internships, or clubs. Don’t limit yourself or close yourself off to areas of the industry and embrace any opportunity you get, as you never know where it could lead. My internship with Under Armour in Hong Kong through the FASH study abroad program really helped me grow personally and professionally and I would not be where I am without that experience.

–End–

Event recording: AI and trade: Will ChatGPT handle your supply chains? (March 2024)

Panel

  • Cecilia Malmström, Nonresident Senior Fellow, Peterson Institute for International Economics (PIIE)
  • Eva Maydell, Member, European Parliament; Rapporteur for the European Union’s AI Act
  • Joshua P. Meltzer, Senior Fellow, Global Economy and Development Program, Brookings Institution

Key points

  • AI has the potential to optimize supply chains, analyze shipping routes, forecast demand, and enhance risk assessment and fraud detection.
  • AI could potentially offer better market intelligence to help businesses make better-informed decisions and improve forecasting accuracy.
  • AI could reduce barriers to trade in services and technical barriers of trade (TBT) and empower small and medium-sized enterprises (e.g., translation services)
  • While trade in goods has peaked, services trade continues to grow substantially, even during COVID-19, with digital services and professional services being the main drivers. AI could further facilitate the expansion of service trade.
  • AI is already affecting the nature of jobs and the services trade.
  • Policymakers need to focus on creating an environment that supports the development and deployment of AI, particularly by balancing the need to provide regulatory guardrails and the need to encourage business innovation.
  • AI regulation is currently fragmented worldwide. However, there is significant potential for establishing international standards and regulatory coherence, offering a common approach to regulating AI.
  • Building more societal trust among the business community, policymakers, and civil society is necessary to address concerns about AI and related challenges.

[This blog post is not open for comment]

US Fashion Companies’ Evolving Sourcing Strategies and the Future of the US Textile and Apparel Industry: Discussion Questions from FASH455

Students in FASH455 have proposed the following discussion questions based on the readings about the US textile and apparel industry and fashion companies’ sourcing strategies. Everyone is welcome to join the online discussion. For FASH455 students, please address at least two questions and mention the question number (#) in your reply.

#1 As a developed country, should the US prioritize further strengthening highly capital-intensive yarn manufacturing, or should we rebuild a vertically integrated textiles and apparel supply chain (e.g., yarns, fabrics, and garments) at home? What is your recommendation, and why?

#2 In FASH455, we discussed how the US textile industry has experienced a decline in employment despite increasing production volumes, largely due to advancements in technology. However, why is import competition often cited in the media as the single largest threat to the US textile industry?

#3 While studies show that US fashion companies are reducing “China exposure,” measured in quantity, China still accounted for 36.1% of US apparel imports in 2023, even higher than 34.7% in 2022. How can we explain this phenomenon? What factors have made US fashion companies hesitant to move away from China?

#4 How will US fashion companies’ growing interest in carrying more sustainable textiles and apparel affect their sourcing destinations and supply chains? Will developing countries with cheap labor and/or developed countries with the right capital and technology be the winners in the sustainability movement? Please provide your thoughts.

#5 Will the growing demand for supply chain transparency and traceability reduce the incentives or add additional burdens for fashion companies to diversify their supply chain further? What are the benefits of pursuing sourcing diversification other than mitigating the potential sourcing risks?

#6 What is your vision for the use of AI in apparel sourcing? What key sourcing and supply chain problems facing fashion brands and retailers can AI potentially solve?

Sourcing Sustainable Fashion Products (II): FASH455 Exclusive Interview with Megan Dawson-Elli, Product Sustainability Manager at Tapestry (UD & FASH BS16)

About Megan Dawson-Elli

Megan Dawson-Elli graduated from the University of Delaware (UD) in 2016 with a degree in Fashion Merchandising. During her time at UD, she was the winner of the Fashion Scholarship Fund case study, a highly competitive national competition. Early in her academic career, she identified her interest in environmental sustainability within the fashion industry. This inspired Megan to study abroad in Hong Kong in 2014, where she was a Sourcing & Sustainability intern for Under Armour. After graduation, Megan worked in merchandising and sourcing before starting her career in environmental sustainability at PVH in 2018. Presently, Megan holds the position of Product Sustainability Manager at Tapestry, where she leads their work on product impact, environmentally preferred materials, and circularity.

In her free time, Megan enjoys reading, running, and traveling. She lives in NYC with her fiancé, also a UD graduate, and likes spending her weekends in Central Park.

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

Sheng: What does a Product Sustainability Manager do? Can you walk us through your typical day at Tapestry? Also, what makes you love your job?

Megan: As a Product Sustainability Manager, I work as an internal consultant to our brands to support their progress towards our Environmental, Social and Governance (ESG) goals and their desire to market and evaluate the environmentally preferred attributes of our products. Many initiatives fall under Product Sustainability, but I would bucket most of the work into several categories: marketing claims substantiation, environmentally preferred materials, product impact, circularity, and packaging. Every day can look different in this role, which keeps it exciting! One day I will be working with teams to craft a marketing claim about a product and the next I will be collecting data from suppliers for a life cycle assessment. My work is very dynamic, with some projects lasting days versus months. I love my job because I get to work with teams across the company that are passionate about sustainability, and even though I no longer work to create products, it’s still the focus of my work.

Sheng: Consumers today, especially our Gen Z students, want to see more “sustainable” fashion products in the market. What does “sustainable product” mean in practice? Can “sustainability” be objectively measured?

Megan: The term “sustainable” has become difficult to define as many initiatives can fit under it, like environmentally preferred materials, responsible sourcing, circularity, etc. It can also be seen as a yes/no question, while sustainability is a journey where progress should grow as new innovations become available. At a product level, the most visible sustainability initiatives that can be seen are environmentally preferred materials or social impact claims being made about the item. There are plenty of initiatives that companies are doing across their supply chain and their operations. Checking out a company’s annual Corporate Responsibility report will show a greater picture of its efforts, commitments, and progress.

Sheng: How can sourcing contribute to a fashion company’s sustainability efforts and make more sustainable products available to consumers?

Megan: At Tapestry, we follow an internal framework known as “Style, Performance and Impact.” This ensures all products meet our high standards of craftsmanship. The framework also guides our decision-making around environmentally preferred materials and material innovation investments.

  • Style: Does it meet design needs or the intended design function of the product?
  • Performance: Does it meet expectations of quality and cost?
  • Impact: Does the material or decision have a measurable reduction in environmental impact?

Additionally, suppliers play a critical role in helping companies realize their environmental and social ambitions. We consistently partner with stakeholders across our value chain to work toward more responsible practices that their businesses can incorporate, especially through increased implementation of environmentally preferred manufacturing practices and using preferred materials.

Sheng: Related to sustainability are the buzzwords “supply chain transparency” and “traceability.” What progress has been made, and what are the key steps for fashion companies in achieving greater transparency and traceability in their supply chains and sourcing?

Megan: To ensure a more responsible and transparent supply chain, it is critical to map supply chains and the relationships between suppliers. At Tapestry, we have begun the process of onboarding suppliers to join TrusTrace, a cloud-based web platform for sustainability, where we intend to conduct more upstream supply chain mapping and the collection of documentation to establish material and product traceability. We envision the platform will help us meet enterprise-wide sustainability commitments and goals, and help us align with upcoming regulatory requirements and industry best practices.

We have also improved downstream traceability by launching a digital product passport program, most notably through Coachtopia products. Customers can hold their smartphones against the cloud emblem on their Coachtopia product until the pop-up appears and then learn the total environmental impact of the product, along with all the potential avenues to extend its useful life under the sub-brand’s circular principles.

Sheng: As legislation related to fashion companies’ sustainability practices continues to be newly implemented or is on the horizon, are there any specific regulations you would recommend our students closely monitor?

Megan: There are many emerging ESG regulations, especially in Europe. Below are some that would be interesting to review.

Europe:

USA:

Sheng: Any reflections on your experiences at UD and FASH? What advice would you offer to current students preparing for a career in fashion sustainability after graduation?

Megan: My “lightbulb moment” for wanting to pursue a career in sustainability happened while I was at UD, specifically from taking the ethics and sustainability in the fashion industry class. After identifying environmental sustainability as my focus and passion, I found ways to include it in every project, case study, and internship during school. The great thing about sustainability is that every department in a company can be part of the collective efforts, so even if you aren’t on an ESG (Environmental, Social, Governance) team, you can make an impact. If you are specifically interested in pursuing a role on an ESG team, I recommend networking with people in the industry that have those roles to learn more about what the job looks like and staying up to date on the latest news, innovations and regulations in the space. Also, there are plenty of college courses and industry certifications in sustainability that can be a great learning resource.

