2022 WTO Public Forum: Resilient and Sustainable Fashion Apparel Supply Chain: Trade and Trade Policy

About the 2022 World Trade Organization (WTO) Public Forum

The 2022 WTO Public Forum (to be held from Sep 27 to 30, in Geneva, Switzerland) will look at how trade can contribute to post-pandemic economic recovery. The Forum will examine, in particular, how trade rules can be strengthened, and government policies improved to create a more resilient, sustainable, and inclusive trading system. The Forum has three subthemes: Leveraging technology for an inclusive recovery, Delivering a trade agenda for a sustainable future, Framing the future of trade.

About the Session:

Apparel is a $2.5 trillion global business, involving over 120 million workers worldwide and playing a uniquely critical role in the post-COVID economic recovery. The session intends to facilitate constructive dialogue regarding the progress, challenges, and opportunities of building a more resilient and sustainable fashion apparel supply chain in the Post-COVID world, which matters significantly to ALL stakeholders, from fashion brands, garment workers, and policymakers to ordinary consumers. The session will explore: 1) Why does building a more resilient and sustainable fashion apparel supply chain matter in the post-COVID world? What role can trade and trade policy play? 2) What significant progress has made the apparel supply chain more resilient and sustainable? What key challenges remain and why? 3) What needs to be done further to make the apparel supply chain more resilient and sustainable, particularly in the post-COVID world?

Panelists:

  • Dr. Arianna Rossi, Senior Research and Policy Specialist, International Labour Organization (ILO)
  • Ralph Kamphöner, Head of EU Office, Confederation of the German Textile and Fashion Industry
  • Dr. Sheng Lu, Associate Professor of Fashion and Apparel Studies, University of Delaware
  • Kekeli Ahiable, Advisor, Tony Blair Institute
  • Laura Husband, Just Style, Managing Editor (Moderator)

(Note: Event recording will be posted here later)

US-China Tariff War and Apparel Sourcing: A Four-Year Review

On September 2, 2022, the Office of the US Trade Representative (USTR) announced it would continue the billions of dollars of Section 301 punitive tariffs against Chinese products. USTR said it made the decision based on requests from domestic businesses benefiting from the tariff action. As a legal requirement, USTR will launch a full review of Section 301 tariff action in the coming months.

In her remarks at the Carnegie Endowment for International Peace on Sep 7, 2022, US Trade Representative Katharine Tai further said that the Section 301 punitive tariffs on Chinese imports “will not come down until Beijing adopts more market-oriented trade and economic principles.” In other words, the US-China tariff war, which broke out four years ago, is not ending anytime soon.

A Brief History of the US Section 301 tariff action against China

The US-China tariff war broke out as both unexpected and not too surprising. For decades, the US government had been criticizing China for its unfair trade practices, such as providing controversial subsidies to state-owned enterprises (SMEs), insufficient protection of intellectual property rights, and forcing foreign companies to transfer critical technologies to their Chinese competitors. The US side had also tried various ways to address the problems, from holding bilateral trade negotiations with China and imposing import restrictions on specific Chinese goods to suing China at the World Trade Organization (WTO). However, despite these efforts, most US concerns about China’s “unfair” trade practices remain unsolved.

When former US President Donald Trump took office, he was particularly upset about the massive and growing US trade deficits with China, which hit a record high of $383 billion in 2017. In alignment with the mercantilism view on trade, President Trump believed that the vast trade deficit with China hurt the US economy and undermined his political base, particularly with the working class.

On August 14, 2017, President Trump directed the Office of the US Trade Representative (USTR) to probe into China’s trade practices and see if they warranted retaliatory actions under the US trade law. While the investigation was ongoing, the Trump administration also held several trade negotiations with China, pushing the Chinese side to purchase more US goods and reduce the bilateral trade imbalances. However, the talks resulted in little progress.

President Trump lost his patience with China in the summer of 2018. In the following months, citing the USTR Section 301 investigation findings, the Trump administration announced imposing a series of punitive tariffs on nearly half of US imports from China, or approximately $250 billion in total. As a result, for more than 1,000 types of products, US companies importing them from China would have to pay the regular import duties plus a 10%-25% additional import tax. However, the Trump administration’s trade team purposefully excluded consumer products such as clothing and shoes from the tariff actions. The last thing President Trump wanted was US consumers, especially his political base, complaining about the rising price tag when shopping for necessities. The timing was also a sensitive factor—the 2018 congressional mid-term election was only a few months away.

President Trump hoped his unprecedented large-scale punitive tariffs would change China’s behaviors on trade. It partially worked. As the trade frictions threatened economic growth, the Chinese government returned to the negotiation table. Specifically, the US side wanted China to purchase more US goods, reduce the bilateral trade imbalances and alter its “unfair” trade practices. In contrast, the Chinese asked the US to hold the Section 301 tariff action immediately.

However, the trade talks didn’t progress as fast as Trump had hoped. Even worse, having to please domestic forces that demanded a more assertive stance toward the US, the Chinese government decided to impose retaliatory tariffs against approximately $250 billion US products. President Trump felt he had to do something in response to China’s new action. In August 2019, he suddenly announced imposing Section 301 tariffs on a new batch of Chinese products, totaling nearly $300 billion. As almost everything from China was targeted, apparel products were no longer immune to the tariff war. With the new tariff announcement coming at short notice, US fashion brands and retailers were unprepared for the abrupt escalation since they typically placed their sourcing orders 3-6 months before the selling season.

Nevertheless, Trump’s new Section 301 actions somehow accelerated the trade negotiation. The two sides finally reached a so-called “phase one” trade agreement in about two months. As part of the deal, China agreed to increase its purchase of US goods and services by at least $200 billion over two years, or almost double the 2017 baseline levels. Also, China promised to address US concerns about intellectual property rights protection, illegal subsidies, and forced technology transfers. Meanwhile, the US side somewhat agreed to trim the Section 301 tariff action but rejected removing them. For example, the punitive Section 301 tariffs on apparel products were cut from 15% to 7.5% since implementing the “phase one” trade deal.

Trump lost the 2020 presidential election, and Joe Biden was sworn in as the new US president on January 20, 2021. However, the Section 301 tariff actions and the US-China “phase one” trade deal stayed in force. 

Debate on the impact of the US-China tariff war

Like many other trade policies, the US Section 301 tariff actions against China raised heated debate among stakeholders with competing interests. This was the case even among different US textile and apparel industry segments.

On the one hand, US fashion brands and retailers strongly oppose the punitive tariffs against Chinese products for several reasons:

First, despite the Section 301 tariff action, China remained a critical apparel sourcing base for many US fashion companies with no practical alternative. Trade statistics show that four years into the tariff war, China still accounted for nearly 40 percent of US apparel imports in quantity and about one-third in value as of 2021. According to the latest data, in July 2022, China accounted for 43% of US apparel imports in quantity and 27.2% in value, far exceeding any other sources. Studies also consistently find that US fashion companies rely on China to fulfill orders requiring a small minimum order quantity, flexibility, and a great variety of product assortment.

Second, having to import from China, fashion companies argued that the Section 301 punitive tariffs increased their sourcing costs and cut profit margins. For example, for a clothing item with an original wholesale price of around $7, imposing a 7.5% Section 301 punitive tariff would increase the sourcing cost by about 5.8%. Should fashion companies not pass the cost increase to consumers, their retail gross margin would be cut by 1.5 percentage points. Notably, according to the US Fashion Industry Association’s 2021 benchmarking survey, nearly 90 percent of respondents explicitly say the tariff war directly increased their company’s sourcing costs. Another 74 percent say the tariff war hurt their company’s financials.

Third, as companies began to move their sourcing orders from China to other Asian countries like Vietnam, Bangladesh, and Cambodia to avoid paying punitive tariffs, these countries’ production costs all went up because of the limited production capacity. In other words, sourcing from everywhere became more expensive because of the Section 301 action against China. 

Further, it is important to recognize that fashion companies supported the US government’s efforts to address China’s “unfair” trade practices, such as subsidies, intellectual property rights violations, and forced technology transfers. Many US fashion companies were the victims of such practices. However, fashion companies did not think the punitive tariff was the right tool to address these problems effectively. Instead, fashion brands and retailers were concerned that the tariff war unnecessarily created an uncertain and volatile market environment harmful to their business operations.

On the other hand, the National Council of Textile Organizations (NCTO), representing manufacturers of fibers, yarns, and fabrics in the United States, strongly supported the Section 301 tariff actions against Chinese products. As most US apparel production had moved overseas, exporting to the Western Hemisphere became critical to the survival of the US textile industry. Thus, for years, NCTO pushed US policymakers to support the so-called Western Hemisphere textile and apparel supply chain, i.e., Mexico and Central American countries import textiles from the US and then export the finished garments for consumption. Similarly, NCTO argued that Section 301 tariff action would make apparel “Made in China” less price competitive, resulting in more near sourcing from the Western Hemisphere.

However, interestingly enough, while supporting the Section 301 action against finished garments “Made in China,” NCTO asked the US government NOT to impose punitive tariffs on Chinese intermediaries. As NCTO’s president testified at a public hearing about the Section 301 tariff action in 2019,

“While NCTO members support the inclusion of finished products in Section 301, we are seriously concerned that…adding tariffs on imports of manufacturing inputs that are not made in the US such as certain chemicals, dyes, machinery, and rayon staple fiber in effect raises the cost for American companies and makes them less competitive with China.”

Mitigate the impact of the tariff war: Fashion Companies’ Strategies

Almost four years into the trade war, US fashion companies attempted to mitigate the negative impacts of the Section 301 tariff action. Notably, US apparel retailers were cautious about raising the retail price because of the intense market competition. Instead, most US fashion companies chose to absorb or control the rising sourcing cost; however, no strategy alone has proven remarkably successful and sufficient.

The first approach was to switch to China’s alternatives. Trade statistics suggest that Asian countries such as Vietnam and Bangladesh picked up most of China’s lost market shares in the US apparel import market. For example, in 2022 (Jan-July), Asian countries excluding China accounted for 52% of US apparel imports, a substantial increase from 41% in 2018 before the tariff war. In comparison, unlike what US textile manufacturers had expected, there was no clear sign that the tariff war had resulted in more apparel sourcing from the Western Hemisphere.  

The second approach was to adjust what to source from China by leveraging the country’s production capacity and flexibility. For example, market data from industry sources showed that since the Section 301 tariff action, US fashion companies had imported more “Made in China” apparel in the luxury and premium segments and less for the value and mass markets. Such a practice made sense as consumers shopping for premium-priced apparel items typically were less price-sensitive, allowing fashion companies to raise the selling price more easily to mitigate the increasing sourcing costs. Studies also found that US companies sourced fewer lower value-added basic fashion items (such as tops and underwear), but more sophisticated and higher value-added apparel categories (such as dresses and outerwear) from China since the tariff war.

China is no longer treated as a sourcing base for low-end cheap product
More apparel sourced from China target the premium and luxuary market segments

Related, US fashion companies such as Columbia Sportswear leveraged the so-called “tariff engineering” in response to the tariff war. Tariff engineering refers to designing clothing to be classified at a lower tariff rate. For example, “women’s or girls’ blouses, shirts, and shirt-blouses of man-made fibers” imported from China can tax as high as 26.9%. However, the same blouse added a pocket or two below the waist would instead be classified as a different product and subject to only a 16.0% tariff rate. Nevertheless, using tariff engineering requires substantial financial and human resources, which often were beyond the affordability of small and medium-sized fashion companies.

Third, recognizing the negative impacts of Section 301 on US businesses and consumers, the Office of the US Trade Representative (USTR) created a so-called “Section 301 exclusion process.” Under this mechanism, companies could request that a particular product be excluded from the Section 301 tariffs, subject to specific criteria determined at the discretion of USTR. The petition for the product exclusion required substantial paperwork, however. Even companies with an in-house legal team typically hire a DC-based law firm experienced with international trade litigation to assist the petition, given the professional knowledge and a strong government relation needed. Also of concern to fashion companies was the low success rate of the petition. The record showed that nearly 90 percent of petitions were denied for failure to demonstrate “severe economic harm.” Eventually, since the launch of the exclusion process, fewer than 1% of apparel items subject to the Section 301 punitive tariff were exempted. Understandably, the extra financial burden and the long shot discouraged fashion companies, especially small and medium-sized, from taking advantage of the exclusion process.

In conclusion, with USTR’s latest announcement, the debate on Section 301 and the outlook of China as a textile and apparel sourcing base will continue. Notably, while economic factors matter, we shall not ignore the impact of non-economic factors on the fate of the Section 301 tariff action against China. For example, with the implementation of the Uyghur Forced Labor Prevention Act (UFLPA), only 13.5% of US cotton apparel imports came from China so far in 2022 (Jan-Jul), the lowest in a decade.  As the overall US-China bilateral trade relationship significantly deteriorated in recent years and the friction between the two countries expanded into highly politically sensitive areas, the Biden administration could “willfully” choose to keep the Section 301 tariff as negotiation leverage. Domestically, President Biden also didn’t want to look “weak” on his China policy, given the bipartisan support for taking on China’s rise.

by Sheng Lu

Utilization of US Trade Preference Programs–Why Fashion Companies Make the Sourcing Decisions They Do? (Video recording)

2022 WTO Aid for Trade Conference

Part 1 – Exporting countries and utilization of US Trade Preference Programs: An Overview

Part 2. Case Studies: Why companies make the sourcing decisions they do?

  • Patrick Fox, Senior Director, Customs and Trade Strategy, VF Corporation
  • Cen Williams, Hub Leader for Africa and Middle East region, PVH
  • Greg Poole, Chief Sourcing Officer, The Children’s Place

Background:

Trade preference programs provide duty-free US market access to selected exports of eligible developing countries. Unlike free trade agreements, all preference programs are unilateral, meaning they do not require reciprocal trade concessions.

