Tag: EU

How EU Fashion Companies Navigate Trump’s Tariffs (Updated November 2025)

This study aims to examine the impacts of the Trump administration’s escalating tariffs on the apparel sourcing and business practices of EU-headquartered fashion companies. Based on data availability, transcripts of the latest earnings call from about 10 leading publicly traded EU fashion companies were collected. These earnings calls, held between August and November 2025, covered company performance in the second quarter of 2025 or later. A thematic analysis of the transcripts was conducted using MAXQDA.

First, reflecting the global nature of today’s fashion apparel industry, many EU-based fashion companies also see tariffs as one of their top business concerns in the second quarter of 2025. However, overall, luxury fashion companies reported less significant tariff effects than fast-fashion retailers and sportswear brands. The result reflected luxury fashion companies’ distinct cost structure, supply chain strategies, and competitive factors, making them less sensitive toward tariff-driven sourcing cost increases.

Second, EU-based fashion companies generally regarded the rising sourcing costs and the resulting pressure on profit margins as the most significant impacts of Trump’s tariffs. Companies also noted that the tariffs’ financial impacts would be more noticeable in the coming months as more newly launched products became subject to the higher import duties. For example:

  • Adidas: “We already had the double digit hit when it gets to cost of goods sold already in Q2 in the U. S…the impact of these duties, if they are the way we have calculated them here, an increase in cost of goods sold of about CHF 200,000,000 (about $250 million USD).”
  • H&M: “Against that, we have the impact of the tariffs that will then, based on the tariffs we pay during Q3, a lot of those garments will be sold during Q4, and that’s when they affect our profit and loss.”

Third, EU-based fashion companies commonly adopted a sourcing diversification strategy to mitigate the tariff impact. Companies also increasingly look for vendors that can deliver speed, flexibility, and agility.  Furthermore, some EU companies have been strategically leveraging regional supply chains to meet the sourcing needs. For example:

  • Adidas: “We work with our suppliers who are mostly multi country…”
  • Hugo Boss: “Since our last update in early May, we have taken concrete steps to mitigate tariff-related impacts. Our well-diversified global sourcing footprint has a clear advantage in this regard. It enables us to swiftly adapt to changing conditions and optimize sourcing decisions.”
  • H&M: “We are working on how to increase the speed and reaction time in our supply chain. That’s a wide work that includes both, as we mentioned before, how we move production closer to the customer with what we call nearshoring or proximity sourcing, but it’s also working with a set of suppliers that can be much quicker and where they can support with a larger part of the product development process.”
  • C&A: “In the last quarter, we developed our logistics strategy to sustain C&A’s growth curve till 2030…This strategy was designed so as to bring greater speed and flexibility to our operational model through a more regionalized network, that is a network that is closer to the stores and major consumption centers, allowing us to have greater capacity to respond to the demands of each store.”

Fourth, like their U.S. counterparts, some EU fashion companies reduced their “China exposure” to lessen the impact of tariffs. Others establish a “China for China” supply chain due to perceived market opportunities there. For example:

  • Puma: “Our China exposure got reduced further for the Spring/Summer 2026 collection…The vast majority of our U. S. Imports originate from Asia, with Vietnam, Cambodia and Indonesia accounting for the majority…”
  • Adidas: “China is almost irrelevant for us because we have reduced the amount of China imports into the U. S. to only 2%…What we did is that we transferred the Chinese capacities to be mostly China for China…We have a more verticalized supply chain in China.”
  • Hugo Boss: “In particular, we have increased our inventory coverages in the U. S. And successfully rerouted product flows from China to other regions.”

Additionally, despite tariff-driven cost pressures, many EU-based fashion companies were cautious about raising prices, worried about losing customers in an overall weak market. Meanwhile, luxury fashion brands seem more comfortable raising prices than non-luxury brands. For example:

  • Adidas: “What kind of price increases could we take depending on the different duties, but there’s no decision on that…We are not the price leader, but we’d, of course, follow, a, what the market is doing, our competitor is doing and also, of course, look very closely what the consumer is accepting because in the end, it’s to keep the balance between all these factors.”
  • H&M: “That we do in the U.S., as we do in all other markets, and that leads to both price decreases and price increases to stay competitive. That’s an ongoing work. We are cautious about looking at the Q4 development in the U.S., given that we know we have already paid tariffs that will impact the gross margins as we look into the fourth quarter.”
  • Inditex (Zara): “With regards to the tariffs in the U.S. specifically, we have a stable pricing policy that we’re always talking about. Of course, all pricing activity, be it in the U.S. or any other geography, is primarily driven by commercial decisions, not financial ones. What we try to do in every market is maintain our relative position.”
  • Burberry: “19% of our revenues are from the US…We spent much of last year looking at the supply chain, looking at price elasticity…We took quite a surgical approach to price increases in the US, and…we really definitely understood where we had price elasticity there.”
  • Hugo Boss: “we will introduce moderate price adjustments globally with the upcoming spring 2026 collections, which will begin delivery towards the 2025. These steps aim to safeguard our margin profile while remaining aligned with broader market dynamics.”

by Sheng Lu

Interview with Modaes (Spain) about the Shifting Global Apparel Trade and Sourcing Patterns (November 2025)

Full interview in English HERE ; Spanish version HERE

Below is the interview summary

Q1. Since the pandemic, has the global fashion supply chain changed?

Key point: The pandemic taught fashion companies the importance of flexibility and agility in sourcing. Heavy reliance on China caused major disruptions during lockdowns, prompting companies to diversify their sourcing base and develop stronger supplier relationships to reduce various sourcing risks.

Q2. Is supply security now more important than price in sourcing decisions?

Key point: Security and sourcing are becoming more closely linked. Leading fashion companies understand that sourcing now requires balancing cost with other important factors such as flexibility, regulatory compliance, and risk management. New regulations related to sustainability demand increasingly detailed supply-chain documentation and transparency. Meanwhile, geopolitical tension between the U.S. and China further adds complexity to fashion companies’ sourcing decisions.

Q3. Are companies continuing to reduce the number of suppliers, and why?

Key point: Recent studies show that many fashion companies are diversifying sourcing beyond China, importing more from emerging supplying countries like Vietnam, Bangladesh, Indonesia, Cambodia, Pakistan, Egypt, and more. However, there are two divergent strategies: some brands expand their supplier base to spread risk and enhance capabilities in sustainable fibers, while others consolidate suppliers to strengthen partnerships with large vendors operating across multiple countries, many of which are still based in China.

Q4. Can the value chain function without China?

Key point: Not realistically. While China’s share of finished garment exports is declining, it still dominates in textiles raw materials. Even when apparel is made in other countries (like Vietnam and Cambodia), much of its fabric, investment, or ownership is Chinese. The newly released OECD data also show that about 30% of Southeast Asian apparel exports include Chinese content.

Q5. Which countries could take advantage of China’s declining role?

Key point: China’s dominance comes not only from its low costs but also from its capacity to produce almost any product category at large scale. To replicate this, companies need to use multiple sourcing locations — a “many-country model” instead of relying on just one. Therefore, diversification, rather than substitution, is the most practical approach. Firms seek to avoid over-dependence on any single country, especially given the volatility of tariffs and supply-chain disruptions.