–END–

Sourcing Sustainable Fashion Products (I): FASH455 Exclusive Interview with Julianna Alfieri, Senior Global Sourcing Specialist at Amscan (UD & FASH BS22)

About Julianna Alfieri

Julianna Alfieri is the Senior Global Sourcing Specialist for Amscan, which serves over 40,000 retail outlets across the globe and owns Party City Holdings Inc. Born and raised in Long Island, Julianna has always had a passion for all things fashion. This passion led her to pursue a Bachelor’s degree in Fashion Merchandising and Management, with a minor in Sustainable Apparel & Textile Innovation, from the University of Delaware. Julianna furthered her expertise with a Graduate Degree from Parsons School of Design in Fashion Sustainability. Her diverse background includes experience in fashion styling, retail, marketing, and indexing, all of which have shaped her approach to global sourcing. With these educational and professional experiences, Julianna has built a solid foundation and acquired the necessary tools to excel in the industry.

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

Sheng: What does a Senior Global Sourcing Specialist do? What does your typical day look like? Also, what makes you love your job, or what is the most exciting part of it?

Julianna: As a Senior Global Sourcing Specialist, my role revolves around fostering cross-functional collaboration and maintaining strong relationships with vendors and suppliers. I oversee specific categories of the company’s business, ensuring effective communication and negotiation to maximize the quality of goods while meeting financial objectives. This involves working closely with my sourcing team, global offices, and utilizing various systems to streamline sourcing processes.

On a typical day, I work closely with my sourcing team and global partners to analyze costs, manage vendor relationships, and collaborate on major projects within my designated categories. Additionally, I assist in updating data in relevant systems and ensuring smooth transitions for new suppliers while also contributing to major projects aimed at enhancing redundancy categories and diversifying our supplier base.

The dynamic nature of the role keeps me engaged and continuously learning, allowing me to apply my education to real-world scenarios and witness the tangible outcomes of our efforts, such as seeing products I’ve contributed to in stores. What I find most exciting is the opportunity for constant growth and the collaborative aspect of working with our global partners!

Sheng: Can you walk us through the sourcing process—for example, the main procedures, who will be involved, and the general timeline?

Julianna: The overall sourcing process is an extremely collaborative effort involving multiple teams and stakeholders. It begins with identifying the need for specific products, which could stem from various reasons such as new product development, transitioning from existing suppliers, or finding vendors offering better cost or quality.

Once the product to be sourced is determined, we engage with suppliers from our matrix. Communication is managed internally for domestic vendors, while for international vendors, our global partners are involved. We evaluate potential suppliers based on their capability to produce the desired product and then proceed to cost negotiations.

Sample gathering is a crucial step where we collect samples from all potential vendors to assess quality and cost-effectiveness. This decision often involves input from both sourcing and product development teams. Using Product Lifecycle Management (PLM) systems, we then generate artwork for the product, collaborating closely with the art team.

Once artwork is finalized, it is shared with the chosen vendor to facilitate production specifications. Lead times for sample creation and production are negotiated with the vendor. Once we receive a pre-production sample, either our global partners or product development teams evaluate its quality and suitability.

Upon pre-production sample approval, the sourcing team updates our systems to indicate the selected vendor for the product. Throughout this process, sourcing manages communication between cross-functional teams and partners.

The timeline for this process typically spans 3 to 6 months, varying on factors such as the country of sourcing, vendor payment terms, lead times, and sample production quality.

Sheng: We know retailers today need to “balance” many sourcing factors today, from costs and speed to market to compliance risks. In practice, how do these factors actually affect companies’ sourcing decisions? For example, are there any specific factors that hold particular importance or are given significant weight in the decision-making process?

Julianna: Sourcing decisions within companies are deeply influenced by a number of factors. Among these factors, cost stands out as a primary consideration, directly impacting the financial health and competitiveness of the company. Balancing cost-effectiveness with other factors is essential to ensure optimal value for the organization.

Quality is another factor that holds significant weight in sourcing decisions. Maintaining specific standards of quality is essential to uphold the brand reputation, customer satisfaction, and overall product integrity. Innovation also drives sourcing decisions, as companies look for suppliers with advanced products, technologies, or processes to stay competitive and meet changing consumer needs.

Other critical factors include supplier reliability and supplier diversity. Dependable suppliers ensure consistent delivery schedules, minimize disruptions, and foster trust, while diversification enhances resilience and flexibility. Building strong relationships with suppliers encourages working together, coming up with new ideas, and achieving long-term success!

Finally, sustainability is now a crucial factor in sourcing decisions, driven by increasing consumer and regulatory demands for environmentally and socially responsible practices. Companies favor suppliers committed to sustainability, such as reducing waste and upholding fair labor standards. Embracing sustainability not only reflects a company’s corporate values, but also ensures long-term business success and resilience in a market that values conscious practices.

Sheng: From your observation, what are the critical sourcing trends and key issues to watch in 2024?

Julianna: In today’s climate, it is evident that there are several critical sourcing trends and key issues to keep a close eye on in 2024. Among these, prioritizing resilience, sustainability, and diversification stands out as essential for companies aiming to navigate the evolving sourcing landscape successfully!

The COVID-19 pandemic has led to a renewed emphasis on strengthening supply chain resilience. Companies are actively diversifying their suppliers and improving risk management to ensure operational continuity. Based on my personal experience in this industry, I’ve recognized the essential role adaptability plays in keeping operations running smoothly without interruption.

Additionally, there is growing attention on sustainability and ethical sourcing. Companies are under pressure to be transparent and accountable due to increased consumer awareness about environmental and social issues. In our organization, we maintain standards through the use of supplier audits to ensure sustainability compliance. Initiatives such as sustainable packaging and collaborations with suppliers certified by reputable organizations like the Forest Stewardship Council (FSC) reflect our efforts to advance sustainability goals.

One of the key challenges I’ve encountered in my sourcing career is the reliance on a limited supplier base. This became evident during our paper bag project when antidumping duties significantly impacted our sourcing strategy. The imposition of antidumping duties on paper bags from certain regions prompted us to explore alternative suppliers globally. This highlighted the importance of diversifying our supplier matrix to reduce dependence on specific regions and mitigate risks associated with geopolitical tensions or trade regulations.

Lastly, uncertain economic climates have significantly influenced what warrants close attention. Our company’s experience with Chapter 11 bankruptcy served as a pivotal moment, illuminating the crucial paths forward. As repeatedly emphasized, maintaining a diverse and resilient supplier base is essential for mitigating risks linked to potential disruptions in the supply chain. Additionally, closely monitoring costs and implementing cost-saving measures becomes imperative for navigating through uncertain economic times. Lastly, fostering robust supplier relationships and enhancing communication and collaboration with suppliers emerge as essential strategies for navigating challenges and ensuring continuity in the sourcing process, especially amidst economic uncertainty.

Sheng: Many retailers have adopted PLM (product life cycle management) and other digital tools to manage sourcing and the supply chain. From your observations, what changes have these tools brought to sourcing?

Julianna: Digital tools are vital for global sourcing as they streamline processes, enhance communication, and provide real-time insights, enabling companies to make informed decisions. Some important tools I work with closely include PLM (Product Lifecycle Management), BPCS (Business Planning and Control System), and Datamyne, as they help to optimize efficiency and mitigate risks in the complex global marketplace.

PLM helps to centralize information and documents, which ensures that all stakeholders have access to real-time data, updates, and feedback, leading to improved alignment. This helps for history purposes and checking previous decision making done by other team members. PLM also assists with processes such as supplier onboarding, product specifications management, and artwork/sample tracking.

BPCS provides a wide range of tools for managing inventory, procurement, and production planning. It helps ensure that inventory levels are optimized, procurement processes are efficient, and production activities are scheduled according to demand forecasts and inventory data. This visibility into inventory levels also allows sourcing partners to access crucial information, such as the amount of inventory on hand, helping us prioritize sourcing efforts based on urgency.

Lastly, Datamyne provides valuable insights into global trade data, including import and export information, tariffs, and compliance requirements. Datamyne also allows users to search for potential suppliers, thus mitigating risks associated with geopolitical factors and trade regulations. In response to the antidumping tariffs affecting our paper bags (previously mentioned), I utilized Datamyne to identify alternative vendors exempt from these tariffs. I thoroughly researched and explored these potential vendors to determine if they could serve as viable alternatives for sourcing paper bags, thereby circumventing the tariffs.

Sheng: Any reflections on your experiences at UD and FASH? What advice would you offer current students preparing for a career in sourcing after graduation?

Julianna: Reflecting on my experiences through the UD fashion program, I am grateful for the comprehensive education and real-world projects that have shaped my understanding of the fashion industry and the global sourcing world. UD provided me with valuable insights into various aspects of the industry and encouraged me to explore my interests deeply. Through specialized courses for my focus on sustainable apparel and textile innovation, I gained practical knowledge that is directly applicable to the sourcing realm. The exposure to relevant case studies and global issues was instrumental in honing my skills and preparing me for my career in global sourcing, and UD has paved the way for the inevitable challenges and opportunities ahead.

For current students preparing for a career in sourcing after graduation, my first piece of advice would be to prioritize networking and building relationships with peers and faculty members. Business is personal, and these connections can open doors to opportunities in the industry! Additionally, dedicating oneself to school projects and seeking any type of industry experience can provide clarity on career paths and offer invaluable insights into different work environments, and help in understanding one’s preferences within the industry.