There are five major trade preference programs enacted in the United States, including:

  • Generalized System of Preferences (GSP), which applies to developing countries as a whole. However, the US GSP program excludes most textile and apparel products due to import competition concerns.  GSP expired on December 31, 2020 and Congress is working with stakeholders to renew the program.
  • Four trade preference programs that target specific regions, including the Andean Trade Preference Act (APTA), the Caribbean Basin Economic Recovery Act (CBERA), the Caribbean Basin Trade Partnership Act (CBTPA), the African Growth and Opportunity Act (AGOA), and the Haitian Opportunity through Partnership Encouragement (HOPE) Act. In 2021, about 2% of US apparel imports came from trade preference partners.
  • US trade preferences reflect both economic development and foreign policy goals. In addition to the economic benefits, eligibility criteria create incentives for beneficiary countries to support objectives such as adopting and enforcing internationally recognized worker rights, reducing barriers to investment, and enforcing intellectual property rights.
  • However, the trade preference program is not without controversies. For example, it is debatable whether the trade preference program effectively enhances the genuine export competitiveness of developing countries. Also, despite preferential duty benefits, US fashion companies often hesitate to source more from trade preference partners due to concerns about a lack of critical infrastructure, limited production capacity, and political instability.

Patterns of US Apparel Imports in the First Half of 2022 and Key Sourcing Trends

First, US apparel imports enjoyed a decent growth but started to face softening demand.

  • Thanks to consumers’ spending, in the first half of 2022, US apparel imports went up 40% in value and 24% in quantity from a year ago.
  • However, due to US consumers’ weakening demand amid the economic downturn, the speed of import expansion is slowing down quickly. As an alert, the US consumer confidence index (CCI) fell to 54.8 in June 2022 (January 2019=100), the lowest since the pandemic. This result suggests that US consumers were increasingly worried about their household’s financial outlook and would hold back their discretionary clothing spending.
  • The month-over-month growth of US apparel imports dropped to only 2.6% in value and nearly zero in quantity in June 2022 from over 10% at the beginning of the year.
  • As the trajectory of the US economy remains highly uncertain in the medium term, we could expect many US fashion companies to turn more conservative about placing new sourcing orders in the second half of 2022 to control inventory and avoid overstock.

Second, fashion companies struggled with hiking apparel sourcing costs driven by multiple factors.

  • The price index of US apparel imports reached 103.9 in June 2022 (January 2019=100), a 3.1% increase from a year ago and the highest since 2019. USITC data further shows that, of the over 200 types of apparel items (HS Chapters 61 and 62) at the six-digit code level, nearly 70% had a price increase in the first half of 2022 from a year ago, including almost 40% experiencing a price increase exceeding 10 percent.
  • According to the 2022 Fashion Industry Benchmarking Study recently released by the US Fashion Industry Association (USFIA), 100 percent of respondents expect their sourcing costs to increase in 2022, including nearly 40 percent expecting a substantial cost increase from a year ago. Further, respondents say that almost everything has become more expensive this year, from textile raw materials, shipping, and labor to the costs associated with compliance with trade regulations.
  • To make the situation even worse, the more expensive “cost of goods” resulted in heavier burdens of ad valorem import duties for US fashion companies. USITC data shows that in the first five months of 2022, US companies paid $6,117 million in tariffs for apparel imports (HS Chapters 61 and 62), a significant increase of 42.9% from a year ago. Of these import duties paid by US companies, about 30% (or $1,804 million) resulted from the controversial US Section 301 action against Chinese imports. Because of the Section 301 tariff action, the average applied US tariff rate for apparel imports also increased from 17.2% in 2018 to 18.7% in the first half of 2022.
  • Even though the US retail price index for clothing reached 102.7 in June 2022 (January 2019=100), the price increase was behind the import cost surge over the same period. In other words, given the intense market competition and weaker demand, US fashion companies couldn’t pass the sourcing cost increase to consumers entirely.

Third, US fashion companies continued to diversify their sourcing base in 2022, which benefited large-scale suppliers in Asia.

  • The Herfindahl–Hirschman index (HHI), a commonly-used measurement of market concentration, went down from 0.11 in 2021 to 0.10 in the first half of 2022, suggesting that US apparel imports came from even more diverse sources. Similarly, the CS3 index, measuring the total market shares of the top three suppliers (i.e., China, Vietnam, and Bangladesh), fell below 50% in the first half of 2022, the lowest since 2018.
  • The Asia region remains the dominant source of apparel for US fashion companies: about 74.4% of US apparel imports came from Asian countries in the first half of 2022 (by value), which has stayed stable for over a decade.
  • One critical factor behind the apparent “contradictory” phenomenon is US fashion companies’ intention to reduce their “China exposure” further. Notably, considering all primary sourcing factors, from cost, speed to market, production flexibility, agility, and compliance risks, relatively large-scale Asian suppliers are the most likely alternatives to “Made in China.” Thus, the CR5 index excluding China (i.e., the market shares of Vietnam, Bangladesh, Indonesia, India, and Cambodia) increased from 40.7% in 2021 to 45.5% in the first half of 2022.

Fourth, US fashion companies’ evolving China sourcing strategy is far more subtle and complicated than simply “moving out of China.”

  • US fashion companies doubled their efforts to reduce sourcing from China in 2022, particularly in response to the newly implemented Uyghur Forced Labor Prevention Act (UFLPA) and the growing geopolitical risks. For example, measured in value, only 13.2% of US cotton apparel imports (OTEXA code 31) came from China in the first half of 2022, which fell from 14.4% a year ago and much lower than nearly 30% back in 2017.
  • Industry sources indicate that US fashion companies are “upgrading” what they source from China, possibly to offset the Section 301 punitive tariffs. The structural change includes importing less basic apparel items (e.g., tops and bottoms) and more sophisticated and higher-valued categories (e.g., dresses). Also, US fashion companies increasingly source from China for apparel items sold in the high-end market. For example, measured by the number of Stock Keeping Units (SKU), about 94% of apparel labeled “Made in China” sold in the US retail market targeted the value segment in 2018. However, of those apparel “Made in China” newly launched to the US retail market between January and July 2022, less than 2% were in the value segment. Instead, items targeting the higher-priced premium and mass market segments surged from 5% to 64%. Another 33% of “Made in China” were luxury apparel items. In other words, US fashion companies no longer see China as a sourcing base for cheap low-end products. Their sourcing decisions regarding China would give more consideration to non-price factors.
  • Further, some US fashion companies still see China as a promising sales market with growth potential. Localizing the supply chain (i.e., made in China for China) could be an increasingly popular practice for these companies. Thus, fashion companies’ vision for China could increasingly differ between those that only import products from China and those that see China as an emerging sales market.

Fifth, US apparel imports from the free trade agreements and trade preference programs partners stayed relatively stable in 2022 but lacked growth.

  • Despite the growing enthusiasm among US fashion companies for expanding near sourcing from the Western Hemisphere, the trade volume stayed stagnant. For example, in the first half of 2022, members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) accounted for 8.8% of US apparel imports in quantity and 9.9% in value, lower than a year ago (i.e., 9.9% in quantity and 11.1% in value). Likewise, Mexico also reported lower market shares in the US apparel import market in 2022. The results remind us that encouraging more US apparel sourcing from free trade agreements and preference program partners should go beyond offering preferential duty treatment.
  • Product diversification is a critical area that needs improvement, particularly regarding Western Hemisphere sourcing. For example, results show that US apparel sourcing from CAFTA-DR and Mexico generally concentrated on basic items such as tops and bottoms. In comparison, Asian countries, such as China, Vietnam, and Bangladesh, could offer much more diverse categories of products. This explains why US fashion companies treat large-scale Asian countries as their preferred alternatives to “Made in China” rather than moving sourcing orders to CAFTA-DR or Mexico.
  • Even though the ultimate goal is to expand US apparel sourcing from the Western Hemisphere, we need to make more efforts to practically and creatively solve the bottleneck of textile raw material supply facing garment producers in the region.

by Sheng Lu

Additional reading: Lu, Sheng. (2022). Asia triumphs in June despite US apparel sourcing diversification efforts. Just-Style.

What’s Happening with Myanmar’s Apparel Exports (Updated August 2022)

Zara (UK) sells plain trench coats “Made in Myanmar”

The prospect of Myanmar as an apparel sourcing base has been a hot-button issue since the country’s 2021 military coup. Notably, the labor-intensive apparel sector remained one of Myanmar’s largest employers and accounted for more than 30% of the country’s total exports in 2021 (UNComtrade, 2022). However, the military coup had also resulted in substantial job losses and growing concerns about the working conditions in Myanmar’s apparel sector.  

Nevertheless, fashion companies’ Myanmar apparel sourcing strategy seems to evolve in 2022 in response to the shifting business environment, particularly the inflation factor and the need to reduce “China exposure.” Specifically:

First, data from UNComtrade shows that fashion brands and retailers continued to source apparel from Myanmar in 2022, although the practice varied by country.

  • While Myanmar’s apparel export suffered a notable decline in 2021, it somehow bounced back in 2022 (Jan-May). Among its top apparel export markets, Myanmar’s market shares stayed stable in the EU and the US, and it enjoyed a remarkable increase in Japan (i.e., back to the level before the military coup).
  • That being said, Mynammar’s market shares in the leading apparel import markets (e.g., US, EU, and Japan) remain tiny (less than 5%). Likewise, fashion brands and retailers typically treat Myanmar as a supplementary sourcing base as part of their overall sourcing diversification strategy.
  • Meanwhile, Myanmar is gradually diversifying its export market after the military coup. For example, over 8.5% of Myanmar’s apparel exports went to other Association of Southeast Asian Nations (ASEAN) members in 2021, up from only 3.0% in 2020 and 2.7% in 2019.
  • As a developing country, Myanmar relies on imported textile raw materials for its apparel production. In 2021, 97.3% of Myanmar’s imported textiles came from Asia, including 72% from China.

Second, Myanmar’s apparel export performance is associated with the level of trade-related sanctions imposed by the importing countries.

Third, from the business perspective, fashion companies commonly use Myanmar as a low-cost sourcing destination for specialized product categories, particularly outwear.

  • Brands and retailers currently source apparel from Myanmar include Zara, H&M, Adidas, Fast Retailing Group, C.P. Company, among others.
  • Outwear is the single largest category of products fashion companies sourced from Myanmar (around 37%).In comparison, fashion companies typically source tops and bottoms from Bangladesh and Vietnam.
  • Also, industry sources indicate that, on average, outwear “Made in Myanmar” (around $70/piece) is priced much lower than those sourced from China (over $200/piece) and Vietnam (over $150/piece) in the retail market (EU, US, and Japan).
  • As fashion companies struggled with the hiking sourcing costs in 2022 and the pressure of reducing China exposure further, Myanmar remains a reasonable sourcing destination to fulfill certain orders from the business perspective.

Nevertheless, Myanmar’s outlook as an apparel sourcing base remains quite uncertain, especially given the recent new political instability in the country. Notably, some labor unions call for the EU to suspend Myanmar’s EBA eligibility. Without the duty-free benefits, it would be detrimental to Myanmar’s apparel exports. Meanwhile, labor unions also ask fashion brands and retailers to “make responsible exit from Myanmar,” including committing to transparency throughout and ensuring workers receive all wages, benefits, and severance payments owed to them.

by Sheng Lu

USTR Webinar Series on CAFTA-DR Textiles and Apparel Provisions (2022)

In February and March of 2022, the Office of the United States Trade Representative (USTR) organized and hosted a series of four webinars on CAFTA-DR trade in textiles and apparel. The objective was to enhance stakeholder understanding of the textile and apparel provisions of CAFTA-DR and identify opportunities for increasing and diversifying two-way trade between the United States and CAFTA-DR partner countries.

Webinar 1: Trends and Opportunities in CAFTA-DR Textile and Apparel Trade

Webinar 2: Making Use of CAFTA-DR’s Rules of Origin for Apparel

Webinar 3: The CAFTA-DR Short Supply Mechanism: What It Is and How To Use It

Webinar 4: Understanding Customs Claims and Customs Verifications in CAFTA-DR

Note: According to the 2022 USFIA Fashion Industry Benchmarking Study, US fashion companies demonstrate new excitement about increasing apparel sourcing from members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR). More than 60 percent of respondents plan to increase apparel sourcing from CAFTA-DR members as part of their sourcing diversification strategy.

Respondents also say the exceptions to the “yarn-forward” rules of origin, such as the “short supply” and “cumulation” mechanisms, provide essential flexibility that encourages more apparel sourcing from CAFTA-DR members.

However, U.S. apparel sourcing from CAFTA-DR has yet to achieve its full potential. For example, measured in value, only 10.2% of US apparel imports came from CAFTA-DR members in May 2022 (and 9.7% year to date), almost no change from 10.6% in 2021. Meanwhile, the CAFTA-DR utilization rate for apparel imports was stagnant at about 75%-80% since 2015, meaning 20-26 percent of U.S. apparel imports from CAFTA-DR members did NOT claim preferential duty benefits every year.

Other recent studies show that the limited textile raw material supply within CAFTA-DR is a significant bottleneck preventing more U.S. apparel sourcing from the region. CAFTA-DR’s textile raw material supply problem could become even worse as the U.S. textile industry switches to making more technical textiles and less so for apparel-related fabrics and textile accessories. Many surveyed US fashion brands and retailers say that providing more meaningful flexibility in rules of origin will encourage MORE apparel sourcing from CAFTA-DR.

2022 USFIA Fashion Industry Benchmarking Study Released

Report release webinar (July 18, 2022)

The full report is available HERE

Key findings of this year’s report:

U.S. fashion companies report significant challenges coming from the macro-economy in 2022, particularly inflation and rising cost pressures. However, most respondents still feel optimistic about the next five years.

  • Respondents rated “increasing production or sourcing costs” and “inflation and outlook of the U.S. economy” as their 1st and 3rd top business challenges in 2022.
  • As a new record, 100 percent of respondents expect their sourcing costs to increase in 2022, including nearly 40 percent expecting a substantial cost increase from a year ago. Further, almost everything has become more expensive this year, from textile raw materials, shipping, and labor to the costs associated with compliance with trade regulations.
  • Over 90 percent of respondents expect their sourcing value or volume to grow in 2022, but more modest than last year.
  • Despite the short-term challenges, most respondents (77 percent) feel optimistic or somewhat optimistic about the next five years. Reflecting companies’ confidence in their businesses, nearly ALL respondents (97 percent) plan to increase hiring over the next five years.

U.S. fashion companies adopt a more diverse sourcing base in response to supply chain disruptions and the need to mitigate growing sourcing risks.