Q6. Does “friendshoring” apply to fashion?

Key point: Politically appealing but impractical for apparel sourcing. The idea of friendshoring — trading only with “like-minded” nations — doesn’t fit with fashion’s global manufacturing system. Europe and the U.S. share values, but Europe lacks large-scale apparel production. Over 70% of U.S. apparel imports still come from Asia, where most countries are not formal U.S. allies. Therefore, political alignment cannot guide sourcing strategy in fashion; cost, capacity, and speed are more important.

Q7. Will geopolitics and the trade war reshape fashion sourcing in Europe or the U.S.?

Key point: Nearshoring remains a popular concept. European companies explore Eastern Europe and the Mediterranean; U.S. firms consider the Western Hemisphere and limited domestic production. Sustainability has emerged as the new opportunity for near-shoring. Fashion companies now aim to use more sustainable fibers in their clothing products. EU sustainability rules could also attract new investment to expand production in the EU. However, in general, small-sized firms need more resources and support to meet these high environmental standards, both to comply with the law and sustain their businesses.

Q8. Is de-globalizing production possible?

Key point: True de-globalization is unlikely. Instead, globalization is shifting toward greater transparency and accountability. Companies now need to track and report where products are made and how workers are treated, including the sourcing of raw materials. This encourages brands to work closely with their suppliers and promote stronger and strategic collaboration.

Q9. Are there enough incentives for production automation in fashion?

Key point: Yes — Automation provides a way to increase efficiency in high-wage countries like the U.S. With labor costs high and factories shrinking, machines and AI are being adopted to boost productivity and customization. Automation can also help cut down on overproduction — one of fashion’s major waste issues — by supporting made-to-order or small-batch manufacturing.

Q10. Why don’t we see full automation yet?

Key point: Cutting, sewing, and material handling today still require human labor, although factories increasingly use automated tools to boost productivity. Asian suppliers are upgrading equipment to handle smaller, faster orders. Automation is bringing back niche manufacturing (e.g., sock production in the U.S.) and supporting recycling efforts, such as sorting used garments. It helps lower minimum order quantities, matching production to uncertain consumer demand.

Q11. How can Europe maintain relevance amid the U.S.–China trade war?

Key point: Europe continues to be a key player in both textile and apparel manufacturing and consumption. Nearly half of the apparel in the EU is produced locally, often in high-wage countries like Italy, Germany, and France. Asian countries are looking for more market access to the EU because of higher tariffs imposed by the US (e.g., trade diversion). Europe also leads in sustainability and regulatory standards. Complying with EU rules often means meeting the highest global standards. Luxury branding (“Made in Italy/France”) remains highly influential, and the EU’s proactive trade agreements might even enable it to export textiles for processing in Asia, expanding supply chain integration.

Q12. Why hasn’t Africa become a viable textile hub yet?

Key point: Africa’s potential greatly relies on trade preferences like the African Growth and Opportunity Act (AGOA), which recently expired. Without duty-free U.S. access, U.S. companies are less likely to source there. However, the EU could help bridge the gap by forging partnerships for recycled textile materials and sustainable production. Regional collaboration could unlock Africa’s place in circular fashion supply chains.

For students in FASH455: Feel free to share your thoughts on any of the interview questions above. You may also challenge and debate any points raised in the interview and present your arguments.

Merchandising and Sourcing: FASH455 Exclusive Interview with Natalie Kaucic, Global Merchant for Dockers at Levi Strauss & Co.

About Natalie Kaucic

Natalie Kaucic is a Merchandising professional currently in the role of Global Merchant for Dockers Men’s Tops at Levi Strauss & Co. She graduated from the University of Delaware in 2019 with a Fashion Merchandising Degree and Business Admin minor. During her studies, she was awarded the Fashion Scholarship Fund scholarship, studied at John Cabot in Rome, participated in the Disney College Program, and was a leader for the Delaware Diplomats. Natalie’s research on the global market for sustainable apparel was published in Just-style, a leading fashion industry trade publication. Post university, Natalie started as an assistant at Minted as a Merchandiser, where she worked in the Wedding category and faced the adverse challenges of the wedding industry during COVID-19. Levi’s was her next endeavor where she started as an assistant, and has since been promoted to run the Dockers Men’s Tops Category for the Globe.

Disclaimer: The comments and opinions expressed below are solely my own and do not reflect the views or opinions of any company.

Sheng: What are your primary job responsibilities as a global merchant? What does a typical day or week look like for you? Which part of the job do you find most exciting? Were there any aspects of the position that surprised you after you started?

Natalie: My primary responsibility is to create a brand-right and consumer-focused product assortment. Under the covers, this looks like a vast variety of tasks that I do on a seasonal basis. I regularly listen and work with regional merchandising to understand their regional specific needs, collaborate with design on new product ideas and fabrics, and meet with product development to work on new fabric innovations and product costing. Every week looks dramatically different for me in my work. Sometimes, I’m heads down in assortment strategy; other weeks, I work on creating templates and calendars for process improvement.

What I find most exciting is seeing the product in person. Most Dockers Tops are not sold domestically, so it’s really fun to see a product you worked on in the wild! I am also grateful to be able to manage an assistant. Seeing things click for her and watching her succeed is incredibly motivating.

What surprised me the most was the number of different teams I work with, including planning, regional merchants, product development, marketing, styling, design, garment/fit development, copy, IT, analytics, sales, business operations, and e-commerce. Learning what everyone does and who to go to was the most significant learning curve and the biggest shock coming into my role.

Sheng: Based on your observation and experience, how do the merchandising, product development, and sourcing teams collaborate in a fashion apparel company? Could you explain their respective responsibilities and how they support one another?

Natalie: In my role, I have more direct contact with our product development team than the sourcing team. I work very closely with product development as they are the team that helps produce our product. They manage fabric & garment development, costing negotiations, and innovation development/testing. They also work through some more micro-sourcing strategies, for example, moving the production from one factory to another to get better duty rates. As a hypothetical example, we sell a poplin shirt primarily in Europe. Pretend we produce the shirt in India at a cost of $10/each. However, shipping it to Europe incurs a 40% import duty, bringing the cost of goods sold (COGS) to $14. If we could produce the shirt in Mexico, where the duty rate to Europe is only 5%, even if the production cost is higher—say $12—the overall cost to Europe would still be lower. There are endless complexities to this that I’m sure you will learn more from FASH455—topics like free trade agreements, yarn forward rules of origin, etc.

Sheng: Fashion companies need to balance various factors such as cost, quality, speed to market, and compliance risks when deciding where to source their apparel products. Could you share your experiences and reflections on managing these challenges in the real world?

Natalie: Below is an example of natural fibers and the cost challenge with cotton-forward apparel products.