Developing strong presentation skills and the confidence to speak up in team settings are essential for standing out as a leader and effectively communicating with vendors, global partners, and cross-functional teams.

Finally, staying informed about current events, especially in the sourcing landscape, is crucial for making informed decisions and staying ahead in the industry.

Feel free to reach out anytime if you’d like to connect, chat, or discuss industry insights – I am always here and eager to engage!

–The END–

Conversation with Katherine Tai, US Trade Representative, on International Trade and US Trade Policy (February 2024)

  • Speaker: Katherine Tai (U.S. Trade Representative, Office of the U.S. Trade Representative)
  • Presider: Michael Froman (President, Council on Foreign Relations; Former U.S. Trade Representative, 2013-17)

Excerpt from the conversation

Worker-Centric US trade policy

Question from FROMAN: “Back in the old days, there was a notion that since the U.S. market is relatively open—we don’t have that much protection here, the average applied tariff is about 3 ½ percent—that if we were able to reduce barriers to other countries disproportionately we could export more made by U.S. workers, and that export-related jobs paid more than non-export related jobs, and that we could use access to our market as a way of getting other countries to reform their labor practices and raise their standards, which would create a more level playing field. That theory is sort of out of vogue at the moment. But, tell me, can you envisage what an agreement that is worker-centric looks like that reduces barriers or increases trade?”

Response from TAI: “The percentage of (U.S.) exports to GDP is around 10 percent—maybe 11 or 12 percent. So it’s not very high. Some of our—some of our trading partners have very, very high exports as a proportion of GDP (e.g., 25 percent)…So you just have to put that (trade liberalization) into context. I think you also have to think about the fact of the balance of exports and imports…”

We’re trying to create and maintain jobs, and good jobs, at home… so then the question becomes not what do I have to pay you to do X, Y, or Z, but how can we put the forces of our cooperation together? What does the deal look like where we are building our middle classes together? And I think that the worker pieces then come in, along with the environment pieces, as something that I shouldn’t have to pay you to do, but as something that you should want to do…”

“Traditionally we’ve kept our scorecard by, you know, how many trade agreements you finished and how many you’ve gotten across the finish line… Our progress lies very much in how the conversation has fundamentally shifted. That the conversation now is very much focused on supply chain resilience, on equity, and how not to leave those within our economies behind further, how not to leave those developing countries behind further.”

Digital trade

Question from FROMAN: “For a long time, the U.S. had a position around the free flow of data across borders, not taxing digital products across borders… given the fact that the U.S. economy is probably—certainly the leader in all things digital, what does it mean for us to move away from defending these principles that have been so core to what we’ve tried to do before?”

Response from TAI: “So in early 2000s that we’re negotiating (digital trade)… It’s called the e-commerce chapter. And it’s the e-commerce chapter in several iterations of FTAs (free trade agreements)…And I think that that makes sense if you think about what the digital economy looked like in the early 2000s. It really was about e-commerce…At the time—thought about e-commerce digital trade provisions as largely facilitative provisions. The flow of data was there, and we wanted to safeguard the flow of data to facilitate traditional trade transactions, the movement of goods across borders, the analogy to services we used also in digital.”

“In 2024, one of the things that you realize is that the flow of data, the decisions around where data needs to be stored, how it needs to be handled, has—on much, much different dimensions because over this period of time, in fact, in the digital economy the data is no longer just about facilitating traditional types of transactions. The data has become the commodity in and of itself. The data is now what has value. The ability to accumulate that data and for vast amounts of data then to be combined with computing power to create things like generative AI and large language models, it starts to give you a sense, just as a normal trade negotiator, that there are much, much bigger equities at stake in what we might be doing in our trade negotiations…It’s not just about facilitating trade, but around how we regulate data and how we regulate the companies that accumulate, harvest, and trade in this data is something that we need to resolve and advance before we can thoughtfully and responsibly engage in trade negotiations to figure out what the limits are in terms of what we should be doing, and what the goals are for what we should be doing with our trading partners… what underlies the digital economy and our digital existences, and just thinking about what the rules should be for how that data is handled, who has rights to that data, and then the international components around trade and prosperity but also trade and national security.”

Tradeoffs in trade policy

Question from FROMAN: “Trade is a great area to talk about tradeoffs. We hate being overly dependent on China for basic goods. We also hate inflation and higher cost of living. The actions taken to deal with the first one will likely exacerbate the second one… How do you talk about that tradeoff with communities around the country? And do you make explicit that, yes, you’re going to pay more at Walmart for this for that, but we’re going to become less dependent on China as a result?”

Response from TAI: “That today, we know that we have critical dependencies and vulnerabilities that are actually bad from a national security and just a geopolitical standpoint. For every sector where we feel that we are critically vulnerable to another country and, say, China in particular, I think that it creates a sense of angst and insecurity that is destabilizing for the world economy and, frankly, for the world… if you look at it from a more holistic, medium-term perspective, supply chain diversity and supply chain resilience is actually a management tool for inflation… “

“For as long as there are concentrated pockets for production and supply—and this is internationally, but this is also the logic behind taking on dominant players in our economy—for as long as you have that kind of dominance, you’re going to have in the hands of certain players the ability to distort the market and to take advantage of that dominance by jacking up prices, whether it’s shrinkflation, or greedflation, or in the international context economic coercion… if you think about the tradeoff as between today and tomorrow, it’s not zero-sum at all. And in fact, these changes are ones that we need to be able to manage, not being faced with the same risks over and over and over again.”

US trading partners

Comment from TAI: “when you talk about some evolution in our (trade policy) approach, I just want to be clear, the evolution in our approach is about what should be in those things, what should be in those agreements, what should be in the exercises and the cooperation that we undertake with our partners. This is not a walking away from those partners, at all…You’ll see how much time I spend in Brussels, how much time I’ve spent in Asia, and the Indo-Pacific over the course of the last three years. And you’ll see that the prioritization of our like-minded partners, our traditional partners if you will, is still very much there.”

Tariffs

Comment from TAI: “What is really important to appreciate about tariffs is that they’re a tool. They’re a tool that can be used in constructive ways… They’re a tool, at least for us, in trade remedies… They are a tool for remedying unfair trade. I actually kind of like the way the Europeans describe these types of tools—dumping, countervail. They call them trade defense instruments.”

“What I also want to reflect is that trade policy and economic policy isn’t just tariffs… we have kept a lot of the tariffs, because we see strategic value in those tariffs in this exercise of building up the middle class and reinvigorating American manufacturing and the American economy… it needs to take the tariffs as a tool, the investments as another tool to help reinforce, policies that support and empower all workers, and to encourage our partners to be supporting and empowering their workers, and then also promoting economic vitality, opportunity through the enforcement of our competition laws…”

Textile industry strategic or not?

Comment from TAI: “You know, there are things that are more strategic, things that maybe we feel like are less strategic or not strategic. But, you know, I think that is actually a really, really important question. And it’s a hard one—what’s strategic and what isn’t? We clearly did not think that surgical masks—surgical, you know, medical-grade gloves and ventilators were that strategic. And so we let that go wherever it was going to go. And in the early days of the pandemic, boy, did that hurt us a lot. So, you know, one of the—one of the stories that came out of the pandemic was all of our—all of our textile manufacturers, you know, were told your industry is not that strategic. They’d been told it for a long time. And yet, we know that it is important. It’s politically important. And USTR has for a very long time had a textiles office and textiles negotiator…it was that textiles industry, what we still have, that was able to repurpose their capabilities and to step up, and to actually start producing some of these things that we were really deficient in during the pandemic, and to save us. So I think that where you draw the lines on strategic and nonstrategic… It’s not necessarily obvious.”

Video discussion questions [For students in FASH455, please address at least two of the following questions in your response]

#1: Tai emphasizes the importance of creating and maintaining good jobs at home and building middle classes together with trading partners. How can the textile and apparel trade contribute to the goal?

#2: Reflecting on the textile industry’s response during the pandemic, Tai raises questions about what industries are considered strategic and the implications of such categorizations. How should policymakers determine which industries are strategic, and what criteria should be used in making these decisions?

#3: How has the role of data evolved in trade discussions, and what are the potential challenges in regulating data in international trade agreements? What are the implications of digital trade governance on today’s fashion business?

#4: Tai discusses the strategic importance of supply chain diversity and resilience. How might diversifying supply chains contribute to national security and economic stability, and what are the challenges in achieving this diversification? Please use the textile and apparel sector as an example.

#5: Any other reflections, thoughts, or feedback on the conversation?

[discussion is closed]

Patterns of US Apparel Imports in 2023 and Critical Sourcing Trends to Watch in 2024

The latest data from the Office of Textiles and Apparel (OTEXA) and the United States International Trade Commission (USITC) suggested several key patterns of US apparel imports in 2023.