  • Asia remains the dominant sourcing base for U.S. fashion companies—eight of the top ten most utilized sourcing destinations are Asia-based, led by China, Vietnam, Bangladesh, and India.
  • More than half of respondents (53 percent) report sourcing apparel from over ten countries in 2022, compared with only 37 percent in 2021.
  • Reducing “China exposure” is one crucial driver of U.S. fashion companies’ sourcing diversification strategy. One-third of respondents report sourcing less than 10% of their apparel products from China this year. In addition, a new record of 50 percent of respondents sources MORE from Vietnam than China in 2022.
  • Nearly 40 percent of respondents plan to “source from more countries and work with more suppliers” over the next two years, up from only 17 percent last year.

Managing the risk of forced labor in the supply chain is a top priority for U.S. fashion companies in 2022, especially with the new implementation of the Uyghur Forced Labor Prevention Act (UFLPA).

  • Over 95 percent of respondents expect UFLPA’s implementation to affect their company’s sourcing. Notably, more than 85 percent of respondents plan to cut their cotton-apparel imports from China, and another 45 percent to further reduce non-cotton apparel imports from the country.
  • Most respondents (over 92 percent) do NOT plan to reduce apparel sourcing from Asian countries other than China. However, nearly 60 percent of respondents also would “explore new sourcing destinations outside Asia” in response to UFLPA.
  • Mapping and understanding the supply chain is a critical strategy adopted by U.S. fashion companies to address the forced labor risks in the supply chain. Almost all respondents currently track Tier 1 and 2 suppliers. With the help of new traceability technologies, 53 percent of respondents have started tracking Tier 3 suppliers this year (i.e., those manufacturing yarn, threads, and trimmings), a substantial increase from 25-36 percent in the past.

There is considerable new excitement about increasing apparel sourcing from members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR). Respondents also call for more textile raw sourcing flexibility to encourage apparel sourcing from the CAFTA-DR region.

  • CAFTA-DR plays a more significant role as a sourcing base. About 20 percent of respondents place more than 10% of their sourcing orders from the region, doubling from 2021. 
  • Over the next two years, more than 60 percent of respondents plan to increase apparel sourcing from CAFTA-DR members as part of their sourcing diversification strategy.
  • CAFTA-DR is critical in promoting U.S. apparel sourcing from the region. Around 80 percent of respondents took advantage of the agreement’s duty-free benefits when sourcing apparel from the region this year, up from 50—60 percent in the past.
  • Respondents say the exceptions to the “yarn-forward” rules of origin, such as the “short supply” and “cumulation” mechanisms, provide essential flexibility that encourages more apparel sourcing from CAFTA-DR members.
  • Respondents say improving textile raw material supply is critical to encouraging more U.S. apparel sourcing from CAFTA-DR members. Particularly, “allowing more flexibility in souring fabrics from outside CAFTA-DR” and “improving yarn production capacity and variety within CAFTA-DR” are the top two priorities.

U.S. fashion companies strongly support another ten-year renewal of the African Growth and Opportunity Act (AGOA). Meanwhile, Ethiopia’s loss of AGOA eligibility discourages U.S. apparel sourcing from the ENTIRE AGOA region.

  • As much as 75 percent of respondents say another ten-year AGOA renewal will encourage more apparel sourcing from the region and making investment commitments.
  • However, despite the tariff benefits and the liberal rules of origin, respondents express explicit concerns about the region’s lack of competitiveness in speed to market, political instability, and having an integrated regional supply chain.
  • Ethiopia’s loss of AGOA benefits had a notable negative impact on sourcing from the country AND the entire AGOA region. Notably, no respondent plans to move sourcing orders from Ethiopia to other AGOA beneficiaries.

Unlocking RCEP for Business: Opportunities for Garment and Textile Industry [Webinar]

The event is hosted by the Association of Southeast Asian Nations (ASEAN) Secretariat.

About the webinar: This webinar seeks to understand the opportunities offered by the Regional Comprehensive Economic Partnership (RCEP) Agreement for the garment and textile industry in the region. Considering that the garment and textile industry involves a large number of MSMEs in its supply chain, it would be important to understand how MSMEs can utilise the RCEP Agreement to grow their business and further integrate themselves into the global supply chain, noting that RCEP members are critical apparel-sourcing country for many big global players in the industry.

The first part of the event includes three presentations. 1) textile and apparel trade patterns in the RCEP region and how to read RCEP’s detailed tariff phaseout schedule. 2) RCEP rules of origin for textiles and apparel; and 3) customs procedure

In the second half, three companies from Cambodia, Thailand, and Indonesia shared their perspectives about the potential impact of RCEP on their businesses.

Speakers:

  • Dr. Sheng Lu, Associate Professor, Department of Fashion and Apparel Studies, University of Delaware (presentation starts at 17m41s)
  • Mr. Chy Sotharith, Chief of Non-Tariff Measures and Export-Import Policy Bureau, Department of Export-Import, General Department of Trade Support Services, Ministry of Commerce, Cambodia
  • Ms. Suchaya Chinwongse, Former Expert of Rules of Origin, the Customs Department of Thailand
  • Mr. Prama Yudha Amdan, Head of Corporate Communications and PR, Assistant President Director Asia Pacific Fibers
  • Mr. Kaing Monika Deputy Secretary General of Garment Manufacturers Association in Cambodia (GMAC)
  • Mr. Jumnong Nawasmittawong, Executive Advisory Board to Textile Industry Club, The Federation of Thai Industries.

What Do Fashion Companies Say about China As an Apparel Sourcing Base? (Updated June 2022)

This study aims to understand western fashion brands and retailers’ latest China apparel sourcing strategies against the evolving business environment. We conducted a content analysis of about 25 leading fashion companies’ public corporate filings (i.e., annual or quarterly financial reports and earnings call transcripts) submitted from January 1, 2022 to June 15, 2022.

The results suggest several themes:

First, China remains one of the most frequently used apparel sourcing destinations. For example:

  • Express says, “The top five countries from which we sourced our merchandise in 2021 were Vietnam, China, Indonesia, Bangladesh and the Philippines, based on total cost of merchandise purchased.”
  • According to TJX, “a significant amount of merchandise we offer for sale is made in China.”
  • Children’s Place says, “We source from a diversified network of vendors, purchasing primarily from Vietnam, Cambodia, Indonesia, Ethiopia, Bangladesh, and China.
  • Ralph Lauren adds, “In Fiscal 2022, approximately 97% of our products (by dollar value) were produced outside of the US, primarily in Asia, Europe, and Latin America, with approximately 19% of our products sourced from China and another 19% from Vietnam.

However, many fashion companies have significantly cut their apparel sourcing volume from China. More often, China is no longer the No.1 apparel sourcing destination, overtaken by China’s competitors in Asia, such as Vietnam.

  • According to Lululemon, “During 2021, approximately 40% of our products were manufactured in Vietnam, 17% in Cambodia, 11% in Sri Lanka, 7% in China (PRC), including 2% in Taiwan, and the remainder in other regions… From a sourcing perspective, when looking at finished goods for the upcoming 2022 fall season, Mainland China represents only 4% to 6% of our total unit volume.”
  • Levi’s says, “The good thing about our supply chain is we’ve got truly a global footprint. We don’t manufacture a whole lot in China anymore. We’ve been slowly divesting manufacturing out of China, if you will, and kind of playing our chips elsewhere on the global map… Less than 1% of what we’re bringing into this country, into the US, less than 1% of it is coming from China.”
  • Adidas says, “In 2021, we sourced 91% of the total apparel volume from Asia (2020: 93%). Cambodia is the largest sourcing country, representing 21% of the produced volume (2020: 22%), followed by China with 20% (2020: 20%) and Vietnam with 15% (2020: 21%).”
  • Victoria’s Secret says, “On China, China is a single-digit percentage of our total inflow of merchandise. We’re not particularly dependent on China at all.”
  • Nike did not mention China as their leading apparel sourcing destination at all, “For fiscal 2021, 30% of NIKE Brand apparel was manufactured in Vietnam, and 24% of NIKE Brand footwear and less than 12% of NIKE Brand apparel was manufactured in Indonesia.”

Meanwhile, fashion companies still heavily use China as a sourcing base for textile raw materials (such as fabrics). For example:

  • Columbia Sportswear says, “in China where a large portion of the raw materials used in our products is sourced by our contract manufacturers.”
  • Lululemon says, During 2021, approximately 48% of our fabrics originated from Taiwan, 19% from China Mainland, 11% from Sri Lanka, and the remainder from other regions.”
  • Likewise, Puma says, “90% of our recycled polyester comes from Vietnam, China, Taiwan (China) and Korea.

Second, fashion brands and retailers express serious concerns about China’s COVID policy and government lockdown measures. Companies say such measures have affected their businesses negatively, from supply chain disruptions and shipping delays to lost sales in the China market. For example:

  • Levi’s says,” The other issue that we’ve been watching real closely is the impact that of COVID shutdowns in China has had on ports there. China, which is only 3% of our total business, was down mid-single-digit as growth in e-commerce was more than offset by declines across other channels due to COVID-related lockdown.”
  • Guess says, “closure of less than 2% of our directly operated stores as of April 30, 2022, mostly in China… Approximately $4.0 million was driven by the lower profit in China due to the impact of the COVID-19 pandemic
  • G-III apparel adds, “The Company’s fiscal year 2023 guidance contemplates the expected impact from the current supply chain conditions, including the current lockdowns in China, expected increased shipping costs and delays in receipt of goods.
  • Columbia sportswear says, “At varying times, government efforts to control the spread of COVID-19 impacted our stores in China.”
  • PVH says, “COVID-related pressures have continued into the first quarter of 2022, although to a much lesser extent than in the prior year period in all regions except China, as strict lockdowns in China have resulted in temporary store closures and have also impacted certain warehouses, which has resulted in the temporary pause of deliveries to the Company’s wholesale customers and from its digital commerce business.”
  • When discussing their outlook for fiscal year 2023, Under Armour says, “approximately three percentage points of (revenue) headwinds related to our strategic decision to work with our vendors and customers to cancel orders affected by capacity issues, supply chain delays, and emergent COVID-19 impacts in China.

Third, fashion companies report the negative impacts of US-China trade tensions on their businesses. Also, as the US-China relationship sours, fashion bands and retailers have been actively watching the potential effect of geopolitics. For example,

  • Express says, “recent geopolitical conditions, including impacts from the ongoing conflict between Russia and Ukraine and increased tensions between China and Taiwan, have all contributed to disruptions and rising costs to global supply chains.”
  • When assessing the market risk factors, Chico’s FAS says, “our reliance on sourcing from foreign suppliers and significant adverse economic, labor, political or other shifts (including adverse changes in tariffs, taxes or other import regulations, particularly with respect to China, or legislation prohibiting certain imports from China)
  • Adidas holds the same view, “In addition, the challenging market environment in China had an adverse impact on the company’s business activities… Additional challenges included the geopolitical situation in China and extended lockdown measures.”
  • Macy’s adds, “At this time, it is unknown how long US tariffs on Chinese goods will remain in effect or whether additional tariffs will be imposed. Depending upon their duration and implementation, as well as our ability to mitigate their impact, these changes in foreign trade policy and any recently enacted, proposed and future tariffs on products imported by us from China could negatively impact our business, results of operations and liquidity if they seriously disrupt the movement of products through our supply chain or increase their cost.
  • Gap Inc. says, “Trade matters may disrupt our supply chain. For example, the current political landscape, including with respect to U.S.-China relations, and recent tariffs and bans imposed by the United States and other countries (such as the Uyghur Forced Labor Prevention Act) has introduced greater uncertainty with respect to future tax and trade regulations.
  • QVC says, “The imposition of any new US tariffs or other restrictions on Chinese imports or the taking of other actions against China in the future, and any responses by China, could impair our ability to meet customer demand and could result in lost sales or an increase in our cost of merchandise, which would have a material adverse impact on our business and results of operations.”

Additionally, some fashion companies still see China as a promising sales market with growth potential. Localizing the supply chain (i.e., made in China for China) could be an increasingly popular practice for these companies. For example,

  • PVH says, “So, I think in general, our production in China is heavily oriented to China for China production. I think for us generally speaking, the biggest impact of the shutdowns that we’ve seen across Shanghai and Beijing has really been focused on the impact to our China market.”
  • Likewise, Levi’s says, “We’re manufacturing somewhere in the neighborhood of 5% of our global production is in China, and most of it staying in China.
  • Hanesbrands says, “we’re committed to opening new stores, and that’s continues to go well, despite, the challenges that are there. Looking specifically at Champion, we continued our expansion in China adding new stores in the quarter through our partners.”
  • H&M says, “we still see China as an important market for us.
  • According to Hugo Boss, “Thanks to overall robust local demand, revenues in China in 2021 grew 24% as compared to 2019.”
  • VF Corporation adds, “Consumer interest in our core categories is growing and we’re committed to continued expansion in China and across Asia-Pacific. Our confidence in the momentum of such key growth engines as our Outdoor & Action Sports businesses and our brands in China is evidenced by our plans to further increase investments in 2022 behind very targeted marketing and brand-building initiatives in these businesses.

by Sheng Lu

US Apparel Imports Face Growing Market Uncertainties (Updated: June 2022)

(See updated analysis: Patterns of US Apparel Imports in the First Half of 2022 and Key Sourcing Trends)

The latest trade data shows that in the first four months of 2022, US apparel imports increased by 40.6% in value and 25.9% in quantity from a year ago. However, the seemingly robust import expansion is shadowed by the rising market uncertainties.

Uncertainty 1: US economy. As the US economic growth slows down, consumers have turned more cautious about discretionary spending on clothing to prioritize other necessities. Notably, in the first quarter of 2022, clothing accounted for only 3.9% of US consumers’ total expenditure, down from 4.3% in 2019 before the pandemic. Likewise, according to the Conference Board, US consumers’ confidence index (CCI) dropped to 106.4 (1985=100) in May 2022 from 113.8 in January 2022, confirming consumers’ increasing anxiety about their household’s financial outlook.

Removing the seasonal factor, US apparel imports in April 2022 went up 2.8% in quantity and 3.0% in value from March 2022, much lower than 9.3% and 11.9% a month ago (i.e., March 2022 vs. February 2022). The notable slowed import growth reflects the negative impact of inflation on US consumers’ clothing spending. According to the Census, the value of US clothing store sales marginally went up by 0.8% in April 2022 from a month ago, also the lowest so far in 2022.