Currently, linen is in high demand, but there isn’t enough crop to meet industry needs—it’s a classic case of supply and demand. Not only does this drive up costs (COGS), but it also complicates the process of securing raw materials. It’s easy to overlook that the apparel industry is fundamentally tied to agriculture, making it vulnerable to factors like bad weather, natural disasters, and inaccurate demand forecasting. These challenges force us to make critical decisions. With rising garment costs, should the company absorb the expense to keep prices steady for consumers? Our product development team might ask if we need to pre-book fibers to lock in pricing—when is the right time to do that, and how much should we purchase?

This isn’t a new challenge. For example, cotton, our primary raw material for clothing, fluctuates in price like oil, making agility in sourcing essential!

Sheng: Studies show that consumers want to see more “sustainable apparel products” in stores. How are fashion companies responding to this demand? What opportunities and challenges does this trend present for fashion companies’ business operations, especially in merchandising, supply chain, and sourcing?

Natalie: This is such a complicated question. I think about this often as I am personally really passionate about this topic!

In my day-to-day work, I focus on sustainable fibers, as the fabric content of a garment is something I can directly influence. Working on a global scale, I collaborate with regions worldwide, each of which—along with their retailers—has different values regarding sustainable products. Europe, for instance, is relatively ahead of the US in sustainability and often requires a certain percentage of sustainable fibers (e.g., organic cotton, recycled cotton) in our products. In Europe, items using 100% organic cotton hold significant value and can command a higher price in stores such as Galeries Lafayette or Zalando. However, not all retailers and consumers globally share the same commitment to sustainability. In some cases, we may need to use synthetics for functional purposes, such as in activewear. In those instances, we prioritize using recycled polyester or nylon to meet our sustainability goals. Regardless of the consumer or price point, our goal is to integrate sustainability at every level and for every product.

One challenge I find particularly interesting is working with “recycled cotton.” As you may know, recycling cotton typically involves breaking down the fibers, which shortens and weakens them. Because of this, there’s usually a limit to how much recycled cotton can be used before fabric quality is affected. That’s why you often see recycled cotton blended with virgin cotton in the same garment. However, newer recycling methods that aim to preserve the staple length are emerging, offering hope for improvements as the technology becomes more mature and accessible.

Ultimately, heavy consumption, regardless of the fabric being recycled or organic, isn’t truly sustainable. The focus should be on choosing pieces you love and investing in items that are made to last.

Sheng: Are there any other major trends in the fashion industry that we should closely monitor in the next 1-3 years?

Natalie: In the next 1-3 years, I’m eager to see what AI-driven tools will be introduced to assist merchants in making smarter, data-backed decisions. In merchandising, we are constantly trying to predict the future. A lot of research and data analysis go into decision making,  but also a big handful of going with your gut. Will AI be able to help us find trends in the past that can better help us make decisions for the future?

It’s not exactly a trend, but I’m really curious about the future of fast fashion giants over the next decade. With growing interest in sustainability and new regulations emerging from Europe, will we eventually see a decline in these dominant players, or will demand for fast, cheap apparel always persist?

Sheng: Last but not least, is there anything you learned from FASH455 or other FASH courses that you find particularly relevant and helpful in your career? What advice would you offer current students preparing for a career in the fashion apparel industry?

Natalie: I felt really prepared coming out of the FASH program for my corporate job. I picked this degree, as I’m sure many have because it combined the necessary key concepts of a business degree with the skills and knowledge to build a career in apparel. I think the classes I reference the most in my day-to-day life are product development classes, textile classes, and apparel buying. As a merchant, I need to be able to talk about fabric types with designers, cost engineering with product developers, and financial metrics with planners. FASH455 was one of my favorite classes because sourcing, trade, geopolitics, and policy constantly pull the strings behind the scenes in the apparel sector. FASH455 gives you insight into how these factors create ripples in the apparel sector.

When it comes to advice, it’s tried and true: network! Talk to teachers, reach out to alumni, sign up for the UD Job Shadow Program, and talk to the career center. There are so many services to take advantage of while at UD. Other than networking, I would highly recommend steering the subjects of your papers to companies and topics you are interested in. I worked on a few reports about Levi Strauss & Co., which confirmed it as a target company for me and helped me succeed in the interview process.

Lastly, be flexible! You might come in, as I did, thinking you want to be a buyer, only to realize it’s not the best fit. Or, you could start with greeting cards and stationery merchandising and pivot to apparel. Or even move out of apparel entirely! Nothing is set in stone, and that’s both the most stressful yet reassuring lesson I’ve learned since graduating.

–The End–

Study: Destinations of Dutch used textiles (February 2024)

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

Size of used textiles trade:

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

Destinations of the used textile exports

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

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

Characteristics of the used textile exports

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

Environmental and social impacts of used textile exports

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

Job creation

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

Regulations

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

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

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

Summary & Key Findings:

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

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

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

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

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

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

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

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

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

By Leah Marsh and Sheng Lu

Discussion questions proposed by FASH455:

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

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

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

Primark’s Global Sourcing for Apparel (Updated September 2023)

Primark’s sourcing strategies

According to Primark, it does not own any factories but sources all apparel products from contracted factories. Any contracted factory that manufactures products for Primark must meet internationally recognized standards before receiving the first sourcing order.

As of October 2022, Primark sourced from 883 contracted factories in 26 countries (note: it was a slight decline from 928 contracted factories in 28 countries as of May 2021). Of these factories, 85.5 percent were Asia-based because of the region’s massive production capacity and a balanced offer of various sourcing factors, from cost, speed to market, and flexibility to compliance risks.

Like many other EU-based fashion companies, near-shoring from within the EU was another critical feature of Primark’s sourcing strategies. About 14 percent of Primark’s contracted garment factories were EU-based (including Turkey).

Measured by the number of workers, Primark’s Asian factories were larger than their counterparts in other parts of the world. For example, while Primark’s factories in Pakistan and Bangladesh typically have more than 2,500+ workers, its factories in Western EU countries like the UK, Germany, Italy, and France, on average, only have 64-200 workers. This pattern suggests that Primark mainly uses Asian factories to fulfill volume sourcing orders, and its EU factories mainly produce replenishment or more time-sensitive fashionable items.

Meanwhile, similar to the case of other retailers like PVH, Primark’s contracted garment factories in China were smaller than their peers in the rest of Asia. For instance, while over 90% of Primark’s garment factories in Bangladesh employ more than 1,000 workers, around 43% of their contracted factories in China have fewer than 100 workers. This pattern suggests Primark could use China as an apparel sourcing base primarily for orders requiring greater flexibility and agility and those involving a wider variety of products but in smaller quantities.

Further, reflecting the unique role of the garment industry in creating economic opportunities for women, females account for more than half of the workforce in most garment factories that make apparel for Primark. The percentage was exceptionally high in developing countries like Tunisia (94%), Morocco (91%), Pakistan (69%), Sri Lanka (69%), Myanmar (64%), India (62%), and Vietnam (59%).