First, affected by the macro economy, US apparel import volume in 2023 suffered the most significant decline since the pandemic. Specifically, US apparel imports decreased by 22% in quantity and value in 2023 compared to 2022, with none of the top ten suppliers experiencing positive growth.

Nevertheless, after several months of straight decline, US apparel imports finally bounced back in December 2023. Thanks to the holiday season and a gradual improvement of the US economy, seasonally adjusted US apparel imports in December 2023 were about 4.5% higher in quantity and 4.2% higher in value than the previous month. Highly consistent with trends, the US Consumer Confidence Index (CCI) increased from 67.2 in November to 76.4 in December (January 2019=100), suggesting US households turned more confident about their financial outlook and willing to spend. That being said, the latest January 2024 International Monetary Fund (IMF) forecasts still predicted the US GDP growth would slow down from 2.5% in 2023 to 2.1% in 2024. Thus, whether the US apparel import volume could continue to maintain growth after the holiday season remains a big question mark.

Second, while the pace of sourcing cost increases has slowed, the costs and financial pressure facing US fashion companies are far from over. Specifically, as of December 2023, the price index of US apparel imports stood at 106 (January 2019=100), almost no change from January 2023. However, two emerging trends are worth watching. One is the declining US apparel retail price index since August 2023, which means US fashion companies may have to sacrifice their profits to attract consumers to the store. The second trend is the surging shipping costs as a result of the recent Red Sea shipping crisis, which were not reflected in the December price data. According to J.P. Morgan, during the week of January 25, 2024, the container shipping rates from China to the US West Coast and East Coast saw a significant spike of around 140% and 120% from November 2023, respectively. Even worse, there is no sign that the Red Sea crisis will soon be solved. Therefore, 2024 could pose another year of financial challenges for many US fashion companies.

Third, diversification remained a pivotal trend in US fashion companies’ sourcing strategy in 2023. For example, the Herfindahl–Hirschman index (HHI), a commonly used measurement of market concentration, went down from 0.105 in 2022 to 0.101 in 2022, suggesting that US apparel imports came from even more diverse sources.

Notably, measured in value, only 71.6% of US apparel imports came from Asia in 2023, the lowest in five years. Highly consistent with the US Fashion Industry Association’s Benchmarking Survey results, OTEXA’s data reflected companies’ intention to diversify their sourcing away from Asia due to increasing geopolitical concerns, particularly the rising US-China strategic competition.

However, it should be noted that Asia’s reduced market share did not benefit “near-shoring” from the Western hemisphere much. For example, in 2023, approximately 14.6% of US apparel imports originated from USMCA and CAFTA-DR members, nearly the same as the 14.3% recorded in 2022. Instead, US apparel imports outside Asia and the Western Hemisphere jumped to 11.4% in 2023 from 9.8% a year ago. Some emerging EU and African suppliers, such as Turkey, Romania, Morocco, and Tunisia, performed relatively well in the US market in 2023, although their market shares remained small. We could highly expect the sourcing diversification strategy to continue in 2024 as many companies regard the strategy as the most effective to mitigate various market uncertainties and sourcing risks.

Fourth, US fashion companies continued reducing their China exposure as much as possible, but China will remain a key player in the game. On the one hand, about 20.0% of US apparel imports in value and 25.9% in quantity came from China in 2023, both hit a new low in the past decade. Recent studies also show that it became increasingly common for China to no longer be the largest source of apparel imports for many US fashion companies.

However, China remains highly competitive in terms of the variety of products it offers. For example, the export product diversification index, calculated based on trade data at the 6-digit HTS code level (Chapters 61 and 62), shows that few other countries can match China’s product variety. Likewise, product level data collected from industry sources indicates that China offered far more clothing styles (measured in Stock Keeping Units, SKUs) than its competitors in 2023. According to the results, rather than identifying 1-2 specific “next China,” US fashion companies appeared to leverage “category killers”—for example, utilizing Vietnam as a sourcing base for outerwear, underwear, and swimwear; India for dresses, and Bangladesh for large-volume basic knitwear items.

Related to this, another recent study found that the top five largest Asian suppliers next to China, including Vietnam, Bangladesh, Indonesia, India, and Cambodia, collectively can offer diverse product categories almost comparable to those from China in the US market.

Fifth, trade data reveals early signs that US fashion companies are gradually reducing sourcing cotton apparel products from Asia because of the implementation of the Uyghur Forced Labor Prevention Act (UFLPA). Notably, when concerns about cotton made by Xinjiang forced labor initially emerged in 2018, US fashion companies quickly shifted sourcing orders for cotton apparel (OTEXA code 31) from China to other Asian countries. However, UFLPA’s enforcement increasingly targets imports from Asian countries other than China due to the highly integrated regional textile and apparel supply chain and Asian countries’ heavy reliance on textile inputs from China. Consequently, Asia (excluding China) accounted for a declining share in the total imports of US cotton apparel in 2023.

Meanwhile, affected by UFLPA’s enforcement, only 11.8% of US cotton apparel imports came from China in 2023, marking a further decline from 13% in 2022 and reaching a new low for the past decade. China also deliberately decreased the percentage of cotton apparel in its total apparel exports to the US market, dropping from nearly 40% in 2017 to only 25% in 2023. In comparison, cotton apparel consistently represented about 45% of total US apparel imports during the same period.

Additionally, while there was no substantial increase in the volume of US apparel imports from CAFTA-DR members, as a silver lining, the utilization of the trade agreement improved. In 2023, about 19.2% of US apparel imports claimed duty-free benefits under US free trade agreements and trade preference programs, a notable increase from 17.7% in 2022. Most such imports came under CAFTA-DR (45.4%) and USMCA (19.7%).

Meanwhile, in the first 12 months of 2023 (latest OTEXA data), about 70.2% of US apparel imports came from CAFTA-DR members claimed the duty-free benefit, up from 66.6% the same period a year ago. Particularly, 65.4% of US apparel imports under CAFTA-DR complied with the yarn-forward rules of origin in 2023, a notable increase from 61.3% in 2022. Another 2.6% of imports utilized the agreement’s short supply mechanism, which also went up from 2.3% in 2022. The results could reflect an ever more integrated regional textile and apparel supply chain among CAFTA-DR members due to increasing investments made in the region in recent years. However, there is still much that needs to be done to effectively increase the volume of US apparel imports from the region.

by Sheng Lu

Study: Destinations of Dutch used textiles (February 2024)

The study is available HERE (published by the Government of the Netherlands). Key findings:

Size of used textiles trade:

  • In 2022, the Netherlands exported 248,000 tons of used textiles (or over €193 million), the highest in the past five years. This trend aligned with the EU’s broader used clothing exports, which reached 1.7 million tons in 2019. The average European price for used textiles was around €0.76 per kg in 2019.
  • In 2018, 84% of used textiles collected in the Netherlands were exported, with 53% being suitable for re-wearing, 33% recycled, and 14% being nonrecyclable and non-renewable.

Destinations of the used textile exports

Trade data analysis (HS6309 and HS6310 from 2017 to 2022) and interviews revealed several key export destinations for used clothing exports from the Netherlands:

  • Poland and Pakistan as Import-export hubs. The high volumes of HS 6309 (used textiles) exports from the Netherlands to Poland likely reflect the lower labor costs for labor-intensive manual sorting in Poland. For the last five years, Pakistan has also been a top-five destination for Dutch used textile exports (under HS6309). Four of the six Dutch collector-sorters interviewed confirmed that Pakistan is a primary export destination, noting that the lowest quality textiles were usually sent there. However, Pakistan is also the world’s sixth largest used clothing exporter, suggesting Pakistan is unlikely to be the final destination for the Dutch used textile exports but an import-export hub.
  • India is positioned as a significant recycling hub, particularly for HS 6310 (sorted and unsorted used rags and textile scraps) imported from the Netherlands. India also receives a substantial volume of HS 6310 textiles originating from the Netherlands via France. Notably, India enforces trade restrictions requiring textiles under HS 6309 (used textiles) to be imported only through the Kandla Special Economic Zone (KASEZ), with a mandate for at least 50% to be re-exported. Panipat in India is home to numerous spinning companies, ranging from large to small. These companies specialize in cleaning and sorting textile waste to produce recycled yarn, which is then supplied to weaving and manufacturing units in Panipat and beyond. Most of India’s used textiles re-exports went to African countries.
  • Ghana and Kenya were significant recipients of used textiles from the Netherlands, yet their export volumes for HS6309 (used textiles) and HS 6310 (sorted and unsorted used rags and textile scraps) were comparatively low. The high import-to-export ratios underscore these two countries’ role as the reuse and disposal destinations of used textiles from the Netherlands.