Apparel import price index

Uncertainty 2: Worldwide inflation. Data from the Bureau of Economic Analysis shows that the price index of US apparel imports reached 103.1 in May 2022 (May 2020=100), up from 100.3 one year ago (i.e., a 2.8% price increase). At the product level (i.e., 6-digit HS Code, HS Chapters 61-62), over 60% of US apparel imports from leading sources such as China, Vietnam, Bangladesh, and CAFTA-DR experienced a price increase in the first quarter of 2022 compared with a year ago. The price surge of nearly 40% of products exceeded 10 percent. As almost everything, from shipping, textile raw materials, and labor to energy, continues to soar, the rising sourcing costs facing US fashion companies are not likely to ease anytime soon.

The deteriorating inflation also heats up the debate on whether to continue the US Section 301 tariff action against imports from China. Since implementing the punitive tariffs, US fashion companies have to pay around $1 billion in extra import duties every year, resulting in the average applied import tariff rate for dutiable apparel items reaching almost 19%. Although some e-commerce businesses took advantage of the so-called “de minimis” rule (i.e., imports valued at $800 or less by one person on a day are not required to pay tariffs), over 99.8% of dutiable US apparel imports still pay duties.

Uncertainty 3: “Made in China.” US apparel imports from China in April 2022 significantly dropped by 26.7% in quantity and 24.6% in value from March 2022 (seasonally adjusted). China’s market shares also fell to a new record low of 26.3% in quantity and 16.8% in value in April 2022. The zero-COVID policy and new lockdown undoubtedly was a critical factor contributing to the decline. Fashion companies’ concerns about the trajectory of the US-China relations and the upcoming implementation of the new Uyghur Forced Labor Prevention Act (UFLPA) are also relevant factors. For example, only 10.5% of US cotton apparel imports came from China in April 2022, a further decline from about 15% at the beginning of the year. Given the expected challenges of meeting the rebuttable presumption requirements in UFLPA and the high compliance costs, it is not unlikely that US fashion companies may continue to reduce their China exposure.

As US fashion companies source less from China, they primarily move their sourcing orders to China’s competitors in Asia. Measured in value, about 74.8% of US apparel imports came from Asia so far in 2022 (January-April), up from 72.8% a year ago. In comparison, there is no clear sign that more sourcing orders have been permanently moved to the Western Hemisphere. For example, in April 2022, CAFTA-DR members accounted for 9.3% of US apparel imports in quantity (was 10.8% in April 2021) and 10.2% in value (was 11.4% in April 2021).

Uncertainty 4: Shipping delays. Data suggests we are not out of the woods yet for shipping delays and supply chain disruptions. For example, as Table 2 shows, the seasonable pattern of US apparel imports in March 2022 is similar to January before the pandemic (2017-2020). In other words, many US fashion companies still face about 1.5-2 months of shipping delays. Additionally, several of China’s major ports were under strict COVID lockdowns starting in late March, including Shanghai, the world’s largest. Thus, the worsened supply chain disruptions could negatively affect the US apparel import volumes in the coming months.

by Sheng Lu

Further reading: Lu, S. (2022). Myanmar loses appeal for US apparel imports. Just-Style.

New Study: Expand U.S. Apparel Sourcing from CAFTA-DR Members and Solve the Root Causes of Migration: Perspectives from U.S. Apparel Companies

The full study is available HERE.

Executive Summary:

This study offers valuable input and practical policy recommendations from U.S. apparel companies’ perspectives regarding expanding U.S. apparel sourcing from CAFTA-DR members. For the study, we consulted executives at 27 leading U.S.-based apparel companies (note: 85% report having annual revenues exceeding $500 million; over 95% have been sourcing apparel from the CAFTA-DR region for more than ten years).

The results confirm that expanding U.S. apparel sourcing from CAFTA-DR could be the best chance to effectively create more jobs in Central America and solve the root causes of migration there. To achieve this goal, we need to focus on four areas:

First, improve CAFTA-DR’s apparel production capacity and diversify its product offers.

  • As many as 92 percent of respondents report currently sourcing apparel from CAFTA-DR members.
  • Highly consistent with the macro trade statistics, the vast majority of respondents (i.e., 60 percent) place less than 10 percent of their company’s total sourcing orders with CAFTA-DR members.
  • Whereas respondents rate CAFTA-DR members overall competitive in terms of “speed to market,” they express concerns about CAFTA-DR countries’ limited production capacity in making various products. As a result, U.S. companies primarily source basic fashion items like T-shirts and sweaters from the region. These products also face growing price competition with many alternative sourcing destinations.
  • Improving CAFTA-DR’s production capacity and diversifying product offers would encourage U.S. apparel companies to move more sourcing orders from Asia to the region permanently.

Second, practically solve the bottleneck of limited textile raw material supply within CAFTA-DR and do NOT worsen the problem.

  • The limited textile raw material supply within CAFTA-DR is a primary contributing factor behind the region’s stagnated apparel export volume and a lack of product diversification.
  • Notably, respondents say for their apparel imports from CAFTA-DR members, only 42.9% of fabrics, 40.0% of sewing threads, and 23.8% of accessories (such as trims and labels) can be sourced from within the CAFTA-DR area (including the United States). CAFTA-DR’s textile raw material supply problem could worsen as the U.S. textile industry switches to making more technical textiles and less so for apparel-related fabrics and textile accessories.
  • Maintaining the status quo or simply calling for making the CAFTA-DR apparel supply chain more “vertical” will NOT automatically increase the sourcing volume. Instead, allowing CAFTA-DR garment producers to access needed textile raw materials at a competitive price will be essential to encourage more U.S. apparel sourcing from the region.

Third, encourage more utilization of CAFTA-DR for apparel sourcing.

  • CAFTA-DR plays a critical role in promoting U.S. apparel sourcing from the region. Nearly 90 percent of respondents say the duty-free benefits provided by CAFTA-DR encourage their apparel sourcing from the region.
  • The limited textile supply within CAFTA-DR, especially fabrics and textile accessories, often makes it impossible for U.S. companies to source apparel from the region while fully complying with the strict “yarn-forward” rules of origin. As a result, consistent with the official trade statistics, around 31 percent of respondents say they sometimes have to forgo the CAFTA-DR duty-free benefits when sourcing from the region.
  • Respondents say the exceptions to the “yarn-forward” rules of origin, including “short supply,” “cumulation,” and “cut and assemble” rules, provide necessary flexibilities supporting respondents’ apparel sourcing from CAFTA-DR members. Around one-third of respondents utilize at least one of these three exceptions when sourcing from CAFTA-DR members when the products are short of meeting the strict “yarn-forward” rules of origin. It is misleading to call these exceptions “loopholes.”

Fourth, leverage expanded apparel sourcing to incentivize more investments in the CAFTA-DR region’s production and infrastructure.

  • U.S. apparel companies are interested in investing in CAFTA-DR to strengthen the region’s sourcing and production capacity. Nearly half of respondents explicitly say they will make investments, including “building factories or expanding sourcing or manufacturing capacities” in the CAFTA-DR region through 2026.
  • CAFTA-DR will be better positioned to attract long-term investments in its textile and apparel industry with a sound and expanded apparel sourcing volume.

Additional resources:

Understand West Africa as an Emerging Apparel Sourcing Hub and Its New Sustainable Development Model: FASH455 Exclusive Interview with Kekeli Ahiable

(photo courtesy: Kekeli Ahiable)

Kekeli Ahiableis a private sector development Advisor with the Tony Blair Institute’s Industrialisation Practice. Working with industry leaders over the past 10 years, she has facilitated business and job creation opportunities in the trade infrastructure, supply chain, and manufacturing sectors across four continents.

In her current technical support role at TBI, she manages the Institute’s regional textile and apparel (T&A) project which aims to support the development of a best in class, sustainable, and circular cotton-to-apparel manufacturing hub across five West African countries.

She holds a Master of Public Policy (MPP) from the University of Oxford, with a focus on trade policy and economic development.

Interview Part:

Sheng: Thank you so much for speaking with us, Kekeli. First of all, would you please tell us a little about the Tony Blair Institute for Global Change (TBI) and your involvement with the textile and apparel (T&A) industry in West Africa?

Kekeli: Sure! The Tony Blair Institute for Global Change (TBI) is a not-for-profit organization that offers strategic advice and practical support to political leaders and governments so they can deliver reforms that raise standards and transform lives. Our work includes advising on a range of sectors including industrialization, energy, and technology. We currently work in 17 African countries.

Since 2019, we have been working with several governments in West Africa – specifically Cote d’Ivoire, Ghana, and Togo – to support the development of a best-in-class and sustainable textile and apparel sector that meets the needs of British, European, and North American retailers and consumers.

Our role has centered around supporting our partner governments to:

  • prepare for doing business; work with them to develop relevant sector strategy & review policy, etc.
  • design attractive investment incentives
  • attract interest in the region from relevant fashion trade actors

For instance, we facilitated a week-long investor roadshow to the three countries in 2019, with participation from three of the largest global apparel brands together with their mills and manufacturers (with a combined turnover of over US$ 70 billion). This was co-sponsored under the banner of Amcham Hongkong.

Covid-19 naturally impacted our physical scoping events and so we moved the conversations to virtual roundtable forums. Last December, eight of the UK’s biggest retailers, plus several European retailers, attended a session we organized, led by Rt Hon. Tony Blair. Representatives from the three main governments and other non-governmental groups involved in developing textiles and apparel in the region were also present to engage in discussion with the investors. We have also worked with the American Apparel and Footwear Association (AAFA) and the United States Fashion Industry Association (USFIA) to update US brands and retailers on West Africa’s potential as a nearshore sourcing destination for the North American market.

In summary, TBI is very much to help create top-of-mind awareness about West Africa’s suitability to grow a viable T&A sourcing hub and ultimately facilitate investment into the priority countries.

Sheng: What is the current state of the textile and apparel (T&A) industry in West Africa? What are the key development trends? How about the impact of COVID?

Kekeli: West Africa’s T&A market is rapidly expanding. Although considered nascent when compared to Asia’s more developed markets, its many greenfield opportunities also mean there are fewer legacy challenges to contend with. This offers a ripe opportunity for investors and manufacturers to start from an almost clean slate, which is crucial as the apparel industry makes strides toward a more environmentally sustainable footprint.

The region also has numerous natural and competitive advantages for textiles and apparel manufacturing and has seen increased interest from global actors, brands, manufacturers, infrastructure developers, development finance institutions, etc., over the last few years.

Key development trends

Recognizing shifting patterns in global T&A trade and the immense value in domestic processing of abundantly available raw materials, West African governments are demonstrating an ambition to harness their competitive advantages and expand their T&A sectors.

The governments of Cote d’Ivoire, Ghana, and Togo especially, are walking the talk. Togo’s agile government closed a ground-breaking €200 million investment deal with Arise IIP, in August 2020. The deal included building a 400-hectare eco-industrial park dedicated to textiles and apparel manufacturing. Apart from the park, the Arise group is investing into vertically integrated (fiber to fashion) knit apparel units which will start commercial operations in mid-2023.

Ghana has the most advanced industrial base of the three highlighted countries and hosts DTRT Apparel, which has been running its operation in Ghana for the past 7 years and is currently the largest apparel exporter from West Africa. As a further boost towards vertical integration, in March, they partnered on a co-creation deal with the International Finance Corporation (IFC) to jointly develop setting up a synthetic fabric mill in the region. Meanwhile, Northshore Apparel, another garment actor, recently began constructing a 10,000-worker garment factory in Ghana. To attract more foreign direct investment (FDI), the government is drafting a new T&A sector policy and incentive framework under the UK’s Foreign, Commonwealth & Development Office (FCDO) funded £16 million-pound JET Programme.

In a similar vein, Cote d’Ivoire, Africa’s second-largest cotton seed grower, is carrying out sector reforms and strategy development aimed at facilitating the domestic transformation of at least 50% of their annual cotton output.

Altogether, it is an exciting time to be developing the T&A sector in West Africa. We are excited to contribute towards this vision to create a best in class, vertical and sustainable manufacturing hub in the region, and help to create 500k direct and indirect jobs.

Impact of COVID

Most existing garment manufacturers pivoted to producing PPE for both domestic and international markets. For instance, DTRT is making this a permanent feature of their production, although orders have resumed from their traditional apparel buyers.

We have also witnessed a stronger resolve from governments to support their domestic T&A manufacturing sectors’ growth.  The Togo deal, for instance, happened at the height of covid lockdowns. Some countries also offered waivers on value-add tax for their textile and apparel manufacturers and used the time to restructure their labor codes to meet international standards.

Sheng: How to understand West African countries’ competitiveness as an apparel-sourcing base for western fashion companies?

Kekeli: First, there is an immense opportunity to vertically integrate the T&A manufacturing value chain. The region produces around 1.5 million metric tons of cotton annually, which represents about 60% of Africa’s total output and 15% of global exports. The vast majority of this is exported unprocessed. Farming methods feature rain-fed irrigation with harvest done by handpicking, leading to 80% being labeled as preferred, sustainable cotton under Better Cotton Initiative (BCI) and Cotton made in Africa (CmiA) standards.

Secondly, its geographical location means it offers a natural nearshore market to Europe and US markets – literally less than two weeks away from Europe by sea.

Note: transit times are shorter depending on the shipping line. Transit references for the US are New York and Charleston, Antwerp and Hamburg for Europe, and Hangzhou for China/Asia. Source: Freightos, Bollore Africa Logistics interviews

Other benefits include an abundant trainable labor force, cost savings to manufacturers under favorable trade instruments like African Growth and Opportunity Act (AGOA), EU’s Economic Partnership Agreement (EPA)/Everything But Arms (EBA) program, etc., as well as consolidated political stability in all three countries. Moreover, there is strong potential for developing a circular textile economy facilitated by green manufacturing and initiatives like our West Africa Regeneration Zone (WARZ) initiative, on which TBI is collaborating with key brands and figures from the industry.

Apart from the main retail regions, there is a growing online retail market in Africa – estimated to increase to $75 billion by 2025 with projected $3.4 trillion aggregate GDP under African Continental Free Trade Area (AfCFTA). As we have seen with recent moves to the continent by Twitter, Google, and others, there is large scope for fashion retailers to use manufacturing in West Africa as a launchpad into this growing continental market, with free movement of goods and services under AfCFTA.

These are attractive propositions for buyers and manufacturers looking to diversify their supply chains and leave a greener carbon footprint in the process.

Sheng: It is of concern that used clothing exports from developed countries to Africa hurt the local textile and apparel industry. What is your assessment?