According to Primark (as of September 2023), its Ethical Trade and Environmental Sustainability team comprises over 120 specialists based in key sourcing countries. The team conducts around 3,000 supplier audits a year to monitor compliance (i.e., fair pay, safety, and healthy working conditions.) Additionally, Primark says its factories were in line with the company’s environmental code of conduct, and the company “donated any unsold merchandise to the Newlife Foundation in Europe and KIDS/Fashion Delivers in the US.

by Sheng Lu

Discussion questions:

What are the unique aspects of Primark’s apparel sourcing strategies? What role does sourcing play in supporting Primark’s business success? Any questions or suggestions for Primark regarding its sourcing practices?

EU Extended Producer Responsibility for Textiles: Potential Impacts (Updated July 2023)

On July 6, 2023, the European Commission proposed a new rule, which aims to reduce textile waste and bolster used textile markets across the European Union (EU). EU says the new initiative will “accelerate the development of the separate collection, sorting, reuse and recycling sector for textiles in the EU, in line with the EU Strategy for Sustainable and Circular Textiles (released in March 2022).

Just-Style consulted a panel of industry experts and scholars to assess the potential ramifications of the new EU rule. Below are my contributions to the discussion, for consideration only.

What are your thoughts on the latest update on the new proposed rules?

The new EU rule goes far beyond existing regulations on sustainable textile and apparel production. For example:

  • While circular fashion is mostly voluntary efforts by companies, the new rule will impose a mandatory “eco-modulation fee” that is used to collect, sort, and recycle used textiles.
  • The proposal also aims to address “the issue of illegal exports of textile waste to countries ill-equipped to manage.”  Notably, despite the controversies surrounding the negative impacts of the used clothing trade on the developing world, few countries impose export restrictions on used clothing.
  • Additionally, there are few specific rules or regulations that explicitly mention stopping “fast fashion.” The new EU rule will be the first of its kind. It will be interesting to see how EU-based fast fashion giants like Zara and H&M respond to the proposal.

How do you think it will affect global apparel production, sourcing and trade?

While we are still waiting for the proposal’s details, the new rule is expected to substantially promote more use of recycled textile fibers in clothing with profound implications for the future of global apparel production, sourcing, and trade patterns.

For example, one of my recent studies found that given the many ways of recycling textile waste (e.g., mechanical and chemical), the supply chain of clothing made from recycled materials is versatile, potentially allowing countries of all kinds to get involved. Also, sourcing clothing made from recycled textile materials may offer many exciting business benefits beyond sustainability, such as reducing “China exposure,” expanding near-shoring, and diversifying the sourcing base.

What are the opportunities for the global apparel industry given these new proposed rules?

One opportunity is on the supply side–the new proposed rule could drive significant new investments in textile recycling, from exploring new textile recycling methods and improving the efficiency of collecting and sorting used clothing to expanding the production capacity in making garments using recycled textiles. In the future, clothing made from recycled textile materials may no longer be a “niche product” but a mainstream offering.

The new rule may also raise public awareness of the environmental and social aspects of clothing. For example, consumers may continue to push brands and retailers to make the apparel supply chain more transparent and inform them about the product’s detailed environmental, climate, and social impact.

What are the challenges for the global apparel industry given these new proposed rules?

It is unsure whether the “eco-modulation fee” will apply to EU-based textile and apparel producers only or will affect any producers that sell products in the EU markets. Given the long and fragmented nature of the textile and apparel supply chain, who will be subject to the “eco-modulation fee” needs clarification.

Fashion brands and retailers may also face higher sourcing costs and more limited product choices when sourcing clothing using recycled textiles. Like it or not, achieving “cost neutral” remains a critical principle for most fashion companies.

On the other hand, reflecting the unique supply chain of clothing made from recycled textiles, fashion companies must strengthen the monitoring efforts beyond the garment factories (i.e., tier 1 suppliers) to include tier 2 and 3 suppliers that handle the initial stages of recycled textile production.

by Sheng Lu

Related reading:

Transition Pathway for EU Textiles: For Sustainable and Circular Value Chains (Webinar)

Speakers

  • Antonio de Sousa Maia, Legal Officer, European Commission;
  • Cecilia Nilsson-Bottka, Policy Officer, European Commission;
  • Enrico Venturini, Senior Researcher, NEXT TECHNOLOGY TECNOTESSILE;
  • Dirk Vantyghem, Director General, EURATEX;
  • Clara Mallart, Senior Specialist for Sustainability, MODACC.

Summary of remarks by Dirk Vantyghem (Director General of the European Apparel and Textile Confederation, EURATEX)

  • EU textile and apparel companies are still struggling with an adverse business environment, from high energy bills and hiking inflation to an economic slowdown. Many companies are in trouble. New “green measures” must be careful about their impacts on companies’ business operations.
  • Textile and apparel is one of the most globalized sectors in the EU. Government sustainability policy must consider the global dimension of their implications on EU companies, such as the impact on fair competition and investments across borders.
  • Consumers’ demand for sustainable textile and apparel products, especially their willingness to pay a premium, remains a question mark.
  • If new sustainability regulations are implemented, it is imperative for the government to assist companies going through the transition. Small and medium-sized enterprises (SMEs) form the backbones of the textile and apparel industry. These SMEs must survive as they provide critical products and services to large-scale fashion brands.
  • Many green legislations impacting the EU textile and apparel industry are coming (e.g., new labeling requirements on sustainable materials). Close collaboration and dialogue between the industry and legislators are essential.

Explore Mango’s Apparel Sourcing Strategies (Updated January 2023)

About Mango

Mango is a fashion company based in Barcelona, Spain that was founded in 1984 by brothers Isak Andic and Nahman Andic. The company has grown significantly since its inception and now has over 2,700 stores in 109 countries worldwide. Mango is known for its trendy and high-quality clothing, which is targeted toward young women.

One of the critical factors in Mango’s success has been its ability to stay current and relevant in the fast-paced fashion world. The company regularly collaborates with top designers and influencers to create unique and fashionable collections that appeal to its target audience. Mango also closely monitors emerging trends and adapts its collections accordingly.

Besides clothing, Mango also offers accessories, such as bags, shoes, jewelry, and a home collection. The company has a solid online presence, with an e-commerce website that allows customers to shop from anywhere in the world.

In December 2022, Mango announced the Sustainable 2030 strategy, which “aims to move towards the full traceability and transparency of its value chain, in order to continue with the process of auditing its suppliers and ensuring that appropriate working conditions are being fulfilled for the workers in the factories the company works with around the world.” As part of the strategy, Mango will “focus its efforts on moving towards a more sustainable collection, prioritizing materials with a lower environmental impact and incorporating circular design criteria, so that by 2030 these will predominate in the design of its products and all its fibers will be of sustainable origin or recycled.”

Mango’s Apparel Sourcing Strategies (as of December 2022)

First, Mango adopted a sophisticated global sourcing network for its apparel products. Specifically, Mango’s apparel supply chain involves 1,878 Tier 1, Tier 2, and Tier 3 factories in 29 countries worldwide. About 31% of these factories produce garments (Tier 1), 19% supply fabrics (Tier 2), and 49% provide textile raw materials like yarns and accessories (Tier 3). Further, about 407 factories (or 21%) have vertical production capability (e.g., making both finished garments and textile inputs).