Characteristics of the used textile exports

  • The report highlights divergent perspectives on the quality and rewearability of textile exports to African countries. Dutch collectors and sorters assert that all exports from the Netherlands to Africa consist of good-quality rewearables. They distance themselves from the problem of textile waste exported to Africa, attributing it to the unregulated practices of certain parts of the used textiles trade that involve illegal contractors and exports.
  • According to the study, textiles deemed suitable for currently viable closed-loop recycling technologies include those made of pure cotton, pure wool, pure acrylic, and cotton-rich and wool-rich blends exceeding 80%. However, the study noted a concerning decline in the proportion of collected textiles suitable for rewear, coupled with a rise in textiles containing synthetic fibers. Most interviewees explicitly attribute the degradation in the quality of used textiles over time to the influence of “ultra-fast fashion.”

Environmental and social impacts of used textile exports

  • Interviews revealed a significant variation in the perceived environmental impacts of the used clothing trade. For example, participants from import-export hubs like Pakistan and recycling hubs like India emphasized minimal environmental harm, focusing on the positive contributions of used textile imports. In contrast, interviewees from reuse and disposal countries, such as Kenya and Ghana, discussed environmental harms and their localized impacts. Interviewees also expressed concerns that “certain sustainability solutions may be developed in such a way that generates additional problems further away” and benefit actors in Europe and the West only.
  • The study also found that 99% of fashion brands “do not disclose a commitment to ultimately reduce the number of new items they produce,” and only 12% of fashion companies have even disclosed the quantity of products produced annually in 2023, down from 15% in 2022.
  • The involved parties acknowledge the considerable difficulty in completely disassociating any participant in the reverse supply chain from the adverse impacts of textile exports. Despite efforts, achieving complete transparency beyond EU borders is deemed nearly impossible, as highlighted by one used textiles collector.

Job creation

  • The used textiles value chain unambiguously generates a huge amount of employment, particularly for women, in the sorting, recycling, selling, cleaning, repairing, re-styling, and distributing processes.
  • A 2023 International Labour Organization (ILO) study showed that new recycling and reprocessing activities could create over 10 million jobs in Latin America and the Caribbean and around 0.5 million jobs in Europe.
  • However, concerns related to job quality and social risks were also raised in interviews, particularly concerning reuse and disposal countries. Even where waste management systems for used textiles are formalized and managed, they often rely on the “labors of informal actors” for various functions such as distribution, resale, and disposal processes. Gender-based disadvantage may also be a concern. For example, the study found that whereas recycling and sorting enterprises are overwhelmingly owned and operated by men, women perform the majority of lower-wage, non-technical, and manual labor-intensive tasks.

Regulations

  • The Dutch government’s Circular Textiles Policy Programme for 2020–2025 outlines a commitment to enhance the proportion of recycled materials in textiles and apparel products available in the Dutch market, including achieving a 10% reuse and 30% recycling rate of sold textiles and apparel by 2025.
  • The Dutch Extended Producer Responsibility (EPR) for textiles was officially implemented on July 1, 2023. Onwards, producers are responsible for “recycling and reusing of textiles…including an appropriate collection system, recycling and reusing of clothing and household textiles and financing this entire system.”
  • The policy landscape for managing and exporting used textiles in Europe has evolved to align with environmental goals, with key milestones such as the EU Strategy for Sustainable and Circular Textiles in March 2022. While this strategy aims to create a greener and more resilient textiles sector, the report suggests a need for a bolder vision and more international orientation, emphasizing responsibility for socioenvironmental impacts beyond Europe.
  • The EU Waste Framework Directive (WFD) is another crucial instrument to tackle the environmental challenges of high textile consumption. The WFD regulates all aspects of textile waste management, including the specific obligations to ensure separate collection, treatment, and reporting requirements. The directive calls for all EU Member States to establish separate collection systems for used textiles by the beginning of 2025.
Supplementary video: Used clothing from Europe: Trash or treasure for Africa?

Exploring the Production and Export Strategies of U.S. Textiles and Apparel Manufacturers

The full study is available HERE.

Textiles and apparel “Made in the USA” have gained growing attention in recent years amid the increasing supply chain disruptions during the pandemic, the rising geopolitical tensions worldwide, and consumers’ increasing interest in sustainable apparel and faster speed to market. Statistics from the U.S. Bureau of Economic Analysis showed that U.S. textile and apparel production totaled nearly $28 billion in 2022, a record high in the most recent five years. Meanwhile, unlike in the old days, a growing proportion of textiles and apparel “Made in the USA” are sold overseas today. For example, according to the Office of Textiles and Apparel (OTEXA) under the U.S. Department of Commerce, U.S. textiles and apparel exports exceeded $24.8 billion in 2022, up nearly 12% from ten years ago.

By leveraging U.S. Department of Commerce Office of Textiles and Apparel (OTEXA)’s “Made in U.S.A. Sourcing & Products Directory,” this study explored U.S. textiles and apparel manufacturers’ detailed production and export practices. Altogether, 432 manufacturers included in the directory as of October 1, 2023, were analyzed. These manufacturers explicitly mentioned making one of the following products: fiber, yarn, fabric, garment, home textiles, and technical textiles.

Key findings:

First, U.S. textile manufacturers exhibit a notable geographic concentration, whereas apparel manufacturers are dispersed throughout the country. Meanwhile, by the number of textile and apparel manufacturers, California and North Carolina are the only two states that rank in the top five across all product categories, showcasing the most comprehensive textile and apparel supply chain there.

Second, U.S. textile and apparel manufacturers have a high concentration of small and medium-sized enterprises (SMEs). Highly consistent with the macro statistics, few textile and apparel manufacturers in the OTEXA database reported having more than 500 employees. Particularly, over 74% of apparel and nearly 60% of home textile manufacturers are “micro-factories” with less than 50 employees.

Third, U.S. textile and apparel manufacturers have limited vertical manufacturing capability. A vertically integrated manufacturer generally makes products covering various production stages, from raw materials to finished products. Results show that only one-third of U.S. textile and apparel manufacturers in OTEXA’s database reported making more than one product type (e.g., yarn or fabric). Meanwhile, specific types of vertically integrated production models are relatively popular among U.S. textile and apparel manufacturers, such as:

  • Apparel + home textiles (5.8%)
  • Fabric + technical textiles (5.1%)
  • Yarn + fabric (3.9%)

However, the lack of fabric mills (N=38 out of 432) appears to be a critical bottleneck preventing the building of a more vertically integrated U.S. textile and apparel supply chain.

Fourth, it is not uncommon for U.S. textile and apparel manufacturers to use imported components. Specifically, among the manufacturers in the OTEXA database, nearly 20% of apparel and fabric mills explicitly say they utilized imported components. In comparison, given the product nature, fiber and yarn manufacturers had a lower percentage using imported components (11%). Furthermore, smaller U.S. textile and apparel manufacturers appear to be more likely to use imported components. For example, whereas 20% of manufacturers with less than 50 employees used imported input, only 10.2% of those with 50-499 employees and 7.7% with 500 or more employees did so. The results indicate the necessity of supporting SME U.S. textile and apparel manufacturers to access textile input through mechanisms such as the Miscellaneous Tariff Bill (MTB).

Fifth, many US textile and apparel manufacturers have already explored overseas markets. Specifically, factories making textile products reported a higher percentage of engagement in exports, including fiber and yarn manufacturers (68.4%), fabric mills (78.9%), and technical textiles producers (69.1%). In comparison, relatively fewer U.S. apparel and home textile producers reported selling overseas.

Sixth, U.S. textile and apparel manufacturers’ export markets are relatively concentrated. Specifically, as many as 72% of apparel mills and 57% of home textiles manufacturers in the OTEXA database reported selling their products in less than two markets. These manufacturers also have a high percentage of selling to the U.S. domestic market. Likewise, because of the reliance on the Western Hemisphere supply chain, more than half of U.S. fiber and yarn manufacturers reported only selling in two markets or less. In comparison, reflecting the global demand for their products, U.S. technical textile manufacturers had the most diverse markets, with nearly 40% exporting to more than ten countries.

Seventh, while the Western Hemisphere remains the top export market, many U.S. textile and apparel manufacturers also export to Asia, Europe, and the rest of the world. For example, nearly half of U.S. textile and apparel manufacturers in OTEXA’s database reported exporting to Asia, and over 60% of U.S. technical textile manufacturers sold their products to European customers.

Additionally, over half of U.S. textile and apparel mills engaged in exports leveraged U.S. free trade agreements (FTAs). U.S. textile mills, on average, reported a higher percentage of using FTAs than apparel and home textile manufacturers. As most U.S.-led FTAs adopt the yarn-forward rules of origin, the results suggest that while such a rule may favor the export of U.S. textile products, its effectiveness and relevance in supporting U.S. apparel exports could be revisited.