Kekeli: That is correct. The reality is that there is strong consumer demand for second-hand clothing, due to the cheap prices and readily available clothing for re-use. This is the main reason why the supply chains are routing the bales to other markets, including Africa. Most consumers in Africa rely heavily on the second-hand clothing markets. In this configuration, it is difficult for local players to compete and attract the same consumers’ appetites.

Moreover, this is quite complex, especially in an era of global value chains and [free] trade pacts that enjoin countries to offer some levels of reciprocity in their trade relations. Governments wishing to partake in international trade cannot simply ban imports of goods to protect their local industries. It is, therefore, crucial to explore practical win-win solutions.

For instance, there is a fast-growing global market for fabrics made from recycled materials as brands and manufacturers are taking steps to make their footprint greener. Receiver countries of second clothes could develop other business opportunities from the materials that arrive, with funding from relevant partners. Take Ghana as an example – its Kantamanto market, arguably the world’s largest reuse, repair, and upcycle market, process hundreds of tons of clothing each week. A large percentage of what comes to the market however ends up as landfilled waste due to various reasons.

One remedy is recycling, which ploughs back the many unsold and non-reusable clothes into the textile manufacturing economy. This not only reduces the need for virgin fibers but with the scale envisioned for the West Africa T&A manufacturing project, it increases the fabric feedstock available for domestic Cut, Make, Trim (CMT) manufacturers thus supporting to differentiate the region as a destination for circular apparel sourcing. Managed properly, we envision this would have positive spillover effects on the domestic market. At TBI, we published a piece on tackling Ghana’s textile waste which can be read here for a deeper dive into the subject.

Sheng: How does the textile and apparel industry in West Africa embrace sustainability?

Kekeli: The strongest aspect is from an environmental perspective. With rain-fed irrigation, around 80% of the region’s cotton is labeled as preferred cotton. Vertically integrating the cotton value chain by processing within one geographical area supports a lower carbon footprint of each final product.

West Africa’s geographical proximity to main buyer markets also increases its environmental sustainability credentials as a nearshore market.

Moreover, circularity is part of the culture in this part of the world – people reuse and pass on clothes to other family relations after use, with very little going to waste. We see an opportunity to scale this with the West Africa regeneration (WARZ) initiative. The WARZ initiative aims to support the development of a sustainable and circular textile and apparel supply base in West Africa where post-consumer textile waste is recycled at scale and becomes feedstock for making new apparel. This would be underpinned by disruptive recycling and traceability technology.

In our role as non-vested convenors and facilitators, we have convened a consortium of international and domestic stakeholders to develop a pilot project in Ghana, which is the world’s number two importer of second-hand clothing. Preliminary scoping puts the entire project size at over US$500 million with the potential to generate over 60K jobs along the value chain over the next 5-10 years. The following image depicts the initial concept for the regeneration zone project:

Relatedly, to demonstrate emerging support at the continental level, the African Development Bank recently approved the establishment of a €4 million Africa Circular Economy Facility to drive integration of the circular economy into African efforts to achieve nationally defined contribution targets.

Sheng: How important are trade preference programs like the African Growth and Opportunity Act (AGOA) to the development of the textile and apparel industry in West Africa? Do you think AGOA should be extended after 2025? Should the agreement keep the liberal “third-country fabric” rules of origin? Why or why not?

Kekeli: Trade preference programs are extremely important to facilitate the growth of Africa’s manufacturing and export capacity. As fundamentals like infrastructure tend to be less developed on the continent, preferential regimes like AGOA serve as a key enabler for manufacturing FDI. The T&A industries in countries like Kenya, Lesotho, and Madagascar have grown tremendously in the past few years thanks to AGOA’s tariff-free concessions. West Africa’s T&A industry is now in the beginning stages of development and needs an extension of AGOA to grow.

I believe in the short-medium term, maintaining third-country fabric rules is also crucial (note: Third-country fabric rules allow for apparel made with fabrics sourced from outside the AfCFTA/Sub-Saharan Africa region to qualify for duty-free access). The simple reason is that West Africa’s cotton value chain needs support to develop. While countries have ambitions for vertical integration by processing cotton within the region, these backward linkages will take time to develop.

A phase-out period may be negotiated to further incentivize accelerating the move towards domestic production of fibers that qualify to be used by CMT manufacturers in the [sub]-region.

Sheng: What does the African Continental Free Trade Area (AfCFTA) mean for the textile and apparel industry in West Africa? 

Kekeli: The AfCFTA pact aims to form the world’s largest free trade area by connecting almost 1.3bn people across 54 African countries. The goal is to create a single market for goods and services to deepen the economic integration of Africa, with a combined GDP of around $3.4 trillion.

Historically, the most developed world regions have been those that have figured out and developed strong regional value chains. The EU, which is the world’s largest regional trade agreement (RTA) by value has over 64% of trade taking place within the regional block. Similar cases pertain in the US-Mexico-Canada (USMCA) and the Association of Southeast Asian Nations (ASEAN) free trade areas.

Intra-Africa trade on the contrary is currently under 20%, with strong potential for growth. Trade figures show that when African countries trade with each other, it is mostly intermediate or finished goods, which naturally have more value. The goal is to encourage more of this.

Textiles and apparel development in West Africa has strong potential to become a flagship example of what AfCFTA implementation could practically look like. In the next couple of years, I envision fabrics from Cote d’Ivoire, Benin, being exported to Ghana duty-free to feed apparel factories, designers from Cote d’Ivoire offering their expertise across the sub-region with no restrictions on their movement, textiles from Ghana being traded in Nigeria, etc. The possibilities are truly endless. 

–END–

State of U.S. Textile and Apparel Manufacturing: Output, Employment, and Trade (Updated May 2022)

Textile and apparel manufacturing in the U.S. has significantly shrunk in size over the past decades due to multiple factors ranging from automation, import competition to the shifting U.S. comparative advantages for related products. However, U.S. textile manufacturing is gradually coming back. The output of U.S. textile manufacturing (measured by value added) totaled $16.59 billion in 2021, up 23.8% from 2009. In comparison, U.S. apparel manufacturing dropped to $9.5 billion in 2019, 4.4% lower than ten years ago (Bureau of Economic Analysis, 2021).

Meanwhile, like many other sectors, U.S. textile and apparel production was hit hard by COVID-19 in the first half of 2020 but started to recover in the 3rd quarter. Notably, as of December 2021, U.S. textile production had returned to its pre-COVID level.

On the other hand, as the U.S. economy is turning more mature and sophisticated, the share of U.S. textile and apparel manufacturing in the U.S. Gross Domestic Product (GDP) dropped to only 0.12% in 2020 from 0.57% in 1998 (Bureau of Economic Analysis, 2021).

The U.S. textile and apparel manufacturing is changing in nature. For example, textile products had accounted for over 66% of the total output of the U.S. textile and apparel industry as of 2019, up from only 58% in 1998 (Bureau of Economic Analysis, 2020). Textiles and apparel “Made in the USA” are growing particularly fast in some product categories that are high-tech driven, such as medical textiles, protective clothing, specialty and industrial fabrics, and non-woven. These products are also becoming the new growth engine of U.S. textile exports. Notably, “special fabrics and yarns” had accounted for more than 34% of U.S. textile exports in 2019, up from only 20% in 2010 (Data source: UNComtrade, 2021).

Compatible with the production patterns, employment in the U.S. textile industry (NAICS 313 and 314) and apparel industry (NAICS 315) fell to the bottom in April-May 2020 due to COVID-19 but started to recover steadily since June 2020. From January 2021 to December 2021, the total employment in the two sectors increased by 4.5% and 4.2%, respectively (Seasonally adjusted). However, the employment level remains much lower than the pre-COVID level (benchmark: December 2019).

To be noted, as production turns more automated and thanks to improved productivity (i.e., the value of output per worker), U.S. textile and apparel factories have been hiring fewer workers even before the pandemic. The downward trend in employment is not changing for the U.S. textile and apparel manufacturing sector.  Related, how to attract the new generation of workforce to the factory floor remains a crucial challenge facing the future of textile and apparel “Made in the USA.”

International trade supports textiles and apparel “Made in the USA.” Notably, nearly 42% of textiles “Made in the USA” (NAICS 313 and 314) were sold overseas in 2019, up from only 15% in 2000. A recent study further shows that product category and the size of the firm were both statistically significant factors that affected the U.S. textile and apparel manufacturer’s likelihood of engaged in exports.

from Nordstrom Rack

It is not rare to find clothing labeled “made in the USA with imported fabric” or “made in the USA with imported material” in the stores. Statistical analysis shows a strong correlation between the value of U.S. apparel output and U.S. yarn and fabric imports from 1998 to 2019.

Like many other developed economies whose textile and apparel industries had reached the stage of post-maturity, the United States today is a net textile exporter and net apparel importer. COVID-19 has affected U.S. textile and apparel trade in several ways:

  • Trade volume fell and yet fully recovered: Both affected by the shrinkage of import demand and supply chain disruptions, the value of U.S. textile and apparel imports dropped by as much as 19.3% in 2020 from a year ago, particularly apparel items (down 23.5%). Likewise, the value of U.S. textile and apparel exports in 2020 decreased by 15.6%, including an unprecedented 26% decrease in yarn exports. Further, thanks to consumers’ robust demand, the value of US apparel imports enjoyed a remarkable 27.4% growth in 2021 from a year ago and but was still 2.5% short of the level in 2019.
  • Trade balance shifted: Before the pandemic, U.S. was a net exporter of fabrics. However, as the import demand for non-woven fabrics (for making PPE purposes) surged during the pandemic, U.S. ran a trade deficit of $502 million for fabrics in 2020; the trade deficit expanded to $975 million in 2021. Meanwhile, as retail sales slowed and imports dropped during the pandemic, the U.S. trade deficit in apparel shrank by 19% in 2020 compared with 2019. However, the shrinkage of the trade deficit did not necessarily boost clothing “Made in the USA” in 2020, reminding us that the trade balance often is not an adequate indicator to measure the economic impact of trade.
  • No change in export market: More than 70% of U.S. textile and apparel export went to the Western Hemisphere in 2021, a pattern that has stayed stable over the past decades (OTEXA, 2022). More can be done to strengthen the Western Hemisphere supply chain and textile and apparel production in the region by leveraging regional trade agreements like CAFTA-DR and USMCA.

By Sheng Lu

Further reading:

What Do You Take Away from FASH455?

I encourage everyone to watch the two short videos above, which provide an excellent wrap-up for FASH455 and remind us of the meaning and significance of our course.

First of all, I hope students can take away essential knowledge about textile and apparel (T&A) trade & sourcing from FASH455. As you may recall from the video, in FASH455:

Whether your dream job is to be a fashion designer, buyer, merchandiser, sourcing specialist, or marketing analyst, understanding how trade and sourcing work will be highly relevant and beneficial to your future career given the global nature of today’s fashion industry.

Second, I hope FASH455 helps students shape a big-picture vision of the T&A industry in the 21st-century world economy and provides students a fresh new way of looking at the world. Throughout the semester, we’ve examined many critical, timely, and pressing global agendas that are highly relevant to the T&A industry, from the impact of COVID-19 on apparel sourcing and trade, apparel companies’ social responsibility practices, the debate on the textile and apparel provisions in U.S. free trade agreements to the controversy of forced labor in the apparel supply chain. It is critical to keep in mind that we wear more than clothes: We also wear the global economy, international business, public policy, and trade politics that make affordable, fashionable, and safe clothes possible and available for hardworking families. This is also the message from many of our distinguished guest speakers this semester, and I do hope you find these special learning events enlightening and inspiring.

Likewise, I hope FASH455 can put students into thinking about why “fashion” matters. A popular misconception is that “fashion and apparel” are just about “sewing,” “fashion magazine,” “shopping” and “Project Runway.” In fact, as one of the largest and most economically influential sectors in the world today, the fashion industry plays a critical and unique role in creating jobs, promoting economic development, enhancing human development and reducing poverty. As we mentioned in the class, over 120 million people remain directly employed in the T&A industry globally, and a good proportion of them are females living in poor rural areas. For most developing countries, T&A typically accounts for 70%–90% of their total merchandise exports and provides one of the very few opportunities for these countries to participate in globalization. COVID-19, in particular, reveals the fashion industry’s enormous social and economic impacts and many problems that need our continuous efforts to make an improvement. 

Last but not least, I hope from taking FASH455, students will take away meaningful questions that can inspire their future studies and even life’s pursuit. For example:

  • How to make apparel sourcing and trade more sustainable, socially responsible and transparent? What needs to be done further–fashion companies, government, consumers and other stakeholders?
  • How has COVID-19 fundamentally and permanently changed the pattern of apparel sourcing and trade? What role can the textile and apparel sector play in contributing to the post-COVID economic recovery?
  • How will automation, AI and digital technologies change the future landscape of apparel sourcing, trade, and job opportunities? What may fashion education look like ten years from now given the shifting nature of the industry?
  • How to use trade policy as a tool to solve challenging global issues such as forced labor and climate change? Or shall we leave these issues to the market forces?

We don’t have solid answers yet for these questions. However, these issues are waiting for you, the young professional and the new generation of leaders, to write the history, based on your knowledge, wisdom, responsibility, courage, and creativity!

So what do you take away from FASH455? Please feel free to share your thoughts and comments.

Dr. Sheng Lu

Japanese Fashion Companies Continue to Diversify Apparel Sourcing Base

Japan has one of the world’s largest apparel consumption markets, with retail sales totaling USD$100bn in 2021, only after the United States (USD$476bn) and China (USD$411bn). Meanwhile, like many other developed economies, most apparel consumed in Japan are imported, making the country a considerable sourcing and market access opportunity for fashion companies and sourcing agents around the globe.

Japanese fashion companies primarily source apparel from Asia. Data shows that Japanese fashion brands and retailers consistently imported more than 90% of clothing from the Asia region, much higher than their peers in the US (about 75%), the EU (50%), and the UK (about 60%). This pattern reflects Japan’s deep involvement in the Asia-based textile and apparel supply chain.

Notably, Japan’s apparel imports from Asia often contain textile raw materials “made in Japan.” Data shows that in 2021, about 65% of Japan’s yarn exports, 75% of woven fabric exports, and 90% of knit fabric exports went to the Asia region, particularly China and ASEAN members. Understandably, in Japan’s apparel retail stores, it is not rare to find clothing labeled “made in China” or “Made in Vietnam” but include phrases like “high-quality luster unique to Japanese fabrics” and “with Japanese yarns” in the product description.