Second, like many EU fashion companies, near-shoring from the EU and Turkey is a critical feature of Mango’s apparel sourcing strategy. For example, about 44.8% of Mango’s Tier 1 garment suppliers were EU based (including Turkey), whereas Asia suppliers only accounted for 54%. Likewise, about 34% of Mango’s Tier 2 fabric suppliers and nearly half of its Tier 3 yarn and accessories suppliers were also EU based. The result reflects the EU’s intra-region textile and apparel trade patterns, supported by the region’s relatively complete textile and apparel supply chain. In comparison, US fashion companies typically source more than 80% of finished garments from Asia, and most of these garments also use Asia-based textile raw materials.

Third, measured by the number of suppliers, Mango’s top Tier 1 apparel production bases include Turkey (187 factories), China (176 factories), India (135 factories), and Italy (107 factories). Industry sources further indicated that between 2021 and 2022, Mango primarily sourced from Turkey and India for Tops (69% and 78%, respectively). Mango’s imports from China and Italy were more diverse in product categories (e.g., dresses, outwear, bottoms, and swimwear). On the other hand, Mango’s apparel imports from Italy were much higher priced ($107 retail price on average) than those from the other three countries ($38-41 retail price on average).

Fourth, the factory size and vertical production capabilities of Mango’s suppliers seem to vary by region. Notably, Mango’s Asia-based suppliers are more likely to be large-sized (with 1,000+ employees) and offer vertical production (e.g., making both finished garments and textile input). Mango’s Africa and America-based suppliers were relatively small-sized or lacked vertical integration.

By Sheng Lu

A New Strategy for the European Textiles and Apparel Industry – EURATEX perspective

Speaker: Dirk Vantyghem / Director General, European Apparel and Textile Confederation (EURATEX)

Topics covered

  • Macro-economic development of the EU textile and apparel industry
  • Impact of COVID-19 on the EU textile and apparel industry
  • The EU trade policy context
  • Key elements of EU textile and apparel industry’s post-COVID development strategy

Additional reading:

EU Textile and Apparel Industry and Trade Patterns (Updated April 2021)

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The EU region as a whole remains one of the world’s leading producers of textile and apparel (T&A). The value of EU’s T&A production totaled EUR137.3 bn in 2019, down around 2% from a year ago (Note: Statistical Classification of Economic Activities or NACE, sectors C13, and C14). The value of EU’s T&A output was divided almost equally between textile manufacturing (EUR68.7bn) and apparel manufacturing (EUR68.6bn).

Regarding textile production, Southern and Western EU, where most developed EU members are located such as Germany, France, and Italy, accounted for nearly 75% of EU’s textile manufacturing in 2019. Further, of EU countries’ total textile output, the share of non-woven and other technical textile products (NACE sectors C1395 and C1396) has increased from 19.2% in 2011 to 23.0% in 2017, which reflects the on-going structural change of the sector.

Apparel manufacturing in the EU includes two primary categories: one is the medium-priced products for consumption in the mass market, which are produced primarily by developing countries in Eastern and Southern Europe, such as Poland, Hungary, and Romania, where cheap labor is relatively abundant. The other category is the high-end luxury apparel produced by developed Western EU countries, such as Italy, UK, France, and Germany.

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It is also interesting to note that in Western EU countries, labor only accounted for 21.7% of the total apparel production cost in 2017, which was substantially lower than 30.1% back in 2006. This change suggests that apparel manufacturing is becoming capital and technology-intensive in some developed Western EU countries—as companies are actively adopting automation technology in garment production.

Because of their relatively high GDP per capita and size of the population, Germany, Italy, UK, France, and Spain accounted for nearly 60% of total apparel retail sales in the EU in 2020. Such a market structure has stayed stable over the past decade.

Data source: UNcomtrade (2021)

Intra-region trade is an important feature of the EU’s textile and apparel industry. Despite the increasing pressure from cost-competitive Asian suppliers, statistics from UNComtrade show that of the EU region’s total US$73.8bn textile imports in 2019, as much as 54.6% were in the category of intra-region trade. Similarly, of EU countries’ total US$204.0bn apparel imports in 2019, as much as 37.4% also came from other EU members. In comparison, close to 98% of apparel consumed in the United States are imported in 2019, of which more than 75% came from Asia (Eurostat, 2021; UNComtrade, 2021).

Regarding EU countries’ textile and apparel trade with non-EU members (i.e., extra-region trade), the United States remained one of the EU’s top export markets and a vital textile supplier (mainly for technical and industrial textiles). Meanwhile, Asian countries served as the dominant apparel sourcing base outside the EU region for EU fashion brands and retailers.  

The EU textile and apparel industry is not immune to COVID-19. According to the European Apparel and Textile Federation (Euratex), the EU textile and apparel production feel 9.3% and 17.7% respectively in 2020 from a year ago.

2021 hopefully will be a year of recovery and growth for the EU textile and apparel industry. According to Euratex, the EU Business Confidence indicator of March 2021 gained momentum, with a confirmed upward trend in the textile industry (+3.8 points), and a modest recovery in the clothing industry (+1.6 points). However, Euratex also noted that EU textile and apparel companies still face daunting challenges and uncertainties in 2021, ranging from the rising raw material price, increasing transportation cost, to political instability in some key sourcing destinations (such as China and Myanmar).

by Sheng Lu

Sourcing Strategy Comparison: EU VS. US Fashion Companies—Comments from Students in FASH455

“Hugo Boss’s sourcing strategies are relatively different from fashion brands and retailers in the US. Hugo Boss’s self-owned production facilities are all located in Europe, and they follow the general trend of Eastern Europe being responsible for mass production items and Western Europe being responsible for more of the fine craftsmanship/made-to-measure items. Hugo Boss’s production distribution, which is 53% in Europe, 40% occurs in Asia, 6% in Africa, and 1% in the Americas, is much more diverse than the production distribution of the United States’ T&A industry, which heavily relies on Asian suppliers. It is indicative of a strong regional supply chain in Europe, and because the regional supply chain in the Americas is not as strong due to complicated trade agreements and lack of production capacity, many fashion brands and retailers heavily depend on overseas production from Asian countries. “

“I think that EU’s sourcing strategies are different from the U.S.’s sourcing strategy in the sense that it is kept within Europe. In the U.S., they are currently trying to bring the sourcing supply chain back to the Western Hemisphere, but it is very difficult for fashion brands to concede when sourcing is cheaper in Asia, and there is not enough labor who are trained for the work that they need. Over at the EU, with everything kept within the organization, it is a lot easier to find factories within different countries without reducing GDP since it is kept within the organization.”

“I think that one of the biggest differences between EU and US fashion brand’s sourcing strategies is the fact that there is a much higher luxury or high-end apparel market in the EU. Since they produce mostly luxury apparel products, they naturally place a lot more emphasis on the quality of their products being made rather than the quantity and speed of production. Since the US is more fast-fashion heavy, we do a lot more outsourcing of production so retailer’s are able to produce as many clothes as possible within a short period of time at a very low cost which is simply not achievable in many US clothing factories.”