Moreover, in line with the macro trade statistics, U.S. textile and apparel manufacturers in the OTEXA database reported a relatively high usage of USMCA, given Mexico and Canada being the two most important export markets. In comparison, U.S. textile and apparel manufacturers’ use of CAFTA-DR was notably lower, even for fiber and yarn manufacturers (37%) and fabric mills (33.3%).

by Kendall Ludwig, Miranda Rack and Sheng Lu

Picture above: On December 13, 2023, Kendall Ludwig and Miranda Rack, FASH 4+1 graduate students and Dr. Sheng Lu, had the unique opportunity to present the study’s findings to senior U.S. trade officials from OTEXA and the Office of the U.S. Trade Representative (USTR) in Washington DC, including Jennifer Knight (Deputy Assistant Secretary for Textiles, Consumer Goods and Materials), Laurie-Ann Agama (Acting Assistant US Trade Representative for Textiles), Maria D’Andrea-Yothers (Director of OTEXA), Natalie Hanson (Deputy Assistant US Trade Representative for Textiles) and Richard Stetson (Deputy Director of OTEXA).

Check the Udaily article that features the research project and the presentation (February 2024).

FASH455 Video Discussion: The Outlook of China as an Apparel Sourcing Destination

Video 1: I Visited a Chinese Factory
Video 2: Comments from Kim Glas, President of the National Council of Textile Organizations (2023)

Additional background reading: China’s U.S. Exports See Biggest Drop in 30 Years (Source: Sourcing Journal| January 19, 2024)

Discussion questions:

#1 What makes China a controversial apparel-sourcing destination with heated debate? What are the benefits of sourcing from China, and what are the concerns?

#2 As noted in the background reading, China accounted for about 21% of US apparel imports 2023, which marked a new record low in the past decade. What are the key drivers behind this shift, and do you anticipate this trend to continue in the next 3-5 years? Why or why not?

#3 Should US fashion companies decouple or derisk with China and to what extent? Please provide reasoning for your recommendation.

#4 Why do you think the US textile industry cares about apparel imports from China? What factual data/statistics supports or challenges the comments in the second video?

#5 Feel free to share any other reflections on the two videos (e.g., anything you find interesting, surprising or thought-provoking).

New Study: Importing Clothing Made from Recycled Textile Materials? A Study of Retailers’ Sourcing Strategies in Five European Countries

Full paper: Leah Marsh and Sheng Lu (2024). Importing clothing made from recycled textile materials? A study of retailers’ sourcing strategies in five European countries. Sustainability, 16(2), 825.

Summary & Key Findings:

With consumers’ growing awareness of the environmental impacts of clothing production and consumption, retailers in Europe (EU) have expressed a heightened interest in selling clothing using recycled textile materials (referred to as “recycled clothing” in this study). For example, fast fashion giants like H&M and Zara and luxury brands such as Hugo Boss have started carrying recycled clothing, aiming to integrate circularity into their product designs and business models.

In the study, we examined retailers’ sourcing strategies for clothing made from recycled textile materials in five European countries, including the United Kingdom (UK), Italy, France, Germany, and Spain. These five countries represent the EU’s largest clothing retail markets, consistently accounting for over 60% of the region’s total apparel sales.

Through an industry source using web crawling techniques and manual verification, 5,000 Stock Keeping Units (SKUs) of clothing items made from recycled textile materials were randomly selected and analyzed. These items were sold by retailers in the UK, Germany, Italy, France, and Spain between January 2021 and May 2023.

The results show that Firist, EU retailers sourced clothing using recycled textile materials from diverse sources, including over 40 developing and developed countries across Asia, America, Europe, and Africa. Second, other than assortment diversity (i.e., the number of color or sizing options for a clothing item), no statistical evidence shows that developing countries had advantages over developed ones regarding product sophistication, replenishment frequency, and pricing for recycled clothing in the five EU markets. Third, a supplying country’s geographic location statistically affects the type of recycled clothing EU retailers import. For example, retailers in the five EU countries typically adopt the following sourcing portfolio by region:

  • Asia: relatively sophisticated clothing items (e.g., dresses and outerwear) targeting the mass and value market.
  • America (North, South, and Central): relatively simple clothing categories (e.g., T-shirts and socks) targeting the mass and value market.
  • Europe: sophisticated clothing categories primarily for the luxury or premium market
  • Africa: relatively simple clothing categories targeting the premium market

The findings offered new insights into the business aspects of recycled clothing, particularly regarding its intricate supply chains and leading suppliers. The study’s results have several additional important implications.

First, while existing studies often suggest “local for local” textile recycling, the study’s findings revealed promising global sourcing opportunities for clothing using recycled textile materials. Particularly, leveraging a diverse sourcing base would allow EU retailers to take advantage of each supplying country’s unique production strength regarding product categories and assortment features and more efficiently balance various sourcing factors ranging from costs and flexibility to speed to market. Meanwhile, the study’s findings indicate that many countries worldwide have begun producing and exporting clothing using recycled textile materials, and the sourcing options and capacities will hopefully continue to grow.

Second, according to the study’s findings, unlike the patterns of making regular garments using virgin fiber, low-wage developing countries demonstrated no noticeable competitive edges over developed economies regarding producing and exporting clothing using recycled textile materials. Instead, developed economies, including many high-wage Western EU countries, emerged as top suppliers and leading sourcing destinations for recycled clothing. Thus, expanding clothing production using recycled textile materials presents an exciting economic opportunity with a promising future in developed countries, where many have plans to revitalize the domestic manufacturing sector and establish a sustainable circular economy.

Third, building on the previous point, the sustained commitment of fashion brands and retailers to carry more clothing made from recycled textile materials in their product assortment could hold significant implications for the future landscape of global apparel trade and sourcing patterns. For example, whereas apparel products are predominantly exported from developing to developed countries today, more trade flows could occur between developed economies in the future, attributed to their increasing production capacity and growing demand for clothing using recycled textile materials. Similarly, major apparel exporters in Asia, such as China and Bangladesh, might assume a less dominant role as a sourcing base for recycled clothing due to their insufficient infrastructure for efficiently sorting used clothing and generating high-quality recycled textile materials.

By Leah Marsh and Sheng Lu

Discussion questions proposed by FASH455:

#1 How might EU fashion companies’ sourcing strategies change as they increase carrying clothing made from recycled textile materials?

#2 Could the US emerge as a leading sourcing destination for clothing made from recycled textile materials? What are the potential advantages and disadvantages?

#3 Is expanding clothing made from recycled textile materials the right approach to achieve fashion sustainability? What is your thought?

FASH455 Discussion: De Minimis Rule and the US Textile and Apparel Industry

Reading material

How the “de minimis” rule (also referred to as Section 321 imports)* might change will be a critical issue to watch in 2024. Under US customs law, specifically the Trade Facilitation and Trade Enforcement Act of 2015, import duties are generally waived for goods valued at $800 or less per person per day, marking an increase from the previous de minimis threshold of $200.

Generally, the reasons for raising the de minimis threshold include: 1) facilitating the clearance of low-value packages and supporting the e-commerce industry (e.g., small-value shipments from online shopping and e-commerce). 2) allowing customs agencies to focus their limited resources on higher-value and higher-risk shipments; 3) lowering compliance and importing costs for importers, especially small businesses.

However, some stakeholders are increasingly concerned about the “de minimis” as a loophole in practice. For example, US textile industry representatives argued that the rule “providing a backdoor to Chinese goods produced with forced labor. The loophole has not only fueled the rise of imports from foreign e-commerce companies and mass distributors, but it has also put our domestic manufacturers and workers at a competitive disadvantage.”

According to CBP’s statistics, the volume and value of U.S. de minimis imports have been surging in recent years, particularly with the booming of e-commerce.

While reforming the “de minimis” rule is likely, its outlook remains uncertain.

  • The “de minimis” rule can only be changed through actions by US Congress. Several bills (e.g., Import Security and Fairness Act and De Minimis Reciprocity Act of 2023) have been introduced recently, calling for lowering the de minimis thresholds or closing the “loophole” to keep shipping from specific countries like China from taking advantage of the benefits. However, the election-year politics, a divided Congress, and their already packed agenda will make the legislative process challenging. That being said, tactically, Congress might include reform of the “de minimis” rule as part of a broader trade package in the future.
  • Not everyone agrees on how to reform the “de minimis.” For example, while some legislation favors lowering the threshold, others prioritize excluding non-market economies like China to benefit from the rule. Furthermore, US e-commerce businesses and influential logistics companies that benefit from the de minimis rule may oppose attempts to revoke the benefits they currently enjoy.
  • As “de minimis” shipments were exempted from CBP review, it also means that policymakers could lack sufficient data to support potential rule changes and evaluate the impacts. For example, while there is suspicion that companies like Shein and Temu exploited the de minimis rule or even that imports containing forced labor did so, it is challenging to present accurate and reliable data to understand their impacts. Thus, data collection “homework”, such as CBP’s section 321 data pilot program, will be necessary for meaningful discussions on reforming the de minimus rule.
  • *Section 321 refers to a part of U.S. law (19 U.S.C. § 1321) that allows duty-free entry of goods valued at $800 or less per shipment, per day, from foreign suppliers to U.S. customers. This is often called the de minimis exemption. Entry Type 86 is one method for filing Section 321 de minimis entries electronically through U.S. Customs and Border Protection (CBP). Entry Type 86 was initially launched as a pilot test by U.S. Customs and Border Protection (CBP) in September 2019.