The Global value chain analysis further shows that of Japan’s $5.32 billion gross textile exports in 2017, around 34% (or $1.79 billion) contributed to export production in other economies, mainly China ($496 million), Vietnam ($288 million), South Korea ($98 million), and Taiwan ($92 million).

China remains Japan’s top apparel supplier at the country level. However, Japanese fashion brands and retailers have been diversifying their sourcing base. Since the elimination of the quota system in 2005, China, for a long time, was the single largest apparel supplier for Japan, with an unparalleled market share of more than 80% measured by value. However, as “Made in China” became more expensive, among other factors, China’s market share dropped to 56.4% in 2021. Japanese fashion brands and retailers actively seek China’s alternatives like their US and EU counterparts. Notably, Japan’s apparel imports from Vietnam, Bangladesh, and Indonesia have grown particularly fast, even though their production capacity and market shares are still far behind China’s.

As Japanese fashion companies source from more places, the total market shares of the top 5 apparel suppliers, not surprisingly, had dropped from over 94% back in 2010 to only 82.3% in 2021, measured by value. Similarly, the Herfindahl-Hirschman Index (HHI), commonly used to calculate market concentration, dropped from 0.64 in 2011 to 0.35 in 2021 for Japan’s apparel imports. In other words, Japanese fashion companies’ apparel sourcing bases became ever more diverse.

Fast Retailing Group’s apparel sourcing base (Data source: Open Apparel Registry)

We can observe the same pattern at the company level. For example, the Fast Retailing Group, the largest Japanese apparel retailer which owns Uniqlo, used to source nearly 100% of its products from China. However, as of 2021, the Fast Retailing Group sourced finished apparel from over 550 factories in more than 20 countries. While about half of these factories were in China, the Fast Retailing Group had strategically developed production capacity in Vietnam, Bangladesh, Indonesia, and India. On the other hand, in April 2021, the Fast Retailing Group opened a 3D-knit factory in Shinonome, allowing the company to re-shoring some production back to Japan.

Additionally, Japan is a member of the Regional Comprehensive Economic Partnership (RCEP), the world’s most economically influential free trade agreement. Notably, Japan commits to reducing its apparel import tariffs to zero for RCEP members following a 21-year phaseout schedule. However, as Table 8 shows, Japan’s tariff cut for apparel products is more generous toward ASEAN members and less for China and South Korea due to competition concerns. For example, by 2026, Japan’s average tariff rate will be reduced from 9.1% today to only 1.9% for apparel imports from ASEAN members but will remain above 6% for imports from China. Given the tariff difference, it can be highly expected that ASEAN members such as Vietnam could become more attractive sourcing destinations for Japanese fashion companies.

by Sheng Lu

Further reading: Lu, Sheng (2022). Japan’s apparel market has strong sourcing potential. Just-Style.

USTR Fiscal Year 2023 Goals and Objectives—Textile and Apparel

In April 2022, the Office of the United States Trade Representative (USTR) released its 2023 Fiscal Year Budget report, outlining five goals and objectives for 2023. Notably, textile and apparel is a key sector USTR plans to focus on in the coming year:  

 Goal 1: Open Foreign Markets and Combat Unfair Trade

  • Provide policy guidance and support for international negotiations or initiatives affecting the textile and apparel sector to ensure that the interests of U.S. industry and workers are taken into account and, where possible, to provide new or enhanced export opportunities for U.S. industry.
  • Conduct reviews of commercial availability petitions regarding textile and apparel products and negotiate corresponding FTA rules of origin changes, where appropriate, in a manner that takes into account market conditions while preserving export opportunities for U.S. producers and employment opportunities for U.S. workers.
  • Engage relevant trade partners to address regulatory issues potentially affecting the U.S. textile and apparel industry’s market access opportunities.
  • Continue to engage under CAFTA-DR working groups and committees to optimize inclusive economic opportunities; strengthen the agreement and address non-tariff trade impediments; provide capacity building in textile and apparel trade-related regulation and practice on customs, border and market access issues, including agriculture and sanitary and phytosanitary regulation, to avoid barriers to trade.
  • Continue to engage CAFTA-DR partners and stakeholders to identify and develop means to increase two-way trade in textiles and apparel and strengthen the North American supply chain to enhance formal job creation.

Goal 2: Fully Enforce U.S. Trade Laws, Monitor Compliance with Agreements, and Use All Available Tools to Hold Other Countries Accountable

  • Closely collaborate with industry and other offices and Departments to monitor trade actions taken by partner countries on textiles and apparel to ensure that such actions are consistent with trade agreement obligations and do not impede U.S. export opportunities.
  • Research and monitor policy support measures for the textile sector, in particular in China, India, and other large textile producing and exporting countries, to ensure compliance with international agreements.
  • Continue to work with the U.S. textile and apparel industry to promote exports and other opportunities under our free trade agreements and preference programs, by actively engaging with stakeholders and industry associations and participating, as appropriate, in industry trade shows.

Goal 4: Develop Equitable Trade Policy Through Inclusive Processes

Take the lead in providing policy advice and assistance in support of any Congressional initiatives to reform or re-examine preference programs that have an impact on the textile and apparel sector.

[This blog post is not open for comment]

Sourcing Apparel from the CAFTA-DR Region—The Modern Cotton Story Podcast

Discussion questions:

  • What are the advantages and disadvantages of CAFTA-DR as an apparel-sourcing base for US fashion companies?
  • What are the key bottlenecks that prevent more apparel sourcing from CAFTA-DR members?
  • Do you support liberalizing the rules of origin or keeping the strict “yarn-forward” rules of origin in CAFTA-DR, and why?

Video discussion: How Fashion Companies Design Products To Avoid Tariffs

Background: Tariff engineering refers to the practice of designing a product (e.g., clothing) to be classified at a lower tariff rate. For example, “women’s or girls’ blouses, shirts, and shirt-blouses of man-made fibers” imported from China can get taxed as high as 26.9%. However, the same blouse added a pocket or two below the waist would instead be classified as a different product and subject to only a 16.0% tariff rate.

US fashion companies like Columbia Sportswear leveraged tariff engineering to mitigate the negative impact of the US-China tariff war. Nevertheless, using tariff engineering requires substantial financial and human resources, which often were beyond the affordability of small and medium-sized fashion companies.

Discussion questions:

What do you think about tariff and tariff engineering based on the video and our lectures?

The Shifts in US Textile Manufacturing Raise Questions About the Availability of US-made Textile Inputs for the Western Hemisphere Apparel Supply Chain

The full study is available here (need Just-Style subscription)

By leveraging production and trade statistics from government databases, we examined the critical trends of US textile manufacturing and supply. Particularly, we try to understand the strengths and weaknesses of the United States as a textile raw material supplier for domestic garment manufacturers and those in the Western Hemisphere. Below are the key findings:

First, fiber, yarn, and thread manufacturing is a long-time strength in the US, whereas fabric production is much smaller in scale. Specifically, fiber, yarn, and thread (NAICS 31311) accounted for nearly 18% of US textile mills’ total output in 2019. In comparison, less than 13% of the production went to woven fabrics (NAICS 31321) and only about 5% for knit fabrics (NAICS 31324).

Second, the US textile industry shifts to make more technical textiles and less apparel-related yarns, fabrics, and other raw materials. Data shows that from 2015 to 2019, the value of US fiber, yarn, and thread manufacturing (NAICS code 31311) dropped by as much as 16.8 percent. Likewise, US broadwoven fabric manufacturing (NAICS code 31321) and knit fabric (NAICS code 31324) decreased by 2.0 percent and 2.7 percent over the same period. Labor cost, material cost, and capital expenditure are critical factors behind the structural shift of US textile manufacturing.

Third, the structural change of US textile manufacturing directly affects the role of the US serving as a textile supplier for domestic apparel producers and those in the Western Hemisphere.

On the one hand, the US remains a critical yarns and threads supplier in the Western Hemisphere. For example, from 2010 to 2019, the value of US fibers, yarn and threads exports (NAICS31311) increased by 25%, much higher than other textile categories. Likewise, in 2021, fibers, yarns, and threads accounted for about 23.3% of US textile exports, higher than 21.0% in 2010. Additionally, nearly 40% of Mexico and CAFTA-DR members’ yarn imports in 2021 (SITC 651) still came from the US, the single largest source. This trend has stayed stable over the past decade.

On the other hand, the US couldn’t sufficiently supply fabrics and other textile accessories for garment producers in the Western Hemisphere, and the problem seems to worsen. Corresponding to the decline in manufacturing, US broadwoven fabric (NAICS 31321) and knit fabric (NAICS 31324) exports decreased substantially.

The US also plays a declining role as a fabric and textile accessories supplier for garment factories in the Western Hemisphere. Garment producers in Mexico and CAFTA-DR members had to source 60%-80% of woven fabrics and 75-82% of knit fabrics from non-US sources in 2021. Likewise, only 40% and 14.6% of Mexico and CAFTA-DR members’ textile accessories, such as labels and trims, came from the US in 2021.

Likewise, the limited US fabric supply affects the raw material sourcing of domestic apparel manufacturers. For example, according to the “Made in the USA” database managed by the Office of Textiles and Apparel (OTEXA), around 36% of US-based apparel mills explicitly say they use “imported material,” primarily fabrics.

The study’s findings echo some previous studies suggesting that textile raw material supply, especially fabrics and textile accessories, could be the single most significant bottleneck preventing more apparel “Made in the USA” and near-sourcing from the Western Hemisphere.

Meanwhile, how to overcome the bottleneck could trigger heated public policy debate. For example, US policymakers could encourage an expansion of domestic fabric and textile accessories manufacturing as one option. However, to make it happen takes time and requires substantial new investments. Also, economic factors may continue to favor technical textiles production over apparel-related fabrics in the US.

As an alternative, US policymakers could make it easier for garment producers in the Western Hemisphere to access their needed fabrics and textile accessories outside the US, such as improving the rules of origin flexibility in CAFTA-DR or USMCA. But this option is likely to face strong opposition from US yarn producers and be politically challenging to implement.

(About the authors: Dr Sheng Lu is an associate professor in fashion and apparel studies at the University of Delaware; Anna Matteson is a research assistant in fashion and apparel studies at the University of Delaware).

Russia-Ukraine War and the Apparel Sector: A Summary (Updated March 2022)

Like many other sectors, the apparel industry is NOT immune to the Russia-Ukraine military conflict. According to data from Euromonitor, as one of the world’s largest apparel consumption markets, apparel retail sales in Russia exceeded USD 28 billion in 2021.

Notably, many well-known global fashion brands, such as H&M, Zara, Uniqlo, Adidas, Hugo Boss, Nike, and the emerging ultra-fast fashion retailer Shein, are top players with the largest market shares in Russia’s apparel retail market.

Russia was a lucrative and growing market for luxury apparel brands. Industry sources indicate that of apparel items launched to the Russian retail market from Jan 2021 to Feb 2022, more than 19% were in the luxury segment, much higher than 10% in the US and 8.7% in Italy, France, German, the UK, and Spain combined.

That being said, store closure, the EU, and US’s export ban of luxury goods to Russia would modestly impact most luxury apparel brands. Notably, Russia remains a relatively small market for luxury apparel brands. For example, less than 2% of LVMH’s annual sales came from Russia and 3% for the Kering Group. In comparison, Western EU and North America combined typically account for half of a luxury apparel band’s annual sales.

Given the fast deterioration of the situation, a growing number of international fashion brands and retailers have decided to suspend their operations in Russia, including Nike, H&M, Puma, Zara, Levi’s, Hermes, Chanel, and Gucci. Japan’s Fast Retailing Group (Uniqlo) initially chose to stay, but later reversed its decision. According to Yale University, as of March 18, 2022, over 400 global companies have withdrawn from Russia, but some remain.

Further, the World Trade Organization data shows that Russia ranked as the world’s No.10 largest apparel importer in 2020 (by value). According to UNComtrade, China served as Russia’s single largest source of apparel in 2020 (40.3%), followed by EU members (12.3%), Bangladesh (10.5%), Turkey (6.2%), and Vietnam (5.1%). However, Russia accounted for a relatively small proportion of these countries’ apparel exports, implying a modest trade impact.

Nevertheless, a few Eastern EU countries rely more heavily on Russia as their top apparel export market, including Uzbekistan (52%), Moldova (40.4%), and Lithuania (18.8%). Apparel producers in these countries could be vulnerable to trade disruption.

On the other hand, the fashion industry faces growing price pressure because of the Russia-Ukraine war. As the immediate result of the escalated tension, the world oil price jumped substantially. This means textile fibers derived from oil, such as polyester, could face tremendous price pressure. As man-made fiber becomes more expensive, the demand for natural fiber could also increase, eventually extending the price inflation to natural fiber.

US Producer Price Index: Textile Products and Apparel: Polyester Fibers
Global Price of Cotton

Further, the vast uncertainty and risk caused by the war for the world economy and geopolitics could be a more significant concern. For example, a fluctuating financial market and a slower world economy would complicate the post-covid recovery. Also, Turkey, one of Ukraine’s close neighbors, serves as a leading apparel supplier for the EU market. Apparel companies that rely on sourcing from Turkey may need to prepare for a contingency plan. Media reports that the Turkish textile and apparel industry suffers as customers in Ukraine and Russia cancel orders.

Summarized by Sheng Lu

Additional resources:

Barcelona Fashion Summit 2022 Exclusive Interview: Apparel Sourcing, Trade, and Globalization

CAFTA-DR Utilization Rate Fell to a Record Low for Apparel Sourcing in 2021, But Why?

As US fashion companies diversify their sourcing from Asia, near-sourcing from the Western Hemisphere, particularly members of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) seems to benefit. According to the latest trade data from the Office of Textiles and Apparel (OTEXA), US apparel companies placed relatively more sourcing orders with suppliers in the Western Hemisphere in 2021. For example, CAFTA-DR members’ market shares increased by 0.31 percentage points in quantity and nearly one percentage point in value compared with a year ago.

However, it is concerning to see the utilization rate of CAFTA-DR for apparel sourcing fall to a new record low of only 73.7% in 2021. This means that as much as 26.3% of US apparel imports from CAFTA-DR members did NOT claim the duty-free benefits.