“Hugo Boss pays close attention to where they are sourcing from and where each of their products should be made within their 4 production facilities. This stuck out to me because I don’t know how many US fashion brands have their own production facilities. I know a lot of brands outsource to countries like China and Bangladesh to factories who are also making clothing for many different brands.”

“EU has developed countries as well as developing countries, unlike the US. Western EU countries like Italy, France, UK and Germany are developed and focus more so on textile production. Whereas developing countries in the EU like Poland and Hungary focus more heavily on apparel manufacturing. In addition, unlike the US, the developed countries in EU also produce apparel exports, of high level, luxury goods.”

“It seems that in the EU the main focus is quality and social standards for these fashion brands and production. In the US, promoting local economic growth seems to be more of the focus of the free trade agreements. Sourcing for HUGO BOSS at least has strategically chosen factories where they can ensure quality checks and know how to conditions are. In the US, outside of the region, it seems that there are a lot of brands who do not know their secondary producers…”

“As the EU is more focused on production in high end markets than is the US, they (EU fashion companies) source more high-end quality fabrics. Progress has been made through technological advances, as the HUGO BOSS group developed the “smart factory” to further improve the quality of their fabrics and recognize any potential flaws before production. This stood out to me as a major difference, considering the US focuses on producing more fast-fashion goods and prioritizes high productivity overall quality garments. Also, they are more careful in their selection of suppliers and strive to build more long-term relationships with their suppliers. In comparision, most US fashion companies just try to produce as cheap and fast as possible through a short-term transctional-based importer-vendor relationship.”

“I think the sourcing strategies are similar to the U.S. in the fact that they source from various countries, creating this sense of “Made in the World.” However, there are differences as well. HUGO BOSS uses their own production facilities in addition to sourcing from other countries which is something we do not see often in the US. In fact, most brands and retailers in the US do not have their own production facilities or vertical supply chain, but instead source from overseas. Additionally, HUGO BOSS carefully selects their suppliers and immediately focus on social responsibility. US sourcing strategies seem to emphsis more on finding a factory with the lowest labor costs. EU brands and retailers, on the other hand, test their suppliers with test orders before selecting them as a supplier for the brand, and immediately develop social responsibility practices, such as trainings and building relationships. In the US, brands and retailers tend to focus on social responsibility in response to bad press and typically do so by a top-down approach.”

“The sourcing strategy in the Europe cares more about social impact. Retailers and brands there promote and educate their suppliers to be sustainable and take over their social responsibility. Another one is the European fashion retailers and brands are more likely to locate their product facilities within the Europe. Since the Europe does have a relatively stable and complete supply chain, the retailers and brands are able to saving transportation cost and expand the lead time. Third, the technology becomes an important factors for retailers and brands to consider. They are attempting to utilize technology to enhance the performance and their production process. “

“Hugo Boss strives to be the most desirable fashion and lifestyle brand in the premium sector. This shows in their emphasis on design, comfort, fit, and durability, as well as being mindful of their social and environmental impacts. They maintain long term relationships with a careful selection of suppliers, demand social compliance, and stay up to date with their “smart factory” aka AIs to speed up production and quality. They also source heavily from Asia, but also developed countries such as Italy and Germany. These values and practices are manifested in American brands, however, I believe we aren’t as extensive with sourcing from developed countries (such as Italy). From what I have learned thus far, it seems we source from countries close by and/or developing, but not so much mingling with luxury known countries, such as France or Italy (and if we do, the prices are expensive, and American customers don’t want to pay higher prices). We (US), too, source heavily from Asia, because it is cheap, and still focus internally on our own country when it comes to being more competitive in technological advancements. American and EU consumers alike value transparency in the clothing brands they buy from, and American brands are mindful of this, too. I would say we are more alike than different.”

[Please feel free to critique the comments above and join our online discussion]

Related readings

How will EU Trade Curb Affect Cambodia’s Apparel Industry?

Key findings:

1. The garment industry matters significantly to Cambodia, both economically, and socially. As of 2019, as much as 70% of Cambodia’s merchandise exports were apparel items. Likewise, around one-third of Cambodia’s manufacturing output currently comes from the garment sector alone. Further, as of 2016, the garment industry in Cambodia employed nearly 928,600 workers (almost 79% were female), an increase of 239% from 2007.

2. Cambodia’s apparel exports have enjoyed steady growth in recent decades,  reaching US$7.83 billion in 2018 – a jump of 256% from US$2.2 billion in 2005. Yet, it faces several major challenges:

  • Due to limited production techniques and capital availability, apparel producers in Cambodia are still mostly engaged in cut-make-trim (CMT) activities, meaning they rely heavily on imported textile raw material and are only able to make a marginal profit based on low-value-added sewing work.
  • Cambodia’s apparel exports are highly concentrated on the EU and the US markets, which together accounted for 73.4% of the country’s total garment exports in 2019.
  • Cambodia is facing intense competition in its main apparel export markets—there has been little growth in Cambodia’s share of EU and US apparel imports over the past two decades, remaining as low as 3% as of 2019.

3. Cambodia has benefited significantly from the EU Everything But Arms (EBA) program. Established in 2001, the EBA trade initiative provides least developed countries (LDCs), such as Cambodia, with duty-free and quota-free access to the vast EU market for all products except weapons and ammunition. Like other EBA beneficiary countries, the majority (around 95%) of Cambodia’s apparel exports to the EU currently claim the duty- and quota-free EBA benefits.  

4. Out of concerns over Cambodia’s “serious and systematic violations of the human rights principles enshrined in the International Covenant on Civil and Political Rights,” the European Commission on 12 February 2020 formally announced the withdrawal of part of the tariff preferences granted to Cambodia under the EBA program. Starting from 12 August 2020, a select group of Cambodia’s apparel exports to the EU, together with all travel goods, sugar, and some footwear will be subject to the EU’s Most-Favored-Nation (MFN) tariff rat, which were at the rate of 11.5% on average for apparel items in 2019. 

5. Even the partial suspension of Cambodia’s EBA eligibility could result in significant and lasting negative impacts on its apparel exports to the EU:

  • The apparel items directly affected by the EBA suspension accounted for around 15% of the value of Cambodia’s total apparel exports to the EU in 2019. For those apparel categories directly targeted by the EBA suspension, EU fashion brands and retailers may quickly shift sourcing orders from Cambodia to other supplying countries to avoid paying the additional tariffs.
  • Social responsibility is being given more weight in fashion companies’ sourcing decisions. This means even those apparel items not directly targeted by the EU EBA suspension could face widespread order cancellations as sourcing from Cambodia is deemed to involve higher social compliance risks. In a worse but possible scenario, Cambodia’s apparel exports to the whole world could be under threat as many EU fashion brands and retailers operate globally and adopt a unified ethical standard and code of conduct for apparel sourcing across different markets.
  • Additionally, the timing cannot be worse: Due to the devastating hit by Covid-19, as of April 2020, Cambodia had reported nearly 130 garment factory closures and more than 100,000 workers laid off. These numbers may increase further as the effect of the pandemic continue to unfold.