Discussion questions:

#1: Please assess the arguments presented in the NY Times article regarding the de minimis rule’s impact on US textile and apparel manufacturers. What evidence or examples support their claims?

#2: Consider the defenders of the de minimis rule who argue that it does not harm the competitiveness of the US textile and apparel industry. What counterarguments and supporting evidence could they present?

#3: What additional information can help us better understand the trade impact of de minimis rules?

#4: Do you support eliminating or lowering the de minimis threshold? Why or why not?

[Instructions: For students in FASH455, please address at least two of the questions above. Additionally, feel free to share any other thoughts on the debates and resources you found relevant and informative.]

Red Sea Attacks and the Global Textile and Apparel Trade (updated January 2024)

Impacts of the Red Sea Attacks on the Supply Chain

Impacts of the Red Sea attacks on the global textile and apparel trade: A summary from the media

US retailers/importers: 1) “40 percent of shipments from Asia go to the U.S. through the Panama Canal” and “with access to the Suez Canal also now limited, vessels carrying goods to the East Coast of America will now take longer to deliver their shipments.” 2) “Companies that depend on inventory supplies from Asia will be impacted…These include things like sneakers, apparel and consumer electronics from countries such as China. Companies may be forced to pay more to get their inventory delivered, the costs of which could be passed on to consumers pushing up prices.”

EU retailers/importers: 1) “the rates for shipping goods from Asia to northern Europe have “more than doubled” since the start of December 2023.” 2) some EU fashion companies say “the crisis has delayed stock deliveries “by three to four weeks” and increased delivery costs by 20%” 3) some fashion retailers are “keen to avoid flying stock from Asia to Europe due to the significant amounts of carbon emissions caused by air freight.” 4) many EU fashion brands and manufacturers “expressed concern that they will have to shoulder the financial burden of the delays.”

China producers/exporters: 1) “Customers involved in China-European trade now face additional costs and a delay of seven to 10 days in such cases” 2) “Some Chinese exporters are shifting to China-Europe Railway Express services to ensure timely delivery of their goods and avoid staggering operational costs if they navigate around the Cape of Good Hope. However, “Some rail freight platform companies have proposed price increases for their railway services to Europe.”

India producers/exporters: 1) “Exports to the US west coast are intact, shipments to Europe, North Africa, and the Middle East have been affected. India exports goods worth $110 billion to the three regions.” 2) “The cost of freight and insurance has risen due to ships being compelled to avoid the region and take a longer route around the Cape of Good Hope. 3) Shipments are being held back by exporters, because they are feeling a pinch of additional freight cost. “Containers could face delays of 12-14 days in their turnaround time, although there is no shortage of containers.”

Bangladesh producers/exporters: 1) “over 70 percent of Bangladesh’s export-laden containers, which are destined for the EU, US East Coast and Canada, cross the Red Sea.” “Meanwhile,  “8 to 10 percent of the country’s imports come through the route.” 2)Bangladeshi exporters and importers are having to pay higher freight charges to the US and Europe.” According to the Bangladesh Textile Mills Association (BTMA), the freight charge has already increased by $700 to $800 per container in case of import-laden vessels. The Bangladesh Garment Manufacturers and Exporters Association (BGMEA) expects Bangladesh’s domestic garment suppliers “will have to ultimately bear the freight cost.”

Pakistan producers and exporters: Textile and apparel shipments are facing stress. On the one hand, Pakistani textile and apparel producers are “highly reliant on timely raw materials and machinery imports. Any disturbances in shipping schedules could lead to production slowdowns and increased costs for manufacturers.” Meanwhile, “There have been “delays in fulfilling orders due to higher lead times and freight charges.” “Exporters have been incurring losses as they were honoring orders when they had assumed freight charges of $750.” However, as of mid-January, “shipping companies have jacked up freight charges to around $1,800, a massive 140% hike.”

(Note: This blog post will be updated as new information becomes available. Industry professionals are welcome to leave comments and share insights.)

Outlook 2024–Key Issues to Shape Apparel Sourcing and Trade

In December 2023, Just-Style consulted a panel of industry experts and scholars in its Outlook 2024–what’s next for apparel sourcing briefing. Below is my contribution to the report. Welcome any comments and suggestions!

What’s next for apparel sourcing?

Apparel sourcing is never about abrupt changes. However, fashion companies’ sourcing practices, from their crucial sourcing factors and sourcing destinations to operational priorities, will gradually shift in 2024 in response to the evolving business environment.

First, besides conventional sourcing factors like costs, speed to market, and compliance, fashion companies will increasingly emphasize flexibility and agility in vendor selection. One driving factor is economic uncertainty. For example, according to leading international organizations such as the World Bank and the International Monetary Fund (IMF), the world economy will likely grow relatively slowly at around 2.6%-3% in 2024. However, it is not uncommon that the economy and consumers’ demand for clothing could perform much better than expected. This means companies need to be ready for all occasions. Likewise, geopolitical tensions, from the Russia-Ukraine war and the US-China decoupling to the military conflict in the Middle East, could cause severe supply chain disruptions anytime and anywhere. Thus, fashion companies need to rely on a more flexible and agile supply chain to address market uncertainties and mitigate unpredictable sourcing risks.

Secondly, it will be interesting to watch in 2024 to what extent fashion companies will further reduce their exposure to China. On the one hand, it is no surprise that fashion companies are reducing finished garments sourcing from China as much as possible. However, fashion brands and retailers also admit that it is difficult to find practical alternatives to China in the short to medium terms regarding raw textile materials and orders that require small runs and great variety. Meanwhile, investments from China are flowing into regions considered alternative sourcing destinations, such as the rest of Asia and Central America. These new investments could complicate the efforts to limit exposure to China and potentially strengthen, not weaken, China’s position in the apparel supply chains. And stakeholders’ viewpoints on “investments from China” appear even more subtle and complicated.

Third, regulations “behind the borders” could more significantly affect fashion companies’ sourcing practices in 2024, particularly in sustainability-related areas. While sustainability is already a buzzword, fashion companies must deal with increasingly complex legal requirements to achieve sustainability. Take textile recycling, for example. The enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) on recycled cotton, the US Federal Trade Commission’s expanded Green Guides, the EU’s extended producer responsibility (EPR) program and its strategy for sustainable textiles, and many state-level legislations on textile waste (e.g., California Textile Recycling Legislation) may all affect companies’ production and sourcing practices for such products. Fashion companies’ sourcing, legal, and sustainability teams will need to work ever more closely to ensure “sustainable apparel” can be available to customers.

Apparel industry challenges and opportunities

In 2024, a slow-growing or stagnant world economy will persist as a significant challenge for fashion companies. Without sourcing orders from fashion brands and retailers, many small and medium-sized manufacturers in the developing world may struggle to survive, leaving garment workers in a precarious financial situation. China’s economic slowdown could worsen the situation as many developing countries increasingly treat China as an emerging export market. With shrinking domestic demand, more “Made in China” apparel could enter the international market and intensify the price competition

Another challenge is the rising geopolitical tensions and political instability in major apparel-producing countries. For example, while a broad base supports the early renewal of the African Growth and Opportunity Act (AGOA), which will expire in 2025, the reported human rights violations in some essential apparel exporting countries in the region could complicate the renewal process in US Congress. Likewise, even though the Biden administration is keen to encourage fashion companies to expand sourcing from Central America, political instability there, from Nicaragua to Haiti, makes fashion companies hesitant to make long-term sourcing commitments and investments. Furthermore, 2024 is the election year for many countries, from the US to Taiwan. We cannot rule out the possibility that unexpected incidents could trigger additional instability or even new conflict.

On the positive side, it is encouraging to see fashion companies continue to invest in new technologies to improve their operational efficiency in apparel sourcing. Digital product passports, 3D product design, PLM, blockchain, Generative AI, and various supply chain traceability tools are among the many technologies fashion companies actively explore. Fashion companies hope to leverage these tools to improve their supply chain transparency, strengthen relationships with key vendors, reduce textile waste, accelerate product development, and achieve financial returns.

It is also a critical time to rethink and reform fashion education. In addition to traditional curricula like apparel design and merchandising, we need more partnerships between the apparel industry and educational institutions to expose students to the real world. More direct engagement with Gen Z will also benefit fashion companies tremendously, allowing them to understand their future core customers and prepare qualified next-generation talents. 

by Sheng Lu

Exploring US Apparel Brands and Retailers’ Evolving Sourcing Strategies (December 2023)

The full article is here (Just-Style access required). Below are the key findings:

Based on a content analysis of the annual reports of about 30 largest US fashion brands and retailers from 2018 to 2023, this study aims to identify these companies’ most critical evolving sourcing practices, including their sourcing destination adjustment, primary sourcing factors, and emerging sourcing-related “hot topics.” The findings provide critical market intelligence, informing US fashion companies about their peers’ emerging sourcing trends and popular practices. The results show that:

First, maintaining a relatively diverse sourcing base remains common among US fashion companies. Results show that large-size companies today typically source from more than 20 countries. One critical factor behind fashion companies’ sourcing diversification strategies is that no single supplying country is “perfect,” given the increasingly complex sourcing factors. Sourcing diversification allows fashion companies to balance various sourcing factors. For example, according to company #19, “the (sourcing diversification) approach provides us with the greatest flexibility in identifying the appropriate manufacturers while considering quality, cost, timing of product delivery and other criteria.” On the other hand, sourcing diversification enables companies to adapt quickly to market uncertainties and enjoy supply chain flexibility and resilience.