The lower free trade agreement (FTA) utilization rate became a problem, particularly among CAFTA-DR members with fast export growth to the US market in 2021. For example, whereas US apparel imports from Honduras enjoyed an impressive 45.6% growth in 2021, only 72.6% of these imports claimed the CAFTA-DR duty benefits, down from 82.3% a year ago. We can observe a similar pattern in El Salvador, Nicaragua, and the Dominican Republic.

The phenomenon is far from surprising, however. For years, US fashion companies have expressed concerns about the limited textile supply within CAFTA-DR, especially fabrics and textile accessories. The lack of textile supply plus the restrictive “yarn-forward” rules of origin in the agreement often creates a dilemma for US fashion companies: either source from Asia entirely or source from CAFTA-DR but forgo the duty-saving benefits.

Likewise, because of a lack of sufficient textile supply within the region, US apparel imports from CAFTA-DR members become increasingly concentrated on basic fashion items, typically facing intense competition with many alternative sourcing destinations. For example, measured in value, over 80% of US apparel imports from CAFTA-DR members in 2021 were shirts, trousers, and underwear. However, US companies import the vast majority (70%-88%) from non-CAFTA-DR sources for these product categories.

Understandably, it will be unlikely to substantially expand US apparel sourcing from CAFTA-DR members without solving the textile supply shortage problem facing the region.

More reading:

COVID-19 and US Apparel Imports: Key Trends (Updated: January 2022)

First, US apparel imports continue to rebound in November 2021 as companies build the inventory for the holiday season. Thanks to US consumers’ strong demand and the upcoming holidays, the value of US apparel imports went up by 15.7% in November 2021 from a month ago (seasonally adjusted) and increased by as much as 39.7% from 2020. However, before the pandemic, the value of US apparel imports always peaked in October and then gradually slipped in November and December. The unusual surge of imports in November 2021 could be the combined effects of price inflation and the late arrival of goods due to the shipping crisis.

Meanwhile, US apparel imports so far in 2021 have been far more volatile than in the past few years because of uncertainties and disruptions caused by COVID-19 and the shipping crisis. For example, the year-over-year (YoY) growth rate ranged from 131% in May to 17.6% in July, causing fashion companies additional inventory planning and supply chain management challenges. Unfortunately, the new omicron variant could worsen the market uncertainty and volatility.

Second, Asian countries remain the dominant sourcing base for US fashion companies as the production capacity elsewhere is limited. Asian countries’ market shares fell from 74.2% in 2020 to 71.3% in July 2021, primarily because of the COVID lockdowns in Vietnam and Bangladesh. US apparel imports came from Asian countries rebounded to 74.8% and 72.5% in October and November 2021, respectively. This result suggests a lack of alternative sourcing destinations outside Asia, especially for large volume items. Meanwhile, the worsening shipping crisis affecting the route from Asia to North America could explain why Asian suppliers’ market shares in November were somewhat lower than a month ago.

Third, US companies continue to treat China as one of their essential sourcing bases in the current business environment. However, companies are NOT reversing their long-term strategy of reducing “China exposure.”  China stays the largest supplier for the US market in November 2021, accounting for 41.5% of total US apparel imports in quantity and 25.8% in value. Due to the seasonal factor, China’s market shares typically peak from June to September and then drop from October until March-April.

Both industry sources and the export product diversification index also consistently show that China supplied the most variety of products to the US market with no near competitors. In comparison, US apparel imports from Bangladesh, Mexico, and CAFTA-DR members concentrate more on specific product categories.

Nevertheless, the HHI index and market concentration ratios (CR3 and CR5) calculated based on the latest data suggest that US fashion companies continue to move their apparel sourcing orders from China to other Asian countries overall. For example, only around 15% of US cotton apparel comes from China, compared with about 27% in 2018. My latest studies also indicate that it has become ever more common to see a fashion company places only around 10% of its total sourcing value or volume from China compared to over 30% in the past. Furthermore, with the growing tensions of the US-China relations and the newly enacted Uyghur Forced Labor Prevention Act, fashion companies could take another look at their China sourcing strategy to avoid potential high-impact disruptions.

Fourth, near sourcing from the Western Hemisphere, especially CAFTA-DR members, continue to gain popularity. Specifically, 17.3% of US apparel imports came from the Western Hemisphere year-to-date (YTD) in 2021 (January-November), higher than 16.1% in 2020. Notably, CAFTA-DR members’ market shares increased to 10.6% in 2021 (January to November) from 9.6% in 2020. The value of US apparel imports from CAFTA-DR also enjoyed a 41.7% growth in 2021 (January—November) from a year ago, one of the highest among all sourcing destinations. The imports from El Salvador (up 42.6%), Honduras (up 47.1%), and Guatemala (36.6%) had grown particularly fast so far in 2021. However, the political instability in some Central American countries could make fashion companies feel hesitant to permanently switch their sourcing orders to the region or make long-term investments.

Additionally, the latest trade data suggests a notable increase in the price of US apparel imports. Notably, the unit price of US apparel imports from almost all leading sources went up by more than 10% from January 2021 to November 2021. As worldwide inflation continues, the rising sourcing cost pressure won’t ease anytime soon.

by Sheng Lu

[The comment is closed]

Outlook 2022– Key Issues to Shape Apparel Sourcing and Trade

In December 2021, Just-Style consulted a panel of industry leaders and scholars in its Outlook 2022–what’s next for apparel sourcing briefing. Below is my contribution to the report. All comments and suggestions are more than welcome!

What next for apparel sourcing?

As “COVID sets the agenda” and the trajectory of several critical market and non-market forces hard to predict (for example, global inflation, and geopolitics), fashion companies may still have to deal with a highly volatile and uncertain market environment in 2022. That being said, it is still hopeful that fashion companies’ toughest sourcing challenges in 2021 will start to gradually ease at some point in the new year, including the hiking shipping costs, COVID-related lockdowns, and supply chain disruptions.

In response to the “new normal,” fashion companies may find several sourcing strategies essential:

One is to maintain a relatively diverse apparel sourcing base. The latest trade data suggests that US, EU, and Japan-based fashion companies have been steadily sourcing from a more diverse group of countries since 2018, and such a trend continues during the pandemic. Echoing the pattern, in the latest annual benchmarking study I conducted in collaboration with the United States Fashion Industry Association (USFIA), we find that “China plus Vietnam plus many” remains the most popular sourcing model among respondents. This strategy means China and Vietnam combined now typically account for 20-40 percent of a fashion company’s total sourcing value or volume, a notable down from 40-60 percent in the past few years. Fashion companies diversify their sourcing away from “China plus Vietnam” to avoid placing “all eggs in one basket” and mitigate various sourcing risks. In addition, more than 85 percent of surveyed fashion companies say they will actively explore new sourcing opportunities through 2023, particularly those that could serve as alternatives to sourcing from China.

The second strategy is to strengthen the relationship with key vendors further. As apparel is a buyer-driven industry, fashion brands and retailers fully understand the importance of catering to consumers’ needs. However, the supply chain disruptions caused by COVID-19 remind fashion companies that building a close and partner-based relationship with capable suppliers also matters. For example, working with vendors that have a presence in multiple countries (or known as “super-vendors”) offers fashion companies a critical competitive edge to achieve more flexibility and agility in sourcing. Sourcing from vendors with a vertical manufacturing capability also allows fashion companies to be more resilient toward supply chain disruptions like the shortage of textile raw materials, a significant problem during the pandemic.

Further, we could see fashion companies pay even closer attention to textile raw material sourcing in the year ahead. On the one hand, given the growing concerns about various social and environmental compliance issues like forced labor, fashion brands and retailers are making more significant efforts to better understand their entire supply chain. For example, in addition to tracking who made the clothing or the fabrics (i.e., tier 1 & 2 suppliers), more companies have begun to release information about the sources of their fibers, yarns, threads, and trimmings (i.e., tier 3 & tier 4 suppliers). On the other hand, many fashion brands and retailers intend to diversify their textile material sourcing from Asia, particularly China, against the current business environment. Compared with cutting and sewing garments, much fewer countries can make textiles locally, and it takes time to build textile production capacity. Thus, fashion companies interested in taking more control of their textile raw material sourcing need to take concrete actions such as shifting their sourcing model and making long-term investments intentionally.

Apparel industry challenges and opportunities

One key issue we need to watch closely is the US-China relations. China currently remains the single largest source of apparel globally, with no near alternative. China also plays an increasingly significant role as a textile supplier for many leading apparel exporting countries in Asia. However, as the US-China relations become more concerning and confrontational, we could anticipate new trade restrictions targeting Chinese products and products from any sources that contain components made in China. Notably, with strong bipartisan support, President Biden signed into law the Uyghur Forced Labor Prevention Act on December 23, 2021. The new law is a game-changer! Depending on the detailed implementation guideline to be developed by the Customs and Border Protection (CBP), US fashion companies may find it not operationally viable to source many textiles and apparel products from China. In response, China may retaliate against well-known western fashion brands, disrupting their sales expansion in the growing Chinese consumer market. Further, as China faces many daunting domestic economic and political challenges, a legitimate question for fashion companies to think about is what an unstable China means for their sourcing from the Asia-Pacific region and what the contingency plan will be.

Another critical issue to watch is the regional textile and apparel supply chains and related free trade agreements. While apparel is a global sector, apparel trade remains largely regional-based, i.e., countries import and export products with partners in the same region. Data shows that from 2019 to 2020, around 80% of Asian countries’ textile and apparel imports came from within Asia and about 50% for EU countries. Over the same period, over 87% of Western Hemisphere (WH) countries’ textile and apparel exports went to other WH countries and about 75% for EU countries.

Notably, the reaching and implementation of new free trade agreements will continue to alter and shape new regional textile and apparel supply chains in 2022 and beyond. For example, the world’s largest free trade agreement, the Regional Comprehensive Economic Partnership (RCEP), officially entered into force on January 1, 2022. The tariff reduction and the very liberal rules of origin in the agreement could strengthen Japan, South Korea, and China as the primary textile suppliers for the Asia-based regional supply chain and enlarge the role of ASEAN as the leading apparel producer. RCEP could also accelerate other trade agreements in the Asia-Pacific region, such as the China-South Korea-Japan Free Trade Agreement currently under negotiation.

As one of RCEP’s ripple effects, we can highly anticipate the Biden administration to announce its new Indo-pacific economic framework soon to counterbalance China’s influences in the region. The Biden administration also intends to leverage trade programs such as the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) to boost textile and apparel production, trade, and investment in the Western Hemisphere and address the root causes of migration. These trade initiatives will be highly relevant to fashion companies that could use the opportunity to expand near sourcing, take advantage of import duty-saving benefits and explore new supply chains. 

Additionally, fashion companies need to be more vigilant toward political instability in their major sourcing destinations. We have already seen quite a turmoil recently, from Myanmar’s military coup, Ethiopia’s loss of the African Growth and Opportunity Act (AGOA) benefits, concerns about Haiti and Nicaragua’s human rights, and the alleged forced labor in China’s Xinjiang region. Whereas fashion brands and retailers have limited or no impact on changing a country’s broader human rights situation, the reputational risks could be very high. Having a dedicated trade compliance team monitoring the geopolitical situation routinely and ensuring full compliance with various government regulations will become mainstream among fashion companies.

And indeed, sustainability, due diligence, recycling, digitalization, and data analytics will remain buzzwords for the apparel industry in the year ahead.

by Sheng Lu

COVID-19 Hits the Bangladeshi Garment Industry

Discussion questions [Anyone is more than welcome to join our online discussions; For FASH455, please address at least two questions in your comment; please also mention the question number (i.e., #1, or #3; no need to repeat the question) in your comment.]

#1: How to understand apparel is a global sector from the video?

#2: How to understand the economic, social, and political implications of apparel sourcing and trade from the video?

#3: What are the top challenges facing Bangladeshi garment factories during COVID-19? Why or why not do think these challenges will go away soon?

#4: How is the big landscape of apparel sourcing changing because of COVID-19? Any apparel trade or sourcing patterns that COVID-19 didn’t change based on the video?

#5: Anything else you find interesting/intriguing/controversial/thought-provoking from the video? Why?

[discussion for this post is closed]

State of Fashion 2022 Report by McKinsey & Co & BOF

In December 2021, McKinsey & Co’ and Business of Fashion (BOF) released its annual State of Fashion report. Below are the key points in the report regarding the sourcing trends in the year ahead:

#1 The logistics challenges could intensify in 2022, with 87% of respondents expecting supply chain disruptions to continue to affect their profit margins in the year ahead negatively.  The global surges in demand create additional and unpredictable pressures on freight services, ports, and terminals. As a result, fashion companies may need to “plan for a permanently more expensive logistical future.”

#2 It will be critical for fashion companies to keep sourcing flexible, build resilience into the supply chain, and work closely with vendors. As one respondent commented, “[crises like] pandemics do happen.”

#3 The interest in nearshoring and reshoring will continue in 2022. Over 70% of respondents plan to increase the share of nearshoring close to company headquarters, and about 25% intend to reshore sourcing to their headquarters’ country. Notably, some EU-based companies have been moving textile manufacturing from China to Turkey to minimize delays.

#4 One crucial free trade agreement to watch is the Regional Comprehensive Economic Partnership (RCEP), to take effect on January 1, 2022. It’s the largest free trade agreement in history, involving nearly 30% of the world’s population. RCEP “has the potential to be at the core of the reconstruction of the global supply chain. RCEP is possibly the only trading block with both production capacity and consumer demand,” meaning it could dramatically facilitate regional trade and investment within Asia.

#5 There is a “significant opportunities in creating a hyperdigital supply chain.” Some companies are leveraging technology to find“competitive advantages in a supply-chain context when it comes to speed, agility, cost efficiency, and price.” However, fashion companies admit, it will remain challenging to plan inventory flow with much precision, which won’t change any time soon.

Other interesting comments from the report:

 “One mega trend…in the sector is the importance of breaking down the traditional boundaries of what’s in the company and [what is done externally]; what can be accomplished together as a network — whether it’s creativity, sustainability, and supply chain, or technology.”

“As fashion brands look to pursue closed-loop recycling solutions, it is increasingly important to engage with suppliers who can help them move toward sourcing circular materials.” “Cost is certainly a factor; recycled fibres are typically more expensive than their virgin counterparts.”

“In the longer term, fashion brands will need to balance the desire to enhance speed to market with the need to alleviate supply chain pressure…That may mean streamlining production, logistics planning, and booking capabilities, as well as putting in place contingency plans and alternative suppliers while remaining as agile and flexible as possible.”