Further reading: Abby Edge and Sheng Lu (2020). How will EU trade curb affect Cambodia’s apparel industry? Just-Style.

Discussion questions:

  1. What you would suggest to the Cambodian government or garment factories there to mitigate the negative impacts of the EU EBA suspension?
  2. Why or why not the EU should reconsider its decision to partially suspend Cambodia’s EBA eligibility because of Covid-19?
  3. If you were fashion brands and retailers that source from Cambodia, what would you do?

EU-Vietnam Free Trade Agreement and Outlook of Vietnam’s Apparel Export

Vietnam’s National Assembly officially approved the EU-Vietnam Free Trade Agreement (EVFTA) on 8 June 2020, which is expected to take into effect as early as in August 2020.

EVFTA will eliminate nearly all tariffs (over 99%) between the EU and Vietnam. However, textile and apparel (T&A) are among a few exceptions that will not be able to enjoy duty-free treatment on day one. Specifically:

Created by Dr. Sheng Lu based on the EVFTA text
  • The EU will eliminate duties with more extended staging periods (up to 7 years) for some sensitive products in the textile apparel and footwear sectors (see the graphs above).
  • By adopting the fabric-forward rules of origin (or the so-called “double transformation”) for apparel items, EVFTA intends to prevent products from a third party (such as China) from flooding the EU market. Specifically, to benefit from preferential access, garments will need to use fabrics produced in Vietnam or the EU. However, through the EVFTA cumulation provision, fabrics originating in South Korea or other ASEAN countries with which the EU has a free trade agreement in force will be considered as originating in Vietnam. (Note: South Korea is a free trade agreement partner of the EU).  While China remains the top textile supplier for Vietnam, the EVFTA apparel-specific rules of origin will provide more incentives for Vietnam to reduce its China dependence and restructure its textile and apparel supply chain. On the other hand, the totality of EU textile fabric exports to Vietnam will be liberalized immediately when the agreement enters into force.
  • Statistics show that Vietnam was EU’s sixth-largest extra-region apparel supplier in 2019 (after China, Bangladesh, Turkey, India, and Cambodia), accounting for 4.3% in value (or US$4.3 billion). Many of Vietnam’s primary competitors already enjoyed duty-free market access to the EU, such as Turkey (through the Customs Union), Bangladesh, and Cambodia (through the EU Everything But Arms program). EVFTA will provide a level playing field for Vietnam, which is expected to see a continuous robust growth of its apparel exports to the EU and gain additional market shares in the years to come. Meanwhile, not eligible for any EU preferential duty benefit, apparel exports from China are likely to face intensified competition in the EU market after the implementation of EVFTA.

EU Textile and Apparel Industry and Trade Patterns (Updated April 2020)

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The EU region as a whole remains one of the world’s leading producers of textile and apparel (T&A). The value of EU’s T&A production totaled EUR146.2bn in 2018, marginally up 2% from a year ago (Note: Statistical Classification of Economic Activities or NACE, sectors C13, and C14). The value of EU’s T&A output was divided almost equally between textile manufacturing (EUR77.4bn) and apparel manufacturing (EUR70.0bn).

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Regarding textile production, Southern and Western EU, where most developed EU members are located such as Germany, France, and Italy, accounted for nearly 73.7% of EU’s textile manufacturing in 2018. Further, of EU countries’ total textile output, the share of non-woven and other technical textile products (NACE sectors C1395 and C1396) has increased from 19.2% in 2011 to 23.0% in 2017, which reflects the on-going structural change of the sector.

3

Apparel manufacturing in the EU includes two primary categories: one is the medium-priced products for consumption in the mass market, which are produced primarily by developing countries in Eastern and Southern Europe, such as Poland, Hungary, and Romania, where cheap labor is relatively abundant. The other category is the high-end luxury apparel produced by developed Western EU countries, such as Italy, UK, France, and Germany.

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It is also interesting to note that in Western EU countries, labor only accounted for 21.7% of the total apparel production cost in 2017, which was substantially lower than 30.1% back in 2006. This change suggests that apparel manufacturing is becoming capital and technology-intensive in some developed Western EU countries—as companies are actively adopting automation technology in garment production.

5

Because of their relatively high GDP per capita and size of the population, Germany, Italy, UK, France, and Spain accounted for 61.1% of total apparel retail sales in the EU in 2018. Such a market structure has stayed stable over the past decade.

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Data source: UNcomtrade (2020)

Intra-region trade is an important feature of the EU’s textile and apparel industry. Despite the increasing pressure from cost-competitive Asian suppliers, statistics from the World Trade Organization (WTO) show that of the EU region’s total US$73.7bn textile imports in 2018, as much as 57.1% were in the category of intra-region trade. Similarly, of EU countries’ total US$205.0bn apparel imports in 2018, as much as 48.0% also came from other EU members. In comparison, close to 97% of apparel consumed in the United States are imported in 2018, of which more than 80% came from Asia (Eurostat, 2020; WTO, 2020).

EURATEX-TC-Business-Confidence-Indicator (1)

The EU textile and apparel industry is not immune to COVID-19. According to the European Apparel and Textile Federation (Euratex), the outbreak of COVID-19 may cause a 50% drop in sales and production for the EU textile and apparel sector in 2020. A recent survey of EU-based T&A companies shows that almost 9 out of 10 respondents reported facing serious constraints on their financial situation and 80% of companies had temporarily laid-off workers. Around 25% of surveyed companies were considering closing down their businesses. Further, EU T&A companies were concerned about EU’s tightened border controls, which have “increased sharply, leading to delays in supplies but also cancelling of orders, thus aggravating the economic impact.”

No-Deal Brexit: UK’s Import Tariff Rates for Apparel Products

The UK government on March 13, 2019 released the temporary rates of customs duty on imports if the country leaves the European Union with no deal. In the case of no-deal Brexit, these tariff rates will take effect on March 29, 2019 for up to 12 months.

According to the announced plan, around 87% of UK’s imports by value would be eligible for zero-tariff in the no-deal Brexit scenario.

Specifically for apparel products, 113 out of the total 148 tariff lines (8-digit HS code) in Chapter 61 (Knitted apparel) and 145 out of the total 194 tariff lines (8-digit HS code) in Chapter 62 (Woven apparel) will be duty-free. However, other apparel products will be subject to a Most-Favored-Nation (MFN) tariff rate ranging from 6.5% to 12%.

Meanwhile, the UK will offer preferential tariff duty rates for apparel exports from a few countries/programs, including Chile (zero tariff), EAS countries (zero tariff), Faroe Islands (zero tariff), GSP scheme (reduced tariff rate), Israel (zero tariff), Least Developed Countries (LDC) (zero tariff), Palestinian Authority (zero tariff), and Switzerland (zero tariff).

On the other hand, the EU Commission said it would apply the Most-Favored-Nation (MFN) tariff rates on UK’s products in the no-deal Brexit scenario rather than reciprocate.  

Appendix: UK’s MFN tariff rate for apparel products (HS Chapters 61-62) in the case of no-deal Brexit.