Second, while US fashion companies are not necessarily leaving any particular countries they source from, many have substantially reduced the number of vendors they work with over the past few years. Specifically, out of the 30 fashion companies the study examined, over 60% explicitly mentioned they consolidated their sourcing base at the vendor level from 2017/2018 to 2022/2023, although the degree varied. For example:

  • Company #4, a leading sportswear brand, cut its contracted factories from 363 to 291 (or down 19.8%)
  • Company #6, which owns several jeans and sportswear brands, reduced its contracted factories from 1,000 to around 340 (or down 66%)
  • Company #9, a well-known specialty clothing store, cut its vendors from 800 to 250 (or down 68.8%)
  • Company #26, a specialty clothing store targeting the youth, cut its vendors from 150 to around 119 (or down 20.7%)
  • Company #28, a discount department store, cut its vendors from 3,100 to around 2,800 (or down 9.7%)

Associated with the trend of “country diversification and vendor consolidation,” US fashion companies are increasingly interested in working with “super vendors,” e.g., those with multiple country presence or vertical manufacturing capability. The use of “super vendor” can also be observed in fashion companies’ willingness to give more sourcing orders to their top suppliers. For example, Company #18, a casual and outdoor wear retailer, reduced its vendors from 200 in 2017/2018 to 110 in 2022/2023, but increased the cap of sourcing orders for its top 10 vendors from 40% to 47% over the same period.

Third, regarding the sourcing base, many US fashion companies have intentionally reduced their apparel sourcing from China, given the US-China tariff war, deteriorating bilateral relations, and the forced labor concerns with China’s Xinjiang region (XUAR). Specifically, more than one-third of the examined companies explicitly mentioned their strategy to reduce finished garments sourcing from China. Furthermore, several US fashion companies indicated their “reducing China exposure” strategy would continue, implying China’s market share in the US apparel import market could decrease further.

Nevertheless, even though fewer finished garments are coming from China, US fashion companies admit that China will continue to play a critical role as a textile raw material supplier as no immediate practical alternative is available. For example, Company #20, a specialty clothing chain focusing on trendy and fashionable items, says, “During fiscal 2022, we sourced most of our finished products with partners and suppliers outside the US and we continued to design and purchase fabrics globally, with most coming from China.”

Fourth, in line with trade statistics, US fashion companies consider other Asian suppliers, such as Vietnam, Bangladesh, Cambodia, and Indonesia, as their top choices as China’s alternatives. In comparison, few fashion companies explicitly mentioned moving their sourcing orders from China to Western Hemisphere countries or other regions.

Additionally, regarding emerging “hot topics” related to sourcing:

  • Geopolitics: the deteriorating US-China relations, escalated trade tensions expanded from tariffs to forced labor, and the potential trade disruptions have concerned US fashion companies significantly. Notably, US fashion companies regard sourcing from China as increasingly risky, with the implementation of the Uyghur Forced Labor Prevention Act (UFLPA) in June 2022. For example, according to Company 2, “The Uyghur Forced Labor Prevention Act and other similar legislation may lead to greater supply chain compliance costs and delays to us and to our vendors.”
  • Near-shoring: due to the decoupling and de-risking from the China movement, US fashion companies have begun actively exploring near-shoring sourcing opportunities in the Western Hemisphere, particularly from members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR). For example, Company #1, the North American manufacturer, disclosed that “(our) Company relies on a number of preferential trade programs (…) including the Dominican Republic – Central America – United States Free Trade Agreement (CAFTA-DR (…) Collectively, these agreements strengthen US economic relations and expand trade with Central America, the Dominican Republic, and Haiti.
  • Sustainability and social responsibility: It is noteworthy that aside from climate change and forced labor, which are typically addressed as risk factors, US fashion companies generally hold an optimistic and forward-looking perspective for sustainability, such as new technologies and endeavors toward more sustainable production and sourcing. Terms such as using preferred or recycled materials, supply chain transparency and traceability, and emerging sustainability technologies have been more frequently mentioned in companies’ annual or ESG reports. For example, Company #17 says, “Increase the usage of environmentally preferred materials to comprise 32.6% of the brand’s global materials footprint.” Company #2 adds, “Our goal is to use preferred materials in 100 percent of our products by 2030.” Company #9 states, “We collaborate with suppliers to increase the supply of preferred raw materials.”
  • Supply chain transparency: US fashion companies attach great importance to improving supply chain transparency and traceability. Compared to the past, fashion companies are more willing to invest in new technologies and digital tools, allowing them to map supply chains and achieve sustainability goals more effectively. Related to this, US fashion companies have actively engaged with industry associations and other industry communities outside the company to stay informed about sustainability trends and learn best practices.

By Emily Delaye and Sheng Lu

Note: Welcome to the webinar hosted by the US Fashion Industry Association (USFIA) on Friday, December 15, 2023 at 2:00pm EST, to hear Emily Delaye discuss the study in detail.

FASH455 Exclusive Interview with Jennifer Pisula, Fabric Sourcing Manager at QVC, about Why Fabric Sourcing Matters

About Jennifer Pisula

Jennifer Pisula is a Fabric Sourcing Manager at QVC. Jennifer is also a member of the Cotton Board, appointed by the U.S. Secretary of Agriculture.

Jennifer has over ten years of experience in the corporate retail industry, where she first started her career as a Buyer at Qurate for QVC, buying for brands such as Isaac Mizrahi, Liz Claiborne, and C. Wonder. Given her love for Product Development and Production, Jennifer shifted her career to Sourcing at QVC where she traveled to China, Hong Kong, and Vietnam for factory and mill visits. Jennifer left QVC to be the Sourcing lead for URBN’s Anthropologie Plus line and the lead for Free People Movement Pre-Production and Production. In 2020, Jennifer returned to Qurate to lead the Fabric Sourcing team for QVC, where she manages sourcing & R&D for over 20 brands, working on both celebrity and core private label brands. Jennifer also works part-time as an Adjunct Professor at Immaculata University, where she teaches Textiles and Fashion Portfolio Development. In addition to her professional positions,

Jennifer Pisula graduated from the Textiles, Fashion Merchandising and Design M.S. program from the University of Rhode Island & earned a B.S. in Fashion Merchandising from Mercyhurst University.

The interview was conducted by Leah Marsh, a graduate student in the Department of Fashion and Apparel Studies at the University of Delaware. Leah’s research focused on​​ exploring EU retailers’ sourcing strategies for clothing made from recycled textile materials and fashion companies’ supply chain and sourcing strategies.

The interview is part of the 2023 Cotton in the Curriculum program, supported by Cotton Incorporated, to develop open educational resources (OER) for global apparel sourcing classes.

Understand the Evolving Production and Trade Patterns of Textiles and Apparel “Made in Asia”: Discussion Questions from Students in FASH455

Students in FASH455 have proposed the following discussion questions based on the videos about the state of textile and apparel in Asia. Everyone is welcome to join the online discussion. For FASH455 students, please address at least two questions and mention the question number (#) in your reply.

#1 We have seen all the improvements and “upgrading” Vietnam has made toward the fashion industry. What can the garment industry in other countries take away from Vietnam’s experiences?

#2 Is Asia’s highly integrated apparel supply chain unique to the region? Can the Western Hemisphere “copy” Asia’s model?

#3 How can Asia’s textile and apparel industry balance the growing demand for sustainability and the need to remain cost-competitive? What innovative strategies can be adopted to achieve this balance?

#4 As Asian textiles and apparel factories continue to improve their efficiency and expand product offers, will it be beneficial for the US to reach a trade agreement with Asian countries? Or do you believe such an agreement might contradict the goals we try to achieve from CAFTA-DR?

#5 Will Vietnam eventually become the next China, or could its labor shortages be a significant barrier preventing its textile and apparel industry from advancing to the next level?

#6 Should textile and garment factories in Asia make more efforts to appeal to the younger generation (e.g., Gen Z)? Or is automation the solution?

#7 To what extent do you think Asian apparel exporting countries (e.g., Bangladesh, Vietnam and Cambodia) will reduce their dependence on textile raw materials supply from China due to the Uyghur Forced Labor Prevention Act (UFLPA)? Or, instead, do you think Asian apparel-exporting countries other than China benefit from UFLPA?

#8 The video shows that Asian countries have begun to invest heavily in new production capacities for textile recycling. Do you believe the region will continue to dominate textile and apparel production in the era of fashion circularity? Or will the emergence of textile recycling shift the world textile and apparel trade patterns in the long run?