Shipping Crisis and Supply Chain Disruptions: Impacts on Apparel Sourcing and Trade (updated December 2021)

Interview with Lululemon CEO
Impact on cotton price and cotton apparel

For FASH455: Please feel free to share any thoughts or propose discussion questions based on the three short videos above.

Which Apparel Sourcing Factors Matter?

Abstract

Today, fashion companies consider a long list of factors when deciding where to source their apparel products, ranging from cost, speed to market, flexibility to the risk of social and environmental compliance. While existing studies have identified these major sourcing factors, whether they are treated equally in companies’ apparel sourcing decisions remains mostly unknown. Neither is it clear how fashion companies make a trade-off among these sourcing factors, given no sourcing destination is perfect.

This study aims to quantitatively evaluate the influence of primary sourcing factors on fashion companies’ determination of apparel sourcing destinations. For the study, we collected the detailed evaluation of the world’s 27 largest sourcing destinations in 2019 against 15 specific performance indicators from GlobalData, one of the most popular sourcing analytics tools. The evaluation uses a 5-point rating scale for each performance indicator.

Because some of these 15 performance indicators measure similar items, we first conducted an exploratory factor analysis, which reduced these indicators to five principal sourcing factors based on their correlation matrix scores.  These five principal sourcing factors cover the following themes:

  • Capacity: It covers seven performance indicators that measure a sourcing destination’s capabilities (including flexibility and lead time) of providing apparel products and other value-added services.
  • Price & Tariff: It covers two performance indicators that measure the financial implications of sourcing from a particular destination, including eligibility for preferential import duties.
  • Stability: It covers two performance indicators that measure a sourcing destination’s macro-business environment, specifically sourcing-related political and economic climates.
  • Sustainability: It encompasses all social and environmental compliance issues related to apparel production and sourcing.
  • Quality: It covers two performance indicators that measure whether a sourcing destination obtains skilled workers and the overall quality of its products.

Next, we calculated the 27 apparel exporting countries’ average scores of these five principal sourcing factors. Based on the results, we further conducted a multiple regression analysis to evaluate the impact of the five principal sourcing factors on the value of these 27 countries’ apparel exports to the U.S., EU, and Asia in 2019, respectively. These three regions combined accounted for more than 80% of world apparel imports that year; however, fashion companies in each area are suggested to have unique sourcing preferences.

First, the result suggests that improving the performance in Stability and Quality can help a country enhance its attractiveness as an apparel sourcing base in the U.S. and Asia markets, but not so much in the EU market.

Second, a higher score for the factor Sustainability does not result in more sourcing orders at the country level in all three markets examined. It seems fashion companies’ current sourcing model does not provide substantial financial rewards encouraging better performance in sustainability. It is also likely that sustainability and compliance are treated more as pre-requisite criteria instead of determining the volume of the sourcing orders.

Third, the impact of Price & Tariff and Capacity on the value of apparel imports is not statistically significant in any of the three markets examined. This result does NOT necessarily mean price and production capacity is irrelevant. Instead, the result implies that fashion companies’ sourcing decision today is not merely about “chasing the lowest price.” Meanwhile, due to concerns about supply chain risks, even the most “economically competitive” sourcing destination won’t receive all the sourcing orders.

The findings of the study suggest that fashion companies’ sourcing decisions today appear to be more complicated and subtle than what is revealed by the existing literature and the public perception. Notably, the findings present different views from previous studies regarding how sourcing cost and sustainability affect fashion companies’ selection of sourcing destinations.

The findings also call our attention to the significant impact of non-economic factors on companies’ sourcing decisions, particularly the perceived political risks. This result explained why fashion companies had quickly reacted to the recent forced labor concerns in Xinjiang, China, and the military coup in Myanmar and halted sourcing from the regions.

By Dr. Sheng Lu and Emma Davis

The study was presented at the 2021 International Textile and Apparel Association (ITAA) annual conference.

Regional Comprehensive Economic Partnership (RCEP) and Textiles and Apparel (Updated November 2021)

What is RCEP?

The Regional Comprehensive Economic Partnership (RCEP) is a free trade agreement between ten member states of the Association of Southeast Asian Nations (ASEAN)* and five other large economies in the Asia-Pacific region (China, Japan, South Korea, New Zealand, and Australia). RCEP was reached on November 15, 2020, after nearly eight years of tough negotiation. (Note: ASEAN members include Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, and Vietnam. India was an original RCEP member but decided to quit in late 2019 due to concerns about competing with Chinese products, including textiles and apparel.)

So far, RCEP is the world’s largest trading bloc. As of 2019, RCEP members accounted for nearly 26.2% of world GDP, 29.5% of world merchandise exports, and 25.9% of world merchandise imports.

As of November 1, 2021, Lao, Burnei, Cambodia, Singapore and Thailand (ASEAN members), as well as China, Japan, New Zealand and Australia have ratified the agreement. This has met the minimum criteria for RCEP to enter into force (i.e., six members, including at least three ASEAN members and three non-ASEAN members).

As announced by Australia on November 2, 2021, RCEP will enter into force on January 1, 2022

Why RCEP matters to the textile and apparel industry?

RCEP matters significantly for the textile and apparel (T&A) sector. According to statistics from the United Nations, in 2019, the fifteen RCEP members altogether exported US$374 billion worth of T&A (or 50% of the world share) and imported US$139 billion (or 20% of the world share).

In particular, RCEP members serve as critical apparel-sourcing bases for many US and EU fashion brands. For example, in 2019, close to 60% of US apparel imports came from RCEP members, up from 45% in 2005. Likewise, in 2019, 32% of EU apparel imports also came from RCEP members, up from 28.1% in 2005.

Notably, RCEP members have been developing and forming a regional textile and apparel supply chain. More economically advanced RCEP members (such as Japan, South Korea, and China) supply textile raw materials to the less economically developed countries in the region within this regional supply chain. Based on relatively lower wages, the less developed countries typically undertake the most labor-intensive processes of apparel manufacturing and then export finished apparel to major consumption markets worldwide.

As a reflection of an ever more integrated regional supply chain, in 2019, as much as 72.8% of RCEP members’ textile imports came from other RCEP members, a substantial increase from only 57.6% in 2005. Nearly 40% of RCEP members’ textile exports also went to other RCEP members in 2019, up from 31.9% in 2005.

What are the key provisions in RCEP related to textiles and apparel?

First, RCEP members have committed to reducing the tariff rates to zero for most textile and apparel traded between RCEP members on day one after the agreement enters into force. That being said, the detailed tariff phaseout schedule for textile and apparel products under RCEP is very complicated. Each RCEP member sets their own tariff phaseout schedule, which can last more than 20 years (for example, 34 years for South Korea and 21 years for Japan.) Also, different from U.S. or EU-based free trade agreements, the RCEP phaseout schedule is country-specific. For example, South Korea sets different tariff phaseout schedules for textile and apparel products from ASEAN, China, Australia, Japan, and New Zealand. Japan’s tariff cut for apparel products is more generous toward ASEAN members and less so for China and South Korea (see the graph above). Companies interested in taking advantage of the duty-free benefits under RCEP need to study the “rules of the game” in detail.

Second, in general, RCEP adopts very liberal rules of origin for apparel products. It only requires that all non-originating materials used in the production of the good have undergone a tariff shift at the 2-digit HS code level (say a change from any chapters from chapters 50-60 to chapter 61). In other words, RCEP members are allowed to source yarns and fabrics from anywhere in the world, and the finished garments will still qualify for duty-free benefits.  Most garment factories in RCEP member countries can immediately enjoy the RCEP benefits without adjusting their current supply chains.

What are the potential economic impacts of RCEP on the textile and apparel sector?

On the one hand, the implementation of RCEP is likely to further strengthen the regional textile and apparel supply chain among RCEP members. Particularly, RCEP will likely strengthen Japan, South Korea, and China as the primary textile suppliers for the regional T&A supply chain. Meanwhile, RCEP will also enlarge the role of ASEAN as the leading apparel producer in the region.

On the other hand, as a trading bloc, RCEP could make it even harder for non-RCEP members to get involved in the regional textile and apparel supply chain formed by RCEP members. Because an entire regional textile and apparel supply chain already exists among RCEP members, plus the factor of speed to market, few incentives are out there for RCEP members to partner with suppliers from outside the region in textile and apparel production. The tariff elimination under the RCEP will put textile and apparel producers that are not members of the agreement at a more significant disadvantage in the competition. Not surprisingly, according to a recent study, measured by value, only around 21.5% of RCEP members’ textile imports will come from outside the area after the implementation of the agreement, down from the base-year level of 29.9% in 2015.

Further, the reaching of RCEP could accelerate the negotiation of other trade agreements in the Asia-Pacific region, such as the China-South Korea-Japan Free Trade Agreement. We might also see growing pressures on the Biden administration to join the Comprehensive and Progressive Agreement of the Trans-Pacific Partnership (CPTPP) to strengthen the US economic ties with countries in the Asia-Pacific region. The economic competition between the United States and China in the area could also intensify as the combined effects of RCEP and CPTPP begin to shape new supply chains and test the impacts of the two countries on the regional trade patterns.

By Sheng Lu

Further reading

Exclusive Interview with FIBRE2FASHION about the Latest World Textile and Apparel Trade Patterns (October 2021)

The full interview is available HERE

Selected interview questions

The virus is here to stay. What steps the companies must take to mitigate its impact?

Sheng: Earlier this year, I, together with the US Fashion Industry Association, surveyed about 30 leading US fashion brands and retailers to understand COVID-19’s impact on their sourcing practices. Respondents emphasized two major strategies they adopted in response to the current market environment. One is to strengthen the relationship with key vendors, and the other is to improve flexibility and agility in sourcing. These two strategies are also highly connected. As one respondent told us “We’re adjusting our sourcing model mix (direct vs. indirect) & establishing stronger strategic supplier relationships across entire matrix continue to build flexibility and dual sourcing options.” Many respondents, especially those large-scale fashion brands and retailers, also say they plan to reduce the number of vendors in the next few years to improve operational efficiency and obtain greater leverage in sourcing.

Which are the countries benefitting out of the US-China tariff war and why?

Sheng: The trade war benefits nobody, period. Today, textiles and apparel are produced through a highly integrated supply chain, meaning the US-China tariff war could increase everyone’s production and sourcing costs. Back in 2018, when the tariff war initially started, the unit price of US apparel imports from Vietnam, Bangladesh, and India all experienced a notable increase. Whereas companies tried to switch their sourcing orders, the production capacity was limited outside China.  Meanwhile, China plays an increasingly significant role as a leading textile supplier for many apparel exporting countries in Asia. Despite the trade war, removing China from the textile and apparel supply chain is impossible and unrealistic.

How do you compare the African and Asian markets when it comes to sourcing and manufacturing? Which are the advantages both offer?

Sheng: Asia as a whole remains the world’s dominant textile and apparel sourcing base. According to statistics from the United Nations (i.e., UNComtrade), Asian countries as a whole contributed about 65% of the world’s total textile and apparel exports in 2020. In the same year, Asian countries altogether imported around 31% of the world’s textiles and 19% of apparel. Asian countries have also established a highly efficient and integrated regional supply chain by leveraging regional free trade agreements or arrangements. For example, as much as 85% of Asian countries’ textile imports came from other Asian countries in 2019, a substantial increase from only 70% in the 2000s. With the recent reaching of several mega free trade agreements among countries in the Asia-Pacific region, such as the Regional Comprehensive Economic Partnership (RCEP), the pattern of “Made in Asia for Asia” is likely to strengthen further.

In comparison, only about 1% of the world’s apparel imports come from Africa today. And this percentage has barely changed over the past decades. Many western fashion brands and retailers have expressed interest in expanding more apparel sourcing from Africa. However, the tricky part is that these fashion companies are hesitant to invest directly in Africa, without which it is highly challenging to expand African countries’ production and export capacity. Political instability is another primary concern that discourages more investment and sourcing from Africa. For example, because of the recent political turmoil, Ethiopia, one of Africa’s leading apparel sourcing bases, could be suspended for its eligibility for the African Growth and Opportunity Act (AGOA). Without AGOA’s critical support, Ethiopia’s apparel exports to the US market could see a detrimental decline. On the other hand, while these trade preference programs are crucial in supporting Africa’s apparel exports, they haven’t effectively solved the structural issues hindering the long-term development of the textile and apparel industry in the region. More work needs to be done to help African apparel producers improve their genuine export competitiveness.

Another issue is Brexit. Is that having any significant impact on the sourcing scenario of the world or is it just limited to the European nations?

Sheng: Despite Brexit, the trade and business ties between the UK and the rest of the EU for textile and apparel products continue to strengthen. Thanks to the regional supply chain, EU countries remain a critical source of apparel imports for UK fashion brands and apparel retailers. Nearly 35% of the UK’s apparel imports came from the EU region in 2019, a record high since 2010. Meanwhile, the EU region also is the single largest export market for UK fashion companies—about 79% of the UK’s apparel exports went to the EU region in 2019 before the pandemic.

However, trade statistics in the short run may not fully illustrate the impacts of Brexit. For example, some recent studies suggest that Brexit has increased fashion companies’ logistics costs, delayed customs clearance, and made talent-hiring more inconvenient. Meanwhile, Brexit provides more freedom and flexibility for the UK to reach trade deals based on its national interests. For example, the UK recently submitted its application to join the Comprehensive Progressive Agreement of the Trans-Pacific Partnership (CPTPP). The UK is also negotiating a bilateral trade agreement with the United States. The reaching of these new trade agreements, particularly with non-EU countries, could significantly promote the UK’s luxury apparel exports and help the UK diversity its source of imports.

How do you think the power shortages happening across Europe, China, and other nations, are going to impact the apparel supply chains?

Sheng: One of my primary concerns is that the new power shortage could exacerbate inflation further and result in a more severe price hike throughout the entire textile and apparel supply chain. When Chinese factories are forced to cease production because of power shortage, the impact could be far worse than recent COVID-related lockdowns in Vietnam and Bangladesh. As mentioned earlier, more than half of many leading Asian apparel exporting countries’ textile supplies come from China today. Also, no country can still compete with China in terms of the variety of apparel products to offer. In other words, for many western fashion brands and retailers, their stores and shelves could look more empty (i.e., having less variety of products to sell) because of China’s power shortage problem.

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