Textile and Apparel and the Proposed U.S.-EU Free Trade Agreement

I. Background

On October 16, 2018, the Trump Administration notified U.S. Congress its intention to negotiate the U.S.-EU Free Trade Agreement. Between 2013 and 2016, the United States and EU were also engaged in the negotiation of a comprehensive free trade agreement– Trans-Atlantic Trade and Investment Partnership (T-TIP) with the goal to unlock market access opportunities for businesses on both sides of the Atlantic through the ambitious elimination of trade and investment barriers as well as enhanced regulatory coherence. The T-TIP negotiation was stalled since 2017, although the Trump Administration has never officially announced to withdraw from the agreement.   

II. Negotiating Objectives

On January 11, 2019, the Office of the U.S. Trade Representative (USTR) released the negotiating objectives of the proposed U.S.-EU Free Trade Agreement after seeking inputs from the public. Overall, the proposed agreement aims to address both tariff and non-tariff barriers and to “achieve fairer, more balanced trade” between the two sides.

Regarding textiles and apparel, USTR says it will secure duty-free access for U.S. textile and apparel products and seek to improve competitive opportunities for exports of U.S. textile and apparel products while taking into account U.S. import sensitivities” during the negotiation. The proposed U.S.-EU free trade agreement also will “establish origin procedures for the certification and verification of rules of origin that promote strong enforcement, including with respect to textiles.” T-TIP had adopted similar negotiating objectives for the textile and apparel sector.

III. Industry viewpoints on the agreement

As of January 2019, leading trade associations representing the U.S. apparel industry and the EU textile and apparel industries have expressed support for the proposed U.S.-EU Free Trade Agreement. In general, these industry associations recommend the agreement to achieve the following goals:

First, eliminate import duties. For example:

American Apparel and Footwear Association (AAFA): “We support the immediate and reciprocal elimination of the high duties that both countries maintain on textiles, travel goods, footwear, and apparel.”…” We also support the immediate elimination of any retaliatory duties imposed by the E.U., as well as any duties imposed by the U.S. (that led to that retaliation). The duties impose costs on activities, including manufacturing activities in the U.S., and undermine markets for U.S. exporters in Europe.”

European Apparel and Textile Confederation (Euratex): “The European Textile and Clothing sector faces high tariffs while exporting to the US market from 11% to up to 32% for some products, namely sewing thread of man-made filaments, suits, woven fabrics of cotton, trousers and t-shirts. Zero customs duties while ensuring modern rules of origin will allow EU companies to boost exports and offer more choice to American consumers and professional buyers.”

Second, promote regulatory coherence (Harmonization). For example:

AAFA: “The E.U. and the United States both maintain an extensive array of product safety, chemical management, and labeling requirements regarding apparel (including legwear), footwear, textiles, and travel goods.”…” Yet they often contain different requirements, such as testing or certification, that greatly add compliance costs.”…” We believe the U.S.‐E.U. trade agreement presents an important opportunity to achieve harmonization or alignment for these regulations.”

Euratex: “Maintaining high level of standards while eliminating unnecessary burdens, removing additional requirements and facilitating customs procedures that impede business are top priorities. Mutual recognition of the EU and US standards will preserve high level of consumer protection on both sides of the Atlantic. Convergence on labelling (fibre names, care symbols and wool labelling), consumer safety on children products and flammability standards is key for the T&C sector.” “EURATEX believes the EU and US standardization bodies should cooperate on setting standards for Smart Textiles taking into account the industry views for facilitating development and trade of such products of the future.”

Third, adopt flexible/modern rules of origin. For example:

AAFA: “We should also support higher usage of the agreement by making sure the rules of origin reflect the realities of the industry today…”the yarn forward” rules, although theoretically promote usage of trade partner inputs, in practice they operate as significant barriers that restrict the ability of companies to use a trade agreement in many cases”…” We need to incorporate sufficient flexibilities into the rules of origin so that different supply chains –and the U.S. jobs they support – can take advantage of the agreement.”

Euratex: “Zero customs duties while ensuring modern rules of origin will allow EU companies to boost exports and offer more choice to American consumers and professional buyers.”

The National Council of Textile Organizations (NCTO), which represents the U.S. textile industry, hasn’t publically stated its position on the proposed U.S.-EU Free Trade Agreement. However, NCTO had strongly urged U.S. trade negotiators to adopt a yarn-forward rule of origin in T-TIP. NCTO also opposed opening the U.S. government procurement market protected by the Berry Amendment to EU companies.

IV. Patterns of U.S.-EU textile and apparel trade

The United States and the EU are mutually important textile and apparel (T&A) trading partners. For example, the United States is EU’s largest extra-region export market for textiles, and EU’s fifth largest extra-region supplier of textiles in 2017 (Euratex, 2018).

Meanwhile, the EU is one of the leading export markets for U.S.-made technical textiles as well as an important source of high-end apparel products for U.S. consumers (OTEXA, 2018). Specifically, in 2017, U.S. T&A exports to the European Union totaled $2,572 million, of which 73.2% were textile products, such as specialty & industrial fabrics, felts & other non-woven fabrics and filament yarns. In comparison, EU’s T&A exports to the United States totaled $4,163 million in 2017, among which textiles and apparel evenly accounted for 48.7% and 51.3% respectively.

V. Potential economic impact of the agreement

By adopting the Global Trade Analysis Project (GTAP) model, Lu (2017) quantitatively evaluated the potential impact of a free trade agreement between the U.S. and EU on the textile and apparel sector. According to the study:

First, the trade creation effect of the agreement will expand the EU-U.S. intra-industry trade for textiles. Meanwhile, the agreement is likely to significantly expand EU’s apparel exports to the United States.

Second, the trade diversion effect of the U.S.-EU Free Trade Agreement will affect other T&A exporters negatively, including Asia’s T&A exports to the U.S. market and EU and Turkey’s T&A exports to the EU market.

Third, the U.S.-EU Textile and Apparel Trade might affect the intra-region T&A trade in the EU region negatively but in a limited way.

Overall, the study suggests that the EU T&A industry will benefit from the additional market access opportunities created by the U.S.-EU Free Trade Agreement. One important factor is that the U.S. and EU T&A industries do not constitute a major competing relationship. For example, the United States is no longer a major apparel producer, and EU’s apparel exports to the United States fulfill U.S. consumers’ demand for high-end luxury products. The U.S.-EU Free Trade Agreement is also likely to create additional export opportunities for EU textile companies in the U.S. market, especially in the technical textiles area, which accounted for approximately 40% of EU’s total textile exports to the United States in 2017 measured in value. Compared with traditional yarns and fabrics for apparel making purposes, technical textiles are with a greater variety in usage, which allows EU companies to be able to differentiate products and find their niche in the U.S. market.

Further, the study suggests that we shall pay more attention to the details of non-tariff barrier removal under the U.S.-EU Free Trade Agreement, which could result in bigger economic impacts than tariff elimination. 

Recommended reading:
Lu, S. (2017). Trans-Atlantic Trade and Investment Partnership: An Opportunity or a Threat to the EU Textile and Apparel Industry? Journal of the Textile Institute, 109 (7), 933-941.